IR 05000373/1999010
| ML20206S553 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/14/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206S535 | List: |
| References | |
| 50-373-99-10, 50-374-99-10, NUDOCS 9905210155 | |
| Download: ML20206S553 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION 111 Docket Nos:
50-373;50-374-License Nos:
50-373/99010(DRS); 50-374/99010(DRS)
Licensee:
Commonwealth Edison Company Facility:
LaSalle Nuclear Generating Plant, Units 1 and 2 Location:
2601 No. 21" Road Marseilles, IL 61341 Dates:
April 19-23,1999 onsite April 26,1999 in-office review Inspector:
G. Pirtle, Physical Security inspector Approved by:
James R. Creed, Safeguards Team Leader Division of Reactor Safety
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9905210155 990514 PDR ADOCK 05000373
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EXECUTIVE SUMMARY LaSalle Nuclear Generation Plant NRC Inspection Report 50-373/99010(DRS); 50-374/99010(DRS)
This inspection included a review of the physical security program. It was an announced inspection conducted by a regional security specialist. Security areas evaluated during this inspection included: security procedures and documentation; staff knowledge and performance; security force training and quali0 cation; quality assurance in security; testing and maintenance; and alarm stations and communications.
Security equipment observed during the inspection functioned as designed. Security
lighting deficiencies have existed for a long period of time. The required level of protection for Heating, Ventilation, and Air Conditioning duct work within a specific i
!ocation in the plant continues to be evaluated (Section S2).
The security force performance was considered a strength (Section S4).
- The security self-assessment effort was varied and well monitored (Section S7).
- A Non-Cited Violation was identified because some contractor employees did not advise
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their supervisors when they detected the odor of alcohol on other employees so a determination could be made if Fitness-For-Duty for-cause testing was necessary (Section S8.5).
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l Report Details IV. Plant Suonort S2 Status of Security Facilities and Equipment a.
Insoection Scope (81700)
The inspector reviewed the condition of security equipment and facilities required by the security plan. The equipment observed included, but was not limited to, search equipment, intrusion alarm equipment, alarm assessment equipment, and equipment within the secondary alarm station (SAS) and Main Access Facility (MAF).
b.
Observations and Findinas Search equipment at the MAF and equipment at the SAS functioned as designed. The performance of the security force at those locations had the required communication equipment and weapons required.
Compensatory measures for reduced protected area lighting have been implemented since January 1999. The implemented compensatory measures were performed in accordance with security procedures. The lighting deficiencies have been entered into the corrective actions program. Discussions with the security staff disclosed that the actions needed to correct this issue are planned to be completed by July 1,1999. The j
lighting deficiencies were identified as a security issue requiring resolution in the LaSalle
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l Unit 2 Restart Readiness Assessment Report, dated March 19,1999. This issue will be monitored as an inspection Follow item (IFl 50-373/99010-01; 50-374/99010-01).
The bullet resistance of the Heating, Ventilation, and Air Conditioning (HVAC) duct work
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to a specific location within the plant was also identified as a security issue in the security Unit 2 Restart Readiness Assessment Report. (The specific location and vulnerability of the duct work is consdered safeguards information and exempt from public disclosure.)
The corporate security staff is coordinating with NRC Nuclear Reactor Regulation (NRR)
staff on the optiotis available to address the issue as a result of the same concem at the licensee's Quad Cities p! ant. The issue may have applicability at other licensee plants also. Based upon NRR's determination, the decision will be made if the issue should be addressed as a generic licenses issue or site specific issue. The issue is considered an I
unresolved item at this time, however, no action is required by the licensee security staff I
until NRR determines the level of protection required for the duct work. The unresolved issue is that additional information is needed to determine what actions are required to address the lack of bullet resistance for the HVAC duct work to a specific location within the plant (URI 50-373/99010-02; 50-374/99010-02).
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Conclusions Security equipment observed during the inspection functioned as designed. Uncorrected security lighting deficiencies have existed for a long period of time. The required level of protection for HVAC duct work within a specific location in the plant continues to be evaluated.
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S3 Security and Safeguards Procedures and Documentation a.
Inspection Scooe (81700)
The inspector reviewed selected procedures pertaining to the areas inspected and also reviewed appropriate logs, records, and other documents pertaining to the areas inspected, b.
Observations and Findinos Procedures reviewed were generally well written. Records reviewed were complete and accurate. The licensee's security staff self-imposed schedule to review and revise procedures was ahead of schedule, c.
Conclusions Security procedures reviewed were generally well written. Records reviewed were I
accurato and complete.
S4 Security and Safeguards Staff Knowledge and Performance a.
Insoection Scooe (81700)
The inspector toured various security posts, including the secondary alarm station and Main Access Facility. The inspector also observed performance of duties to determine if the security officers were knowledgeable of post requirements. Security event logs and other records pedaining to security force performance were also reviewed.
b.
Observations and Findinac The security force performance was considered a strength. Only five security loggable events were caused by security force errors within the past six months, and no loggable security events have been caused by the security force since November 1998. No deficiencies were noted during visits to the security posts.
During review of 14 training tecords, it was noted that one individual did not have j
documented evidence in the training file of completing the required physical examination.
For several security officers upgraded to armed officer positions, the training was documented on training forms completed and certified as accurate prior to the upgrade training being completed (used forms previously completed). These deficiencies are not risk significant and the licenset.? oecurity staff agreed to correct the deficiencies noted.
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Conclusions The security force performance was considered a strength.
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S7 Quality Assurance in Security and Safeguards Activities a.
Inspection Scope (81700)
The inspector reviewed security program audits completed within the past year and other self-assessment efforts used by the security staff to assess performance, identify problems, and correct deficiencies noted.
b.
Observations and Findinas The security self-assessment effort was varied and well monitored. Within the past year, nuclear oversight and corporate security completed separate program audits; the security contractor staff completed an audit; and the security department completed a LaSalle Unit 2 Restart Readiness Assessment Evaluation which addressed several areas of the security force mission. The scope of the audits reviewed was adequate.
Approximately six root cause analysis evaluations were completed. No programatic weaknesses were identified as a result of these root cause evaluations. Documentation of the analysis effort was extensive, detailed, and thorough. The security staff reviewed their performance results on a quarterly basis with the Site Vice President, Plant Manager, and Director of Corporate Security. Additionally, three security staff members have completed two weeks training for root cause evaluation, and eight security staff members have completed eight hours of root cause overview training. The station security administrator is a member of the corrective action review board.
Self-assessment findings were monitored until resolved,and at times, effectiveness evaluations were completed to determine the effectiveness of corrective actions implemented.
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Conclusions The security self-assessment effort was varied and well monitored S8 Miscellaneous Security and Safeguards issues S8.1 An unresolved item was identified in reference to an incident in which an individual was determined to be presumptive positive for a Fitness-For-Duty (FFD) test at the licensee's Braidwood Station on November 9,1998, and was granted access to the licensee's LaSalle station on November 9,1998, even though he was placed on the licensee's denied access list. This issue was identified by the licensee, required NRC prompt reports were completed (Licensee Event Report (LER) 98-S-03, dated December 9, 1998), and implementation of the corrective actions identified in the LER were verified.
The unresolved item is what was the basis to take administrative action against the individual (placed on the licensee's denied access list on November 9,1998), prior to the medical review officer talking with the individual on November 16,1998, and determining that the FFD test result was positive (URI 50-373/99010-03; 50-374/99010-03).
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S8.2 (Closed) Unresolved Item (Inspection Report No. 50-373/98017-01: 50-374/98017-01):
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A FFD for-cause test was not conducted when a supervisor detected the odor of alcohol on an employee. A Severity Level lil violation (No. 01013) was cited in a March 29, 1999, Notice of Violation (EA 98-560). This item is closed as an unresolved item and opened as an escalated enforcement item which is also closed in section SS.3 (VIO 50-373/99010-04; 50-374/99010-04).
S8.3 (Closed) Violation (Inspection Report No. 50-373/99010-04: 50-374/99010-04): FFD for-cause test was not conducted when a supervisor detected the odor of alcohol on an employee. A Severity Level 111 violation (No. 01013) was cited in a March 29,1999, Notice of Violation (EA 98-560). The inspector confirmed that the long term corrective actions to prevent recurrence identified in the licensee's February 17,1999 letter, Subject: " Response to Apparent Violation in inspection Report No. 50-373/98017 (DRS);
50-374/98017 (DRS)", were implemented.
S8.4 (Closed) Unresolved item (Inspection Report No. 50-373/98017-02:50-374/98017-02):
An unresolved item pertaining to a contractor supervisor and three contractor personnel who did not report the odor of alcohol on a coworker so the need for FFD for-cause testing could be determined in accordance with 10 CFR 26. 24 (a)(3). NRC review of this issue concluded that the failure of the personnel to advise their supervisors is a violation of 10 CFR 26.24 (a)(3) and the licensee's FFD procedures. This issue is closed j
as an unresolved item and opened as an enforcement issue and closed in section S8.5 (50-373/99010-05; 50-374/99010-05).
S8.5 (Closed) Non-cited Violation (Insoection Report No. 50-373/99010-05:
50-374/99010-05): A contractor supervisor and three contractor personnel did not report the odor of alcohol on a coworker so the need for FFD for-cause testing could be determined.
10 CFR 26.20 (d) requires the licensee to establish and implement written policies and procedures designed to meet the general performance objectives and specific requirements of 10 CFR Part 26.
Commonwealth Edison Corporate Nuclear Security Guideline No. 207, Section 5.2.2 requires that after the supervisor becomes aware that the individual's fitness is questionable, the supervisor shall immediately remove the individual from work activities and the individual is escorted at all times until the concem is satisfactorily resolved or until the individual exists the protected area.
Commonwealth Edison Corporate Nuclear Security Guideline No. 207, Revision 7, dated April 1998, Section 5.5.1 requires employees to report to their supervisor instances of violation of FFD policy and/or procedures which might adversely impact safe operation and maintenance of the station.
Contrary to the above, on May 11,1998, a contract supervisor who became aware that an individual's fitness was questionable, failed to escort the individual at all times until the concern was satisfactorily resolved or until the individual left the protected area.
Additionally, three contractor employees on various occasions detected the odor of alcohol on a coworker and failed to report it to their supervisor.
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NRC review of this issue concluded that the event was identified by the licensee, information was provided to the NRC, and significant remedial action was taken (employment terminated). The licensee's February 17,1999 letter, Subject:
" Response to Apparent Violation in Inspection Report No. 50-373/98017(DRS);
50-374/98017(DRS)", and Section S1.1 of Inspection Report No. 50-373/98017(DRS);
50-374/98017(DRS)", dated September 2,1998, described the corrective actions implemented for this issue. This Severity Level IV violation is being treated as a Non-Cited Violation (NCV), consistent with Appendix C of the NRC Enforcement Policy (NCV 50-373/99010-05; 50-374/99010-05).
A member of the site licensee staff contacted the Safeguards Team Leader and requested consideration be given to not including the item described in section S8.5, above, as a separate Non-Cited Violation. He indicated that because they identified the issue, and because the corrective action taken was the same as for the problem identified in section S8.2, it should be subsumed therein and not held separately. The matter was reviewed by the Region ill enforcement staff, and it was determined that the issue identified in section S8.5 of their report involved different people at different times and that the facts dictated that this item should be handled separately.
As expressed by the licensee, the corrective action was adequate, no further action is necessary and NRC concludes the matter is closed.
S8.6 (Closed) Inspection Followuo item (Inspection Report No. 50-373/98017-06:
50-374/98017-06): Potential adverse impact of a significant reorganization of the contract security force staff. Approximately eight overhead staff positions were eliminated during the reorganization. Interviews with contract security and licensee security supervisors, and with staff members disclosed that the reorganization did not have an adverse impact on performance. The personnel interviewed believed that the existing staff was as effective as the previous staff structure.
V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the onsite inspection results to members of the licensee management on April 23,1999. The licensee management representatives acknowledged the findings presented. The inspector asked the licensee if any inspection findings discussed during the exit meeting should be considered as proprietary or safeguards information. No proprietary or safeguards information was identified.
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I PARTIAL LIST OF PERSONS CONTACTED Licensee:
S. Barrett, Maintenance Manager P. Holland, Regulatory Assurance V. Gengler, Security Supervisor S. Johnson, Nuclear Oversight R. Lane, Corporate Security Manager E. Shankle, Support Services Manager S. Shields, Regulatory Assurance F. Spangenberg, Regulatory Assurance Manager R. Stachniak, Nuclear Oversight C. Wilson, Security Force Manager, Bums Intemational Security Services, Inc. (BISSI)
NRC K. Riemer, Senior Resident inspector INSPECTION PROCEDURES USED
IP 81700:
Physical Security Program For Power Reactors IP 92904:
Followup-Plant Support
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ITEMS OPENED AND CLOSED Ooened 50-373/374-99010-01 IFl Security Lighting Deficiencies
50-373/374-99010-02 URI Bullet Resistance of HVAC Duct Work at a Specific Location Within the Plant 50-373/374-99010-03 URI Fitness-For-Duty Administrative Actions i
l Prior to MRO Declaring FFD Test Positive 50-373/374-99010-04 VIO Supervisor Failed to Conduct For-Cause l
FFD Test 50-373/374-99010-05 NCV Not Advising Supervisors When The Odor of Alcohol Was Detected on Co-workers l
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Qlpsed 50-373/374-98017-01 URI Supervisor Failed to Conduct For-Cause FFD Test 50-373/374-98017-02 URI Failure to Report Violations of FFD Program l
50-373/374-98017-06 IFl Contract Security Reorganization Effect on Performance 50-373/374-99010-04 VIO Supervisor Failed to Conduct For-Cause FFD Test 50-373/374/99010-05 NCV Not Advising Supervisors When The Odor of Alcohol Was Detected on Co-workers Discussed None l
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LIST OF ACRONYMS USED BISSI Burns Intemational Security Services, Inc.
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DRS Division of Reactor Safety FFD Fitness For Duty HVAC Heating, Ventilation, and Air Conditioning IFl Inspection Followup ltem IP inspection Procedure
MAF Main Access Facility MRO Medical Review Officer NCV Non-Cited Violation NRR Nuclear Reactor Regulation SER Security Event Report SAS Secondary Alarm Station
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URI Unresolved item l
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i PARTIAL LISTING OF DOCUMENTS REVIEWED Security Event Reports for the Period between October 1,1998 and March 30,1999 Notice of Violation and Exercise of Enforcement Discretion (NRC Inspection Report No. 50-373/98017(DRS); 50-374/98017(DRS) and NRC Office of Investigations Report No. 3-98-015, dated March 29,1999 Commonwealth Edison Letter, Subject;" Response to Apparent Violation in inspection Report No. 50-373/98017(DRS); 50-374/98017(DRS)", dated February 17,1999 LaSalle Station Post Order 100," Compensatory Measures For Degraded or Failed Security System", Revision 45, approved October 31,1997 l
LaSalle County Station Post Order No.113 " Security Equipment Testing", Revision 44, approved June 19,1998 i
LaSalle County Station Post Order No.110, " Personnel / Package Search /MAF Ingress",
Revision 23 LaSalle County Station Post instruction No.108, " Search Lane Equipment Testing",
Revision 34, approved December 8,1998 LaSalle County Station Post instruction No.116, " Badge Fabrication", Revision 28, Approved December 2,1998 Borg-Warner Protective Services Quality Assurance Audit (EGSG 98-11) for Period between May 26 and June 1,1998 LaSalle Security Unit 2 Restart Readiness Assessment Report, dated March 19,1999 Commonwealth Edison Nuclear Oversight Security Audit No. QAA Comed-98-6 for the Period between May 21 and July 10,1998 Nuclear Oversight Assessment QVS-01-98-090, dated December 7,1998 Security LaSalle County Station 1999 Exposure Reduction Plan, dated January 15,1999 Effectiveness Review Summary of the Security "Get Well Program", dated February 15,1999 Exit Notes for Security "A-Team" Audit Conducted Between October 5-9,1998
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