IR 05000456/1999004

Insp Repts 50-456/99-04 & 50-457/99-04 on 990222-24 & 0303 Onsite & 0309 & 11 Region 3 Ofc.No Violations Noted.Major Areas Inspected:Physical Security Program

ML20204J467
Person / Time
Site:	Braidwood
Issue date:	03/23/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204J430	List: IR 05000456/1999004 ML20204J424
References
50-456-99-04, 50-456-99-4, 50-457-99-04, 50-457-99-4, NUDOCS 9903300099
Download: ML20204J467 (11)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos: 50-456; 50-457 License Nos: NPF-72; NPF-77 Report Nos: 50-456/99004(DRS); 50-457/99004DRS)

Licensee: Commonwealth Edison Company Facility: Braidwood Generating Station, Units 1 and 2 Location: RR #1, Box 84 Braceville,IL 60407 Inspection Dates: February 22-24 and March 3,1999 onsite March 9 and 11,1999 NRC Region lli Office Inspector: G. Pirtle, Physical Security inspector

. Approved by: J. Creed, Safeguards Team Leader Division of Reactor Safety

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EXECUTIVE SUMMARY Braidwood Generating Station, Units 1 and 2 NRC Inspection Reports 50-456/99004; 50-457/99004  !

i This inspection included an announced review of the physical security program. It was an announced inspection conducted by a regional security specialis e Equipment observed functioned as designed and compensatory measures were !

seldom needed. Repetitive problems seidem occurred. Maintenance support for security equipment was generally timely (Section S.2).

e Records and documents reviewed were complete and accurate. Some automated records systems enhanced vehicle controls. Procedura:, reviewed were well written (Section S.3).

• Security force performance was a strength, as demonstrat'ad by a significant reduction in performance errors. An issue was identified pertaining to the security force tumover rate, primarily as it pertains to P.med security personne Firewatch responsiUlities have not degraded the secJrity force's capability to respond to security contingencies (Section S.4).

e The quality of self-assessment efforts we', e the, rough, well documented, and findings monitored until resolved (Socibn S.7).

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Report Details IV. Plant Suncort

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S2 - Status of Security Facilities and Equipment Insoection Scooe (81700)

The inspector reviewed the condition and performance of security equipment and facilities required by the security plan. The equipment observed included, for example,

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search equipment, intrusion alarm equipment, alarm assessment equipment, and equipment within the security alarm stations. Facilities observed included the Main Access Facility and both alarm stations ; Observations and Findingg-Security equipment observed during the inspection functioned as designed and compensatory measures were implemented when appropriate. Maintenance support for security equipment was generally timely (See Section S8.9 for exception). Security personnel observed on post, especially the alarm station operators, were familiar with equipment capabilities and system status for equipment on their post A technician was assigned to the security department for maintenance of a major -

segment of the alarm system. Interviews with the technicicn responsible for security equipment showed that he was very knowledgeable of system and component performance, and the historical performance of major security systems under his control. Review of security event logs and other data showed that repeated problems for the alarm systems seldom occurred, and maintenance support appeared effective in identifying causes for and correcting problems before an adverse trend develope The technician supporting the security equipment maintenance effort was being scheduled for specialized training to further maintain the high level of security equipment maintenance support. Tha inspector also interviewed the Superintendent, Mechanical Maintenance to determhe the status of various security maintenance issues (see Sections S8.1, S8.4 anc S8.9 for related information). Conclusions Equipment observed functioned as designed and compensatory measures were seldom needed. Repetitive problems seldom occurred. ' Maintenance support for security equipment was generally timely,

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S3 Security and Safeguards Procedures and Documentation Inspection Scope (81700)

'ThG inspector reviewed selected procedures pertaining to the areas inspected end also reviewed appropriate logs, records, and other documents, Qbservations and Findinas Records and documents reviewed during the inspection were complete and accur + i The security department had implemented an excellent computerized overtime monitoring system. Prior to a security officer working overtime, the individual's me and overtime hours to be worked are entered into the data base. If any of the i guidelines" for excessive work hours would be exceeded, the criteria exceeded is highlighted and necessary authorizations can be obtained. A computerized vehicle ,

entry and exit logging system has also been implemented which, among other features, automatically deletes a designated vehicle authorization if it is outside of the protected area for more than 24 continuous hours. Procedures reviewed were well written and of sufficient detail to describe the responsibilities and tasks to be performed for the pos Conclusions Records and documents reviewed were complete and accurate. Some automated records systems enhanced vehicle controls. Procedures reviewed were well writte S4 Security and Safeguards Staff Knowledge and Performance Inspection Scope (81700) ,

l The inspector toured various security posts and observed performance of duties to determine if the officers were knowledgeable of post requirements. S9curity event logs ana other records pertaining to security force performance were also reviewe j l Observations and Findinas The security force performance trend has improved since November 1998. Since November 1998, only about five security loggable events have been caused by the security force, and only two such events have occurred for the January and February 1999, time-frame. This is excellent performance by the security force and considered a strength. No deficiencies were noted during visits to several security posts. Personnel observed on post were very knowledgeable of post responsibilities and requirements and the operation of equipment applicable to the security pos An issue was identified pertaining to the security force tumover rate, primarily as it pertained to armed security personnel. Eleven security force members have left the

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security organization within the first two months of 1999. Section 2'of the contract ,

security force management audit (conducted in December 1998) noted the need to gain control over the turnover rate. The present trend, if not controlled, has the

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potential to cause excessive overtime,' and could impact on other aspects of performance, particularly before the new protection strategy is implemented in July 1999. The issue has already affected the type of work schedule currently in effect for armed response members. The security staff has implemented several actions to address this concem, such as initiating hiring new personnel, discussions with security force union representatives about fitness and agility standards for response force members, and other actions. The effectiveness of these actions could not be detennined as of 2ie close of this inspection. Therefore, this issue will be monitored as an Inspection Followup Item (IFl 50-456/99004-01; 50-457/99004-01).

- The security organization recently assumed firewatch responsibilities that were previously performed by another contractor. The inspector determined through interviews with security force officers, security shift supervisors, and licensee and

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contractor security managers that those responsibilities have not degraded the security l force's capability to respond to security contingencies. Areas that would interfere with I the security contingency response capability have been identified to security shift supervisors. Firewatch responsibilities within those areas of the plant are assigned to organizations other than security. All security personnel interviewed were aware that their security contingency response actions would take precedence over routine

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firewatch responsibilities, except for significant emergency condition Conclusions Security force performance was a strength as demonstrated by a significant reduction in performance errors. An issue was identified pertaining to the security force turnover rate, primarily as it pertains to armed security personnel. Firewatch responsibilities have not degraded the security force's capability to respond to security contingencie i S7 Quality Assurance in Security and Safeguards Activities Inspection Scope (81700)

The inspector reviewed self-assessment evaluations conducted by security staff and other personnel (licensee and contractor).

l Observations and Findinas j l

The quantity of documented self-assessments had decreased since the reduction of j the contract security force overhead staff. However, self-assessments being I conducted were of excellent quality. Review of the most recent Nuclear Oversight annual audit, contract security force managemant audit, and self-assessments pertaining to ingress search process; designated vehicle program; and increases in ,

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security force errors were very broad in scope, excellently documented with supporting information, and finding results were being monitored until closed or resolve Conclusions The quality of self-assessment efforts were thorough, well documented, and findings were monitored until resolve S Miscellaneous Security and Safeguards issues (92904)

S (Closed) Inspection Followuo item (Report No. 50-456/97020-03: 50-457/970?O-03):

Several enhancements or construction of additional barriers for plant protection purposes were identified. Although all of the delay barriers and other modifications have not been completed, the remaining work may not even be needed under the current plant protection strategy, or the new protection strategy planned to be implemented in July 1999. The security staff is currently reviewing the applicable work requests and vill identify those projects that no longer require completion to support the plant protection strateg S8.2 (Open) Inspection Followup item (Report No. 50-456/97201-1): A concem was identified about the weapons available for certain security force members (details are considered safeguards information and exempt from public disclosure). The licensee security staff has obtained soma new weapons to address this concem, and the new weapons are planned to be deployed when the new plant protection strategy is implemented in July 199 S8.3 (Open) Inspection Followup item (Report No. 50-456/97201-2): A concern was identified about some aspects of the weapons course of fire used for the security force (details are considered safeguards information and exempt from public disclosure).

The licensee security staff has addressed this concem and completion of the revised weapon course of fire will be completed prior to planned implementation of the new plant protection strategy in July 199 S8.4 LClosed) Inspec+ ion Followuo item (Report No. 50-466/97207-3): The need for a delay barrier by the containment escape hatch was identified. Tr' containment escape hatch delay barrier has been placed into positio S8.5 ~ (Closed) Violation (Report No. 50-456/98010-02: 50-457/98010-02): Two incidents of inadequate ingress searches by security personnel was observed. Inspection Reports 50-456/98010; 50-457/98010, dated July 2,1998, noted that appropriate corrnctive actions had been taken at the time the violation was cited. No security event reports nave been written for inadequate ingress searches within the past six months. During observation of entry into the protected area during peak entry time, no inadequate searches by security personnel were note i (

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l (Closed) Insoection Followuo item (Report No. 50-456/98010-03: 50-457/98010-03): A l

. significant reduction in the contract security force overhead staff positions was I implemented. The purpose of this IFl was to evaluate the potential adverse impact the j staff reduction may have on security force performance. Reviaw of the security force performance data and interviews with the security staff managers (licensee and contractor) disclosed that the reduction in staffing has been well managed and has not had an adverse impact on security force performance. The most obvious result of the force reduction appears to be the significant decrease in documentation of self- i assessments. Self-assessment efforts that were completed on a routine monthly basis, j have been discontinue S8.7 (Closed) Inspection Followuo item (Report No. 50-456/98010-04:50-457/98010-04): A negative performance for the security force was noted. Review of security event logs and security-related Problem Identification Forms (PlFs) data for the past six months showed that security force performance has been excellent with very few security event

. reports being completed for security force error ,

i S8.8 (Closed) Unresolved item (Report No. 50-456/98017-03: 50-457/98017-03): Tho ,

adequacy of compensatory measures implemented for the Vehicle Barrier System when the steam generators were removed from the protected area was questione !

NRC Headquarters reviewed the compensatory measures inylemented when the l steam generators were removed from the protected area and concluded that the -

compensatory measures were adequat S8.9 - (Open) Inspection Followuo item (Report No. 50-456/97020-03: 50-457/97020-03):

Several routine maintenance requests for the Vehicle Barrier. System were not )

completed in a timely manner. Revisw of this issue during this inspection disclosed that many items identified (some as earsy as 1996) were still pending completion. Some of the items were found to not be in the maintenance scheduling system because of an error during a maintenance personnel change. Interviews disclosed that the need to j get some of the maintenance items into the scheduling system was not passed on by the individual previously monitoring the work. None of the maintenance items however decreased the overall effectiveness of the vehicle barrier S8.10 (Open) Inspection Followuo item (Recort No. 50-456/98017-03: 50-457/98017-03): A l licensee's investigation concluded that several contractor personnel may have adulterated their Fitness-For-Duty urine specimens to mask use of prohibited substances. NRC actions are still pending on this matter. No further actions are required by the licensee's security staf Exit Meeting Summary The inspector and Safeguards Team Leader presented the inspection results to licensee !

management personnel by telephone on March 11,1999. The licensee personnel l acknowledged the findings presented. The inspector asked the licensee personnel whether any materials examined or inspection findings discussed during the exit meeting should be considered as proprietary or safeguards information. No proprietary or safeguards information was identifie _

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PARTIAL LIST OF PERSONS CONTACTED Licensee:

G. Baker, Station Security Administrator D. Cecchett, Lead Licensing Engineer R. Davis, Training Coordinator, Burns international Security Services, Inc (BISSI)

M. Embree, District Manager, BISSI J. Guiffre, Superintendent, Mechanical Maintenance C. Herzog, Services Superintendent

. R. Lane, Nuclear Generation Group Security Director R. Mau, Assistant Station Security Administrator M. Riegel, Nuclear Oversight Manager J K. Schwartz, Station Manager l D. Tumer, Assistant Station Security Administrator j D. Walker, Security Force Manager, BISSI H. Wetnam, Response Team Member, BISSI R. Wright, Security Shift Supervisor NRC

J. Adams, Resident inspector i D. Pelton, Resident inspector f C. Phillips, Senior Resident inspector INSPECTION PROCEDURES USED

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IP 81700 Physical Security Program For Power Reactors IP 92904 Followup - Plant Support 1

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ITEMS OPENED , CLOSED AND DISCUSSED Ooened 50-456/99004-01 IFl Personnel Turnover Rate for the Security Force 50-457/99004-01 IFl Personnel Turnover Rate for the Security Force Closed 50-456/97020-03 IFl Modification of Security Barriers in Support of the Plant Protection Strategy 50-457/97020-03 IFl Modification of Security Barriers in Support of the Plant Protection Strategy 50-456/97207-3 IFl Barrier for The Containment Escape Hatch f

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50-456/98010-02 VIO Two Incidents of inadequate Ingress Searches 50-457/98010-02 VIO Two incidents of inadequate Ingress Searches 50-456/98010-03 IFl Impact on Performance Caused by Reduction in Contract ,

Security Overhead Positions l

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50-457/98010-03 IFl Impact on Performance Caused by Reduction in Contract Security Overhead Positions 50-456/98010-04 IFl Negative Performance Trend by the Security Force 50-457/98010-04 IFl Negative Performance Trend by the Security Force

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50-456/98017-03 URI Compensatory Measure for the Vehicle Barrier System j 50-457/98017-03 URI Compensatory Measure for the Vehicle Barrier System l

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l l Discussed 50-456/97020-03 IFl Maintenance Requests for the Vehicle Barrier System 50-457/97020-03 IFl Maintenance Requests for the Vehicle Barrier System 50-456/97201-1 IFl Concem About Weapon Mix For Certain Armed Response Force Members

! 50-456/97201-2 .IFl Concem About the Weapons Training i

50-456/98017-03 IFl Adulterated Fitness-For-Duty Urine Testing Samples 50-457/98017-03 IFl Adulterated Fitness-For-Duty Urine Testing Samples LIST OF ACRONYMS USED

l IFl Inspection Followup Item PIF Problem identification Form URI Unresolved item

.VIO Violation

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PARTIAL LISTING OF DOCUMENTS REVIEWED Security Event Logs from September 1998 through February 15,1999 Nuclear Generation Group Security /FFD/ PADS Audit Report No. Comed-98-06, dated August 19,1998 Nuclear Oversight Memorandum to Licensee Senior Managers, Subject; " Nuclear Oversight-Transmittal of Amendment to Comed Security /FFD/ PADS Audit Report No. QAA Comed 98-06, dated August 31,1998

- Security Self assessment Report, Subject; " Security ingress Search Process, for July 6-14, 1998 Assessment Period Security Serif Assessment Report, Subject; " Security's Designated Vehicle Program", for December 14,.1998 to January 6,1999 Assessment Perio >

Borg-Wamer Protective Services Quality Assurance Audit Report No. EGS 98-26 for the

- Period Between December 14-17,199 Comed Braidwood Station Trend investigation Report For increased Human Performance

- Errors in the Security Department for the Period Between May 23,1997 - June 11,1998 Security-related Problem Identification Forms (PlFs) for Period Between September 1998 and February 1999 Comed Nuclear Generating Group PS.3:" Contract Security Turnover Ratio."

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