IR 05000352/1988010
| ML20153F411 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/02/1988 |
| From: | Keimig R, Lancaster W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20153F382 | List: |
| References | |
| 50-352-88-10, NUDOCS 8805100318 | |
| Download: ML20153F411 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-352/88-10 Docket No.
50-352 License No.
NPF-27 Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name.
Limerick Generating Station Inspection At:
Limerick, Pennsylvania Inspection Conducted: April 11-15, 1988 CA,M M 6-A-TI Inspector:
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V. K. Lancaster, Physical Security Inspector date
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Approved by:
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/R. R. KeimigMhief,f5Efeguards Section date Division of Radiattdn Safety and Safeguards Inspection Summary:
Routine Unannour.ced Ph 11-15, 1988 (ysical Security ~ Inspection 507 52/88-10)
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Areas Inspected: Management Effectiveness; Organization; Physical Barriers -
Protected Area; Lighting; Alarm Stations; Personnel Training and Qualifications; Access Control - Personnel; Access Control - Packages; and Access Control - Vehicles.
Results: The licensee was in compliance with NRC requirements in the areas examined.
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Details
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1.
Key Personnel Contacted i
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A.
Philadelphia Electric Company (pECO)
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G. M. Leitch, Vice President, Limerick Generating Station
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J. H. King, Jr., Support Manager, LGS
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F. J. Larkin, Nuclear Security Specialist i
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R. J. Weindorfer, Director, Nuclear Plant Security
P. R. Supplee, Analyst, Nuclear Plant Security-
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j G. A. Bird, Nuclear Quality Assurance
V. M. Vitale, Protection Technology, Inc., Program Manager
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B.
V. S. Nuclear Regulatory Commission (NRC)
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T. J. Kenny, Senior Resident Inspector
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The inspector also interviewed other Philadelphia Electric Company
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..i personnel and members of the Protection Technology, Inc. (PTI),
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Management Effectiveness - Security program
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L A.
The licensee has developed an action plan and tracking program for l
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implementing NRC physical security at the Limerick Generating
Station Unit No. 2.
A portion of this action plan includes revising
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the Limerick Generating Station's Physical Security Plan (the j
i Plan). The licensee anticipates submitting it to the NRC for
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approval during the summer of 1988. The licensee has taken the i
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following actions in preparation for Unit No. 2 licensing-
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A Security Coordinator, Shift Security Assistant, Nuclear
i Security Analyst and two contract security specialists are
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presently assigned to monitor Unit No. 2 construction
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activities, evaluate and assign compensatory posts for all Unit
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F No.1/ Unit No. 2 protected area barrier interfaces, and to
j provide coordination, as needed.
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General Employee Training (GET) has been updated to address the j
Unit No. 1 / Unit No. 2 final configuration and personnel i
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l Security procedures have been revised to reflect Unit No. 2
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requirements, as well as anticipated Plan changes.
i The present security system has been upgraded to enable
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j handling of Unit No. 2 system activities.
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beekly interface meetings with Engineering have been initiated
in order to provide Unit No. 2 security system integration and equipment upgrades.
B.
The following actions have been taken by the licensee since the last NRC routiae physical security inspection to enhance the existing security program:
The Shift Security Assistants are assuming more of the
day-to-day security auditing functions previously performed by the security force contractor.
The Security Technical Assistant has become a qualified CAS/SAS
operator.
The Shift Security Assistants will all receive CAS/SAS
familiarization training beginning in May, 1988.
All of the Shif t Security Assistants have been trained in the
station's Surveillance Testing program to ensure that all security systems and equipment are maintained in a operable condition as required by the Plan.
All of the Shift Security Assistants have been trained as
Emergency Preparedness Security Team Leaders.
Card reader key pads for personal identification codes have
been installed on the Protected Area entrance turnstiles to ensure against the potential of issuing a wrong badge / key card.
The licensee security representatives are meeting with the
station's Instrumentation and Control (I&C) group to exchange information, prioritize work support activities, and provide input to enhance the preventive maintenance program for security systems and equipment.
C.
The following actions have been taken by the licenser's security force contractor since the last NRC routine physical security inspection to enhance the existing security program:
Additional training aids have been incorporated into the
security force training program.
They include walk-through metal and explosive detectors, intrusion detection system components and specimens of various physical barriers. Other training enhancements are being planned for use in the training program, such as videos and overheads.
Establishment of a equipment issue / arms room system and a full-
time equipment issue / maintenance officer.
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Establishment of a sixth Shif t Sergeant to maintain continuity
of daily security force coetations.
Rotation of Shift Sergeants on a quarterly schedule in order to
enhance familiarity with all aspects of station operations.
Development of a qualified and trained supervisory pool to
provide succession planning.
Establishment of a radio battery maintenance program.
- Identification and requisition of additional contingency
equipment to include additional response weapons.
Upgrading the weapons training program to include the use of
the state-of-the-art weapons training facility offsite.
Upgraded security patrol vehicles.
- Development and implementation of Emergency Preparedness (EP)
task training to enhance ability of the security force to perform EP tasks and to provide an objective testing method to evaluate the capabilities of security force members.
Completion of the annual program of sampling security force
members' abilities to perform the required critical security tasks.
D.
On April 15, 1933, the Limerick Generating Station had a nuclear security force consisting of 270 members (263 qualified plus 7 trainees). A review of the security force contractors records revealed that the contractor has been experiencing a average monthly attrition rate of 5.75 since January 1,1988.
E.
In summary, the licensee and the licensee's security force contractor appear to have the common goal of establishing and maintaining a high quality and effective performance-based security program rather than a compliance oriented program.
Both the licensee and the security force contractor continue to demonstrate initiative by instituting new measures to improve their respective program responsibilities.
Both appear intent upon identifying problems indicators and correcting those before they become problems. As an example, the inspector noted that when he found a security computer problem in the CAS on April 13, 1983, the security force contractor had already identified it, and the licensee hed taken corrective measures to upgrade the system and eliminate it.
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3.
Security Organization
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l The licensee reorganized the nuclear security organization on l
April 1, 1988.
The organization currently in place is different than the l
security organization that is described in Chapter 1 of the licensee's
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NRC-approved Security Plan (the Plan). As a part of this reorganization,
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the station's Nuclear Security Specialist reports to station management instead of to the Director of Nuclear Plant Security.
The licensee stated at the exit interview that the Plan would be revised to reflect the new station security organization and responsibilities by June 1, 1988, as required by 10 CFR 50.54(p).
4.
Physical Barriers - Protected Area The inspector conducted a physical inspection of the protected area barriers. The inspector determined, by observation, that the barriers were installed and maintained as described in the Plan.
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Lighting The inspector conducted a physical inspection of the security lighting system in the protected area and isolation zones on April 13, 1988, from 8:00 p.m. to 11: 45 p.m.
The inspector determined, by observation, that the lighting system was installed and maintained as described in the Plan.
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Alarm Stations
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The inspector observed the operation of both the CAS and SAS and found them to be operated as committed to in the Plan.
CAS and SAS operators were interviewed by the inspector a'id were found to be knowledgeable of their duties and responsibilities.
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Personnel Training and Qualification - General Requirements The inspector examined the PTI Personnel Training and Qualification program. This examination consisted of the following:
observation of several initial training classes for watchmen, interviews of security force trainees, PTI instructors, PTI management personnel, security force members on post and PECO Security Shift Assistants on duty; observation of initial on-the-job-training (0JT) being conducted for watchmen and
CAS/SAS Operators; observation of annual Training and Qualification Plan
recertifications being conducted on watchmen, security officers and CAS/SAS operators; and by reviewing training records, lesson plans and PTI policies concerning promotions.
l The inspector determined that all required training had been conducted in accordance with security program plans and that all such training was properly documented.
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Access Control - Personnel and Packages The inspector reviewed the personnel and package access control procedures ~and. determined that they were consistent with commitments in the Plan.
This. determination was made by observing personnel access processing during shift changes, visitor access processing, and.
discussions with members of the security force about personnel and package procedures.
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Access Control - Vehicles The inspector reviewed the vehicle access control procedure and determined that it was consistent with commitments in the Plan. This determination was made by observing vehicle access processing into the Protected area, and discussions with members of the security force about vehicle procedures.
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Exit Interview The inspector met wit.% the licensee representatives listed in Paragraph 1.A. at the conclusion o.' the inspection on April 15, 1988, and reviewed the purpose and scope of the inspection and presented the inspection findings.
No written material was provided to the licensee during this inspection.
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