IR 05000361/1998021

Insp Repts 50-361/98-21 & 50-362/98-21 on 981207-11. Violations Noted.Major Areas Inspected:Licensee Physical Security Program

ML20198N527
Person / Time
Site:	San Onofre
Issue date:	12/30/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198N508	List: IR 05000361/1998021 ML20198N505 ML20198N522
References
50-361-98-21, 50-362-98-21, NUDOCS 9901060151
Download: ML20198N527 (13)

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!' ENCLOSURE 2

= U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50-361 j, 50-362 i License Nos.: . NPF-10

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NPF-15

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Report No.: 50-361/98-21 50-362/98-21 Licensee: Southern California Edison C . Facility: San Onofre Nuclear Generating Station, Units 2 and 3 Location: 5000 S. Pacific Coast Hw San Clemente, California Dates: December 7-11,1998 Inspector: A. N ceJ Earnest, Security Specialist, Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Attachment: Supplemental information

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9901060151 981230 PDR ADOCK 05000361 G PDR t

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-2-EXECUTIVE SUMMARY San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 50-361/98-21; 50-362/98-21 This routine, announced inspection focused on the licensee physical security program. The areas inspected included review of security communication, access control - packages, testing and maintenance, lock and key control, security plans and procedures, security event logs, training and qualifications, management effectiveness, security program audits, protection of safquards information, followup of previously identified items, and onsite review of event report Plant Suocort

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The security communications system met regulatory and physical security plan requirements (Section S1.1).

Package and material access to the protected area was effectively controlled. A licensee identified issue in reference to storage of items that can not be searched until they are inside the protected or vital areas, Category lli and IV items, was identified as an inspection followup item (Section S1.2).

An effective and well documented test and maintenance program was implemented (Section S2.1).

The licensee maintained an outstanding lock and key control program (Section S2.2).

Changes to security plans were reported within the required time frame. The licensee is conducting a major rewrite of the implementing procedures (Section S3.1).

A good safeguards event reporting system was in place (Section S3.2).

Overall, the training and qualification program for security officers was excellent. A violation was identified in weapons qualifications. The licensee implemented proper corrective actions; therefore, no response to the violation is required (Section S5.1).

The security program received very strong management support. Security management staff demonstrated excellent management capabilities (Section S6.1).

Audits of the security, access authorization, and fitness-for-duty programs were effective, thorough, and intrusive (Section S7.1).

The safeguards protection program was effectively implemented (Section 88.1).

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-3-l Report Details IV. Plant Support S1 Conduct of Security and Safeguards Activities (81700)

S Communications Insoection Scope The communications capabilities were inspected to determine compliance with the requirements of 10 CFR 73.55 (f)(1) through (4), (g)(3), and the requirements of the physical security plan. The areas inspected included the operability of both radio and telephone systems, and the capability to effectively communicate both telephonically 1 and by radio with the local law enforcement agencie ; Observations and Findinas The inspector i nfirmed that the licensee had telephone and radio systems capable of meeting all ce iunications requirements of the security organization. The inspector observed a tet. af the radio system from the secondary alarm station on December 9, 1998. The it. Nas successful.10 CFR 73.55(f)(3) requires the licensee to have j continuous race communication to the local law enforcement organization from both alarm stations. Review of a recent physical security plan change and interviews with l security management personnel revealed that a recent change to the initial responding local law enforcement agency left the licensee with some coordination problems with the San Diego office of the FBI. The inspector reviewed safeguards event logs and, in addition to the unannounced radio test, determined that the communication problem '

with the responding local law enforcement agency had been reduced to an acceptable leve Conclusion l

The security communications system met regulatory and physical security plan requirement S1.2 Access Control - Packaaes Inspection Scope The package access control program was inspected to determine compliance with the requirements of 10 CFR 73.55 (d)(3) and the physical security pla Observations and Findinos j

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The inspector observed the searching of packages and materials at the personnel access control points. The package and material search process was effective. Tests l

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-4-documented that the X-ray equipment performed in a proper manner. The security officers operating the equipment appeared to be well trained and promptly and completely answered all the inspector's question During a self assessment of the package and material search program, the licensee identified a potential problem area with the requirements for control of Category lli and IV materials permitted into the protected area without being searched. During the inspection, the inspector did not identify any areas of noncomplianc CFR 73.55(d)(3) requires that all packages and materials shall be searched for prohibited items except those Commission approved packages and materials specifically designated by the licensee to be searched within the protected and vital areas for reasons of safety, security, or operational necessity. NUREG 0908 guidance defines those types of materials or packages as Category ill and IV packages or l material. Security Procedure SO123-IV-5.3.3, " Search and Inspection," defines Category lli and IV materials and states that Category lli packages and materials shall be positively controlled, for example, stored in a locked area and controlled by a person (s) familiar with the package / material contents. For Category IV packages sealed by the manufacturer, the procedure requires that the items will be stored in a <

locked area and opened at their final destination point under the supervision of a person )

familiar with their content The issue of a potentiallack of positive control and what constitutes an adequate locked area was identified as an inspection followup item (361/9821-02; 362/9821-02).

c. Conclusion Package and material access to the protected area was effectively controlled. A licensee identified issue in reference to storage of items that can not be searched until they are inside the protected or vital areas, Category lll and IV items, was identified as an inspection followup item.

S2 Status of Security Facilities and Equipment (81700)

S2.1 Testina and Maintenance a. Inspection Scope The testing and maintenance programs were inspected to determine compliance with the requirements of 10 CFR 73.55(a), (g)(1) through (3), and the physical security pla 'b. Observations and Findinas The inspector rWiewed testing and maintenance records and confirmed that the records required in the physical security plan were on file, well documented, and readily available for review. The licensee provided instrumentation and controls technicians to repair or replace any security equipment that required corrective maintenance. The

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inspector determined through a review of work records and interviews with security

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quarterly preventive maintenance program was in place for the security system >

The security officers performing system tests were knowledgeable of testing requirements and techniques. Especially noteworthy were quarterly tests conducted December 4-6,1998. The staff identified six perimeter detection zones that were '

vulnerable to defeat by the testing methodology used, Conclusion

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An effective and well documented test and maintenance program was implemente j S2.2 Locks. Keys. and Combinations Inspection Scope The locks, keys, and combinations program was inspected to determine the licensee's compliance with the requirements of 10 CFR 73.55(d)(8), and the requirements of the physical security plan.

p Observations and Findinas

The inspector reviewed lock and key inventory records and determined that inventory

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records indicated inventories were completed as required by procedure. Further the records indicated that annual rotation of locks and keys had occurred. In addition, the locks and keys were rotated or changed upon the termination of employees who had t- access to security locks and keys.- Security of the additional sets of lock cores and keys was effective in preventing compromise. Records of the keys,' locks, and core sets, ;

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records of all changes and the inventory records were meticulously maintained. The locksmiths were professional and answered all of the inspector's questions about the l system with confidence in their knowledge.

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L The licensee maintained an outstanding lock and key control program.

S3 ' Security and Safeguards Procedures and Documentation (81700)

S Security Proaram Plans and Procedures Inspection Scope j' The physical security plan and the implementing procedures were inspected to p determine compliance with the requirements of 10 CFR 50.54(p) and the physical

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1 Observations and Findinas The inspector determined that plan changes were submitted to the NRC within the required time frame. The inspector verified that the licensee maintained an effective management system for the development and administration of procedures, and that changes to the procedures did not reduce the effectiveness of the security progra l A major rewrite of the security procedures was underway prbr to and during the inspection. The current procedures were too specific in some areas and not spec:fic enough in others and, due to their complexity, were not user friendly. Another problem identified was that the procedures often contradicted the requirements of the physical security plan. An example is security procedure SO123-IV-6.8 that defines, in great detail, the compensatory measures for any failed or degraded security system. The physical security plan allows the use of armed response personnel and the assessment officers in the guard towers to be used as compensatory officers for a short period as j long as the response officers are immediately available to respond to emergencies. The use of those officers is within NRC compensatory measures guidance. The procedure l does not allow the use of those officers. A change to that procedure, allowing the use of the response officers and assessment officers, was reviewed and the inspector determined that the change removed the contradiction with the physical security pla The licensee is using a slow, studied approach in making changes to procedures that l will cause the product to be user friendly and comprehensiv Conclusions Changes to security plans were reported within the required time frame. The licensee is conducting a major rewrite of the implementing procedure S32 Security Event Loos a. Insoection Scope The security program records and reports were inspected to determine compliance with the requirements of 10 CFR 73.71(b) and (c),10 CFR 73.70(a)-(c), and the physical security plan. The inspector reviewed the safeguards event logs for the third and fourth quarters of 1998.

l b. Observations and Findinas

The inspector determined that the licensee conformed to the regulatory and license j requirements to report security events. The licensee's security staff correctly identified l security events required by regulations. In addition, the licensee used the information

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contained in their records and reports to track and trend problem area .

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L, -7- Conclusion A good safeguards event reporting system was in plac S5 Security and Safeguards Staff Training and Qualifications (81700)

S Security Trainina and Qualifications Inscection Scoce The security training and qualification program was inspected to determine compliance with the requirements of Appendix B of 10 CFR Part 73,73.55(b)(4), (h)(5), and the training and qualifications pla Observations and Findinas The inspector interviewed four security officers and determined that they were confident in their training and proficient in their duty performance. However, when the inspector requested a demonstration of training on the firearms range, he discovered that approximately 70 percent of the armed security officers had not been qualified on the 9-millimeter rifle before being allowed to carry the weapon on shif Appendix B, Paragraph lilA, to 10 CFR Part 73, requires that guards, response personnel and armed escorts requiring weapons training to perform their assigned duties to be trained in accordance with the NRC approved training and qualifications

plan. Paragraph 1.1 of the training and qualification plan requires that all security officers will be qualified on Tasks 3 - 20 of the training ano qualification plan. Task 12 of the training and qualification plan requires qualification with tne 9-millimeter rifle. The failure to train the armed security officers on the 9 millimeter rifle prior to allowing them j to carry the weapons on shift is a violation of Appendix B,10 CFR Part 73 and .

paragraph 1.1 of the training and qualification plan (50-361/9821-01;-362/9821-01). I The licensee implemented corrective actions including issuing a different caliber weapon l to security officers and completing a 10 CFR 50.54(p) change to the training and qualification plan that will allow officers to carry the 9 millimeter rifle based on qualification with the 223 caliber rifle. The two rifles are identicalin design. The single difference is the caliber of each. The separate course of fire was considered an enhancement and would not have been required if the licensee had not separated the rifle qualification into two rifle qualifications. The separate course of fire change was commendable and demonstrated the licensee's commitment to excellent training. While the 10 CFR 50.54(p) change made during the inspection brought the licensee into compliance, they stated their intent was to qualify all armed security officers on the 9-millimeter course of fire as soon as practicable.

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-8- Conclusion Overall, the training and qualification program for security officers was excellent. A violation was identified in weapons qualifications. The licensee implemented proper corrective actions; therefore, no response to the violation is require l S6 Security Organization and Administration (81700)

S Manaaement Effectivenajis insoection Scope The effectiveness and adequacy of the licensee's management as it related to the security program was evaluated. The inspector reviewed the status of security program improvements and interviewed security management personnel in order to determine the level of support from licensee senior level managemen Observations and Findinas The inspector determined that senior level management provided very strong support to the security program. Plans were being finalized to upgrade security systems based on i self assessment l The inspector determined that security management staff was proactive, highly professional, and well trained and qualified to manage the security progra Improvements were evident in all areas reviewed by the inspector. Action Request backlogs were significantly reduced. The security manager and supervisor of security operations were spending a larger amount of time with the on-duty security shift Higher morale was evident among the shift personnel along with their greater participation in security program improvement Conclusion The security program received very strong management support. Security management staff demonstrated excellent management capabilitie S7 Quality Assurance in Sect:rity and Safeguards Activities (81700)

S7.1 Security Proaram Audits Inspection Scope (81700)

The audits of the security program were inspected to determine compliance with the

requirements of 10 CFR 50.54(p) and the physical security plan.

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. Observations and Findinas

, The inspector verified that security program, access authorization, and fitness-for-duty I

audits had been conducted at the proper interval. The inspector interviewed audit personnel and confirmed that they were independent of plant security management and plant security management supervision. The inspector determined that the audits of the security plan and contingency plan, and the access authorization and fitness-for-duty programs were effective, thorough, and intrusiv The licensee had undertaken several audits during the latter part of 1997 and throughout most of 1998. The audits were due in some part to problems experienced within the security program during that same time frame. Numerous areas needing significant improvement were identified. An independent security assist team followup report, dated October 30,1998, indicated that significant improvement had been made in most areas. The inspector interviewed numerous audit and security management l

personnel as well as confirming by inspection that the audit assessment of progress was well founde Conclusions Audits of the security, access authorization, and fitness-for-duty programs were ,

effective, thorough, and intrusiv S8 Miscellaneous Security and Safeguards issues (81700) (92904) (92700)

S8.1 Protection of Safeauards Information Insoection Scope The program to protect safeguards information was inspected to determine compliance with 10 CFR 73.21 and the physical security plan. The inspector reviewed the c assification and marking of safeguards information, program procedures, and the physical protection of the safeguards information when left unattende Observations and Findinas The inspector confirmed that the licensee had a very conservative program for protecting safeguards information. Significant reductions in the amount of safeguards information and the locations where safeguards information was stored has been completed. All personnel observed handling safeguards information during the inspection were thoroughly familiar with protection requirements. Depositories were locked or someone was in attendance at all times. The safeguards protection program was significantly improved over past performance . . . - - . - - - - . . - - - - . _ . . - .

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-10- Conclusions l

l The safeguards protection program was effectively implemente '

S8.2 Followuo-Plant Sucoort S8.2.1 (Closed) inspection Followuo item 50-361:-362/9802-01: Communications in a previous inspection, the inspector determined that there was a potential deficiency in the ability to contact the FBI, the licensee's primary local law enforcement support l agency. During this inspection, the inspector confirmed that the radio communication '

problem with the FBI had apparently been corrected. The inspector observed an unannounced communication check on the backshift t'.at successfully contacted the FBI

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office by radi S8.2.2 (Closed) Violation 50-361:-362/9812-04: Inaccurate Information Submitted to the NRC The licensee's corrective actions were extensive and comprehensive. Significant training was conducted detailing managements expectations relating to information submitted to the NRC. Interviews and a review of records by the inspector confirmed that the corrective actions had been completed and should prevent recurrenc S8.3 Onsite Review of Event Reports S8.3.1 (Closed) LER 50-361:-362/9804-01: Safeauards Information The licensee identified several safeguards information documents that were not adequately protected. The discovery of these documents was part of the corrective actions for a previously identified Severity Level lli violation (EA 97-585). The original LER 98-04 was closed in NRC Inspection Report 50-361/98-12; 50-362/98-12. This addendum to the original LER was addressed as part of that closure and is administrative!y close S8.3.2 (Closed) Licensee Event Rooort (50-361:-362/9701-02: Missed Tests of the Security j System  ;

The inspector reviewed the circumstances documented by the license event report in NRC Inspection Report 50-361/97-04; 50-362/97-04. The licensee failed to complete protected area detection system quarterly tests on three e-field detection zones within l

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the required time frame. This item was cited as a non-cited violation in the report. This addendum to the original LER was included in that non-cited violation and is administratively close . - -

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V Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on December 11,1998. The licensee acknowledged the findings presented. No proprietary information was identifie l l

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l ATTACHMENT SUPPLEMENTAL INFORMATION

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l PARTIAL LIST OF PERSONS CONTACTED

l l Licensee R. Baker, Technical Specialist, Nuclear Oversight Division ,

G. Broussard, Security Operations Supervisor j l G. Cook, Compliance supervisor j J. Denton, Nuclear Oversight Division i

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M. Hunter, Nuclear Oversight Division ,

! R. Krieger, Vice President, Nuclear Generation l D. Nunn, Vice President, Engineering and Technical Services G. Plumlee, Supervisor, Security Compliance l' R. Reiss, Security Self Assessment l E. Scherer, Manager, Compliance K Slagle, Manager, Nuclear Oversight Division l C. Stinson. Supervisor, Nuclear Training Division

! J. Wallace, Manager, Security Division H. Wood. Nuclear Auditor

! M. Zar, Nuclear Auditor

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NRC

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i' ~ B. Murray, Chief, Plant Support Branch ,

J. Kramer,' Resident inspector  !

L. Ricketson, Se.7ior Radiation Specialist, Plant Support Branch M. Hay, Radiation Specialist, Plant Support Branch

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! INSPECTION PROCEDURES PSED L

l 81700 Physical Security Program for Power Reactors '

! 92904 Followup 92700 Onsite Review of Event Reports L

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ITEMS OPENED. CLOSED. AND DISCUSSED

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Opened 50-361;-362/9821-01 V!O Inadequate Weapons Qualification 50-361;-362/9821-02 IFl Package and Material Search Closed 50-361;-362/9821-01 VIO Inadequate Weapons Qualification  ;

50-361;-362/9802-01 IFl Radio Communications With FBI 50-361;-362/9812-04 VIO ' Inaccurate Information Submitted To the NRC 50-361;-362/9804-01 LER Snfeguards Information Drawings inappropriately Decontrolled 1 50-361;-362/9701-02 LER Missed Security Surveillance LIST OF DOCUMENTS REVIEWED  ;

l Physical Security Plan, Revision 59 Security Procedure SO123-IV-5.3.3, Revision 5, " Search and Inspection" Security Procedure SO123-IV-6.8, Revision 3, " Protected Area and Vital Area Barrier Patrols" Security Proceaure SO123-IV-6.3, Revision 7, " Security Alarm Testing Program" l Security Procedure SO123-IV-4.4, Revision 5, " Security Lock and Key Control" i

- Security Event Logs, Third and Fourth Quarters,1998 Independent Security Assist 'eam Follow-up Report SA 98-007