IR 05000346/1997010

Insp Rept 50-346/97-10 on 970806-07 & 0903-04.No Violations Noted.Major Areas Inspected:Review of Vehicle Barrier Sys

ML20211P250
Person / Time
Site:	Davis Besse
Issue date:	10/11/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211P223	List: IR 05000346/1997010 ML20211P219
References
50-346-97-10, NUDOCS 9710200113
Download: ML20211P250 (7)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lll Docket No: 50 346 License No: NPF-3 Report No: 50 346/97010(DRS)

Licensee: Toledo Edison Company

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Facility: Davis Besse Nuclear Power Station Location: 5503 N. State Route 2 Oak Harbor, OH 43449 Dates: August 6 7,1997 onsite September 3-4,1997 in NRC Region til Office inspector: G. Pirtle, Physical Security inspector Approved by: James R. Creed, Chief, Plant Support Branch 1

. Division of Reactor Safety

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9710200113 PDR 971011 O ADOCK 05000346 PDR

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EXECUTIVE SUMMARY Davis Besse Nuclear Power Station NRC Inspection Report 50 346/97010 This announced inspection included a review of the Vehicle Banier System (VBS). Temporary Instruction 2515/132 " Malevolent Use of Vehicles at Nuclear Power Plants" was used for inspection guidanc No violations or deviations were noted. The features and structures that form the VBS met the des!gn characteristics established by the NRC. The vehicle barrier components, or acceptable other barriers, and the location of the barriers were as described in the summary description of the VBS submitted by the licensee to the NRC, or as described in the current security pla Two unresolved items and one inspection followup item were noted as described below;

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No violations or oeviations were noted. The provisions for land vehicle control measures met regulatory requiremerts and licensee commitment * An unresolved item was noted pertaining to the proper designation and protection requirements for a vehicle barrier gate (Section S1.1.b.3(a)).

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An inspection followup item was noted pertaining to some vehicle barrier system-related procedure deficiencies (Section S1.1.b.3(b)).

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Reoort Delalla IV. Plant Sunnort 81 Conduct of Security and Safcuuards Activities S1.1 Temocrary Instruction 2515/132. " Malevolent Use of Vehicles at Nuclear Power Plants" insoection Scone (Tl 2515/132)

Areas examined included the i ..,nsee's provisions for land vehicle control measures to protect against the malevolent use of a land vehicle and to determine compliance with regulatory and licensee commitment Observations and Findinas Vehicle Barrier System

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The inspector found that the features and structures that form the Vehicle Barrier System (VBS) met the design characteristics established by the NRC. The vehicle barrier components and the location of the barrier were as described in the summary description of the VBS submitted by the licensee to the NRC or as described in the security pla A visual walkdown performed by the inspector confirmed that the general type of vehicle barrier described in the VBS summary description, or an acceptable alternate type of barrier, had been Installed and that the barrier was continuou No significant signs of barrier damage was noted during the walkdown of the VBS. The inspector also confirmed that the active barriers (gates) had manufacturer's certifications that the barriers would meet or exceed the maximum parameters of the design basis vehicle threa . Bomb Blast Analysis inspector field observations of standoff distances were consistent with those documented in the summary description, The licensee confirmed that calculation of minimum standoff distance was based on NUREG/CR 6190 or an independent engineering analysi . Procedural Controls The licensee appropriately defined criteria for maintenance, surveillance, and compensating for the VBS in appropriate procedures. The procedures were generally well written and detailed except as noted in (b) below. Discussions with the Manager, Security and a telephone interview by the inspector confirmed that procedures necessary to safely shutdown the unit after a bomb blast were reviewed and found to be adequate by Operations personnel. A specific

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procedure for damaged equipment by a bomb blast was not prepared, but the existing abnormal operation and emergency operating procedures were considered adequate to cope with loss of equipment because of a bomb blas (a) The licensee's security procedures designated a moveable vehicle barrier gate as a * passive " barrier and therefore it did not require tamper alarming under certain conditions, or quarterly inspections of the barrie However, Table 5.1 of NUREG/CR 6190, * Protection Against Malevolent Use of Vehicles at Nuclear Power Plants", Section 5.2 of NEl Document 96-01, " Nuclear Power Plant Guidelines for Operational Planning and Maintaining Integrity of Vehicle Barrier Systems", and Section 5 of the licensee's " Safety Evaluation Mod 94 0026," identify gate type barriers as

" active" barriers which would require quarterly inspections and additional alarm protection under certain conditions (the details of the protection requirements and potential deficiencies with the barrier are considered safeguards information). The Manager, Security considered the device (gate barrier) to be a " passive" barrier because it was in a " permanent" locked closed position and would not be used or opened, except for emergency conditions. As such, the gate barrier functined as a passive barrier since it was not used in a functional manner on a continuous basis. The unresolved matter is to determine whether this active type gate that is used as a " passive" barrier require quarterly inspections 50 346/97010-01).

(b) During review of security procedures, the following weaknesses were noted. Correction of the weaknesses will be monitored as an Inspection Followup Item (50 346/97010-02).

The licensee's procedure for reporting and logging security incidents /

events relating to the PBS did not identify what degradations or vulnerabilities would be reported to the NRC or logged as security events / incidents in accordance with 10 CFR 73.71. Existing NRC guidance for reporting and logging security events / incidents does not describe examples of VBS degradations or vulnerabilities that warrant reporting or logging. The licensee will be informed of that guidance when it is develope The characteristics of the design basis vehicle described within the security plan was incorrec Portions of the Security Plan and some procedures need to be revised to address actions identified in NEl Document 96-01 " Nuclear Power Plant Guidelines for Operational Planning and Maintaining Integrity of Vehicle Barrier Systems", or equivalent measures, for VBS compensatory measures, observations and inspectiorw of the VBS, and other areas addressed in NEl Document 96 01. The security t,taff prepared procedures based upon guidance in the draft NEl 96-01 document and

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did not revise the guidance in the procedures when changes were made to the draft NEl document and the document was distributed in final for The inadequate guidance did not cause any violations of NRC requirements because compensatory measures have not been needed for the VBS since its constructio Two segments of the VBS (east wall of the weld building and an open segment of the barrier with a 90 degree turn) did not have a formal analysis documented to assure that the barriers were adequate. The west wall of the weld building had heavy equipment in place along the wall and the area was marked with signs to contact security before any equipment was moved from the wah. The opening in the VBS barrier had one 90 degree turn that appeared to be too narrow to aUow a vehicle of the design basis characteristics to negotiate the turn and therefore breach the barrier. However, neither location of the VBS had the analysis documented, Conclusions The licensee's provisions for land vehicle control measures met regulatory requirements and licensee commitments. The VBS program was cons,istent with the summary description submitted to the NRC or the security plan; installed components were identified in Nt; REG /CR-6100 or the licensee's engineering analyses; and appropriate procedures had been developed and implemented. An unresolved item was noted portalning to the protection required for one gate barrier. An inspection followup item was identified for weaknesses noted with some VBS related procedure X1 Exit Meeting Summary The inspector presented the inspection results to members of the licensee management at the conclusion of the onsite inspection on August 7,1997. The licensee acknowledged the findings presented. The inspector asked the licensee whether any materials examined or inspection findings discussed during the exit meeting should be considered as proprietary or safeguards information. It was agreed that any potential deficiencies with the vehicle gate barrier should be considered safeguards information until the issue was resolved. No other proprietary or safeguards information was identifie The inspector also requested that additional information pertaining to any safety evaluation being completed for the VBS be sent to the NRC Region ill office for review. The requested documentation was recolved September 3,1997. The Manager, Security was advised on September 16,1997, that the document review was completed and there were no further question ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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PARTIAL LIST OF PERSONS CONTACTED l Licensee ,

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C. Detray, Auditor Quality Assurance ~

D. Eshelm, Operations Manager D. Lockwood, Supervisor, Compilance D. Miller, Senior Engineer, Regulatory Affairs T. Myers, Director, Support Services A. Schumaker, Supervisor, Security Support G. Skeel, Manager, Securit/

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NBC Stan Stasek, Senior Resident inspector INSPECTION PROCEDURE USED i

Tl 2515/132 " Malevolent use of Vehicles at Nuclear Power Plants" Issued January 18,1996 ITEMS OPENED Ooened 50 346/97010-01 URI Designation and Protection Requirements For a Segment of the VBS 50-346/97010-02- IFl VBS Related Procedure Weaknesses

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LIST OF ACRONYMS USED VBS Vehicle Barrier System IFl inspection Followup item URI Unresolved item PARTIAL LIST OF DOCUMENTS REVIEWED Vehicle Barrier System Description, dated February 27,1995 (with Blast Effects Analysis of the Davis Besse Nuclear Power Station to Establish Safe Standoff Distances as Required by the 10 CFR 73 Rule), dateo February 27,199 Changes to the Vehicle Barrier System Description,(with Blast Effects Analysis of the Davis Besse Nuclear Power Station to Establish Safe Standoff Distances as Required by the 10 CFR 73 Rule), dated February 8,199 Quality Assessment Surveillance Report SR 95 SECUR 02, dated January 25,1996, (Implementation of the Malevolent Vehicle Rule).

Cait,ulations For Unanchored Concrete Blocks, dated May 2,199 Procedure IS DP-08917," Weekly IDS Operabilty Test", Revision 06, Approved March 14, 199 Procedure IS DP-08512. " Vehicle Control Procedure", Revision 2, Approved March 15,1996.

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Procedure IS DP 04011," Inspection of the Passive Vehicle Barrier System", Revision 0, Approved September 24,199 Procedure IS DP 00518," Reporting Requirements", Revision 9, Approved November 14,199 Procedure IS DP 08005," Duties and Responsibilities of a Patrol Officer", Revision 5, Approved June 16,199 Safety Evaluation for Modification 94-0026, * Protection Against Malevolent Use of Vehicles at Nuclear Power Plants *, Approved October 18,199 USAR Change Notice No.95-079, dated July 10,199 _ _ _ _ _ _ _ - _ - _ _ _ -