IR 05000331/1998018

Insp Rept 50-331/98-18 on 981116-20 Onsite & 1208 NRC Region 3 Ofc.No Violations Noted.Major Areas Inspected:Review of Physical Security Program

ML20202G161
Person / Time
Site:	Duane Arnold
Issue date:	12/16/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20202G154	List: IR 05000331/1998018 ML20202G149
References
50-331-98-18, NUDOCS 9902050019
Download: ML20202G161 (9)

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OFFICIAL RECORD COPY U.- S. NUCLEAR REGULATORY COMMISSION l

REGION II Docket No: 50-331 License No: DPR-49 Report N /98018(DRS)

Licensee: IES Utilities In l l

Facility: Duane Arnold Energy Center

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Location: 200 First Street P. O. Box 351 Cedar Rapids, IA 52406-0351 Dates: November 16-20,1998 onsite December 8,1998, NRC Region 111 Office Inspector: Gary L. Pirtle, Physical Security inspector Approved by: James R. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety i

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9902050019 981216 i PDR ADOCK 05000331 G PDR ,

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EXECUTIVE SUMMARY  !

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Duane Arnold Energy Center i NRC Inspection Report 50-331/98018 This inspection included a review of the physical security program. It was an announced l inspection conducted by a regional physical security specialis '

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Observed security facilities were well maintained and security equipment functioned as designed. The security equipment testing program was aggressive, and the maintenance support program was considered a strength (Section S2).

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Security procedures and records reviewed were complete and accurate (Section S3).

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Security personnel were very knowledgeable of post requirements and responsibilities. Security supervisors provided excellent oversight of ongoing security activities. An unresolved item was identified pertaining to occasions when the  !

number of armed response force members were reduced below the level required by the security plan, and the reporting requirements for such incidents (Section S4).

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The unescorted access authorization for a contractor employee was terminated because of potential omission or falsification of criminal history information that should have been disclosed during the access authorization process. A copy of the individual's case file was requested for further review This is an inspection Followup Item (Section S8).

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Report Details

I IV. Plant Support  !

S2 Status of Security Facilities and Equipment Inspection Scope (IP 81700)

The inspector reviewed the status and condition of security facilities and equipment required by the security plan. The equipment and facilities observed included, but were not limited to, intrusion detection equipment, assessment equipment, search equipment, alarm stations, access control facilities, and security barrier Observation and Findino The security equipment testing and maintenance program was a strength. The presence of two technicians assigned to the security department to maintain security-y equipment has resulted in the vast majority of security equipment being repaired l generally in two days or less. Support by the other maintenance departments was l also timely. Only three security-related work requests were open for security L equipment during the period of the inspection and these maintenance requests did not involve compensatory measures or noncompliance with the security plan. The maintenance support was also a major contributing factor to the several recent delay barriers installed within the plant to improve the security force's capability to protect the plan The security force has a very aggressive equipment testing program. Several

, components such as the perimeter alarm system are tested more frequently than l

required by regulations. This aggressive testing program identifies potential problems at a very early stage and allows maintenance to correct the problems l before major component failure occurs. Equipment testing procedures reviewed were well written, and observed equipment testing was completed in accordance l with appropriate procedure Two minor items were noted pertaining to equipment testing. Pass / fail testing i

criteria was not identified in the testing procedures for the explosive detectors and alarms on the vehicle barrier system gates. This matter was quickly addressed and resolved by the security staff prior to the close of the inspectio Compensatory measures were seldom needed for equipment malfunctions. The vast majority of compensatory measures were not caused by failed equipment or lack of preventative maintenance. Compensatory measures which were implemented and reviewed were in accordance with security procedures and well documented.

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! Alarm station facilities were spacious, clean, and functionally designed for efficient

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operation of alarm station equipment.

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i_ Conclusions Observed security' facilities were well maintained and security equipment functioned as designed. The security equipment testing program was aggressive, and the maintenance support program was considered a strength.

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83 Security and Safeguards Procedures and Documentation

. Insoection Scope (IP 81700)

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The inspector reviewed selected security procedures pertaining to the areas inspected and also reviewed appropriate logs, records, and other documentation pertaining to the areas inspected,

. Observation and Findina No deficiencies or major problems were identified during review of security procedures. The procedures were well written, reviewed and revised at appropriate -

intervals, and generally were in sufficient depth to describe the tasks to be performed. An unresolved item was identified pertaining to procedure guidance for t documenting instances when the minimum number of armed response force _ ,

members were not immediately available for response to a security contingency (See Section S4.b.2 for related information). Logs and records reviewed were

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complete and accurat Conclusions Security procedures and records reviewed were complete and accurat S4' Security and Safeguards Staff Knowledge and Performance inspection Scope (IP 81700)

The inspector toured various security posts and observed performance of security

.related duties. Security event logs and other records pertaining to security force performance were also reviewe Observation and Findina Security personnel interviewed and observed on post were aware of post responsibilities and procedure requirements, and familiar with the functional capabilities of security equipment located on their posts. Security supervisors provided excellent oversight of ongoing security activitie Security event logs were accurate, completed within the time frame prescribed by regulations and well documented. Very conservative criteria was applied in

. determining which events to formally log in accordance with 10 CFR 73.71. There

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was, however, an unresolved item relating to the adequacy of the licensee's practice of logging, rather than reporting within one hour, instances in which the number of

. available armed responders was reduced below the level required by the security c plan. The question related to whether the licensee's practice and procedure for reporting security events are in accordance with 10 CFR 73.71. (Refer to S4.b.2 for related information).

An observation was noted pertaining to the use of a specific alarm station operator (ASO) as a member of the armed response force during a specific attack threat scenario. The use of the ASO for this purpose would require the operator to leave the bullet resistant structure (as described in the security plan), and the operator would not be able to perform the potential critical duties required by the ASO during such a contingency. Such actions would be contrary to 10 CFR 73.55(e.1) and the Duane Amold Security Plan, which requires two bullet resistant alarm stations to be continuously manned and able to perform required functlons. No violation of security plan requirements occurred because the ASO position has never actually been left unmanned or unable to perform required functions during contingency drills. The use of the ASO as a response force member was primarily a contingency planning option. The security staff agreed not to use the ASO as a member of the armed response force, An unresolved item was noted in reference to the number of times in 1998 when the number of armed response force personnel required by the security plan we.re not immediately available for response to security contingencies, and the reporting requirements when such situations occurre Review of the security event logs showed that on six occasions between January and June 1998, the security staff logged security event reports because the number of armed responders required by the security plan were not immediately available to !

respond to a security contingency because one of the response force members was ,

. used for compensatory measures. Subsequent review and analysis by the security !

staff concluded that there were only four occasions when the number of armed responders were reduced (the other two occasions were primarily a too conservative reporting determination). During these four occasions, additional security force members had to be recalled to meet the minimum manning requirements identified in the Duane Amold Energy Center (DAEC) security plan. The DAEC security plan allows the security force to be reduced for a designated period of time when extensive compensatory measures are required to be implemented. In each of the :

four cases noted above, the compensatory measure requirements required only one l

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armed responder to be used for compensatory measures. The other compensatory posts were manned by unarmed security personnel. This frequency of having to implement call-in of personnel to address reduced manning levels appears excessive, and may not have been the intent intended when the provision of the security plan was approved. Such actions are usually necessary only when catastrophic security equipment failure occur In February 1998, the licensee security staff added delay barriers and other measures for plant protection purposes and reduced the required armed responders

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per shift. The situations requiring use of a:med responders for extensive compensatory measures, and call-in of personnel, may be due more to insufficient shift manning, rather than the extent of equipment failure, if the overall shift staffing had not been reduced in February 1998, there would have been no occasions in 1998 when the number of armed personnel not immediately available for response to a security contingency was in questio The reporting requirements for occasions when the number of armed response ,

force members were reduced also surfaced during review of this issue. The  !

licensee's security procedure for reporting security events requires such incidents *

l Just to be logged, and each event was in fact logged as a security event report. The i procedure guidance may be incorrect. Licensee management provided a written document (copy attached) which addresses their understanding of the security reporting requirements in reference to the reduced number of armed response force members immediately available for response to a security contingency. An important element of their reasoning is the position that compensatory measures are in effect at the time the call-in is initiated, rather than the time of arrival onsite of the person called in. This iaasoning may also be incorrec Therefore, there are two elements of the unresolved item pertaining to the immediate availability of the required number of armed responders. These element are: (1) was the option identified in the security plan to reduce the number of armed responders for a designated period of time granted with the expectation that such an option would be used only for emergencies, illness, or catastrophic equipment failure, and (2) what are the reporting requirements when the required number of armed responders are not immediately available for response to a security contingency? (URI 50-331/98018-01). This issue will be evaluated by NRC Headquarters and resolution of the issue will be addressed by separate correspondence, Conclusions Security personnel were very knowledgeable of post requirements and responsibilities. Security supervisors provided excellent oversight of ongoing security activities. An unresolved item was identified pertaining to occasions when the required number of armed response force members were reduced, and the reporting requirements for such incident S8 Miscellaneous Security and Safeguard issues S8.1 (Closed) Licensee Event Report No. 97-S01-00): This Licensee Event Report (LER)

was dated July 16,1997, and pertained to a security officer being inattentive while on duty on June 16,1997. The inspector confirmed that the corrective actions identified in the LER were implemented. No similar incidents have occurre __ _ _ ___ _ ._

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S8.2 (Closed) Licensee Event Report No. 98-S01-00): This Licensee Event Report (LER)

was dated January 30,1998, and pertained to the loss or failure of security l equipment to be properly compensated for on January 16,1998. The inspector j confirmed that the corrective actions identified in the LER were implemente !

S8.3 During review of Security Event Logs, the inspector noted that a contractor employee's unescorted access authorization was terminated because of possible willful omission or falsification of some criminal history information that was required to be disclosed as part of the access authorization review process. A copy of the i l individual's case file was requested for further review at the NRC Region lll offic This issue will be monitored as an Inspection Followup Item (IFl 50-331/98018-02). Exit Meeting Summary The inspector presented the inspection results to members of the licensee management at the conclusion of the onsite inspection on November 20,1998. The personnel present acknowledged the findings presented. The inspector asked the licensee representatives whether any materials examined or inspection findings discussed during the exit meeting should be considered as proprietary or safeguards information. No proprietary or safeguards information was identifie The licensee management personnel advised the inspector that they wanted to be able to submit a written description of their position pertaining to the reporting requirements for instances when the required number of armed response personnel were not immediately available. The written document was received on December 3,1998. The Security Supervisor was advised on December 8,1998, that our review had been completed, that their correspondence would be included as an attachment to the inspection report, and that our decision was to continue to consider the issue as an unresolved ite .

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PARTIAL LIST OF PERSONS CONTACTED Licensee D. Wilson, Assistant Vice President-Nuclear R. Anderson, Outage and Support Manager K. Bark, Quality Assurance Engineer S. Catron, Security M. Duss, Security D. Englehart, Security Supervisor B. Junoosque, Site Manager, Per Mar inc D. Jantosik, Quality Assurance Manager J. Karrick, Nuclear Licensing Specialist M. Meeks, Security B. Murrell, Regulatory Communications K. Putnam, Licensing Manager K. Peveler, Manager, Regulatory Performance D. Stiefel, Security Specialist G. Van Middleswworth, Plant Manager G. VonRoden, Security technician NRC M. Kurth, NRC Region 111 Resident inspector INSPECTION PROCEDURES USED IP 81700 Physical Security Program for Power Reactor IP 92904 Followup - Plant Support ITEMS OPENED, AND CLOSED Opened 50-331/98018-01 URI implementation and Reporting of Occasioris When Required Armed Responders Were Not immediately Available 50-331/98018-02 IFl inaccurate and incomplete Access Authorization Record o

For a Contractor Employee Closed

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97-SO1-00 LER Inattentive Member of The Security Force

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98-S01-00 LER Irnproper Compensatory Measure For Security i

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Equipment l PARTIAL LIST OF DOCUMENTS REVIEWED Weekly intrusion Detection System Tests Between August 8 and October 31,1998 Weekly Vital / Protected Area Portal Tests Between August 10 and October 26,1998 ,

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DAEC Security Directive SD-01, " Self Inspection Program", Revision 2, November 20,1995 DAEC Security Directive SD-2, " Communications", Revision 9, December 19,1997 DAEC Security Directive SD-4, " Explosive detectors", Revision 11, March 11,1995 DAEC Security Directive SD-5, " Metal Detector", Revision 10, July 11,1998

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DAEC Security Directive SD-8, "CAS/SAS Operations", Revision 38, September 24,1998 i DAEC Security Directive SD-16, " Secondary Security System", Revision 3, March 18,1998

DAEC Security Directive SD-17, " Perimeter intrusion Detection System Tests", Revision 13, March 16,1998 DAEC Security Directive SD-19, " Security Control Point Operations", Revision 6, September 18,1997 Twenty-Three Action Request Forms from January 2 through October 22,1998 Attachment: Licensee's Position on Reporting Certain Security incidents  !

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