Information Notice 1987-11, Enclosure of Vital Equipment within Designated Vital Areas

Enclosure of Vital Equipment within Designated Vital Areas

ML031210619
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date:	02/13/1987
From:	Jordan E NRC/IE
To:
References
IN-87-011, NUDOCS 8702110131
Download: ML031210619 (14)

SSINS No.: 6835 IN 87-11 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, D.C. 20555 February 13, 1987 IE INFORMATION NOTICE NO. 87-11: ENCLOSURE OF VITAL EQUIPMENT WITHIN

DESIGNATED VITAL AREAS

Addressees

All nuclear power reactor facilities holding an operating license or

construction permit.

Purpose

This notice is provided to describe examples of significant degradation

of facility security programs resulting from the failure to enclose vital

equipment within designated vital areas. It is expected that recipients

will review the information for applicability to their facilities and

consider actions as appropriate to ensure that similar degradations do not

exist or occur at their facilities. However, suggestions contained in this

information notice do not constitute NRC requirements; therefore, no specific

action or written response is required.

Past Related Correspondence:

IE Information Notice 85-79, "Inadequate Communications between Maintenance, Operations, and Security Personnel."

IE Information Notice 86-27, "Access Control at Nuclear Facilities."

Description of Circumstances

Failure to provide adequate physical protection for vital equipment is one

of the most significant safeguards vulnerabilities that can occur at a nuclear

power facility. In recent months, plant walkdowns and inspections by NRC and

licensee personnel have identified instances in which vital equipment was

incompletely enclosed in a vital area designated in the physical security

plan, resulting in inadequate protection. The following examples were

discovered.

1. High-pressure coolant injection (HPCI) pump rooms and 480-V shutdown

transformers were not enclosed within designated vital areas with

positive access controls established.

2. 125-V dc power panels and steam supply piping designated as vital equip- ment was not enclosed within designated vital areas.

870

IN 87-11 February 13, 1987 3. The vital area barrier surrounding the diesel generator room had

openings in it that would have allowed someone to reach in and

manipulate valves on vital equipment.

In the first two examples, positive access controls or compensatory measures

had not been established to restrict access to the vital equipment.

Discussion:

Failure to protect vital equipment by not ensuring that the equipment is

located within an appropriately established and controlled vital area poses

a potentially significant threat to the security and safety of the facility

because of the opportunity for unauthorized and undetected access.

A review of the circumstances of the examples noted above indicate that the

most significant factors contributing to the degradations in protection of

vital equipment were:

- Failure by the licensee to adequately review and verify the as-built

drawings relative to the location and identity of designated vital

equipment.

- Failure of the site security organization to verify the location

and protection afforded areas and equipment identified as vital in

the physical security plan.

- Inadequate training of security and other licensee personnel in

the necessity for appropriate protection for designated vital

areas and equipment.

- Failure to adequately coordinate and followup on maintenance and

modification activities that may result in exposing vital equipment

to an inadequately protected environment.

. r

'-' IN 87-11 February 13, 1987 No specific action or written response is required by this information notice.

If you have any questions regarding this matter, please contact the Regional

Administrator of the appropriate NRC regional office or the technical contact

listed below.

Edward L. Jordan, Director

Division of Emergency Preparedness

and Engineering Response

Office of Inspection and Enforcement

R. P. Rosano, IE

(301) 492-4006 Attachments:

1. IE Information Notice 85-79

2. IE Information Notice 86-27

3. List of Recent'ly Issued IE Information Notices

• IE:PPMB *DD:DEPER *D: DEPER

DGable SASchwartz ELJordan

12/29/86 2/9/87 2/9/87

• IE:DI:ORPB AIE:DI:ORPB *IE:DI:ORPB *IE: DI: DD *IE:DI:D *IE:DEPER

RPRosano:jj LJCunningham PFMcKee RLSpessard JGPartlow RLBaer

1/8/87 1/14/87 1/14/87 1/15/87 1/28/87 2/4/87

OFC :IE:PPMB 5R- F E :D:DEPER

NAME :DGable :ELJ

DATE :12/ /86 /86

IN 87 No specific action or written response is required by this information notice.

If you have any questions regarding this matter, please contact the Regional

Administrator of the appropriate NRC 7egional ffice of the technical contact

listed below.

Edward L. Jordan, Director

Division of Engineering and

Quality Assurance

Office of Inspection and Enforcement

Technical Contact:

R. P. Rosano, (301)492-4006 Attachments:

IE Information Notice 85-79, "Inadequate Communications

between Maintenance, Operations, and Security Personnel"

IE Information Notice 86-27, "Access Control at Nuclear

Facilities"

OFC :IE:DI:ORPB :IE:DI:ORPB :IE:DI:ORPB :IE:DI:DD :IE:DI:D :IE:DEPER

______- ___ __ __ __ ___----__ __---------__---------___-___

- __ __ __-__ __ __ __

NAME :RPRosano:jj :LJCunningham :PFMcKee :RLSpessard :JGPartlow :REBaer

______- _ ______________ - -------------- _

- __------------- _ _ _ _ _ __ _ _ _ _

DATE :12/ /86 :12/ /86 :12/ /86 :12/ /86 :12/ /86 :12/ /86 OFC :IE:PPMB :DD:DEPER :D:DEPER

NAME :DGable § :SASchwartz :ELJordan  :

DATE :12/1)/86 :12/ /86 :12/ /86  :

Attachment

IN 87-11 v- SSINS No.: 6835 February 13 IN 85-79 1987 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, D.C. 20555 September 30, 1985 IE INFORMATION NOTICE NO. 85-79: INADEQUATE COMMUNICATIONS BETWEEN MAINTENANCE,

OPERATIONS, AND SECURITY PERSONNEL

Addressees

All nuclear power reactor facilities holding an operating license (OL) or

construction permit (CP), research and nonpower reactor facilities, and fuel

fabrication and processing facilities using or processing formula quantities

of special nuclear material.

Purpose

This information notice is provided to alert addressees of the need to ensure

that actions of a temporary or permanent nature taken by operations, maintenance, or other personnel that may affect the integrity of the physical barriers used

to control access to protected, material access, and vital areas, or other por- tions of the overall security program, are coordinated with the organization -

directly responsible for security before being implemented. It is expected

that the recipients will review the information for applicability to their

facilities and consider actions, if necessary, to preclude a similar problem

occurring at their facilities. Suggestions contained in this information

notice do not constitute NRC requirements; therefore, no specific action or

written response is required.

Description of Circumstances

During plant walkdowns and/or inspections, NRC and licensee personnel have

identified instances where actions by plant organizational elements other than

security have resulted in the degradation of protected and vital area barriers

and other security/safeguards measures without proper compensation. Some

examples are:

o removal of portions of protected and vital area barriers, including

fences, hatches, or other portals that allow unauthorized access to

the protected area or vital areas

o removal of equipment that had formed part of the barrier, such as

piping or valves that would allow passage of small objects into or

out of a material access area or vital area

o creation of holes in protected and vital area barriers to facilitate

construction

8509260122

IN 85-79 September 30, 1985 o leaving vital area door alarms in access mode after work is completed

o removal of essential telephone lines from an independent power source

o building or placing equipment, structures, or vehicles within the

isolation zone of the protected area or within exterior "clear" zones

of sensitive facilities, such as storage vaults

The incidents that lead to the issuance of this information notice have resulted

in the degradation of protected and vital area barriers and access controls

necessary for protection of vital equipment and, in one case, the loss of the

means to communicate with local law enforcement officials or emergency response

personnel. In many cases, the loss of this protection has been accompanied by

the failure of the licensee to notify the NRC in accordance with the applicable

provisions of 10 CFR 73.71, depending on the degree to which the security system

has been degraded.

Discussion:

A review of each incident has indicated that the modification or repairs that

degraded the protected and vital area barriers and communications systems were

made without an adequate, or in some cases any, notification of the facility's

security organization by the organization planning or performing the modifica- tions or repairs.

The likelihood of degradation may be substantially lessened at sites where the

organization responsible for security is part of the planning or scheduling

phase of any facility modifications or repairs. In such facilities, the

barriers and equipment necessary to provide security to the facility are

identified and the proper compensatory measures planned and scheduled to allow

for the efficient implementation of the planned modifications or repairs. An

integrated planning system allows for all facility organizations to have input

to the planning and scheduling phase of maintenance and facility modifications, especially when the actions taken can negatively impact on the effectiveness of

other essential programs.

The reporting requirements of 10 CFR 73.71 may apply to security incidents of

the type described above, depending on the degree to which the security system

has been degraded.

~'>IN 85-79 September 30, 1985 No specific action or written response is required by this information notice.

If you have any questions about this matter, please contact the Regional

Administrator of the approprate NRC regional office or this office.

dward ordan, Director

Divisi f Emergency Preparedness

and 6'gineering Response

Office of Inspection and Enforcement

R. Rosano, IE

(301) 492-4006 Attachment: List of Recently Issued IE Information Notices

Attachment 1 IN 85-79 September 30, 1985 LIST OF RECENTLY ISSUED

IE INFORMATION NOTICES

Information Date of

Notice No. Subject Issue Issued to

85-78 Event Notification 9/23/85 All power reactor

facilities holding

an OL or CP

85-77 Possible Loss Of Emergency 9/20/85 All power reactor

Notification System Due To facilities holding

Loss Of AC Power an OL or CP

85-76 Recent Water Hammer Events 9/19/85 All power reactor

facilities holding

an OL or CP

85-75 Improperly Installed Instru- 8/30/85 All power reactor

mentation, Inadequate Quality facilities holding

Control And Inadequate Post- an OL or CP

modification Testing

85-74 Station Battery Problems 8/29/85 All power reactor

facilities holding

an OL or CP

84-70 Reliance On Water Level 8/26/85 All power reactor

Sup. 1 Instrumentation With A facilities holding

Common Reference Leg an OL or CP

85-73 Emergency Diesel Generator 8/23/85 All power reactor

Control Circuit Logic Design facilities holding

Error an OL or CP

85-72 Uncontrolled Leakage Of 8/22/85 All power reactor

Reactor Coolant Outside facilities holding

Containment an OL or CP

Containment Integrated Leak 8/22/85 All power reactor

85-71 facilities holding

Rate Tests

an OL or CP

Teletherapy Unit Full 8/15/85 All material

85-70 licensees

Calibration And Qualified

Expert Requirements (10 CFR

35.23 And 10 CFR 35.24)

OL = Operating License

CP = Construction Permit

SSINS No.: 6835 IN87-J11t1Lf

IN 86-27 February 13, UNITED STATES 198 NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, DC 20555 April 21, 1986 IE INFORMATION NOTICE NO. 86-27: ACCESS CONTROL AT NUCLEAR FACILITIES

Addressees

All nuclear power reactor facilities holding an operating license (OL) or

construction permit (CP), research and nonpower reactor facilities, and fuel

fabrication and processing facilities using or possessing formula quantities

of special nuclear material.

Purpose

This information notice is provided to describe examples of significant physical

security problems in the area of access control. It is expected that recipients

will review the information for applicability to their facilities and consider

actions, if appropriate, to preclude similar problems from occurring at their

facilities. However, suggestions contained in this information notice do not

constitute NRC requirements; therefore, no specific action or written response

is required at this time.

Description of Circumstances

In recent months, the number of incidents related to degraded access control at

nuclear facilities appears to have increased considerably. Breakdowns in positive

access control, especially those that could have allowed access into vital areas

(VAs) and material access areas (MAAs), are among the most significant safeguards

vulnerabilities that can occur at nuclear facilities.

Examples of the most frequent access control problems are:

° Weapons have been found on vehicles by security personnel during protected

area exit searches instead of entry searches. Also, individuals already ,

granted access have discovered that they mistakenly brought weapons on site

via vehicle or package. In some cases, no entry search was conducted, while

in others, a search was conducted but the weapon was not detected. Secu- rity personnel have asked drivers of vehicles if they had any weapons on

their persons, but failed to ask if there were any weapons in the vehicles.

o Individuals have gained access to facilities by tailgating or by using

someone else's badge. Also, individuals not authorized access to VAs and

MAAs have tailgated into those areas. In many cases, they were not chal- lenged by the person being tailgated or by personnel working in the area.

Some violators displayed badges that clearly indicated they were not

authorized to be in the area, while others did not even display a badge.

8604160379

IN 86-27 April 21, 1986 * VA and MAA doors have been found unsecured because they would not close

properly. Also, these doors have been found taped or propped open for

operational convenience. In other instances, the closure time for power- controlled VA and MAA doors has been excessive, inviting tailgating or

unauthorized entries. Poor maintenance programs and inadequate compensa- tory measures have frequently compounded these problems.

• Guards being used as compensatory measures for VA and MAA barriers and/or

security alarm systems, have been found asleep at their posts or have left

their posts before barriers and/or alarm systems have been returned to an

effective state of operation.

o Responses to protected area and VA and MAM alarms have been very untimely

and, in some cases, no responses have been made.

In several of these cases, NRC has taken escalated enforcement action for

failure to properly control access to the site protected area and VAs. Under

the NRC Enforcement Policy, failure to control access such that contraband is

introduced into the site protected area or individuals are allowed access to

protected areas or VAs without proper authorization may be categorized as

Severity Level III or higher violations. Depending on the particular

circumstances of such incidents, a substantial civil penalty may be imposed.

Discussion:

The above examples of frequent access control problems indicate that many

licensees may share some of the following program management problems:

o Failure to properly train and motivate security personnel and other employees

in discharging their security-related responsibilities.

o Failure to place appropriate priorities on maintenance of security equipment.

a Poor security awareness or attitudes by employees.

o Poor access control procedures, especially concerning searches, issuance of

badges, and use of turnstiles.

Human error, ineffective training, and poor attitudes towards the security

program appear to be the most significant factors in the problem areas identified.

NRC inspectors are directing more inspection effort in'these areas, and violations

will be processed in accordance with NRC Enforcement Policy.

IN 86-27 April 21, 1986 No specific action or written response is required by this information notice.

If you have any questions regarding thts matter, please contact the Regional

Administrator of the appropriate NRC regional office, or this office.

Efard ,iJordan

Divisi of Emergency Preparedness

and Engineering Response

Office of Inspection and Enforcement

N. Ervin, IE

(301) 492-7855 Attachment: List of Recently Issued IE Information Notices

Attachment 1 IN 86-27 April 21, 1986 LIST OF RECENTLY ISSUED

IE INFORMATION NOTICES

Information Date of

Notice No. Subject Issue Issued to

86-26 Potential Problems In 4/17/86 All power reactor

Generators Manufactured By facilities holding

Electrical Products an OL or CP

Incorporated

86-25 Traceability And Material 4/11/86 All power reactor

Control Of Material And facilities holding

Equipment, Particularly an OL or CP

Fasteners

86-24 Respirator Users Notice: 4/11/86 All power reactor

Increased Inspection Frequency facilities holding

For Certain Self-Contained an OL or CP; research

Breathing Apparatus Air and test reactor

Cylinders facilities; fuel

cycle licensees and

Priority 1 material

licensees

86-23 Excessive Skin Exposures Due 4/9/86 All power reactor

To Contamination With Hot facilities holding

Particles an OL or CP

86-22 Underresponse Of Radition 3/31/86 All power reactor

Survey Instrument To High facilities holding

Radiation Fields an OL or CP and

research and test

reactors

86-21 Recognition Of American 3/31/86 All power reactor

Society Of Mechanical facilities holding

Engineers Accreditation an OL or CP and all

Program For N Stamp Holders recipients of NUREG-

0040 (white book)

86-20 Low-Level Radioactive Waste 3/28/86 All power reactor

Scaling Factors, 10 CFR facilities holding

Part 61 an OL or CP

86-19 Reactor Coolant Pump Shaft 3/21/86 All power reactor

Failure At Crystal River facilities holding

an OL or CP

OL = Operating License

CP = Construction Permit

- , 4 , at

r

Attachment 3 IN 87-11 February 13, 1987 LIST OF RECENTLY ISSUED

IE INFORMATION NOTICES

Information Date of

Notice No. Subject Issue Issued to

87-10 Potential for Water Hammer 2/11/87 All BWR facilities

During Restart of Residual holding an OL or CP

Heat Removal Pumps

87-09 Emergency Diesel Generator 2/5/87 All power reactor

Room Cooling Design facilities holding

Deficiency an OL or CP

87-08 Degraded Motor Leads in 2/4/87 All power reactor

Limitorque CD Motor facilities holding

Operators an OL or CP

87-07 Quality Control of Onsite 2/3/87 All power reactor

Dewatering/Solidification facilities holding

Operations by Outside an OL or CP

Contractors

87-06 Loss of Suction to Low- 1/30/87 All power reactor

Pressure Service Water facilities holding

System Pumps Resulting From an OL or CP

Loss of Siphon

87-05 Miswiring in a Westinghouse 2/2/87 All Westinghouse

Rod Control System power reactor

facilities holding

an OL or CP

87-04 Diesel Generator Fails 1/16/87 All power reactor

Test Because of Degraded facilities holding

Fuel an OL or CP

87-03 Segregation of Hazardous 1/15/87 All NRC licensees

87-02 Inadequate Seismic Quali- 1/15/87 All power reactor

fication of Diaphragm facilities holding

Valves by Mathematical an OL or CP

Modeling and Analysis

87-01 RHR Valve Misalignment 1/6/87 All PWR facilities

Causes Degradation of holding an OL or CP

ECCS in PWRs

OL = Operating License

CP = Construction Permit