L-12-114, LER 12-S02-00, for Perry Nuclear Power Plant, Unit 1, Regarding Potential Vulnerability in a Safeguards Security System

LER 12-S02-00, for Perry Nuclear Power Plant, Unit 1, Regarding Potential Vulnerability in a Safeguards Security System

ML12089A132
Person / Time
Site:	Perry
Issue date:	03/22/2012
From:	Emily Larson FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-12-114 LER 12-S02-00
Download: ML12089A132 (5)

Text

FENOC Perry Nuclear Power Plant 10 Center Road PO. Box 97 FirstEnergyNuclear OperatingCompany Perry, Ohio 44081 March 22,'201-2-,Z L.,-1 2-114,,?

- . - ,*ý!-

-'-,"; 10 CFR 73.71(a)(4) 10 CFR 73, Appendix G, 1(c)

ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant, Unit 1 Docket No. 50-440, License No. NPF-58 Security Licensee Event Report Submittal Enclosed is Security Licensee Event Report (SLER) 2012-S02, "Potential Vulnerability in a Safeguards Security System." There are no regulatory commitments contained in this submittal.

If there are any questions or if additional information is required, please contact Mr. Robert Coad, Manager - Regulatory Compliance, at (440) 280-5328.

Sincerely, Eric A. Larson Site Vice President, Acting

Enclosure:

SLER 2012-S02 cc*:, NRC Project Manager NRC R6sident Inspector NRC Region III Director, Division of Security Policy, Office of Nuclear Security and Incident

Response

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NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 EXPIRES 10/31/2013 (10-2010) Estimated burden per response to comply with this mandatory collection request: 80 hrs. Reported lessons learned are incorporated into the licensing process and fed back to industry. Send comments regarding burden estimate to the FOIA/Privacy Section (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by internet e-mail to infocollects.resource@nrc.gov, and to the Desk Officer, Office of Information LICENSEE EVENT REPORT (LER) and Regulatory Affairs, NEOB-10202 (3150-0104), Office of Management and (See reverse for required number of digiS/car aterse for r redcnuberokf Budget, Washington, DC 20503. Ifa means used to impose an information collection does not display a currently valid OMB control number, the NRC may digits/characters for each block) not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME 2. DOCKET NUMBER 3. PAGE Perry Nuclear Power Plant, Unit 1 05000440 1 OF4

4. TITLE Potential Vulnerability in a Safeguards Security System

5. EVENT DATE 6. LER NUMBER J 7. REPORT DATE 8. OTHER FACILITIES INVOLVED ISEQUENTIAL REV FACILITY NAME DOCKET NUMBER.

MONTH DAY Y YEAR NUMBER [ N MONTH DAY YOEAR 01 25 2012 2012 - S02 - 00 03 122 12012

9. OPERATING MODE 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)

[1 20.2201(b) El 20.2203(a)(3)(i) El 50.73(a)(2)(i)(C) E] 50.73(a)(2)(vii)

E] 20.2201(d) El 20.2203(a)(3)(ii) E] 50.73(a)(2)(ii)(A) E] 50.73(a)(2)(viii)(A)

El 20.2203(a)(1) El 20.2203(a)(4) [] 50.73(a)(2)(ii)(B) [1 50.73(a)(2)(viii)(B)

-- 20.2203(a)(2)(i) E] 50.36(c)(1)(i)(A) E] 50.73(a)(2)(iii) El 50.73(a)(2)(ix)(A)

10. POWER LEVEL El 20.2203(a)(2)(ii) E] 50.36(c)(1)(ii)(A) [] 50.73(a)(2)(iv)(A) El 50.73(a)(2)(x)

El 20.2203(a)(2)(iii) [] 50.36(c)(2) [] 50.73(a)(2)(v)(A) Z 73.71 (a)(4) 100 E] 20.2203(a)(2)(iv) E] 50.46(a)(3)(ii) [] 50.73(a)(2)(v)(B) El 73.71(a)(5)

E] 20.2203(a)(2)(v) El 50.73(a)(2)(i)(A) El 50.73(a)(2)(v)(C) [ OTHER Specify in Abstract below E] 20.2203(a)(2)(vi) El 50.73(a)(2)(i)(B) El 50.73(a)(2)(v)(D) orpin NRC Form 3BrA

12. LICENSEE CONTACT FOR THIS LER FACILITY NAME TELEPHONE NUMBER (Include Area Code)

Lloyd Zerr, Compliance Engineer, Regulatory Compliance (440) 280 - 5274.

14. SUPPLEMENTAL REPORT EXPECTED El YES (If yes, complete EXPECTED SUBMISSION DATE).

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)

On January 25, 2012, at 1350 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.13675e-4 months <br />, Perry Nuclear Power Plant (PNPP) Site Protection Section (SPS) personnel determined that the analysis of a safeguards system failed to identify a potential vulnerability that could have allowed unauthorized or undetected access to the protected area for which sufficient compensatory measures had not been employed prior to discovery. All identified vulnerabilities were promptly compensated at the time of discovery.

The cause of this event was determined to be that management failed to ensure adequate reviews and implementation of regulatory and industry guidelines regarding unattended openings. Actions taken were insufficient to ensure that regulatory requirements were met. Also, SPS management did not ensure a complete response to the October 2007 NRC non-cited violation for the failure to periodically check appropriate exterior areas. Other contributing causes were identified and are included in the report.

Corrective actions include developing a program to address unattended openings and establishing processes that formalize security specific operating experience. The programs will include validation that unattended openings and traversable protected area pathways have been identified, assessed, and appropriate measures have been put in place. A corrective action was also created to track completion of the final solutions for unattended pathways in the corrective action program.

This is a safeguards event described in paragraph 1(c) of 10 CFR 73, Appendix G. This event is being reported in accordance with 10 CFR 73.71 (a)(4) and 10 CFR 73, Appendix G, section 1(c) which requires NRC notification within one hour of discovery, followed by a written report within 60 days.

NRC FORM 366 (10-2010)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (10-2010) LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FACILITY NAME 2. DOCKET 6. LER NUMBER 3. PAGE SEQUENTIAL REV YEAR NUMBER NO.

Perry Nuclear Power Plant, Unit 1 05000-440 2 O2F4 2012 -- S02 -- 00 NARRATIVE INTRODUCTION On January 25, 2012, at 1350 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.13675e-4 months <br />, Perry Nuclear Power Plant (PNPP) Site Protection Section (SPS) personnel determined that the analysis of a safeguards system failed to identify a potential vulnerability that could have allowed unauthorized or undetected access to the protected area for which sufficient compensatory measures had not been employed prior to discovery. All identified vulnerabilities were promptly compensated at the time of discovery.

The power plant was operating in MODE 1 (i.e., Power Operation) at 100 percent rated thermal power at the time of this event. At 1413 hours0.0164 days <br />0.393 hours <br />0.00234 weeks <br />5.376465e-4 months <br />, a notification was made to the NRC Operations Center (ENS Number 47621) in accordance with 10 CFR 73.71 (a)(4) which requires a one hour report for any failure, degradation, or discovered vulnerability in a safeguard system that could allow unauthorized or undetected access to a protected area, material access area, controlled access area, vital area, or transport for which compensatory measures have not been employed.

This is a safeguards event described in paragraph I(c) of 10 CFR 73, Appendix G. This event is being reported in accordance with 10 CFR 73.71 (a)(4) and 10 CFR 73, Appendix G, section 1(c) which requires NRC notification within one hour of discovery, followed by a written report within 60 days.

EVENT DESCRIPTION Due to an increasing number of industry operating experience events regarding unattended openings not meeting 10 CFR 73.55 regulations, a reevaluation of unattended pathways was directed to ensure compliance with the regulatory requirements.

On January 12, 2012, PNPP SPS personnel started the reevaluation of the PNPP's physical protection program requirements regarding unattended openings. During this reevaluation, the underground pathways surveillance method and frequency were questioned and a condition report was initiated.

While resolving these issues, conservative compensatory measures were implemented.

On January 17, 2012, PNPP SPS personnel identified that surveillance frequencies for some unattended openings were insufficient to detect and prevent unauthorized access to the protected area.

As a direct result of the review, a 24-hour Reportable Events Log entry was recorded due to uncertainty in meeting identified task times defined by the NRC endorsed guidance in NEI 09-05, "Guidance on the Protection of Unattended Openings that Intersect a Security Boundary." Additional compensatory measures were implemented and a condition report was initiated.

During the condition report investigation, additional extent of condition concerns were identified. On January 25, 2012, at 1350 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.13675e-4 months <br />, with the plant operating in MODE 1 at 100 percent rated thermal power, itwas determined that the existing analysis of a safeguards system failed to identify a potential vulnerability that could have allowed unauthorized or undetected access to the protected area for which sufficient compensatory measures had not been employed prior to discovery.

NRC FORM 366A (10-2010)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (10-2010) LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FACILITY NAME 2. DOCKET 6. LER NUMBER 3. PAGE ITSEQUENTIAL REV YEAR NUMBER NO.

Perry Nuclear Power Plant, Unit 1 05000-440 - 30F4 2012 -- S02 -- 00 NARRATIVE On January 25, 2012, at approximately 1413 hours0.0164 days <br />0.393 hours <br />0.00234 weeks <br />5.376465e-4 months <br />, PNPP made a one-hour report to the NRC in accordance with 10 CFR 73.71(a)(4). The one hour reportable event was based on the discovery of additional protected area pathways/openings that did not meet regulatory requirements. Specifically, 10 CFR 73.55(i)(5)(iii) requires that unattended openings that intersect a security boundary such as underground pathways must be protected by a physical barrier and monitored by intrusion detection equipment or observed by security personnel at a frequency to detect exploitation.

CAUSE OF EVENT The cause of this event was determined to be that management failed to ensure adequate reviews and implementation of regulatory and industry guidelines regarding unattended openings. Actions taken were insufficient to ensure that regulatory requirements were met. Also, SPS management did not ensure a complete response to the October 2007 NRC non-cited violation for the failure to periodically check appropriate exterior areas.

Other contributing causes were determined to be that a formal process was not in place for the review of security-related NRC and industry guidance documents to ensure the necessary rigor is applied to the evaluation and implementation of required/recommended actions. Also, less than adequate rigor was applied to procedure changes made to address unattended pathway issues; SPS training did not address the purpose for the unattended pathway inspection criteria or method of monitoring; and no program guidance existed for control of security delay barriers.

EVENT ANALYSIS This event had minimal safety significance to nuclear safety. There were no known actual consequences that occurred as a result of this event, and no abnormal conditions were identified upon inspection of each protected area pathway/opening. However, this event has regulatory significance in that management of unattended openings did not meet regulatory requirements. No safety systems were directly or indirectly impacted or threatened.

PNPP utilizes a proprietary on-site security force. No Local, State, or Federal law enforcement agencies were contacted regarding the event and there was no press release.

CORRECTIVE ACTIONS Immediate compensatory actions were implemented for the identified deficiencies. Corrective actions were created to address several programmatic issues. For example, a corrective action was initiated to create a program for control and monitoring of unattended openings based on the guidance in NEI 09-05, "Guidance on the Protection of Unattended Openings that Intersect a Security Boundary." This will also include validation that traversable protected area pathways have been identified, assessed, and appropriate measures are in place. A corrective action was created to track completion of the final solutions for unattended pathways in the corrective action program.

The "Security Operating Experience Guideline," will be revised to include a required review of new and revised security-related NRC and industry guidance documents. Additionally, a review will be conducted of the NRC and industry security-related documents for the past five years in order to validate and document PNPP's compliance.

NRC FORM 366A (10-2010)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (10-2010) LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FACILITY NAME 2. DOCKET 6. LER NUMBER 3. PAGE SEQUENTIAL REV YEAR NUMBER NO.

Perry Nuclear Power Plant, Unit 1 05000-440 4 OF 4 2012 -- S02 -- 00 NARRATIVE Other corrective actions include performing self-assessments, developing and providing training, and making procedure changes to address the unattended openings shortcomings. The lessons learned will be shared with PNPP SPS personnel, management, and other FENOC facilities.

PREVIOUS SIMILAR EVENTS A search of Licensee Event Reports and corrective action program documents for the last three years at the PNPP did not identify any similar issues prior to this event. However, the root cause investigation did identify a similar occurrence in 2007.

On October 26, 2007, the NRC completed a security baseline inspection at the PNPP and a green non-cited violation was identified as a result of failing to periodically check appropriate exterior areas of the protected area to detect and deter the presence of unauthorized personnel. The immediate response by the PNPP SPS personnel failed to identify all unattended pathways, and as a result, the surveillance monitoring implemented in response to this non-cited violation was not complete.

The condition report investigation was focused on the issue with surveillance frequency of the affected unattended openings. The investigation did not recognize that monitoring methods were not employed in all needed locations; that the drawing review did not include all applicable drawings and configuration update notices; and that a corrective action was written to allow closure to a notification and did not provide for long-term tracking in the Corrective Action Program for the final solutions intended to resolve the unattended opening issue.

The previous event was similar in nature and the associated investigation and corrective actions were narrowly focused. The investigation and corrective actions should have been sufficiently rigorous to prevent the condition documented in this report.

COMMITMENTS There are no regulatory commitments contained in this report. Actions described in this document represent intended or planned actions, are described for the NRC's information, and are not regulatory commitments.

NRC FORM 366A (10-2010)