IR 05000445/1990030

Insp Repts 50-445/90-30 & 50-446/90-30 on 900723-0802.No Violations or Deviations Noted.Major Areas Inspected: Security Program Audits,Protected & Vital Area Physical Barriers,Detection & Assessment Aids & Access Control

ML20059J628
Person / Time
Site:	Comanche Peak
Issue date:	09/11/1990
From:	Caldwell R, Powers D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059J623	List: IR 05000445/1990030 ML20059J617
References
50-445-90-30, 50-446-90-30, NUDOCS 9009200098
Download: ML20059J628 (9)

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APPENDIX

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

i NRC Inspection Report: 50-445/90-30 Operating License: NPF-87 l'

50-446/90-30 Construction Permit: CPPR-127 Dockets: 50-445 50-446

Licensee: TV Electric (TVEC)

Skyway Tower 400 North Olive Street, L.B. 81 a Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES) ,

Inspection At: CPSES, Glen Rose, Texas Inspection Conducted: July 23 through August 2, 1990 t

Inspector: -

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12 MM A. Caldwell, Physical Security Specialist

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h 8/ 9d Security and Emergency Preparedness Section , Dpe / ,

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Approved: , ##Ld/

Dr. D. A. Powers, Chief. Security and Y23/Yd Date i

Emergency Preparedness Section *

Inspection Summary Inspection Conducted July 23 through August 2. 1990 (Report 50-445/90-30) .

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, Areas Inspected: Routine, unannounced inspection of the licensee's physical

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security program. The areas inspected within the physical security program included management support; security program audits; protected and vital area physical barriers, detection and assessment aids, and access control of I personnel, packages, and vehicles; alarm stations; communications; power ,

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supply; testing and maintenance; compensatory measures; security training and qualifications; and records and report Results: Within.the program areas inspected, no violations or deviations were identified. The inspector found that the licensee has maintained a sound and I effective security program consistent with the requirements of the physical security plan and regulatory requirements. Staffing and security organization '

activities were effective and efficient. The licensee has been performance 900920009s 9009115J PDR ADOCK 05000445 G PNUr

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- oriented and demonstrated a commitment to sound security practices. . The licensee's testing and maintenance program for security-equipment has bee .

outstanding. Documentation of required records and reports demonstrated I

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competent licensee proficiency for identifying ano characterizing root causes of security weaknesses and equipment malfunctions.~ Licensee initiatives to correct self-identified deficiencies have been. prompt and effectiv Surveillances of security practices by the quality issurance department have ,

been we11' planned, performed by qualificd personnel, and documentation and followup on findings have been adequat The inspector provided the following observations for licensee consideration:

(1) off-duty self-improvement of security officers for developing firearms .  ;

proficiency at the site is not possible because of firearm range availability; (2) the vital area access authorizatior, program provides authorized entry to  !

personnel without demonstrated need; (3) the. licensee has no method'o detecting slow degradation of closed circuit television (CCTV) picture quality caused by either the CCTV camera or monitor; and (4) licensee. operational '

personnel do not regularly pick up emergency access keys ~ on a daily shif t basi I Inspection Conducted July 23 through August 2. 1990 (Report 50-446/90-30)

Areas Inspected: No inspection of Unit 2 was conducted.-

Results: Not applicabl >

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DETAILS Persons Contacted TV Electric

• B. Lancaster, Manager, Plant Support

• A. Scogins, Security Manager

• T. Hope, TV Site Licensing

• B..Southam, Plant Security Manager

• J. Rumsey, Corporate Security

• G. Bell, Senior 1.icensing Engineer

• J. Ardizzoni, TV Security

• 0. Bhatty, Issue Interface Coordinator

• 2. Gojak, Operations Support Engineer

• L. Fuller, Security Coordinator

• K. Britt, Security Coordinator

• J. Britt, Corporate Security Representative

• B. Hartman, Quality Technical Support

• P. Mills, Quality Technical Support

• J. Braun, Security Coordinator

• C. Baker, Office Assistant A NRC

• Johnson, Senior Resident Inspector Others

• D. Hickey, Burns Security Chief

• D. Proffitt, Assistant Burns Security Chief 3

• D. New, Burns Training Supervisor

• G. Willis, Burns Training Officer

• Denotes those that attended the exit interview on August 2, 199 The inspectorThose inspectio also interviewed employees other licensee included empioyees members during the-of the licensee s technical and management staff and members of the security organization, p Physical Security Program (81700)

The inspector reviewed certain elements of the licensee.'s physical security program in order to determine compliance with the NRC-approved physical security plan (PSP). Evaluations and determinations are based primarily on observations of activities and interviews with security personnel. The following paragraphs describe the inspection findings in each of the program areas inspecte l

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t a. Management support, Security Program plan, and Audits  :

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The security plan and implementing procedures and security program j audits were ihspected to determine the adequacy and compliance with r the requirements of 10 CFR 50.54(p) and 73.55(g)(4).and the PS ;

Licensee management support for the physical security program was '

also inspected. The areas inspected included ~ changes to the security !

plan and procedures, procedure development and implementation, _ audit l personnel qualifications, audit frequency, quality and  :

comprehensiveness, and licensee response to audit finding t

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The inspector confirmed that licensee upper management has been: e sensitive to security program requirements. Based on observations !

and interviews, the inspector determined that site and ,

corporate-level management support for the security program has been :

apparently effective in managing site security. The security staff was observed to work well as a team with excellent interpersonal communications and intraorganizational interfacing.- Staffing and security activities appeared to be effective, efficient, and '

adequate. The licensee's management team has demonstrated competent and proficient security management activitie ,

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The inspector reviewed the changes made to the PSP since the site wa licensed in February 1990 and also reviewed proposed changes to the e PS Revision 7,10 CFR 50.54(p) change, was an acceptable change made in July 1990. The inspector performed an early review of the *

proposed Revision 8 to the PSP. This revision is anticipated as a submittal under the provisions of 10 CFR 50.54(p).

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Personnel from the lice see's audit organization were interviewed about their security audit activities. The licensee has not performed a complete security audit since plant operating license '

issuance. The licensee is not required, however, to complete a security audit until February 1991. The inspector reviewed two quality surveillance reports (QSRs)~ completed by the quality technical support organization. QSRs QAS-90-453 and QAS-90-459,

" Control of Keys, Locks, and Combinations" and " Security Access Controls," respectively, were reviewed. The inspector noted that the quality assurance auditor who performed the surveillances evaluated performance activities and programmatic function '

l f No violations or deviations were identified in these program area b. Protected and Vital Area Physical Barriers and Detection and Assessment Aids

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The protected and vital area barriers and detection and assessment ,

aids programs were inspected to determine the adequacy and compliance with the requirements of 10 CFR 73.55(c)(1) through (6), (d)(7) and -

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(8), (e)(2) and (3), and (h)(4) and (6), and the PS The areas '

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l inspected included barrier construction; maintenance and penetration *

resistance; detection system capability; observation of alarms;

, potential vulnerabilities; detection system security; and assessment ,

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system cepability, security, and effectivenes t The inspector visually inspected the protected area (PA) and vital *

area (VA) barriers and determined that they were constructed to

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provide adequate penetration resistance. The PA and VA barriers ;

appear to be well maintaine t t

The inspector observed the licensee perform PA and VA intrusio (

detection system (IDS) functional performance tests. All VA IDS i tests sampled by the licensee passed.the performance tests. The i licensee testers were able to defeat one IDS zone once on the perimeter. However, on two subsequent retries, the testers were unable to defeat the particular IDS zone. Both the PA and VA IDS '

systems performed their designed function in a manner that ensured l that intruders would be detected upon entry. The inspector observed that two Pa IDS zones required frsquent review due to potential !

degradation by environmental causes and alignment drif ~

The assessment aids system (AAS) was, inspected for functional use and

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perfo*mance capabilities. The AAS system is an adequate syste !

However, the inspecto- observed that differences in image resolution !

occurred between different monitors in the same alarm station. The :

inspector also observed that one AAS camera field-of view was i obstructed because of alignmen t No violations or deviations were identified in these program area c. Protected and Vital Area Access Control of Personnel. Par:kages. and i Vehicles _

i That access control program for personnel, packages, and vehicles was inspected to determine the adequacy and compliance with the ,

requirements of 10 CFR 73.55(b)(3) and (d) and the PSP. The areas inspected included identification and authorization of personnel, #

badging and escort procedures, access control facilities and equipment, package authorization procedures, packages searches, and control of packages and materials onsite. Procedures and practices +

for vehicles admittance control, searches, and control of designatod vehicles onsite were also inspecte CFR 73.55(d)(7)(1) requires that-licensees limit unescorted access to VAs in nonemergency conditions to individuals who require-access -

in order to perform their duties. The regulation further requires that the cognizant manager or supervisor review this list each 31 days. The regulation also requires an access authorization syste '

! designed to accommodate the potential need for rapid entry or exit of individuals during emergency conditions or situation '

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The licensee uses a key card system that codes the key cards to f provide entry to VAs to correspond with the VAs to which unrestricted ,

authorized personnel have access. The cognizant licensee manager or j supervisor reviews the access authorization list each 31 days, j

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The inspector observed that the licensee has assigned authorized f access to VAs to a large number of personnel that have not i demonstrated a need for such access by their entry into VAs. For ;

example, the inspector reviewed a 90-day window of entry transactions ;

to VAs that indicated that.only 11-27 percent of the personnel with authorized unrestricted access.to selected VAs-required entry during i the 90-day period. In regard. to the control room, the licensee i

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authorized 2243 personnel unrestricted access. In the 90-day period,.

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1084 of the 2243 (48 percent) authorized personne1' with unrestricted l access to the control room-did not require entry to the control roo l The inspector determined that a very high percentage (73-89 percent) i t of all authorized personnel with unrestricted access to VAs have more ;

l unrestricted access than was required to perform work. This !

observation was discussed with the licensee and the licensee stated

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i their intention to reduce' the percentage of personnel with authorized :

access to VA t The inspector observed that the licensee has a temporary acesss-authorization system where those with infrequent but demenstrated *

need can be provided access to VAs. The. inspector determined tha >

l- only approximately 50 personnel per month use this method of authorized unrestricted acces ;

l The inspector observed that the licensee _provides means for emergency *

l access to designated personnel by issuing keys to be carried on their I person. The inspector observed that operational personnel have not 1'

routinely picked up the emergency access keys on a daily shift basi The licensee took immediate action.to followup on this matter, as ,

documented in the resident inspector's report 50-445;'50-446/90-3 l No violations or deviations were identified in these program area .

1 Alarm Stations and Communications  !

The alarm stations and communications equipment were inspected to determine the adequacy and compliance with the requirements of 10 CFR 73,55(e)(1) through (3), (f)(1) through (4) and (g)(1) through (3), and the PS The areas inspected included alarm station capabilities;-redundancy, diversity, and protection of alarm stations; system security; continuous communications capability; '

hard-wired and radio communications systems; and duress alarm' ,

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-7-The inspector observed that the alarm stations were independent, redundant, and had diverse means of annunciating and assessing alarm in conformance with the PSP and regulatory requirements. Both alarm stations had diverse means of initiating response to alarms by both'

onsite and offsite response force No violations or deviations were identified in these program areas.

i Power Supply The security system power supply was inspected to determine the adequacy and compliance with the requirements of 10 CFR 73.55(e)(2)

and (f)(4) and the PSP. The areas inspected included the emergency power supply, uninterruptible power systems, the independent power for nonportable communications equipment, and the automatic switchover capabilitie No violations or dwiations were identified in this program area, Testino. Maintenance, and Compensatory Measures The testing, maintenance, and compensatory measures programs were inspected to determine the adequacy and compliance with the requirements of 10 CFR 73.55(g)(1) through (4) and the PSP. The areas inspscted included the operability of security-related devices and equipment, test procedures, performance testing,. testing and maintenance of security system power supplies, deployment of compensatory measures, and effectiveness of these measure Traditionally, the licensee's time required to repair failed security equipment averaged less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspector determined that an extensive testing and maintenance program which ensured the integrity, reliability, and effectiveness of the security equipment has been instituted by the licensee. -The-licensee has tested each intrusion alarm for performance at least once every 7 days when the system has been in continuous use and after each out-of-service perio The inspector observed that the licensee had no method of detecting slow degradation of picture quality caused by either the AAS camera or monitor. The licensee did have the ability.to test the alignment of AAS cameras to ensure that the complete coverage of an area intended to be viewed is=kept under constant surveillanc No violations or deviations were. identified in this program are Security Trainino and Qualification (T&Q)

The security training and qualifications (T&Q) program was inspected-to determine the adequacy and compliance with 10 CFR 73, Appendix B;

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50.54(p); and 73.55(b)(4) and (h)(5); and the T&Q plan. The areas

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and employment' suitability and qualification criteria for security

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officers and watchperson , .

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The inspector interviewed: licensee contract security-officers and-observed licensee operations at. access control areas and in the- l secondary alarm station. The security officers. interviewed .  !

demonstrated knowledge'of the diverse responsibilities required o ,

their positions, -The inspector observed that morale was high in most '

areas of security operations and a professional attitude'was apparent:

within the security organizatio ;

I i l The inspector. reviewed crucial task testing precedures and r

interviewed security officers to determine why some security officer ?

l bad failed a crucial task. A repeat examination was required for ,

such occurrences. The inspector determined that training .

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requirements were being met by the security training staff in -

accordance with the PSP and regulatory requirement ,

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The inspector observed that the firearms range availability was- '

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limited to times when there is a' requirement for requalification of  ;

security officers with firearm There was no program which allowed ;

off-duty self-improvement by the security officers for developing firearm proficiency at the sit No violations or deviations were identified in thisfprogram are , Records and Reports (81038)

A sampling of the records and reports:was inspected to determine the..

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adequacy and compliance with the requirements of.10 CFR 73.71(b) and (c);.

I 10 CFR 73, Appendix B, Criteria A;-and the psp. The areas. inspected *

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included a review of reports of physical security events, security personnel qualification records, testing and mainter.ance program records, ,

and routine activity report ,

The inspector determined through review of the licensee's records and '

reports that the licensee has maintained all required documentation to l meet the regulatory and PSP requirements. The inspector interviewed-personnel who prepared the documentation and found the personnel .

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l knowledgeable of record keeping responsibilities. The licensee's testi.n l and maintenance program records for security equipments-were extremely I well documented. The licensee has established records to follow trends in.

l multiple areas of the security program. For example, the licensee >

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maintained trend analysis on barriers, cardkeys, cardreaders,- . .

fitness-for-duty, human errors, keys, safeguards information,' unauthorized i entries, and vehicle security field reports. The trend analysis for all .

security equipment and human error violations was consistent with expected' )

performance for a newly licensed plant,

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The inspector observed that only one area required additional attention as !

determined by the licensee's trend date. Specifically, in June.1990, the [

trending data showed an upward trend for key infractions,  !

No violations or deviations were identified in this program are '

~ Inspector Observations The inspector discussed observations with the licensee during the exit ' ;

interview. These observations are neither violations nor unresolved items. They were provided for_ licensee consideration-for program ;

improvement, but they have'no specific regulatory requirement. The ,

licensee indicated'that these items would be considere q

, ; Exit _ Interview (30703)

The inspector met with the NRC senior resident _ inspector. and license i representatives denoted in paragraph 1 on August =2, 1990, and summarized-the scope and findings of the inspection as presented in this report. The licensee did not identify as proprietary any of the matters discussed in ,

this report, ,

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