IR 05000293/1988018

Physical Security Insp Rept 50-293/88-18 on 880425-29 & 0503-04.No Violations Noted.Major Areas Inspected:Mgt Effectiveness of Licensee Proprietary Security Organization

ML20151H770
Person / Time
Site:	Pilgrim
Issue date:	07/11/1988
From:	Bailey R, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151H764	List: IR 05000293/1988018 ML20151H762
References
50-293-88-18, NUDOCS 8808020044
Download: ML20151H770 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-18 Docket N License N OPR-35 Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth, Massachusetts Inspection Conducted: April 25-29 and May 3-4, 1988

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Type of Inspection: Routine, Unannounce_d Physical Security Inspector: / .- .

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' . BaTley, 'ysicWTect[fity inspector, date Safeguards Sect, ion, FRS&SB, OR Sr

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Approved by: __/[f 7' Mte 7'

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R. R. Kefylg, Chief, Saf uards Section, FRS&SB, DRSS .

Inspection Summary: Routine, Unannounced Phy_sical Security Inspection on Apr1D5-29 and May 3-4, T9BT(Report No. 50-24/sF18)

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Areas Inspected: Management effectiveness of the licensee's proprietary security organizatio Results: The licensee has established and is implementing a significantly ip proved security program over that which existed when the station was shutdown in April, 1986. Most noteworthy is a greatly expanded proprietary security organization comprising experienced personnel with well defined duties and responsibilities in specific functional areas to administer the program and oversee the contract security forc .

0000020044 PDR 000714ADOCK 050002'/3 PNV O

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r DETAILS > Key Persons Contacted ,

Boston Edison Company ,

K. Highfill, Station Director

• C. Kraft, Plant Support Manager

• P. Hamilton, Compliance Division Manager

• R. Cannon, Compliance Olvision P. Moraitis, Maintenance Planning Supervisor

• 0. Long, Security Section Manager

• R. Deacy, Security Operations Division Manager

• J. Neal, Security Administration Division Manager

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• E. MacCormack, Corporate Security

• J. McEachran, Security Staff Assistant T. Nichnison, Security Compliance Specialist

D. Zinter, Security Technical Supervisor R. Hird, Access Authorization Supervisor

• T. Flaherty Security Shift Supervisor

, Globe Security Force Contractor

* R. Rodriguez, Chief of Security ,

L. Morris, Deputy Chief U. S. Nuclear Regulatory Commission

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l C. War rrq, Senior Resident Inspector

• J. Lyash, Resident Inspector

. * T. Kim, Resident laspector ,

• R. Keimig, Chief, Safeguards Section, Region I  :

, * present at the exit interview  :

Other supervisory and non-supervisory personnel were interviewed, I including contract security force personnel, on and off sit . Exit Interview The inspector met with the licensee represantatives, as indicated ab1ve, on May 4, 1988 to summarize the scope and results of the inspectio l No written material was provided to the licensee by the inspector during -

the inspection.

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3. Background During the past two years, the NRC identified numerous significant concerns relative to the adeque v of the security program at the Pilgrim Station. These conc'rns incluc.J: vital area barriers; compensatory measures; lighting; assessment capabilities; intrusion detection; maintenance; security computer; oversight of the contractor; and propriatary security nanagement. In mid-1536, the licensee initiated corrective actions in response to the concerns irlentified by NRC. Since -

that time, NRC inspectors have reviewed the licensee's progress on correcting hardware and equipment type problems during routine inspections and these problems have been substantially corrected. The licensee had also taken actions to strengthen the identified weakness in proprietary security r.anagement and oversight of the security contractor during this period. The licensee's efforts in this regard were also reviewed durir.g routine NRC inspections and, in April 1988, the licensee's proprietary security organization had stabilized and was at its full complement. Therefore, a review of the new organization was undertake . Purpose The purpose of the inspection was to assess the licensee's proprietar, organization structure, the effectiveness of the organization's performance, and the experience and qualification of the incumbent personne . Scope of Inspection The scope of the inspection included a review of the licensee's proprietary organization structure, policies, plans and procedures ud extensive personal interviews with the f ndividuals identified in psragraph 1 above, members of the contract security force and Other station personnel. No review of ,

security systems or equipment were made durIng this inspection, on 6. Findings The following represent the bases for and the inspector's determinations as a result of this inspectio Organization Structure '

The licensee's proprietary security organization is headed by a ,

Section Manager who reports directly to the Plant Support Manager, under the Station Director. Assisting the Security Section Manager are five supervisors with specific functional areas of responsibility (operations, administration, technical, compliance and access authorization) and a staff assistant. Additionally, there are seven proprietary shift supervisors who are responsible to .

monitor the performance of the contract security force, around-the-cloc _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - __ _ _ _ _ _ _ _ _ _ _ _ _ __ _

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This represents a staff increase of thirteen over that which was in place in April, 1986. At that time, the licensee's program was carriei out by a group leader, who had other concurrent duties, and a supe viso The inspector found that the licensee's organization structure is

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sound and sufficiently staffed to be operationally effective, Policies and Procedures The licensee has established and is implementing written security policies and procedures that are consistent with the NRC-approved security program plans. The policies and procedures are periodically

, reviewed by licensee security specialists and are being revised as

need and experience with their use dictate. All pertinent security functional areas appear to be adequately addressed. Dissemination of I policy and procedures is effected through staf f meetings, formal and on-the-job training and self-study programs. Personnel interviewed consider these policies and procedures to be clear and practical, and a significant improvement over those that existed previously.

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Revisions to the security program plans (security, contingency and training and qualification) were recently completed to increase their overall effectiveness and clarit In Oddition, revisions to the procedures that implement these plan * wr indertaken to make

, them consistent with the re*ised plans ans to bprove clarity. That effort is nearing completion and will be reviewed by NRC during a subsequent inspection.

I During discussions with security and station maintenance personnel, I the inspector learned that the Maintenance Planning Supervisor and the Security Section Manager had developed a draft preventive maintenance program for security related systems and equipment. The inspector performed a cursory review of the program scope and found it to be generally adequate. In addition, administrative procedures had also been developed to ef fect prompt corrective maintenanc '-oprietary Staff Responsibilities Th' 1 ensee has established and clearly defined the duties and respunsibilities of the proprietary security staff in the written policy and procedures addressed above, and in position descriptions. The organization has been established with specific functional areas of responsibility and each functional area is assigned to one 'adividual. Adequate authority to carry out the tsponsibilitirs of each functional area appear to be provided.

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! During interviews with the r ; :etary staf f, the inspector found j that the staff members clea.'- aderstood their responsibilities and

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authority. The inspector d- srned that the staff was highly motivated

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and appeared to be working toward the common goal of establishirg and implementing an effective security program. It was apparent that i some interface problems among the staff still existed but that they had been generally identified and that actions had been initiated to effect resolution. This was confirmed by the Security Section Manager who indicated that he was being successful in resolving those types of problems and that their incidence was decreasin The inspector was also able to discern some activity in improving the interface and relationship between the security organization and other station functions, such as maintenance and operations. It was most apparent with the maintenance function in that security equipment and systems were being provided prompt and proper repair by specially trained and assigned personnel, and a preventive maintenance program was being developed for security equipment and system The inspector observed that the proprietary security organization was not located in a common office space but rather '.1 several locations on the site and in one location off sit The inspector questioned the Security Section Manager about the efficacy of that arrangement and the potential pitfall The Security Section Manager stated that plans have been developed to centralize the organization in one location on site in the near futur '

I The inspector found that the proprietery security organization was adequately carrying out its functions and was providing the necessary oversight of the security program implementation and the performance of the contract security forc Independent oversight of the program is also being provided through surveillance by experienced corporate security personnel assigned to the station and through periodic audits 7 by Quality Assurance personne ,

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d. Experience and Qualifications of Proprietary Staf f Members A brief summary of the experience and qualifications of several proprietary staff members, selected for review by the inspector, follows for illustrative purposes:

(1) The Security Section Manager has held positions as Commissioner l

of Public Safety for the State of Connecticut; Commanding Officer, t Connecticut State Police; Chairman and Co-Chairman for various -

Connecticut State Commiss: ens; and Security Department Head for !

GPU Nuclear. He holds a Degree in Criminal Justice Administration (

and an Associate of Arts Degree in Police Science and l Administratio (2) The Security Operations Division Manager has held various security

, and engineering positions including Senior Engineer for the Impell Corporation; Industrial Security Administrator, Stone and Webster L Engineering; and Security Specialist, First Security Services ,

Corporation. He holds a Bachelor of Science Degree in Criminal Justice.

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- 6 (3) The Security Administration Division Manager has held administrative and supervisory positions at the Browns Ferry, Sequoyah and Pilgrim

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Nuclear Power Stations for over nine years as a Security Shift Supervisor, as a Training Instructor and has been responsible for various administrative functions related to security. He has also participated in the development of training programs for security and plant operating personnel. He has attended the University of Tennessee and Alabama A&M University to enhance his administrative skill (4) The Security Technical Supervisor has twenty-one years of engineering, maintenance, testing and operating experience in nuclear and fossil generating plants. He has held various engineering positions at the Perry Nuclear Power Plar.t. Cheswick Pcwer Station, Beaver Valley Nuclear Power Plcnt and others

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throughout the mid west and western United States. He holds an Associate of Arts Degree in Engineering and Pre-Law, and has also taken other courses at Western State University, Anaheim, California and at California Western University, Santa Ana, Californi (5) The Security Compliance Specialist has eleven years of experience in the security organization at the Pilgrim Station, both as a member of the guard force and as a supervisor for the license Before that, he served as a Master Sergeant in the United States Air Forc (6) The Access Authorization Supervisor has held various positions in security administration during employment with several large t nuclear power stations and in the United States Air Force. He i has an Associate of Arts Degree in police Science from the

Community College of the USAF, and has attended several special l secur1*y and police oriented training at Syracuse University and

at the USAF Air University in Alabama. He is a certified i

protection professional (CPP).

(7) One of the proprietary security shif t supervisors has been employed in various senior supervisury positions at several nuclear power stations and with Burns International Security Incorporated with responsiblities for security functions such as access control and protected and vital area integrity. The incumbent has a Bachelor of Science Degree in Criminal Justice (Magna Cum Laude) from the University of Wisconsin and has performed graduate work in labor and industrial relations at the Michigan State Universit (8) Another of the proprietary security shift supervisors has been employed by Globe Security Systems, Incorporated for the past four years with responsibilities for key operational security functions. The incumbent has a Bachelor of Arts Degree in l Sociology and a minor in Psychology.

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(9) Another of the proprietary security shift supervisors held the position of Commanding Officer, Aviation Section, Massachusetts Department of Public Safety (State Police). Additionally, for the past two years, the incumbent has been assigned at the Pilgrim Station as a Security Shift Supervisor. The incumbent has been actively engaged in providing oversight of the contract security force and has been instrumental in the recent revisions to procedures which implement the NRC-approved security plans. The incumbent has master credits in Law Enforcement Management from Bobson College, an Associate of Science Degree in Aviation Technology from Lincoln College, a Bachelor of Science Degree in Law Enforcement / Criminal Justice from Northeastern University, and a Masters Degree in Social Education / Criminal Justice from Boston University, e. Management Attitude In contrast to his prior experience with and knowledge of the Pilgrim Station, the inspector noted that the new proprietary security organization, in particular, was aggressively pursuing innovations and initiatives relative to security program improvements and enhancements. These are typified by the work done on the protected and vital area barriers, protected area lighting, main and alternate access points, systems and hardware, program plans, as well as the increase in proprietary staffing. The inspector also noted a significant improvement in the working relationship with other station functions and, particularly, with the contract security force, which exhibited much better professionalism and higher morale, While the impetus for some of these changes were the concerns identified by the NRC, the inspector noted that the licensee had not only alleviated the specific concerns, but had made enhancements to improve the effectiveness of the program beyond NRC requirements. Other changes were also made, at the licensee's initiative, to enhance the effectiveness of the security program, and it was apparent that these had been given considerable attention by knowledgeable personnel during their development and implementatio The inspector also discerned a much more positive attitude and conscious regard of the security program by all station personnel. The inspector learned from personnel interviews that this was a result of licensee management's overt and widely publicized commitment to establish and implement an effective and high quality security program. This commitment was apparent to the inspector from the capital and personnel resources that had been, and are being, expended on the program and management's continued responsiveness to the NRC regarding the progra The inspector also found that the licensee had required its proprietary security staff members to attend special training in areas such as supervision, security practices, plant operation, etc., as needed, based on their prior background and work experience and that the licensee is developing a continuing training program for its proprietary staf _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ________ _________________ __ _ _ - _ _ _ _ _

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l 8 1 The inspector concluded that there had been significant changes in licensee management attitude with regard to the security program and that the security program was now receiving appropriate support and i attention by licensee management, Awareness - Communications i

A significant weakness perceived by the NRC regarding the security group in the past was that it did not participate in on going plant activities, nor was its participation sought, and that this resulted in a serious communications gap between security and other plant functions. This was particularly apparent when maintenance activities occurred that affected plant security without the knowledge of the security group. It was also apparent in the lack of maintenance on security systems and equipment that caused the systems and equipment to be out-of-service for extended periods, requiring members of the security force, of ten on overtime, to compensate for the inoperative systems and equipment. Licensee management previously did not recognize, or would not accept, this weakness as a contributing factor in the poor performance of the security force and in the degradation of the security program in genera Recently, and especially during this inspection, the inspector observed that the proprietary security organization's participation and knowledge of day-to-day plant activities had increased significantl Through interviews and observations, the inspector found that a member of the proprietary security organization was regularly present in the plan-of-the-day meetings and that security was routinely interfacing with other plant functions. As an example, the inspector noted that each proprietary security shif t supervisor meets informally with the Plant Operations Shif t Supervisor on each shift to exchange information. Additionally, the Security Section Manager holds routine staff meetings, which include the participation of the security contractor's supervisors, to discuss plant activities, events, guard force performance and other matters pertinent to maintaining an effective security progra The inspector also observed that licensee and station management are using several internal publications to disseminate informatton about the station to its staf f, e.g. , Nuclear Information Of fic= news releases, daily news letters, and the Work Force Information Progra Those publications periodically include articles about the security program and the security forc To ensure effective com unications within the security force, the inspector found that the licensee had required its security contractor

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to implement a work schedule for the security force that would permit l

each member to receive training on at least one day per week. During that session, current sctivities, issues and problems are also discussed in an open group foru This allows interaction among members of the

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force and supervision, both licensee and contractor, and provides a mechanism to obtain feedback from the force regarding the program.

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Additionally, the licensee has initiated guard formations prior to starting each shift for the purpose of providing current information on s curity and plant activities ta each member of the shif Each guard formation is attended by the proprietary shift superviso . Conc 1Lsion Based upon the inspector's reviews, interviews and observations, the inspector concluded that the licensee has taken significant actions to improve the effectiveness of the security program, including the establishment of a very capable proprietary security organization. The results o'/ most of those actions are readily apparent and the remainder are visibl There is obvious evidence of continuing attention to and support of the program by licensee management. Most of the licensee's proprietary staff are new to the program and to each other. There is ample evidence that they, thus far, have worked together diligently to Establish and implement a potentially ,

high quality and effective program. The existing program is basically i sound and comparable to highly effective programs being implemented at other nuclear stations. Continued licensee management support and attention is required for the program to be effective if the station is permitted to return to operatio Any changes necessary to accommodate an operating plant must be closely monitored, as some changes may be necessary to accommodate an operating plant. The background and experience that the licensee has available in its proprietary organization should provide the i capability to monitor the program properly and assess when those changes are needed.

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