IR 05000397/1999001

Insp Rept 50-397/99-01 on 990201-04 & 0303-05.No Violations Noted.Major Areas Inspected:Physical Security Program

ML20204F042
Person / Time
Site:	Columbia
Issue date:	03/19/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20204F032	List: IR 05000397/1999001 ML20204F026
References
50-397-99-01, 50-397-99-1, NUDOCS 9903250205
Download: ML20204F042 (12)

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ENCLOSURE U '4 ~ JUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-397 License No.: NPF-21 Repori No.: 50-397/99-01 Licensee: Washington Public Power Supply System Facuity: Washington Nuclear Project-2 Location: 3000 George Washington Way Richland, Washington Dates: February 1-4, and March 3-5,1999 Inspector: Thomas W. Dexter, Senior Physical Security Specialist Plant Support Branch

Approved By: Gail M. Good, Chief, Plant Support Branch Division Reactor Safety Attachment: Supplemental Information

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9903250205 990319 PDR ADOCK 05000397 G PM

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-2-EXECUTlW SUMMARY Washington Nuclear Project-2 NRC Inspection Report 50-397/99-01 This routine, announced inspection focused on specific areas of the licensee's physical security program. These areas included review of access control of personnel, packages, and vehicles; compensatory measures; locks, keys, and combinations; plans and procedures; security event logs; security training and qualification; management effectiveness; staffing levels; and audit Plant Sucoort

• Security program implementation continued to be highly affective in most areas. An effective program for searching personnel, packages, and vehicles was maintaine The compensatory measures program was effectively implemented. A highly effective lock and key control program was maintained and implemented. Changes to security programs and plans were reported to the NRC within the required time frame. Overall, implement:ng procedures met the performance requirements in the physical security plan. The security staff correctly reported security events; event records were accurate and neat. An excellent training program was implemented. Security program management was effective (Sections S1.1, S2.1, S2.2, S3.1, S3.2, SS.1, and S6.1).

• The annual audit of the Fitness-for-Duty Program was excellent. The audit was intrusive and performance based (Section S7.1).

• On-shift staffing of security armed response personnel was in accordance with the minimum requirements of the physical security plan. However, an inspection followap item was identified involving the following concerns: (1) the practice of relocating armed response personnel may have invalidated response time to plant equipment target sets and weapons deployment and (2) the difference between the number of armed responders committed to in the physical security plan and the number of armed response personnel used during the September 1998 Operational Safeguards Response Evaluation (OSRE). During the OSRE, the licensee successfully demonstrated its ability to defend against the design basis threat (Section S6.2). ;

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l l S1 Conduct of Security and Safeguards Activities S Protected Area Access Control of Personnel. Packaaes. and Vehicles 1 Inspection Scope (81700)

The access control program for personnel packages and vehicles was inspected to determine compliance with the requirements of the security pla , Observations and Findinas Through observations at the primary access facility and vehicle sallyport, the inspector determined that the licensee properly controlled personnel, packages, and vehicle access to the protected area. The protected area access control equipment was inspected and found to be functional and well maintained. The inspector also observed X-ray machine use and package and material searches at the main access facility. The operators were efficient and well traine Conclusions An effective program for searching personnel, packages, and vehicles was maintaine S2 Status of Security Facilities and Equipment S Compensatory Measures Inspection Scoce (81700)

The inspector reviewed the licensee's compensatory measures program to determine compliance with the requirements of the physical security plan. The areas inspected included deployment of compe. 3atory measures and the effectiveness of those

- measure Observations and Findinas The inspector confirmed through a review of Physical Security Plan implementing l Procedure SEC-18, " Safeguards Compensatory Measures," Revision 0, dated February 19,1998, that the licensee deployed compensatory measures in a manner consistent with the requirements in the physical security plan. Through interviews, the inspector determined that the security personnel available for assignment to l compensatory security posts were properly trained for those duties.

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4 . Conclusions The compensatory measures program was effectively implemented. The security procedure for compensatory measures met the requirements in the physical security plan. Security personnel were well trained on program requirement S2.2 Locks. Kevs. and Combinations Inspection Scoce (81700) l 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 pla I Observations and Findinas The inspector reviewed lock and key procedures and determined that inventories were completed as required. In addition, the locks and keys were rotated or changed when employees who had access to security locks and keys were terminated. Security of the additional sets of lock cores and keys was effective in preventing compromise. Records of keys, locks, core sets, and all changes were accurately maintained. The locksmith was professional and appropriately answered all of the inspector's question c Conclusion A highly effective lock and key control program was maintained and implemente S3 Security and Safeguards Procedures and Documentation S3.1 Security Proaram Plans and Procedures Inspection Scoce (81700)

The physical security plan and the implementing procedures were inspected to determine compliance with the requirements of 10 CFR 50.54(p) and the physical security pla Observations and Findinas The inspector determined that previous plan changea, were reported to the NRC within the required time frame, and changes submitted did not reduce the effectiveness of the plan. The inspector reviewed implementing procedures for adequacy, ensured that the licensee maintained an effective management system for the development and administration of procedures, and verified that changes to the procedures did not reduce the effectiveness of the licensee's security progra _ . _ _ . . . _ _ _ . . _ . - _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ . _ _ _ _ - . _ _ _ _ _ _ _

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-5- l Conclusions Changes to security programs and plans were reported to the NRC within the required time frame. Overall, implementing procedures met the performance requirements in the physical security pla S3.2 Security Event Loas l

a- Insoection Scope (81700)

l The inspector reviewed safeguards event logs and security incident reports to determine i compliance with the requirements of 10 CFR 73.21(b) and (c),10 CFR 26.73, and the i physical security plan. The inspector reviewed the safeguards event logs from July 9 through December 31,1998.

i Observations and Findinas The inspector determined that the records were maintained for the time required by - ,

regulations and conformed to the regulatory requirements regarding the reporting of l security events. The logs and supporting reports were accurate, neat, and contained sufficient detail for the reviewer to determine reportability and implemented corrective action Conclusions The security staff correctly reported security events; event records were accurate and

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l SS Security and Safeguards Staff Training and Qualification S Security Trainina and Qualification Inspection Scope (81700)

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The inspector reviewed a portion of the licensee's security training and qualification program to determine adequacy and compliance with the requirements of the Security, L Training and Qualification Plan and the Contingency. Pla Observations and Findinas

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i The inspector verified that the security organization conducted security training in i accordance with its approved security, training, and contingency plans. By reviewing l security shift records, the inspector confirmed that on-shift contingency drills were conducted periodically Documentation of the shift drills was apprf ilately maintained.

l The inspector also observed security officers during the performance of their dutie ]

Observed security officers demonstrated excellent knowledge of the procedural I

requirements for the task they were performing, i.

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6- Conclusions An excellent training program was implemented. Documentation of training activities by the security shifts and training section was very goo S6 Security Organization and Administration S6.1 Manaaement Effectiveness Inspection Scoce (81700)

The effectiveness and adequacy of security program management were evaluate Discussion s

The security program was managed by a well trained and highly qualified security staf The quality of the facilities and equipment demonstrated management support of the security progra Conclusion Security program management was effectiv ,

S6.2 Staffina Levels Inspection Scoce (81700)

The staffing level of the security organization was evaluated to determine compliance with the requirements of the physical security plan. Additionally, the inspector reviewed

the Operational Safeguards Response Evaluation (OSRE) report dated l December 9,1998.

l Observations and /indinas l

l Based on discussions with security supervisors and reviews of security shift personnel l rosters, the inspector determined that the minimun number of on-duty armed security l response personnel met the requirements of the physical security plan. However, l concerns were identified involving the frequent relocation of armed response personnel 1 and their contingency weapons inside the protected area, and the difference between j the number of armed responders committed to in the physical security plan and the

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number of armed response personnel used during the September 1998 OSRE.

j The following regulations apply to these concerns:

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• 10 CFR 73.55(a) requires, in part, that licensee physical protection systems shall be designed to protect against the design basis threat of radiological sabotage as stated in 10 CFR 73.1(a).

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Part I of the licensee's physical security plan stated, in part, that the physical ,

security plan meets the requirements of 10 CFR 73.55(a). l Section 3.4.7.1 of the licensee's physical security plan, Revision 38, stated, in part, that armed response personnel are available for response in the event of a security contingenc To meet the 10 CFR Part 73 design basis threat, Section 10.2 of the licensee's physical I security plan stated, in part, that X armed security (response) officers (specific number is safeguards information) were selected and trained to respond to security j contingencies and were available at all times, in addition to those security officers who manned the central and secondary alarm station ;

From September 21-24,1998, the NRC's Office of Nuclear Reactor Regr.lation (NRR)

performed an Operational Safeguards Response Evabation (OSRE) at the Washington Nuclear Project-2 reactor facility (Inspection Report 50-397/98-201 dat ad December 9, 1998). The primary purpose of the OSRE was to assess the licensee's ability to respond to the " external threat" pc Son of the design basis threat as roquired by 10 CFR 73.55(a). During the OSRE, the NRC observed four licenseo contingency exercises, in all four exercises, security personnel, armed with contiagency weapons, l responded to interdict the adversaries from what was described by the licensee as l normal duty posts. During the OSRE, the licensee elected to utilize five additional (X+5)

armed security response personnel per shift. This was five more armed response personnel than required by the physical security plan. The licensee's overall protective strategy was based on its total number of armed response personnel (X+5) positioned i at specific locations inside the protected are Based on a review of security posting records and security personnel interviews, the )

inspector determined that following the OSRE, the licensee relocated some of the (X+5) l armed response personnel to compensatory posts or other security posts that were not i part of the licensee's original response time evaluation. This practice was more prevalent on the back shift. These posts were not utilized during the OSRE and were ,

not in close proximity to the OSRE normal duty posts. The " relocated" response personnel were normally armed with only a sidearm and were not armed with a l contingency weapon. The licensee could not assure that these " relocated" response l

personnel could adequately respond to an attack threat in time to defend vital target sets. During the OSRE, these vital target sets were identified by the licensee as l necessary for the safe shut down of the reactor. The licensee's practice of relocating l armed response personnel may have invalidated their response times to both the l contingency weapons and to plant equipment target sets.

l Based on the results of the OSRE, the licensee demonstrated that it could respond to a design basis threat with X+5 armed response personnel. However, since the physical security plan only required X armed response personnel, the licensee could reduce its numbers and still remain in compliance, even though the ability to respond to a design basis threat with X armed response personnel has not been verified. It is important to note that following the OSRE, tha licensee has continued to maintain an on-duty shift strength of X+5 armed response personne _ _ _ _ _ __ _ _ _ _ _ .

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During the inspection, the licensee stated that its Denial Plan Guideline, Revision 1,

. dated September 21,1998, remained in effect and that this plan would be implemented

- when the NRC, or another agency, notified the site of a potential threat. Upon implementation, this plan provides, in part, for an immediate increase in the number of armed response personnel inside the protected are On March 3-5,1999, Ms. G. Good, Chief, Plant Support Branch, telephonically notified Messrs. J. Mcdonald, Manager, Plant Production, and D. Coleman, Manager, Regulatory Affairs, that the NRC was concerned with:

(1) The pract:ce of relocating armed response personnel. This practice may have invalidated the licensee's response time to both the contingency weapons and to plant equipment target set (2) Differences between physical security plan staffing and actual staffing. During the September 1998 OSRE, the licensee utilized X+5 armed response personnel to successfullly defend against the design basis threat. However, Paragraph 10.2 of the licensee's physical security plan required the licensee to provide only X armed response personnel to meet this requirement. The licensee could reduce its numbers and still remain in compliance, even though the r ulity to respond to a design basis threat with X armed response personn . nas not been verifie These two concerns will be reviewed during a subsequent security inspection (IFl 50-397/9901-01).

For background purposes, in June 1998, NRR recommended, and the NRR Executive Council agreed, that the OSRE program be eliminated by the end of Fiscal Year 199 The staff responded to numerous inquiries from the media and Congress, and briefed the Chairman and certain Commissioners on the OSRE program. These briefings included a discussion of possible alternatives to the OSRE program to support NRC's future validation of licensees' tactical response capabilities. In October 1998, the NRC formed a Safeguards Performance Assessment (SPA) Task Force to study the lessons l learned from the NRC OSRE program and to develop recommendations for tactical I

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response evaluations in the future. The Chairman instructed the task force to review safoguards performance issues and report its findings and recommendations back to the Commission by the end of calendar year 1998. This task has been accomplished with four specific recommendations that involve changes to regulations (to require target J set identification, development of protective strategies, and periodic exercises), the development of a regulatory guide, changes in the existing inspection program, and changes to security inspector training modules, Conclusions On-shift staffing of security armed response personnel was in accordance with the minimum requirements of the physical security plan. However, an inspection followup item was identified involving the following concerns: (1) the licensee's practice of relocating armed response personnel may have invalidated response time to plant equipment target sets and weapons deployment and (2) the difference between the

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number of armed responders committed to in the physical security plan and the number l of armed response personnel used during the September 1998 OSRE. During the OSRE, the licensee successfully demonstrated its ability to defend against the design l basis threa S7 Quality Assurance in Security and Safeguards Activities 87.1 Security Proaram Audits I Inspection Scoce (81700)

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Security program audits were reviewed to determine compliance with the requirements j of 10 CFR 50.54(p) and the physical security plan. The inspector reviewed the l fitness-for-duty audit listed in the attachmen i l

Obsentations and Findinas

' The inspector verified that an audit of the fitness-for-duty program was conducted at least every 12 months and that audit personnel were independent of plant security management and plant security management supervision. The audit scope covered required program areas and accurately focused on program effectiveness. The audit team included four subject matter experts from other utilities. The audit was both compliance and performance based. The techniques employed to accomplish the audit included personnelintentiews, document reviews, and performance observations. The l document reviews included an evaluation of implementing procedure and regulatory requirements. Observations were performed to evaluate the effectiveness of program ,

implementation. The audit identified two strengths, one finding, and eight l recommendations. The finding was corrected prior to the end of the audi )

i Conclusions

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The annual audit of the fitness-for-duty program was excellent. The audit was intrusive and performance base S8 Miscellaneous Security and Safeguards issues (Onsite Rt. 2w of Event Reports)

S8.1 Licensee Event Report 98-S01: Contract Emolovee Foreman (Supervisor) Adulterated )

Urine Sample l l

On October 6,1998, an individual was drug and alcohol tested as a part of the licensee's random test program. The on-site Enzyme Multiplied Immunoassay l Technique (EMIT) laboratory conducted an integrity check on the specimen, and it tested positive for nitrite contaminatio On October 7,1998, the Fitness-for Duty Supervisor authorized "for-cause/ reasonable testing" as a result of the EMIT test. The individual provided a second urine specime Due to attempts at adulteration, the Medical Review Officer (MRO) requested the Health and Human Services certified laboratory to perform "special processing."

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On October 14-27,1998, the MRO ordered additional testing by the laboratory o' ;: . -

the random and for-cause specimens. Both specimens were negative for drug On October 19,1998, the MRO met with the foreman for a clinical interview and discussion of the nitrite contamination. The foreman was informed that both tests were negative for drugs, but the laboratory report showed the random test was nitrite positive and not consistent with normal physiological nitrite concentrations in the urine. The foreman mentioned a medical condition, and the MRO agreed to continue investigation of the cause of the nitrite On October 27,1998, the MRO again met with the foreman and informed him of the results of the invest!;ation and also informed the Supply System Fitr.ess-for-Duty section of the results. The MRO's final determination was that the nitrite adulteration was positive, since the level in the urine specimen was not consistent with human lif The licensee's actions were correct and in accordance with regulations. The licensee immediately suspended the individual's unescorted plant access. Following an investigation by the licensee, the individual's unescorted access was revoked for a period of 3 years, and the individual's name was entered into the Personnel Access Data System (PADS) that is used by plarits nation wid 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 February 4,1999. The licensee acknowledged the findings presented. Cn March 3-5,1999, the Chief, Plant Support Branch, Region IV, telephonically notified Messrs. J. Mcdonald, Manager, Plant Production, and D. Coleman, Manager, Regulatory Affairs, of the two concerns discussed in Paragraph S6.2 above. These concerns were identified by the NRC as an inspection fcllowup ite !

ATTACHMENT SUPPLEMENTAL INFORMATION l PARTIAL LIST OF PERSONS CONTACTED Licensee A. Barber, Acting Quality Manager ,

D. Coleman, Manager, Regulatory Affairs j A. Conner, Security Operations Lead j F. Dehart, Supervisor, Safeguards and Investigations l R. Givin, Security Force Supervisor j J. Gloyn, Security Supervisor, Training

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V. Harris,, Assistant Maintenance Manager j M. Jewell, Security Sergeant j l

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2-D. Martin, Manager, Security Programs J. Mcdonald, Manager, Plant Product:on V. Parrish, Chief, Executive Officer R. Webring, Vice President, Operations Support C. Whitcomb, Assistant, to Vice President, General / Plant General Manager A. Witt, Fitness-for-Duty Lead O. Yonts, Security Training Specialist B. Yule, Security Lieutenant NRC L. Smith, Acting Chief, Branch E, Division Reactor Projects, Region IV J. Spets, Resident Inspector INSPECTION PROCEDURES USED IP 81700 Physical Security Program for Power Reactors IP 92704 Followup - Plant Support ITEMS OPENED. CLOSED AND DISCUSSED Opened 50-397/99-01 IFl Relocation of Armed Response Personnel Closed None Discussed 50-397/98-S01 LER Adulteration of Urine Specimen LIST OF LICENSEE DOCUMENTS REVIEWED

WNP-2 Physical Security Plan, Revision 3 Security Plan implementing Procedure SEC-18," Safeguards Compensatory Measures,"

Revision 0, February 19,1998

! Security Force Compensatory Measures Guideline No 1, " Unplanned CPU, Power or MUX

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Failure," Revision 2, August 4,1997

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Security Force Compensatory Measures Guideline No 4," Loss of CCTV Due to Adverse

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Environmental Factors," Revision 2, August 4,1997 l

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-3-Security Program implementing Procedure, Vehicle Escort Officer, Vehicle Search Officer, and Protected Areas Perimeter Gates, Revision 1, May 12,1998 Site-Wide Procedure SEC-05, " Contingency Events, Response and Reporting," Revision 0, February 19,1998 -

Response Force Drill records from October 1998 through January 199 Security Program implementing Procedure intrusion Detection System Alarms, Annunciators,

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Operability Test, inspection and Maintenance Records, Revision 1, March 2,199 Site Wide Procedure, Access Key Control, Revision 0, May 12,1997 Security Program implementing Procedure, Key and Lock Control, Revision 0, February 19,1998  ;

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