IR 05000352/1989008

Partially Withheld Physical Security Insp Repts 50-352/89-08 & 50-353/89-14 on 890307-09 & 20-23 (Ref 10CFR73.21).Violations Noted.Major Areas Inspected:Action on Previously Identified Items & Security Program Plans

ML20245C250
Person / Time
Site:	Limerick
Issue date:	04/14/1989
From:	Cameron D, Keimig R, Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20245C241	List: IR 05000352/1989008 ML20245C240 ML20245C249
References
50-352-89-08, 50-352-89-8, 50-353-89-14, NUDOCS 8904270077
Download: ML20245C250 (7)

Text

_ _ _ _ - _ _ _ - _ - _ - _ _ - _ _ _ -

,nrnrp M: i:

-

-

z,

-

f ,

,, .

N [. ,s pr)

. -

t .._ a ). j:f ,

AR'WTWZ (c1 m:Izn.c.)

MLZ..N U r)

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /89-08; and 50-353/89-14 Docket No. 50-352 and 50-353 License No. NPF-39 and CPPR-107-Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania Facility Name: Limerick Generating Station, Units 1 and 2 Inspection At: Limerick, Pennsylvania Inspection Conducted: March 7-9 and 20-23, 1989 Type of Inspection: Routine Unannounced Physical Security Inspectors: . ./4. 99  !

G. C. Smith, Safeguaw0s Specialist date Y0 4% 4.l4 99 D. F. Cameron, Reactor Engineer-Physical date Security Approved by: A 4. /4 t 9 R. R. Keimig, Chief,/Safeguardt Section date Division of Radiation Safety and Safeguards Inspection Summary: Routine Unannounced Physical Security Inspection on March 7-9 and 20-23, 1989 (Report Nos. 50-352/89-08 and 50-353/89-14)

Areas Inspected: Licensee Action on Previously Identified Items; Management Support, Security Program Plans and Audits; Protected and Vital Area Physical

,

i Barriers, Detection and Assessment Aids; Protected and Vital Area Access Control of Personnel, Packages and Vehicles; Alarm Stations and Communications; Power Supply; Testing, Maintenance and Compensatory Measures; Security Training and Qualifications, and the Safeguards Information Progra Results: The licensee was in compliance with NRC requirements in the areas inspected except for a Vital Area Access Control problem that was promptly and effectively corrected during the inspectio DR 9904j7 g ADOCK 05000352 PNU

- _ - - _

.

,- .

.-

DETAILS Key Persons Contacted Licensee and Contractor Personnel i

• J. King, Jr. , Support Manager, Limerick Generating Station (LGS)

• F. Larkin, Nuclear Security Specialist, LGS

• P. Supplee, Nuclear Security Analyst, LGS R. Weindorfer, Director, Nuclear Plant Security Corporate Support

• V. Vitale, Vice President, Protection Technology, Inc. (PTI)

• B. Batten, Security Force Supervisor, Protection Technology, In (PTI)

• Smith, Lead Auditor, Nuclear Quality Assurance

• W. Sokso, Junior Technical Assistant, Licensing W. Shych, Chief, Security Coordinator D. Merrick, Badging and Screening R. L,nauts, Technical Assistant, Security R. Ludwig, I&C Supervisor U. S. Nuclear Regulatory Commission T. Kenny, Senior Resident Inspector, Unit 1 R. Gramm, Senior Resident Inspector, Unit 2 R. Fuhrmeister, Resident Inspector, Unit 2

• Indicates those present at the exit meeting Other PECo and PTI personnel, including members of the security force, were interviewed during the inspectio . Licensee Action on Previously Identified Items (Closed) Violation 50-352/86-01-03: Failure to report a violation of the Security Contingency Plan. The security contractor conducted a remedial training course for all supervisors on the requirements and responsibili-ties for reporting security related events in accordance with 10 CFR 73.71. This remedial training has been effective as evidenced by the prompt reporting of simi'ar and other events that have occurred since that tim (Closed) Inspector Follow Item 50-352/86-19-02: NRC review of responses to the Annual Security Audit. The inspectors reviewed the responses to the Annual Security Audit and found the corrective actions to be timely and effectiv (Closed) Violations 50-352/86-25-01 and 50-352/87-20-01: Failure to properly mark a document that contained Safeguards Information and failure to store Safeguards Information in a container approved by the General Service Administration (GSA). The inspectors reviewed the licensee

- _ - _ _ _ _ _ _ _ _ _

- ___ - _ - -

.

,- . ,-

!

'

program for the control, marking, and storage of Safeguards Informatio No discrepancies were noted and all Safeguards Information was stored in GSA approved container . Management Support, Security Program Plans, and Audits Management Support - Management support for the licensee's physical security program was determined to be adequate by the inspector This determination was based upon the inspectors' reviews of various aspects of the licensee's program during this inspection.

l Security Program Plans - The inspectors verified that changes to the licensee's Security, Contingency, and Guard Training and

'

Qualification Plans, as implemented, did not decrease the effectiveness of the respective plans, and that they had been submitted in accordance with NRC requirement Audits - The inspectors reviewed the 1988 annual security program audit report and the scope of the 1989 audit, which was in progres The inspectors verified that the audits had been conducted in accordance with the Security Plan (the Plan). The audits were comprehensive in scope with the results reported to the appropriate levels of management. The inspectors' reviews included the response of the security organization to the audit findings and the corrective action taken to remedy any adverse findings. The documented corrective actions appeared appropriate for the finding . Protected and Vital Area Physical Barriers, Detection and Assessment Aids Protected Area Barriers - The inspectors conducted a physical inspection of the PA barrier on March 8 and 22, 1989. The inspectors determined, by observation, that the barriers were installed and generally maintained as described in the NRC-approved security plan (the Plan), Protected Area Detection Aids - The inspectors observed the PA l perimeter detection aids on March 8 and 22, 1989 and determined that they were installed, maintained and operated as committed to in the Pla Isolation Zones - The inspectors verified that isolation zones were adequately maintained to permit observation of activities on both sides of the PA barrie Protected Area and Isolation Zone Lighting - The inspectors conducted a lighting survey of the PA and isolation zones on March 22, 198 The inspectors determined, by observation, that lighting in the isolation zones was in accordance with commitments in the Pla _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.. .. .-

• *

.):

4 Asse;sment' Aids - The inspectors observed the 'PA perimeter assessment aids and determined that they were installed, maintained, and operated as committed to in the Pla Vital Area Barriers - The inspectors conducted a physical inspection of several Vital Area (VA) barriers on March 8,1989. The inspectors determined, by observation, that the barriers were installed and maintained as described in the Pla Vital Area Detection Aids - The inspectors observed the VA detection aids and detennined that they were installed, maintained and operated as committed to in the Pla . Protected and Vital Area Access Control of Personnel, Packages and Vehicles The inspectors reviewed the licensee's vital area access controls for personnel and packages on several occasions throughout the inspection. The controls were found to be in accordance with the Plan and implementing procedures, except as described belo Tills PARAGRAPH CONIAINS SAFEGUARDS IRFORMAllGW AND IS NOT FOR PUBLIC DISCLOSURE, IT IS INTENil0NAllY LEFT BLAN The failure to positively control access to these two vital areas is an apparent violation of NRC requirements. (50-352/89-14) However, since the licensee the licensee took prompt and effective corrective action and modified the access control procedures accordingly, no I

L________-..__

-

_ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ ___ _ _ _ - - - - - - . - _ - - . _ - - - - - - - - - - - - - - - _ _ - - - - _ - - - _ - _ - _ - _ - - - - - - - - _ - - - _ - . - - - _ - - - - _

__-___ __-_ - __ - _ -

k-

[ . y ,-

-

s

.

, written response to this violation is required and the violation is l close .

l The inspectors also reviewed PA access controls and determined that the licensee was exercising positive control over personnel access to

'

the PA. This determination was based on the following:

1) The inspectors verifie'd that personnel are properly identified and authorization is checked prior to issuance of badges and key-card ) The inspectors verified that the licensee has a program to confirm the trustworthiness and reliability of employees and contractor personne This program includes checks on employment history, criminal' history, physical examination, and a psychological examinatio ) The inspectors reviewed the security lock and key procedures and determined that they were consistent with commitments in the Pla The inspectors also reviewed the PA and VA key inventory logs, and discussed lock and key procedures with members of the security force and the licensee's security staf ) The inspectors verified that the licensee takes precautions to ensure that only authorized individuals can be added to the access list by having a member of management review the list every 31 day ) The inspectors verified that the licensee has a search program, as committed to in the Plan, for firearms, explosives, incendiary devices and other unauthorized materials. The inspectors observed personnel access processing during shif t changes and visitor access processing, and interviewed members of the security force and licensee's security staff about personnel access procedure ) The inspectors determined, by observation, that individuals in the PA and VAs display their access badges as require ) The inspectors verified that the licensee has escort procedures for visitors to the PA and VA ) The inspectors verified that the licensee has provisions for expediting prompt access to vital equipment during emergencies and that the provisions are adequate for the purpos ) The inspectors verified that unescorted access to VAs is limited to authorized individuals. The VA access list is revalidated at least

,once every 31 days as committed to in the Pla The inspectors also reviewed and determined that the licensee was exercising positive control over packages and material that are brought into the PA. The inspectors reviewed the package and material control procedures and found that they were consistent with

- - - - -__

.

j .

,

.

'

commitments in the Plan. The inspectors also observed package and material processing and interviewed members of the security force and the licensee's security staff about package and material control procedure The inspectors also reviewed and determined that the licensee properly controls vehicle access to, and within, the PA. The

. inspectors verified that vehicles are properly processed prior to entering.the PA and that the process was consistent with commitments in the Plan. The inspectors also reviewed the vehicle search procedures and determined that they were consistent with commitments in the Plan. This determination-was made by observing vehicle processing and sear:h, inspection of vehicle logs, and by inter-viewing members of the security force and licensee's security staff about vehicle proce ssing and search procedure . Alarm Stations and Commt nications Alarm Stations The inspectors observed the operations of the CAS and SAS and determined that they were maintained and operated as committed to in the Plan. CAS.and SAS operators were interviewed by the inspectors and found to be knowledgeable of their duties and responsibilitie The inspectors verified that the CAS and SAS do not contain any operational activities that would interfere with the assessment and response function Communications The inspectors observed tests of all communications capabilities in both the CAs and SAS and reviewed the testing records for the communications channels. All were found to be as committed to in the Pla . Emergency Power Supply The inspectors verified that there are several systems (batteries, diesel generators, and plant on-site AC power) that provide backup power to the security system and reviewed the accompanying test and maintenance procedures for these systems. The system and procedures were consistent with the Plan. The inverter, diesel generator, and backup power switchgear are located in VA The inspectors also verified that the door access control system for VAs will permit emergency ingress and egress when normal power is los . Testing, Maintenance and Compensatory Measures The inspectors reviewed testing and maintenance records and confirmed that the records committed to in the Plan were on file and readily available I

L-_-__-------._--------A. - - - _ - _ - - - - . - - - - - - . _ _

_ - _

,

. ,o

-

i for NRC revie The station Nuclear Security Organization has dedicated instrumentation and controls technicians as a part of the security organization to repair / replace and test any security equipment which requires preventive or corrective maintenance. A check of repair records indicated that repairs / replacements and testing is accomplished in a timely manner so as to reduce the need for compensatory measure The inspectors also reviewed the licensee's use of compensatory measures arid found them to be reasonable and as committed to in the Pla . Security Training and Qualification The inspectors randomly selected and reviewed the training and qualifi-cations records for six security officers (S0s). Physical qualifications and firearms qualifications records were inspected. These records were for armed guards, security monitors and supervisory personnel. The inspectors determined that the required training had been conducted in accordance with the security program plans and that it was properly documented, Several 50s were interviewed to determine if they possessed the requisite knowledge and ability to carry out their assigned duties. The interview results indicated that the 50s were very professional and knowledgeable of their job requirement The inspectors also verified that the armed response force meets the commitments in the Plan and that there is always one full-time member of the security organization on-site who has the authority to direct security activitie . Safeguards Information Program The inspectors reviewed the licensee's site procedure and records, interviewed personnel and inspected several Safeguards Information (SGI)

repositories to determine if the licensee's on-site program for the protection of SGI meets the requirements of 10 CFR 73.21. The inspector's review encompassed the types of information being protected, physical protection (in-use and in-storage), markings, access, external transmissions and automatic data processing systems. No discrepancies were identifie . Exit Interview The inspectors met with the licensee representatives indicated in paragraph 1 at the conclusion of the inspection on March 23, 1989. At the time, the purpose and scope of the inspection were reviewed and the findings were presente No written material was provided to the licensee during the inspection.