IR 05000352/1987010

Insp Rept 50-352/87-10 on 870324-26.No Violations Noted. Major Areas Inspected:Security Organization & Security Contingency Plan (Response Drills)

ML20214J685
Person / Time
Site:	Limerick
Issue date:	05/05/1987
From:	Bailey R, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214J676	List: IR 05000352/1987010 ML20214J674
References
50-352-87-10, NUDOCS 8705280159
Download: ML20214J685 (4)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-10

Docket N License N NPF-27 Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Generating Station Inspection At: Limerick, Pennsylvania Inspection Conducted: March 24-26, 1987 Date of Last Physical Security Inspection:- January 6-9, 1987 Inspector: _

[ M #7 R. J. Bailey 9sical Sgturity Inspector date/

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Approved by: 3-c .y S 5 B7 g. R. Keimig, Chief, Sa ards Section date DRSS Inspection Summary: Unannounced, Physical Security Inspection on March 24-26, 1987 (Inspection Report No. 50-352/87-10).

Areas Inspected: Security Organization and Security Contingency Plan (Response Drills).

] Results: The licensee was in compliance with NRC requirements in the areas examine I

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8705280159 870521 PDR ADOCK 050003521

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DETAILS Key Persons Contacted J. F. Franz, Plant Manager R. J. Weindorfer, Director, Nuclear Security P. R. Supplee, Technical Analyst, Nuclear Security N. R. Carter, Corporate Security Staff F. J. Larkin, Nuclear Security Specialist W. A. Rekito, Compliance Engineer B. J. Pellegrini, President, Protection Technology, In M._V. Annast, Senior Vice President, Protection Technology, In C. J. Mannila, Performance Analyst, Protection Technology, In J. D. Mcdonald, Program Manager, Protection Technology, In E. M. Kelley, NRC Senior Resident Inspector The inspector also interviewed other licensee and Protection Technology, Inc. personne . Security Organization The inspector was provided a copy of a new-PECo security organization chart. The chart depicts the licensee's security management staff for Limerick, under the corporate Manager, Nuclear Support Department. The new organization reflects those changes and commitments made to NRC Region I in the past to provide' additional PECo' management oversight of the security contracto The inspector verified that the licensee established, at Limerick, the security staff identified on the organization chart. Each position was filled and personnel were performing their assigned duties, with one exception. The Director of Nuclear Security informed the inspector that only one of the five Shift Security Assistants (SSAs) is near qualifica- I tion. The remaining four SSAs will require up to 6 months of specialized training before being assigned full-time duties. The Director further stated that the SSAs will be under direct supervision of the Nuclear Security Specialist and will receive training from the security force training sectio In addition to the security organization reporting to the corporate Nuclear Support Department Manager, a security manager will be assigned to the corporate Manager, Electric Production. He will be responsible for i conducting annual audits of the onsite security organization. This i position has been filled and the incumbent is currently undergoing trainin l On March 20, 1987, Day and Zimmermann, Inc., parent company of YOH Security, Inc., the licensee's security contractor, announced the formation of Protection Technology, Inc., (PTI) a new, wholly-owned

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subsidiary, to direct and manage its security services business. PTI is now responsible for performing the services previously provided by YOH Security, Inc. at the Limerick facilit The inspector discussed the changeover with Mr. B. J. Pellegrini, the President of PTI, and the Senior Vice President, Mr. M. V. Annast, who were on site during this inspection, and was provided a copy of the organization charts for the PTI Operations management staff, the training staff and the administrative staff for Limerick. The inspector confirmed that all key positions were fille The inspector was also informed that all members of the YOH security force had been retained by PTI. The

inspector determined that the staffing of PTI was consistent with the licensee's NRC-approved security pla ,

3. Security Contingency Plan (Response Drills)

The inspector found that the security force contractor had suspended the contingency response drill program on February 27, 1987, as a result of a

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problem with a drill that occurred on February 26, 1987. That drill,

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identified as a Security Challenge-Program drill (Security Instruction 037), consists of a member of the Performance Analysis Group (PAG) drilling a single member of the security force. The security force member must correctly respond or lose task certificatio On February 26, 1987, the Central Alarm Station (CAS) Operator was j selected for a Security Challenge Program drill. The CAS operator's response to the challenge was correct and, at that time, the CAS operator's supervisor, who was aware of the drill, should have announced the situation as a drill to stop further respons However, the super-visor allowed the response to go forward and the security force responded as if it were an actual situation. The response was eventually terminated without incident, but it had the potential for serious personal safety consequences. During a critique of the occurrence, security force manage-ment determined that the lack of action by the CAS operator's supervisor was contrary to procedure and irresponsibl The inspector reviewed the documentation on this drill and found three significant failings: supervisor (sergeant) failing to follow approved procedures; neither the licensee nor the security contractor had addressed that the response team was not properly equipped when it responded; and the actions of other members of the security force were not totally correct for the situatio l The licensee acknowledged these failings and stated that additional l analysis of the drill would be conducte In addition, the licensee's l security representatives proposed the following corrective actions to j prevent recurrence: Reemphasize to all supervisors the importance of following approved written security procedures and instructions,

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i Review SI-037 and revise, if necessary, to ensure that this instruction adequately provides checks for preventing drills involving only one individual from becoming uncontrolled, Review SI-033 (another security instruction for conducting drills)

for adequacy and ensure that this instruction provides the necessary checks for simulated drills and exercises, and

. Establish a management review process to analyze all security events for safeguards significance and degradations of security program effectivenes The inspector informed the licensee that the drill program will be reviewed during future inspection . Exit Interview The inspector met with the licensee representatives listed in paragraph 1 on March 26, 1987, and discussed the scope and results of the inspectio No written material was provided to the licensee during this inspectio l l

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