IR 05000454/1998016
| ML20236W255 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/31/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236W250 | List: |
| References | |
| 50-454-98-16, 50-455-98-16, NUDOCS 9808050173 | |
| Download: ML20236W255 (14) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGIONlli Docket Nos:
50-454;50-455 License Nos:
50-454/98016(DRS); 50-455/98016(DRS)
Licensee:
Commonwealth Edison Company Facility:
Byron Nuclear Generating Plant, Unit 1 and 2 Location:
4448 North German Church Road Byron, IL 61010-9750 Dates:
July 13-17,1998 Inspector:
G. Pirtle, Physical Security inspector i
Approved by:
James R. Creed, Chief, Pl ant Support Branch 1
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Oivision of Reactor Safety
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9909050173 990731 DR ADOCK O
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EXECUTIVE SUMMARY Byron Nuclear Generation Plant NRC Inspection Reports 50-454/98016; 50-455/98016 This announced inspection included selected aspects of the physical security program involving: security equipment maintenance, procedure and records review, personnel performance, self-assessment and previously identified issues. The inspection was completed onsite by one region-based physical security inspector.
Security equipment observed during the inspection functioned as designed, and
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compensatory measures for equipment failure were seldom required. Inspector observed portions of annual testing of the perimeter alarm system conSrmed that the testing was conducted in accordance with procedures (Section S2).
Security procedures reviewed were generally well-written. Records reviewed were
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accurate and complete, except for alarm history records for multiple alarms within a zone, a problem which also exists at other Comed sites. (Section S3).
Security force members were knowledgeable of post requirements and performed their
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duties in an adequate manner. A significant reorganization of the contract security force occurred since the last inspection. The licensee went below the minimum armed security officer shift manning level for a short period of time (Section S4).
Self-assessment activities were effective in identifying potential problem areas (Section
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S7).
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Report Details jL Plant Suonort i
S2 Status of Security Facilities and Equipment a.
Insoection Scoce (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
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equipment, intrusion alarm equipment, alarm assessment equipment, and equipment within the secondary alarm station (SAS) and Main Access Facility (MAF). The inspector observed portions of the annual alarm system test for four zones of the perimeter alarm system.
I b.
Observations and Findinos Search equipment at the MAF and equipment at the alarm stations functioned as designed. Observed security force personnel were appropriately equipped with operable, required communication equipment and weapons. The security equipment testing program was generally very strong and at times exceeded security plan commitments, especially for the perimeter alarm system. Maintenance support for l
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security equipment appeared to be timely, especially when security compensatory measures were required.
inspector observed portions of annual testing for four perimeter alarm zones confirmed that the testing was conducted in accordance with the applicable test procedures.
Appropriate compensatory measures were also implemented during the testing.
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c.
Conclusions
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Security equipment observed during the inspection functioned as designed, and compensatory measures for equipment failure were seldom required. Annual testing of the perimeter alarm system was in accordance with procedures.
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I S3 Security and Safeguards Procedures and Documentation (
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insoection Scoce (81700)
l The inspector reviewed selected procedures pertaining to the areas inspected and also reviewed appropriate logs, records, and other documents pertaining to security operations observed.
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Observations and Findinos Records reviewed were generally complete and accurate. Proper controls were observed for protecting records and procedures that were designated as Safeguards Information in accordance with 10 CFR 73.21.
Intrusion alarm records did not contain the level of detail required by the security plan.
Section 14.4.6 of the security plan required certain specific information to be recorded for all alarms. All of the required information was not being documented when multiple
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alarms occurred. When multiple alarms occurred, the security computer generated
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records showed only the required information for the first and last alarm in the series, and gave an alarm count for the total number of alarms for the zone. The specific I
information required by the Byron security pian for the alarms between the first and last I
alarm was not recorded. Discussions with Corporate Security Staff showed that this method of record keeping had been approved in security plans for other Comed sites.
Additionally, the inspector confirmed that all alarms were received as required.
The lack of required information was caused,in part, by software changes in the most recent modification of the security computer system. Additionally, alarm station operators not acknowledging and clearing alarms as early as practical during tests contributed to the volume of inadequate alarm history records. During alarm system testing observed by the inspector, it was noted that the final clearing of the alarms was not completed until all of the alarm testing was completed. This practice resulted in the information required for each test alarm not being recorded; the required information was recorded only for the first and last alarms. Discussions with the security staff showed that this practice for system testing had just evolved, and was not addressed by security procedures. Immediate corrective actions were implemented to advise alarm station operators to acknowledge and clear alarms as early as practical to reduce the volume of alarms with inadequate record information. Long term resolution of the issue was being evaluated by the security staff. This issue will be monitored as an Inspection Followup Item (50-454/98016-01; 50-455/98016-01).
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Conclusions
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i Security procedures reviewed were generally well-written. Records reviewed were generally accurate and complete, except for alarm history records for multiple alarms.
l Deficiencies for alarm history records is being monitored as an inspection Followup l
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I S4 Security and Safeguards Staff Knowledge and Performance a.
Insoection Scoce (81700)
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The inspector toured various security posts, including the secondary alarm station and Main Access Facility. The inspector also observed performance of duties to determine f
whether the security officers were knowledgeable of post requirements. A sampling of I
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security event logs and other records pertaining to security force performance were also reviewed.
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Observations and Findinos No deficiencies were noted in security force personnel's performance during post checks. Security Shift Supervisors were very knowledgeable of ongoing security activities and the status of security equipment, personnel, and activities requiring security support.
(1)
The inspector reviewed the recent implementation (June 26,1998) of a significant reduction in the contract security force overhead (administrative)
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positions. The staff positions were reduced about 50%. Examples of positions eliminated included Operations Coordinator; four Support Services positions; an Administrative Clerk; and others. Several administrative people were in a
" learning curve" mode for new positions, or positions they may be qualified for.
Transition orientation related to the reorganization was also in progress. The reorganization has not been in effect for sufficient time to allow meaningful evaluation of its impact on regulatory based security force performance. The inspector did note however, that monthly trending and analysis of eight performance areas was terminated in June 1998 because the person performing the task was reassigned. This analysis and self-assessment effort may be resumed at a later date. The impact of the significant reorganization of the contract security force on security force performance will be monitored as an inspection Followup Item (50/454/98016-02; 50-455/98016-02).
l (2)
The Byron Station Security Plan identifies the minimum number of armed
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security personnel that must be available onsite at all times to counter the security design basis threat (radiological sabotage) identified in 10 CFR 73.1(a)(1), (the specific minimum number of armed security officers assigned to
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a shift for a particular nuclear plant is considered safeguards information and I
exempt from public disclosure). The inspector reviewed the circumstances of an incident on July 3,1998, in which the minimum number of armed security force personnel were not available on site for a short period of time. During this time, one less than the minimum number of armed responders was onsite. The armed security officer minimum manning level was not met for the short period of time because a security officer had injured himself while on duty and had to be I
transported offsite for medical evaluation and treatment. Normally, because of the number of personnel assigned to a shift, other security officers who could have been armed to replace the injured officer would have been available on site. Such was not the circumstances however for the July 3,1998 incident due to scheduling peculiarities. The incident was reported to the NRC in accordance with 10 CFR 73.71.
Corrective actions taken included increasing the armed staffing level per shift to one above the minimum number identified in the security plan. Additionally, a
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revision to the security plan will be made allowing staffing levels to be below this minimum standard for a designated emergency period of time.
The circumstances described above constituted a violation of Sections 3.2.4 and
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3.2.6 of the station security plan. This non-repetitive, licensee-identified and
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l corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy.
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c.
Conclusions
Security force members were knowledgeable of post requirements and performed their duties in an adequate manner. Security shift supervisors were very effective in l
monitoring security activities. The impact of the significant reorganization of the contract security force on security force performance will be monitored as an Inspection Followup
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item. A licensee identified Non-Cited Violation was noted for not complying with the
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minimum armed security officer shift manning level for a short period of time.
Quality Assurance in Security and Safeguards Activities a.
Insoection Scone (81700)
The inspector reviewed self-initiated performance evaluations conducted by security
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staff and personnel (licensee and contractor) and the Nuclear Oversight Department.
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Observation and Findings The self-assessment efforts continued to be varied and effective. All self-assessment findings were documented and were being monitored and addressed by the security staff. Since January 1998, security program audits have been completed by the corporate security staff, the contract security audit staff, and the licensee Nuclear
Oversight department. Additionally, a self assessment conducted by the licensee's
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security staff was reviewed.
The corporate security evaluation (dated March 6,1998) identified some procedure weaknesses and a weak security drill program. The licensee plans to strengthen the weaknesses. Strengths included repairs of the security system and computer programs developed to support the Fitness-For-Duty program.
J The Nuclear Oversight (NO) department audit of the security program was conducted
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between June 15-26,1998 (Audit No. CE-98-06). The audit concluded that the overall implementation of the site security plan and program were acceptable and effective. No
. significant weaknesses were noted in the physical security portion of the audit. The preliminary audit conclusions also noted that the recent security reorganization
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presented challenges to the members of the licensee staff and security force. No major j
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problems pertaining to the reorganization were noted at the conclusion of the audit. The i
scope and depth of the Nuclear Oversight audit was adequate.
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The BURNS security audit (No. RSBU 98-02) was conducted between January 12-16, 1998. The scope and depth of the audit was very good, and the au: lit results were well documented. Supervisors effectiveness and communications, personnel and vehicle access procedures and controls, and a sound and comprehensive self-assessment program were positive attributes identified in the report. Some administrative areas were identified which warranted further attention. Thirteen findings (6 strengths; 3 recommendations, and 4 weaknesses) were identified during the audit.
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Followup actions had been initiated on those findings warranting fudher action.
j The inspector also reviewed the security section's Department Performance Review meeting minutes, which was conducted March 13,1998. The areas evaluated included review of areas of concern identified during the most recent NRC inspection and licensee Corporate security sponsored audit. The meeting minutes (dated April 28, 1998) accurately characterized the issues identified in the two audits and action plan items had been identified for each of the identified " performance gaps and causes."
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Conclusions Self-assessment activities were effective in identifying potential problem areas.
S8 Miscellaneous Security and Safeguards issues (92904)
S8.1 (Closed) Insoection Followuo item (50-454/97011-03: 50-455/97011-03): A security i
plan revision had not been prepared addressing exempting certain vehicles from search
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upon entry into the protected area when certain security measures had been implemented. The licensee indicated that the practice will be discontinued.
S8.2 (Closed) Insoection Followuo item (50-454/97011-04: 50-455/97011-04): Degraded alarm system assessment capability, and alarm station operators not clearing alarms in a timely manner. Observed alarm station operations showed that the assessment capabilities were routinely in service, and alarm station operators were clearing alarms in a timely manner, except as noted in section S.3.b.
S8.3 LCked) Insoection Followuo item (50-454/98003-03: 50-455/98003-03): A locking capability within the Main Access Facility (MAF) was not always available. The post requiring the need for a locking capability was terminated at the end of the Steam Generator Replacement Project.
S8.4 (Closed) Insoection Followuo item (50-454/98007-01: 50-455/98007-01): Procedure guidance was not developed to describe requirements for entry into the protected area for certain types of equipment. Adequate procedure guidance has been developed.
During observations of vehicle entry into the protected area, these items were processed in accordance with the procedure guidance.
S8.5 (Closed) Insoection Followuo item (50-454/98007-02: 50-455/98007-02): A possible adverse performance trend was noted in a previous inspection. Review of security plan I
deviations showed that only four such deviations have occurred between February and
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l June 1998 (five months), compared to eight such deviations between August 1997 and i
January 1998 (six months). An adverse trend does not appear apparent.
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S8.6 (Closed) Security Event Reoort (SER) 96-S03-00: This SER was dated November 6, 1996, and pertained to incomplete corrective actions to secure two hatches. Although the hatches were secured adequately to prevent entry or introduction of any prohibited security items, they were not secured to the level of protection committed to by the licensee. Interviews with the licensee's security staff and review of photographs of the access hatches after they were modified confirmed that the hatches are properly secured.
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X1 Exit Meeting Summary The inspector presented the onsite inspection results to members of the licensee management
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at the conclusion of the onsite inspection on July 17,1998. The licensee acknowledged the findings presented. The inspector asked the licensee whether 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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PARTIAL LIST OF PERSONS CONTACTED Licensee:
D. Wozniak, Acting Station Manager D. Brindle, Regulatory Assurance Supervisor G. Bowers, Assistant Station Security Administrator R. Cassidy, Assistant Station Security Administrator R. Colglazier, NRC Coordinator R. Lane, Director, Corporate Security W. Israel, Assessment Manager M. Mareth, Force Manager, BISSI S. Mills, Station Security Administrator D. Minor, Training Coordinator, BISSI R. Spencer, General Manager, BISSI NEC E. Coby, Senior Resident inspector, NRC Region lil N. Hilton, Resident inspector, NRC Region til
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B. Kemker, Resident inspector, NRC Region ill (
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INSPECTION PROCEDURES USED IP 81700 Physical Security Program For Power Reactors IP 92904 Followup - Plant Support
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PARTIAL LIST OF PERSONS CONTACTED Licensee:
D. Wozniak, Acting Station Manager D. Brindle, Regulatory Assurance Supervisor G. Boviers, Assistant Station Security Administrator R. Cassidy, Assistant Station Security Administrnhi R. Colglazier, NRC Coordinator R. Lane, Director, Corporate Security W. Israel, Assessment Manager M. Mareth, Force Manager, BISSI S. Mills, Station Security Administrator.
D. Minor, Training Coordinator, BISSI R. Spencer, General Manager, BISSI NBC E. Coby, Senior Resident inspector, NRC Region ill N. Hilton, Resident Inspector, NRC Region 111 8. Kemker, Resident inspector, NRC Region til INSPECTION PROCEDURES USED IP 81700 Physical Security Program For Power Reactors IP 92904 Followup - Plant Support
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ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-454/98016-01 IFl incomplete Alarm History Records for Multiple Alarms 50-455/98016-01 IFl Incomplete Alarm History Records for Multiple Alarms 50-454/98016-02 IFl Security Force Reorganization impact on Regulatory Based Performance 50-455/98016-02 IFl Security Force Reorganization impact on Regulatory Based Performance Closed 50-454/97011-03 IFl Security Measures Used to Exempt Vehicles From Search at Licensee's Sites Are Not Addressed by Security Plan 50-455/97011-03 IFl Security Measures Used to Exen.pt Vehicles From Search at 1icensee's Sites Are Not Addressed by Security Plan 50-454/97011-04 IFl Degraded Alarm Assessment Capability Because of Some Alarm Station Operators Actions 50-455/97011-04 IFl Degraded Alarm Assessment Capability Because of Some Alarm Station Operators Actions 50-454/98003-03 IFl Access Control Problem in MAF 50-455/98003-03 IFl Access Control Problem in MAF 50-454/93007-01 IFl Procedure Needs to be Developed For Certain Types of Equipment Entering the Protected Area 50-455/98007-01 IFl Procedure Needs to be Developed For Certain Types of Equipment Entering the Protected Area 50-454/98007-02 IFl Possible Adverse Trend Noted in Security Force
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50-455/98007-02 IFl Possible Adverse Trend Noted in Security Force
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50-454/96-S03 SER incomplete Corrective Actions to Secure Barrier
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LIST OF ACRONYMS USED BISSI Burns international Security Services, Inc.
IFl inspection Followup item MAF Main Access Facility NCV Non-Cited Violation RWST Refueling Water Storage Tank SAS Secondary Alarm Station j
SER Security Event Report
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PARTIAL LISTING OF DOCUMENTS REVIEWED Byron Station Security Performance Trending Reports from March 1998 through May 1998 Corporate Nuclear Security Guideline No.1," Reporting and Recording of Security Events",
Revision 12, dated February 1998 Security Event Report Number 454:96-S-03, dated November 6,1996, incomplete Corrective Actions for RWST Hatches" Security Plan Violations Summary Printout, dated July 13,1998 Byron Station Security Self-Assessment No. 98-03 for period between February 21-March 13, 1998 Byron Security / PADS /FFD Audit (CE-98-06) Security Debrief Notes, June 26,1998 (Formal
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report pending)
Byron Security Assessment Exit Debrief Preliminary Results, March 6,1998 (Corporate Security sponsored audit)
Borg-Warner Protective Services Quality Assurance Audit Report No. RSBU 98-02, for period between January 12-16,1998 Site / Department Performance Review Meeting Minutes, dated April 28,1998
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Sample review of Log of Security Maintenance Requests covering the period between February 27 and July 14,1998
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Zone Alarm History filter by Zone and/or Zone Group reports for zones 18 and 19 on July 16,1998, and zone 11 for July 15,1998 P!F B1988-02593, Report 454-181-98-00001," Improper Compensatory Measures by Security" Sampling of Security Event Logs for the perad between February 1 and July 1,1998 Byron Post Order 11, " Vehicle Search Officer", March 27,1998 Corporate Nuclear Security Guideline No.107, " Maintaining Search Integrity Between Stations",
Revision 0, dated February 1998 Byron Procedure BHP 4200-20, " Annual Door Intrusion Alarm Maintenance Inspection", Revision
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8, approved April 21,1998 Daily ingress Detection Equipment Test Documentation for June 1-30,1998 l
Seven Day Alarm Test Records for Doors and Perimeter for April 29 through July 6,1998
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Seven Day Test Procedure for Security Doors, Revision 1, November 1994 Microwave Test Procedure, August 25,1997 MAF/CAF Turnstile Locking Device Test Procedure, Revision 6, March 3,1998 Seven Day / Quarterly and Annual E-Field / Microwave Testing Guidance Seven Day E-Field Testing Procedure, August 25,1997 l
Annual E-Field Testing Procedure, July 1997
Quarterly E-Field Testing Procedure, July 1997 Annual Microwave Testing Procedure, July 1997 J
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