IR 05000352/1990005
| ML20011F741 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/26/1990 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20011F738 | List: |
| References | |
| 50-352-90-05, 50-352-90-5, 50-353-90-04, 50-353-90-4, NUDOCS 9003070348 | |
| Download: ML20011F741 (8) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION 1-50-352/90-05
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Report Nos.
50-353/90-04 50-352
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Docket Nos.
50-35_3
NPF39'
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License Nos.
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' Licensee:
Philadelphia Electric Company 2301 Market-Street Philadelphia, Pennsylvania
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Facility Name:
Limerick. Generating Station, Units 1 and 2
Inspection At:
Limerick, Pennsylvania Inspection Conducted: January 29, - February 2, 1990 Type of Inspection: Routine, Unannounced Physical Security Inspectors:
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G. - C. Smith, SeM or urity Specialist date '
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Approved by:
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/R. R. Kellflig, fjillef, Safeguards Section date Division of Rddiation. Safety and Safeguards g
LInspection Summary: Routine, Unannounced Physical Security Inspection on-
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January 29 -- February 2, 1990 (Report Nos. 50-352/90-05 and 50-353/90-04)
Areas Inspected: Management Support, Security Program Plans and Audits; p
. Frotected and Vital Area Physical. Barriers, Oetection and Assessment Aids;
~ Protected and Vital Area Access Control of Personnel, Packages and Vehicles; Alarm Stations and Communications; Testing, Maintenance and Compensatory Measures;- Security Training and Qualifications; and the establishment of contingency procedures for land vehicle bombs.
Results: The licensee was in compliance with NRC requirements in the areas
inspected. However, pctential weaknesses were identified in the Protected Area detection and assessment aids, and Testing, Maintenance and Compensatory Measures.
A L9003070348 900226
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DETAILS
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1.
Key Persons Contacte'd
.a.
Licensee and Contractor Personnel G. M. Leitch, Vice President, Limerick Generating Station (LGS)
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P. Duca, Support Manager, Limerick Generation Station-(LGS)
' R. Wei_ndorfer, Director, Nuclear Plant Security - Corporate W. Shych, Chief Security Cc,ordinator
~J. Spencer, Superintendent - Maintenance /I&C, LGS J. Doering, Project Manager, LGS R. Smith, Senior Auditor, Nuclear Quality Assurance V. Vitale, Vice President,. Protection Technology Inc. (PTI)
D. Feaster, Fire Protection Supervisor, LGS M. Berner,-Assistant Regional Director, PTI
'R. Linauts, Security Analyst, Nuclear Plant Security-Corporate
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M. Alexander,-Site Captain, PTI
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b.
U. S. Nuclear Regulatory Commission
.T. Kenny', Senior Resident Inspector L. Scholl, Resident Inspector M. Evans, Resident Inspector The above' personnel were present at the exit meeting. Other PECo and PTI personnel, including members of the security force, were
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interviewed during,the inspection.
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2.
Management Support, Security Program Plans, and Audits
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a._
Management Support - Management support for the licensee's physical security' program was determined to be adequate by the inspectors.
This determination was based upon the inspectors' reviews of various aspects of the licensee's program during this inspection as documented in this report.
b.
Security Prugram Plans - The inspectors verified that changes to the Contingency and Guard Training and Qualification Plans, as
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implemented, did not decrease the effectiveness of the respective plans and that they had been submitted in accordance with NRC requirements.
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c.
Audits - The inspectors reviewed the 1989 annual security program p
audit report. The inspectors verified that the audit had been conducted in accordance with the NRC-approved Physical Security Plan (the Plan).
The audit was comprehensive in scope with the results reported to the appropriate levels ef management. The inspectors'
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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-findings.
3. -
Protected and Vital Area Physical Barriers. Detection and Assessment Aids a.
Protected Area Barriers - The inspectors conducted a physical inspection of the Protected Area (PA) barrier on January 30, 1990.
The inspectors deterniined, by observation, that the barriers were installed and maintained as described in the Plan.
b.
Protected Area Detection Aids - The inspectors observed the PA perimeter detection _ aids on January 30, 1990 and determined they were generally installed, maintained and operated as committed to in the Plan, except as described below.
The inspectors identified several zones where the PA Intrusion Detection System (IDS) was potentially wea). The licensee implemented appropriate compensatory security measures when these areas were identified. The inspectors also noted that the licensee had compensatory posts in the general vicinity that would have observed unusual activities in the deficient zones. The inspectors verified by reviewing testing records that the PA IDS zones were being tested as required by the Plan.
However, the inspectors determined by reviewing the licensee's testing procedure and by interviewing Security Force Members (SFMs) and Instrumentation and Controls (I&C) Technicians, that the testing, as performed, would not always ensure the-full effectiveness of the system. The licensee
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committed to revising the testing procedures to ensure their effectiveness and to correcting the identified weaknesses.
This is kn Inspector Follow-up Itera (IFI 50-352/90-05-01 and 50-353/90-04-01).
c.
Isolation Zones - The inspectors verified that isolation zones were adequately maintained to permit observation of activities on both sides of the PA barriers, d.
Protected Area and Isolation Zone Lighting - The inspectors conducted a lighting survey of the PA and isolation zones on
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g February 1,1990.
The inspectors determined, by observation, that lighting-in the isolation zones and the PA was in accordance with commitments in the Plan.
e.
Assessment Aids - The inspectors observed the PA perimeter assessment system and determined that it was installed and generally operated
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l as committed to in the Plan. Maintenance of the system is addressed in paragraph 7.
The following potential weaknesses were noted in
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the system:
El PIntWil 00MAMS SAFEGl!MDS I"!M"nii:i! iS 13 (OT F03 PBLIC
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f.'.3E3EE, li IS liii3TIMALLY -
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The licensee committed to correcting these potential weaknesses with an aggressive I&C repair program.
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This is an~ Inspector follow-up Item.
(IFI 50-352/90-05-02 and 50-353/90-04-02),
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Vital Area Barriers - The inspectors cor. ducted a physical inspection
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of Vital Area (VA) barriers on February _1, 1990. The inspectors determinad, by observation, that the barriers were installed and maintained as described in the Plan. No discrepancies were noted.
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Vital Area Detection-Aids - The inspectors observed the VA detection
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aids and determined that they were installed, maintained and operated as committed to in the Plan. No discrepancies were ncted.
Protected and Vital Area Access Control of Personnel. Packages and Vehicles a.
Personnel Access Control - The inspectors determined that the
' licensee was exercising positive control over personnel access to s
the PA and VAs.- This determination was based on the following:
(1) The inspectors verified that personnel are properly identified and authorization is checked prior to issuance of employee badges and key-cards. No discrepancies were noted.
(2) The inspectors verified that the licensee has a program to N.
confirm the trustworthiness and reliability of employees and contractor personnel.
No discrepancies were noted.
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(3) The inspectors verified the licensee takes precautions to ensure that an unauthorized name cannot be added to the access list by having a member of management review the list every 31 days. No discrepancies were noted.
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-(4) '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
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inspectors observed personnel access processing during shift j
changes, visitor access processing, and interviewed SFMs and the
licensee's security. staff about access procedures. No discre-pancies were noted.
(5) The inspectors determined, by observation, that individuals in the PA and VAs df*, play their badges as required. No discrepancies were noted.
(6) The inspectors verified that the licensee has escort procedures for visitors. in the PA and VAs,. No discrepancies were noted.
(7) - The inspectors verified that the licensee has a mechanism for expediting access to vital equipment during emergencies and
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that the mechanism is adequate for its intended purpose.
No discrepancies were noted.
(8) The inspectors verified that unescorted access to VAs is limited to authorized individuals with a right and need to work in the areas.
The access list is revalidated at least once every 31 days as committed to in the Plan.
No discrepancies were noted, b.
Package and Material Access Control - The inspectors determined that the licensee was exercising positive control over packages and materials that are brought into the PA at the main access portal.
'Theinspectorsobservedthepackageandmaterialprocessingand
. interviewed SFMs and the licensee s security staff about package and material.-control procedures. No discrepancies were noted.
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Vehicle A: cess Control - The inspectors determined that the licensee properly controls 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 P'an.
This determination was made by observing vehicle processing and search, and. interviewing SFMs and the licensee's security staff about vehicle search procedures and processing.
No discrepancies were noted.
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5.
Alarm Stations and Communications a.
Alarm Stations - The inspectors observed the operations of the Central Alarm Station (CAS) and the Secondary Alarm Station (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 responsibilities. The inspectors verified that the CAS and SAS operators, do not have :ny operational activities that would
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interfere with the assessment and response functions. No discre-
pancies were noted.
L b.
Communications - The inspectors observed the operations of
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communications in both the CAS and SAS and reviewed testing records I
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-to_in the Plan. No discrepancies were noted, j
6.
Emeroency Power Supply
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The inspectors verified that there are several systems (batteries; diesel
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generators, and plant on-site AC power) that provide backup power to the
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security system and reviewed the accompanying test and maintenance i
procedures for these systems.
The system and procedures were consistent l
with the Plan and are located in VAs.
The inspectors also verified that the door access control system for VAs will permit emergency ingress and egress when normal power is lost, 7.
Testing, Maintenance and Compensatory Measures The inspectors reviewed the testing and maintenance records and confirmed
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that the records committed to in the Plan were on file and readily
available for licensee and NRC review. -The licensee provides dedicated
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I&C technicians to conduct preventative and corrective maintenance on security equipment. A check of repair records indicated that repairs, replacement and testing is not always being accomplished in a timely manner. The inspectors determined from interviews with members of the
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licensee's security staff and the I&C supervisor _that there was not a
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formal-Preventive Maintenance (PM) program for security equipment and that-
maintenance of the system was primarily reactive.
Some examples are:
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THIS PMAPH C0hTAINS SAFEGUARDS li:SGTi2! f"] 13 IST FOR PllBil0 013Cl0SEE, IT IS IDTIONALLY i
LEFI BLANK.
The licensee committed to implement a PM program for security equipment
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and to provide priority maintenance support for the security system.
l This is an Inspector Follow-up Item (IFI 50-352/90-05-03 and 50-353/90-04-03).
The inspectors also reviewed the licensee's use of compensatory measures and.found them to bc as committed to in the Plan.
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THl3 P/RWPH CONTAINS SAFECUARDS L
li!fEGTi:.1 S 13 IST T0.R PUBUC T4SCl0SEE, li IS IL7950M!LY.
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This is a Inspector Follow-up Item (IFI 50-352/90-05-04 and 50-353/90-0_4-04).
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8.
Security Training and Qualification-The. inspectors randomly selected and. reviewed the training and qualifi-cations records for several SFMs.
Physical qualifications and firearms qualifications records were also inspected.
These: records-were for armed
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guards, security watch of ficers 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 SFMs were interviewed to determine if they possessed the requisite knowledge and ability to carry out their assigned duties. The interview results indicated that the SFMs were professional and knowledgeable of their job requirements.
i The inspectors also verified that the armed response force meats the o
commitments in the Plan and that there is always one full-time member of h
the security organization on-site who has the authority to direct
security activities.
The inspectors also reviewed an allegation (RI-89-A0142) concerning a contractor security training-instru:: tor who had not followed proper
procedures while being certified as an alarm-station instructor. The inspectors reviewed alarm history records to determine whether any_
standard procedures and practices had been violated..The. inspectors found that the training instructor had not violated the security plan or-implementing procedures. -The inspectors also determined that no violations had occurred during the training instructor's certification Y,
period. -The allegation was.not substantiated.
9.
-Land Vehicle Bomb Contingency Procedure'
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h The inspectors conducted a review of the licensee's Land Vehicle Bomb Contingency Procedure.
The licensee's-procedure detailed short-term-actions that would be taken to protect against attempted radiological sabotage invniving a land vehicle-bomb in the event such a threat were to materialize. The procedure appeared adequate for its intended purpose.
No discrepancies were noted.
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10.
EgtIntervies
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The inspectors met with the licensee representatives indicated in paragraph I at the conclusion of the inspection on February 2,1990. At
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the tin, the purpose _and scope of the inspection were reviewed and the findings were presented. The licensee's commit! rents, as documented in
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this report, were' reviewed and confirmed with the licensee.
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