IR 05000373/1997002

Insp Repts 50-373/97-02 & 50-374/97-02 on 970113-17.No Violations Noted.Major Areas Inspected:Evaluation of Audit Program,Corrective Action Sys,Mgt Support & Controls for Identifying,Resolving & Preventing Problems

ML20134P030
Person / Time
Site:	LaSalle
Issue date:	02/14/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20134N997	List: IR 05000373/1997002 ML20134N994
References
50-373-97-02, 50-373-97-2, 50-374-97-02, 50-374-97-2, NUDOCS 9702250073
Download: ML20134P030 (9)

Text

. . _ . ._ _ _ . . . _ . _ _ . . _ . . . _ . . _ _ _ _ _ _ _ _ . . ._ -- _ . _ _ _ _

l'

.

U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos: 50-373: 50-374 Licenses No: NPF-11: NPF-18 Reports No: 50-373/97002(DRS): 50-374/97002(DRS)

Licensee: Commonwealth Edison Company Facility: LaSalle County Station, Units 1 and 2 Location: 2601 N. 21st Road Marseilles, IL 61341 Dates: January 13-17,1997 l

Inspector: J. Belanger, Senior Physical Security inspector I

!

Approved by: J. R. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety

i

l

!

i

!

I i

!

i

!

9702250073 970214

,

'

PDR ADOCK 05000373 G PDR

.-

--- . . . . - . _ _ - . - - -- - . _ - . - . - - _ - .

.

'

'

EXECUTIVE SUMMARY

. LaSalle County Station, Units 1 and 2 NRC Inspection Reports 50-373/97002; 50-374/97002 l

i This inspection of the licensee's physical security program included an evaluation of the  !

( audit program; corrective action system; management support; controls for identifying, j

resolving and preventing problems; and interior protected area detection systems.

i e in general, the conduct of the security activities was professional with - l marked improvements in: (a) communications among alllevels of the l j security organization; (b) the definition of roles and responsibilities of staff )

members; (c) reduction of administrative and other duties that distracted l

. from the primary function of supervisors; and (d) procedure developmen Senior site security management involvement was good. (Section S6.1) )

-

e Security staff identified an increase in the number of security doors left unsecured after use and responded promptly and effectively in conducting a root cause analysis of these events. (Section S1.1)

e A security force member identified a visitor within the protected area without an escort due to inappropriate transfer of escort responsibilitie Adequate corrective action was taken. (Section S8.1)

e Self assessment activities were effective. (Section S7)

e Security staffing was adequate. Key personnel changes were made in top 1 management positions since the previous security inspection. (Sections S and S6.2) l I

-. - .. _- .-- . - . . .

.

.

IV. Plant Sue S1 Conduct of Security and Safeguards

,

} S1.1 Corrective Action System

! Insoection Scope (81700)

The inspector reviewed safeguards event logs for a randomly selected two month

.

period (July through August 1996) to determine if appropriate analyses were performed and corrective actions taken.

4 Observations and Findinas l

'

' in April 1996, the licensee initiated a Root Cause investigation in response to several events involving security doors used by personnel and left unsecured after

' use (PIF 96-1063 dated April 11,1996). These were high traffic, Auxiliary to l Turbine Building double doors. In calendar year 1995, there were sixteen j

,

unsecured door events. In the first quarter of 1996, there were twenty-five such

' event. The security plan required security doors to be secured after use or be '

compensated. (Unsecured doors are loggable safeguards events.) The licensee's

<

arialysis included reviews of human performance factors, door hardware suitability, i design applications and door maintenance effectivenes !

The investigation identified that, in the human performance element, individuals j failed to assure security doors were closed behind them due to a lack of individual accountability. This was determined to be the primary cause for the increase in the

' number of unsecured doors. However, other important contributing factors included: (a) lack of training for maintenance personnel on the mechanics of how l

to use construction documents, door problem assessment and resolution, hardware ;

application, and adjustments; (b) long term formal records of door maintenance or hardware replacement were not available to determine the effectiveness of maintenance and door life expectancy; (c) a high differential pressure; and (d)

i obsolete door hardwar Corrective actions taken by the licensee included:

e The security staff interviewed and counteled each door violator and their superviso e Senior management's expectations were verbally promulgated, stressing the importance of individual accountabilit e ,

Publications to station personnel periodically stressed the importance of individual accountabilit e Maintenance staff was trained in closer attention to door hardware replacement record i

. _ . _. _ _ _ .. . ._._. _ _ _ _ _ . _ - _ _ _ . . _ . . _ . _ _ _ . _

!

.

l l * Obsolete door hardware was replaced.

! e Ventilation modifications were in progress to properly control differential

! pressure between the turbine and auxiliary building.

3-i i

e Task training for dedicated maintenance personnel on door repairs was being

developed.

.

o One damaged door was replaced. Actions were in prograss to replace several others.

.

1 On January 16,1997, the inspector frequently observed many individuals entering

}

and exiting though the high traffic turbine and auxiliary building security doors.

,

Personnel observed properly assured that the door was secured after exiting.

.

. Conclusions

} The inspector concluded that the security staff appropriately analyzed the increase i

in unsecured doors and that corrective actions taken or in progress were technically

! adequat SS Security Organization and Administration S6.1 Security Ornanization Manaamment Channes and Raa==ionment of Job Duties Insnaction Scone (81700)

The inspector reviewed the current security organizational structure, position descriptions, and responsibilities. New managers were also interviewe Observations and Findinos The licensee made personnel changes in the following key management positions within the security organization: Station Services Director; Station Security Administrator; and Fitness for Duty Coordinator. The security contractor made a

{

personnel change in the Security Force Manager position and established two new i positions, a Shift Specialist and a Procedure Writer. Several personnel reassignments were also made by the contractor within the staff organizatio !

The new management staff continued to improve performance as a result of weaknesses identified during a root cause investigation of events involving contractor security force human performance deficiencies (See Section S8.2).  !

Specific changes were initiated to: (a) im.orove communications among the levels of the security organization and improve supervisory oversight: (b) better define personnel roles and responsibilities and eliminate redundara and overlapping duties; and (c) improve employee moral _ , , . _ - , . - a * a , _ . - .m._. . _ -._m o_.-. .m.m__.._ ..__ m,- . . . ~ . , . . . - .2 -.~.e . . . . .

r

• I r

4  !

, .

A morning meeting was re-established similar in form to the Station's " Plan of the '

Day." A new "LaSalle Security Newsletter" was initiated. The security contractor

' developed an employee recognition and miscellaneous incentives policy,to recognize

' the efforts of the security force as a team, along with incentives for excellence in .

individual performance. Effective June 3,1996, the training lieutenants were assigned to specific shifts to provide an overview of operations and to identify ,

'

,

training needs. Beginning June 28,1996, the Operations Coordinator was available

on backshifts a minimum of once per month on each shif i The security management team established a Shift Specialist Position to handle t

.

many of the administrative tasks that prevented shift leaders from overseeing shift

r-operations. Most of the administrative roles and responsibilities previously performed by supervision were eliminated or reassigned to staff positions. The contractor also established a " Management By Walking Around Program," the focus of which was to get supervisors out of the office and into the fiel i Security force members interviewed were positive in their comments regarding the i actions taken, but indicated that a spirit of teamwork continued to be lacking. The Station Security Administrator acknowledged that developing such a spirit was his major challeng Conclusions Security management appeared aggressive in addressing self-identified weaknesses relating to performance. Changes and improvements continu S6.2 Sacurity Staffino Insoection Scone (81700)

I The inspector reviewed contractor status reports and overtime statistics. The Station Security Administrator and the Security Force Manager were interviewe Observations and Findinos The inspector's review of the licensee's base hours, required of their security force contractor to meet security commitments and categories of security staffing ( majors, !!?utenants, sergeants, nuclear security officers, watchpersons and clerical staff), showad that overall staffing was adequate. The watchperson category was overstaffed Ly seven, four of whom were waiting for weapons handling authorization cards from the State of Illinois. Upon receipt of these cards, the four individuals could be upgraded to nuclear security officer (NSO) status. The NSO category was understaffed by one individua :

Slightly more than half of the security organization possessed more than ten years experience. Approximately one quarter more had five to ten years experienc Less than ten percent of the force had less than one year experienc _

__.____ ._ _ _ _ - _ _ - _ . _ _ _ __ ._ _ - . . . _ _ _ _ .

I

.  !

,

,

Despite adequate staffing, security force overtime was required because of

!

unscheduled employee absences (call-offs) each month by security force members,

' and temporary compensatory measure posts needed to support the plant outag Call-offs for the month of December 1996 totaled 56, which represented

! approximately fifty percent of the total contract security organization. Call-offs L

occasionally resulted in mandatory overtime. The inspector's review of overtime

.

hours worked showed that NRC guidelines were me # Conclusions i

Staffing was adequate to meet security commitments. Unscheduled employee i absences and compensatory measures necessitated some overtime which met NRC

{ guidelines for hours worked. Security force experience was considered good.

i s7 ouality Amaurence in security and safeguards Activities

. a .- Insoection Scone (81700)

!'

i'

,

The inspector examined audit reports of the licensee's security program conducted since the previous security inspection. Attention was given to negative findings,

!

!

suggestions for improvement, trends, and actual or programmatic weaknesses. The

.

inspector interviewed the lead auditor involved in the Station Quality Verification (SOV) audit and reviewed the audit checklis i

.

j Observation and Findinas

Two audits of the security program were conducted since the last security

inspection. One of the audits was performed by the licensee's SOV staff. This audit met the annual audit requirement in the approved security plan. The second

,

audit was sponsored by the security contractor, using auditors from other nuclear 3 station ! I

i~

The audit performed in September 1996 by security contractor staff, addressed compliance with security commitments and performance. The three auditors were

supervisors with operational experience in security from three different nuclear sites. The audit identified the need for re-writing and/or consolidating written procedures, which the auditors felt were in some cases too detailed, contradictory, and inaccurate. This finding was similar to a weakness identified during the root cause investigation of security force human performance errors reported to management in May 1996 (See Section S8.2).  :

l The contractor security audit concluded that the security department staff provided

" good service in general" and that, with recent management changes, special )

j attention should be given to daily operations to preclude unnecessary human error The audit performed by SOV staff in November 1996 (QAA 01-96-12) reviewed maintenance and testing of equipment, searching implementation, security barrier intrusion detection, security force training,' response to drills, conduct of patrols,

6 __ -_ __ _ _ _ _ _ _ __

_ - _ _ _

'

,

,

interface with local law enforcement, control of safeguards information, Personnel Access Data System (PADS) program implementation and Fitness For Duty (FFD)

program implementation. Three findings relating to the implementation of the FFD and PADS program had minimal or no impact on safety. Performance in the areas

• reviewed was acceptable. The inspector found the audit checklist to be detailed and comprehensive. The SQV audit team included a member with extensive experience auditing nuclear security.

, Conclusions Audit requirements of the security plan were met. The audits were effective in assessing and evaluating security program effectivenes SB Miscellaneous Security and Safeguards lasues S8.1 (Closed) SER 96-SO1-00: An unescorted visitor was found in the protected area due to inadequate turnover of escort responsibilities. On Thursday, August 8, 1996, while performing rounds, a security force member discovered a visitor within the protected area without escort. The visitor was without an escort for approximately 60 minutes. The licensee's staff determined that the root cause of the event was human performance failure involving inadequate transfer of escort responsibilitie The licensee's staff promptly corrected this human performance inadequacy, in addition, the licensee's security staff reviewed this event thoroughly and identified contributing factors of less than adequate attention to detail and a less than adequate questioning attitude. By directly observing visitors in protected and vital areas, the inspector verified that escort responsibilities were properly execute The inspector determined that the safety significance of ths avent was minima The visitor did not enter vital areas. The visitor was screened for unescorted access and did have unescorted access at the station from January 10,1996 through July 19,1996. The event occurred less than 30 days after unescorted access had been terminate The inspector determined that this event constituted a violation of Section 7.1.2 of the station security plan. This licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with NUREG-1600 of the HRQ Enforcement Poliev. (NCV 50-373(374/97002-01)

S8.2 (Onen) Follow-Un item 50-373/96005-11: 50-374/96005-11: Root cause investigation of security force performance events from January 1,1995 through March 9,1997 identified four significant weaknesses: (1) unclear roles and responsibilities for supervisors, coupled with too many administrative and other duties that distracted from primary functions; (2) weak supervisory techniques and methods were used to monitor, direct, and control the work force; (3) training methods were not always effective; and (4) procedure development was not

.

. _ _ _ . . . _ _ . _ . _ _ _ _ . . _ . . . _ - - . _ _ . _ - _ . _ _ _ _ ~ . - . _ . _ _

'

,l l

^

!

,

effective. Interviews conducted by the investigation team identified poor security  ;

communications, lack of teamwork, and a less than adequate questioning attitud '

t

Regarding item (1), licensee management defined personnel roles and

,

' responsibilities and eliminated redundant and overlapping duties. Roles and responsibilities relating to administration, previously performed by supervisors, were

,

eliminated or reassigned to staff positions. Regardmg item (2), licensee

'

management established a new Shift Specialist position to relieve shift supervision from the administrative aspects of the job and allow them to better supervise their shift. A " Management by Walking Around" process was implemented. Regarding item (3), a Training Lieutenant was assigned to a specific shift to provide an  ;

-

overview of operations and identify any needs for training. Regarding item (4), the licensee established a full-time procedure writer position to take ownership of the

procedure development process.

J {

'

The progress of upgrading procedures, (i.e. elimination of inconsistencies,  :

' consolidation of similar information and use of consistent format) was limited to l seven of forty post orders. This item will remain open pending completion of  !

i corrective action i i

S8.3 Undated Final Safety Analvals p=aa t (UFSAR) R -4;w: A discovery of a licensee I operating their facility in a manner contrary to the UFSAR description highlighted 1

,

i the need for a special focused review that compares plant practices, procedures  ;

and/or parameters to the UFSAR descriptions. While performing the inspection .

discussed in this report, the inspector reviewed the applicable portions of the ,

UFSAR, Volume Vill, Chapter 13.0, Section 13.7 that related to the areas inspected. The inspector verified that the UFSAR's wording was consistent with  !

observed plant practices, procedures and/or parameter ma-----7,;7,; --;;7,as X1 Exit Meeting Summary The inspector presented the results of this inspection to licensee management, listed on Page 9, at an exit meeting on January 17,1997. The licensee acknowledged the findings presente .

l l

'

, - , . . , - - - - - - - , - - - - - - - - - , - - . ~ + - . - ---

-. - . .. -. . . . - _ .

-

.

I

,

PARTIAL LIST OF PERSONS CONTACTED Licensee W. Subalusky, Jr., Site Vice President D. Ray, Station Manager B. Finlay, Station Security Administrator R. Robey, Services Director W. Bartlett, Security Staff Assistant

,

R. Morley, Nuclear Security Administrator, Corporate Security D. Combs, Assistant Station Security Administrator P. Barnes, Regulatory Assurance Supervisor M. Embree, Burns Security District Manager B. Askren, Security Force Manager J. Drago, NRC Coordinator

,

W. Washkowiak, Burns Training Coordinator

. L. Hunter, Procedure Writer NRC M. Huber, Senior Resident inspector

,

K. Ihnen, Resident inspector

,

INSPECTION PROCEDURES USED

IP 81700

Physical Security Program for Power Reactors

,

,

LIST OF ACRONYMS USED j DRS Division of Reactor Safety l FFD Fitness for Duty IR Inspection Report NRC Nuclear Regulatory Commission PADS Personnel Access Data System PlF Problem identification Form SER Security Event Report 9