ML020450141

Unplug Salem Campaign E-Mail Oyster Creek Osre

ML020450141
Person / Time
Site:	Salem, Oyster Creek, Hope Creek
Issue date:	01/09/2002
From:	Cohen N Coalition For Peace & Justice, UNPLUG Salem Campaign
To:	Robert Fretz NRC/NRR/DLPM
Fretz, R, NRR/DLPM, 415-1324
References
TAC MB2941
Download: ML020450141 (17)

Text

From: Norman Cohen <ncohen12@home.com>

To: Robert Fretz <RXF@nrc.gov>

Date: Wed, Jan 9, 2002 5:53PM

Subject:

[Fwd: Oyster Creek OSRE]

Hi Bob Attached is the OSRE report on Oyster Creek. Please add that to our submissions.

I will be emailing a few other documents tonite, and thee main documents by Friday.

Thanks Norm Coalition for Peace and Justice and the UNPLUG Salem Campaign; 321 Barr Ave., Linwood, NJ 08221; 609-601-8537 or 609-601-8583 (8583: fax, answer machine);

ncohen12@home.com UNPLUG SALEM WEBSITE: http://www.unplugsalem.org/ COALITION FOR PEACE AND JUSTICE WEBSITE: http:/www.coalitionforpeaceandjustice.org The Coalition for Peace and Justice is a chapter of Peace Action.

"First they ignore you; Then they laugh at you; Then they fight you; Then you win. (Gandhi)

"Why walk when you can fly?" (Mary Chapin Carpenter)

Mail Envelope Properties (3C3CC9ED.CDD : 13 : 36061)

Subject:

[Fwd: Oyster Creek OSRE]

Creation Date: Wed, Jan 9, 2002 5:43PM From: Norman Cohen <ncohen12@home.com>

Created By: ncohen12@home.com Recipients nrc.gov owf4_po.OWFN_DO RXF (Robert Fretz)

Post Office Route owf4_po.OWFN_DO nrc.gov Files Size Date & Time MESSAGE 714 Wednesday, January 9, 2002 5:43 PM Mail Mime.822 136568 Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed

Subject:

No Security: Standard

From: "Dave Lochbaum" <dlochbaum@ucsusa.org>

To: <ncohen12@home.com>

Date: Mon, Aug 13, 2001 5:10PM

Subject:

Oyster Creek OSRE Hello Norm:

When I replied to your inquiry this morning, I didnt know the results from the latest OSREs at Salem, Hope Creek, or Oyster Creek. This afternoon, I got on ADAMS and found the recent report for Oyster Creek. It is attached.

Apparently, the NRC observed four (4) force-on-force tests. On one of those tests, the security responders were unable to prevent the simulated instruders from destroying all of the equipment necessary to cool the reactor core. According to the interim crayon guide in use by the NRC, this means that a GREEN crayon cannot be used. Itll probably be the WHITE crayon.

Thanks, Dave Mail Envelope Properties (3C3CC9ED.CDE : 14 : 36062)

Subject:

Oyster Creek OSRE Creation Date: Mon, Aug 13, 2001 5:10PM From: "Dave Lochbaum" <dlochbaum@ucsusa.org>

Created By: dlochbaum@ucsusa.org Recipients home.com ncohen12 Post Office Route home.com Files Size Date & Time MESSAGE 624 Monday, August 13, 2001 5:10 PM OC-OSRE-2001.pdf 96712 Header 1245 Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed

Subject:

No Security: Standard

June 22, 2001 EA-01-141 Mr. Ronald J. DeGregorio Vice President, Oyster Creek AmerGen Energy Company, LLC P.O. Box 388 Forked River, New Jersey 08731

SUBJECT:

OYSTER CREEK GENERATING STATION - NRC INSPECTION REPORT 05000219/2001-011

Dear Mr. DeGregorio:

On May 10, 2001, the NRC completed an Operational Safeguards Response Evaluation (OSRE) at your Oyster Creek power reactor facility. The enclosed report presents the results of that evaluation. The preliminary results of this inspection were discussed on May 10, 2001, with you and other members of your staff. Subsequently, a final exit was conducted with you and members of your staff by telephone conference on May 30, 2001.

This evaluation was an examination of activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. Within these areas, the evaluation consisted of a selective examination of physical security plans, procedures and representative records; review and walk-down of selective portions of the Oyster Creek facility; conduct of table-top exercises; examination and review of target sets; observations of force-on-force response exercises and exercise critiques; observation of firearms proficiency by security officers; and interviews with selected personnel.

Based on the results of this inspection, one preliminary finding of low to moderate safety significance was identified. On May 8-9, 2001, the NRC OSRE team observed and evaluated four force-on-force exercises. In one force-on-force exercise, your response strategy was insufficient to successfully interdict an adversary force. Consequently, there was a loss of a complete target set that was necessary to prevent or mitigate core damage. In this particular force-on-force exercise, your response strategy was considered inadequate. We understand that you have implemented compensatory measures and subsequently initiated review of this matter to determine corrective measures. Notwithstanding this performance strategy issue, all other evaluated elements of your physical protection system were considered acceptable.

We applied the Interim Physical Protection Significance Determination Process to establish the safety bearing and importance of this issue. The circumstances were such that the demonstrated failure to protect a complete target set in a force-on-force exercise may be viewed as having a credible impact on safety, and a reasonable precursor to a significant event.

The issue impacts the Physical Protection Cornerstone relative to the intended function of the physical protection system with regard to performance, design, and implementation. The preliminary finding involved a required safeguards contingency response in a force-on-force exercise in which there was the loss of at least one complete target set; and the loss was not

Mr. Ronald J. DeGregorio the result of a broad programmatic problem with the physical protection system. Accordingly, the finding was assessed to have low to moderate safety significance, and is presently considered as a preliminary WHITE finding pending a final significance determination. In accordance with Enforcement Guidance Memorandum (EGM) 01-001, no enforcement action is being considered in this matter since the finding was revealed through the conduct of a force-on-force exercise.

We believe we have sufficient information to make a final significance determination for this finding. However, in accordance with the current NRC Enforcement Policy, you may provide a written statement of your position on the significance of this finding, including any supporting information or reference to previously submitted material. You may also request a Regulatory Conference to present your own assessment and evaluation of this matter for the consideration of the NRC staff. A Regulatory Conference on this matter would be closed to public observation because Safeguards Information may need to be discussed, and it is required to be protected in accordance with 10 CFR 73.21.

Please contact Mr. John R. White at (610) 337-5114 within 7 days of the date of this letter to notify the NRC of your intentions in this matter. If a response is not received within 10 days, excepting a granted extension, we will continue with our significance determination process and subsequently inform you of our final significance determination.

In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).

We appreciate your cooperation. Please contact Mr. White if you have any questions regarding this letter.

Sincerely,

/RA/

Wayne D. Lanning, Director Division of Reactor Safety Docket No. 05000219 License No. DPR-16

Enclosure:

NRC Inspection Report No. 05000219/2001-011

Mr. Ronald J. DeGregorio cc w/encl:

AmerGen Energy Company - Correspondence Control Desk J. A. Benjamin, Licensing - Vice President, Exelon Corporation J. A. Hutton, Director-Licensing Manager, Nuclear Safety and Licensing R. Brown, Manager, Experience Assessment R. Shadis, New England Coalition Staff State of New Jersey

Mr. Ronald J. DeGregorio Distribution w/encl:

Region I Docket Room (with concurrences)

L. Dudes, DRP - NRC Resident Inspector H. Miller, RA J. Wiggins, DRA J. Rogge, DRP N. Perry, DRP W. Kane, NRR B. Sheron, NRR D. Dambly, OGC S. Figueroa, OE D. Holody, EO, RI R. Urban, ORA, RI F. Congel, OE (OEMAIL)

V. Ordaz, NRR (RidsNrrDipmRss)

P. Hiland, OEDO E. Adensam, NRR (RidsNrrDlpmLpdi)

H. Pastis, PM, NRR T. Colburn, Backup PM, NRR R. Schaaf, Alt PM, NRR W. Lanning, DRS J. White, DRS G. Smith, DRS D. Orrik, NRR DOCUMENT NAME: G:\RSSB\SMITH\OC2001-011OSRE REV4.WPD After declaring this document An Official Agency Record it will be released to the Public.

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RI/DRS RI/DRP HQ/NRR RI/DRS RI/DRS NAME GSmith JRogge VOrdaz (ViaPhone) JWhite WLanning (J. Arildsen for)

DATE 06/21/01 06/21/01 06/19/01 06/21/01 06/22/01 OFFICIAL RECORD COPY

Summary of Findings IR 05000219-01-011; on 5/7-10/2001; Oyster Creek Generating Station; Operational Safeguards Response Evaluation.

The inspection was conducted by two NRC Region I Safeguards/Security inspectors, one Nuclear Reactor Regulation Safeguards Specialist, and three contractors. The inspection identified one preliminary White finding of low to moderate safety significance. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609 Significance Determination Process (SDP). Findings for which the SDP does not apply are indicated by No Color or by the severity level of the applicable violation. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described at its Reactor Oversight Process website at http://www.nrc.gov/NRR/OVERSIGHT/index.html.

A. Inspector Identified Findings Cornerstone: Physical Protection

 Preliminary White. During the conduct of a force-on-force exercise, the licensees security response strategy was insufficient to successfully interdict an adversary force.

Consequently, there was a presumed loss of a complete target set that was necessary to prevent or mitigate core damage. Accordingly, the physical protection response strategy for this specific circumstance was considered inadequate.

This finding was considered to be of low to moderate safety significance because the demonstrated failure to protect a complete target set in a force-on-force exercise may have a credible impact on safety and may be a reasonable precursor to a significant event. The preliminary finding involved a required safeguards contingency response in a force-on-force exercise in which there was the loss of at least one complete target set; and the loss was not the result of a broad programmatic problem with the physical protection system. In accordance with Enforcement Guidance Memorandum (EGM) 01-001, no enforcement action is being considered in this matter since the finding was revealed through the conduct of a force-on-force exercise. (Section 40A5)

U. S. NUCLEAR REGULATORY COMMISSION REGION I Docket No: 05000219 License No: DPR-16 Report No: 05000219/2001-011 Licensee: AmerGen Energy Company, LLC Facility: Oyster Creek Generating Station Dates: May 7 - 10, 2001 Inspectors: Gregory C. Smith, Senior Security Inspector (Team Leader)

Paul R. Frechette, Security Inspector David Orrik, Reactor Safeguards Specialist (NRR)

NRC Contractors (3)

Approved by: John R. White, Chief Radiation Safety and Safeguards Branch Division of Reactor Safety

Report Details

3. Safeguards Cornerstone: Physical Protection 4OA5 Operational Safeguards Response Evaluation (OSRE)(81110)

.1 Management Overview of Protective Strategy (81110-02.01)

a. Inspection Scope The inspectors met with the licensee and security contractor management to review:

(1) the licensees fundamental strategy to protect against the design basis threat, in accordance with the requirements of 10 CFR 73.1; (2) armed response force manning levels, in accordance with the NRC-approved Physical Security Plan; (3) contingency equipment and deployment positions, in accordance with the NRC-approved Contingency Response Plan; and (4) plant operations participation in defining and validating the protective strategy.

b. Findings No findings of significance were identified.

.2 Preliminary and Onsite Target Analyses (81110-02.02)

a. Inspection Scope The initial target sets, as submitted by the licensee on April 9, 2001, were reviewed for completeness and technical acceptability. The NRC review was in-office and included assessment by Region I and the Office of Nuclear Regulation. Upon subsequent revision, the target sets were confirmed to be acceptable on May 7, 2001; and were documented in the Oyster Creek Target Set Listing.

b. Findings No findings of significance were identified.

2

.3 Protected and Vital Area Tour (81110-02.03)

a. Inspection Scope A tour of the Protected and Vital areas was conducted to assess and evaluate potential Protected Area entry points that could be used by an adversary force, including routes, barriers, and distances to various target sets and associated equipment. Response personnel deployment positions, locations of response equipment, physical protection systems, and firearms were reviewed. The design and location of various response force defensive positions were evaluated for adequacy.

b. Findings No findings of significance were identified.

.4 Table-Top Drills, Force-on-Force Exercises, and Licensee Exercise Critiques (81110-02.04)

a. Inspection Scope Table-top drills and force-on-force exercises were used to evaluate the sufficiency of the design, performance, and implementation of the physical protection system to protect against a design bases threat of radiological sabotage. The evaluation considered the specifications of the licensees Physical Security Plan, Tactical Defense Response Policy, and Target Set Listing; and assessed the licensees ability to effectively deploy the required number of appropriately armed and equipped security response officers to various tactical positions, within certain time limits, to interdict adversaries and prevent damage or loss of target sets. The evaluation included:

(1) the conduct of four table-top drills with appropriately qualified security personnel to assess the number of responders to be deployed, deployment positions, defensive strategy, and response times; (2) the observation of four force-on-force exercises to demonstrate the effectiveness of design, performance and implementation of the physical protection system; and, (3) observation of the licensees critique of each force-on-force exercise to determine the ability of the licensee to critically evaluate effectiveness, and identify problems in design, performance, or implementation of the physical protection system.

3

b. Findings On May 8-9, 2001, the NRC OSRE team observed and evaluated four force-on-force exercises. In one of the four force-on-force exercises, the response force was unsuccessful in effectively interdicting the mock adversary force and preventing the loss of a complete target set that was necessary to prevent or mitigate core damage. Based on this performance strategy failure, the NRC OSRE team was unable to confirm that the design of the physical protection system was sufficient to protect against a design basis threat of radiological sabotage.

The selection of the four force-on-force exercise scenarios was based, in part, on the information gained from the table top drills to verify the appropriateness of the response strategies and identify suspected vulnerabilities. This particular force-on-force scenario was selected due to a suspected vulnerability. Based on the actual outcome of this individual exercise, the OSRE team determined that: (1) the specific response strategy was flawed in that one component, of a two component target set, was initially left undefended, by design; and (2) the response strategy was such that the security officers assigned to defend one of the target set components could be neutralized, leaving both components of the target set vulnerable to damage or destruction by an adversary force. Accordingly, the relative ease with which the adversary force was able to damage or destroy both components of the target set indicated a performance flaw in response strategy and implementation for this particular target set.

The licensee identified in a May 18, 2001 submittal, that some exercise artificialities were possible contributors to the loss of the complete target set. For example, the failure of the drill controllers to simulate a door alarm which would have, presumably, alerted the response organization to probable loss of one of the two target set components; and the light glare in a fire door window which required the responder to leave his protected position and increase his vulnerability to gain a better shooting advantage on the adversary force. However, the NRC OSRE team observed that:

(1) there was radio communication between responders that should have provided sufficient indication that the one of the components was probably lost, even without the door alarm; and (2) the glare on the fire door window should not have been an issue, since even if the window was not in place, the responder would not have been in a protected defensive position.

The circumstances in this matter were such that the demonstrated failure to protect a complete target set in a force-on-force exercise may be viewed as having a credible impact on safety, and a reasonable precursor to a significant event. Exploitation of the strategy flaw by a real adversary could potentially subject the facility to core damage, absent effective operator intervention.

The issue impacts the Physical Protection Cornerstone relative to the intended function of the physical protection system with regard to performance, design, and implementation. The OSRE demonstrated that the strategy designed for the protection of this particular target set was not sufficient to provide high assurance of successful interdiction by responders. Further, performance errors by the responders (i.e., failure to stand-off from an explosive charge, and the presumption of protection behind a

4 hollow core door) was contrary to training, and led to the neutralization of the initial responders and loss of the target set component they were protecting.

Applying the Interim Physical Protection Significance Determination Process, the finding involved a required safeguards contingency response in a force-on-force exercise in which there was the loss of at least one complete target set. Given the observed good performance in all other aspects demonstrated during the OSRE (i.e., successful interdiction of adversaries and protection of the complete target sets in all other force-on-force exercises; the demonstrated training and qualification of the response organization, and the overall quality of the facilitys physical protection system), the weakness observed in this single force-on-force exercise does not appear to be the result of a broad programmatic problem with the physical protection system. Rather, the performance failure appears isolated to the protective strategy employed for this particular target set, and not specifically related to procedures or training.

Notwithstanding, the strategy flaw appears to be potentially predictable or repeatable, i.e., the flaw could be exploitable by an informed adversary, and result in possible loss of the target set.

Accordingly, the finding was assessed to have low to moderate safety significance, and is presently considered as a preliminary WHITE finding pending a final significance determination. In accordance with Enforcement Guidance Memorandum (EGM) 01-001, no enforcement action is being considered in this matter because the finding was revealed through the conduct of a force-on-force exercise. Upon identification, this issue was entered into the licensees corrective action program as CAP 02001-0796.

(FIN 05000219/2001-011-01)

.5 Tactical Training (81110-02.06)

a. Inspection Scope The tactical performance of the response officers, both individually and as a team, including command, control and communications, was observed during the onsite force-on-force exercises; and evaluated for its effectiveness.

b. Findings No findings of significance were identified.

.6 Firearms Training (81110-02.07)

a. Inspection Scope The firearms training was evaluated on May 9, 2001, by observing a live-fire demonstration by five armed response officers. The officers demonstrated firearms proficiency (safety, speed, and accuracy) on a tactical stress firing course that simulated actual in-plant response conditions and shooting situations. The firearms demonstration included firing from elevated positions and from behind barricades; and at fixed, moving and pop-up targets; and firing while wearing a respirator.

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b. Findings No findings of significance were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary The inspectors presented the preliminary inspection results to Mr. R. DeGregorio, Site Vice President, and other members of licensee management at the conclusion of the inspection on May 10, 2001. A final exit was conducted telephonically, with Mr. R.

DeGregorio and other members of licensee management, on May 30, 2001.

6 ATTACHMENT SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee R. DeGregorio Site Vice President D. LeQuia Director, Site Support R. Ewart Manager, Nuclear Security E. Harkness Plant Manager H. McNally Regional Manager, Nuclear Security R. Lane Exelon Security Director P. Scallon Manager, Nuclear Oversight M. Godknecht Plant Engineer L. Defbaugh Security Training Contractor - The Wackenhutt Corporation G. Shannon Project Manager R. Cogdell Director, Nuclear Operations NRC L. Dudes Senior Resident Inspector T. Hipschman Resident Inspector J. White Chief, Radiation Safety and Safeguards Branch G. Smith Senior Security Specialist P. Frechette Security Specialist D. Orrik Reactor Safeguards Specialist LIST OF ITEMS OPENED Opened 05000219/2001-011-01 FIN In an evaluated exercise (OSRE), the response strategy was insufficient to successfully interdict an adversary force. Based on this performance problem, the NRC OSRE team was unable to confirm that the design of the physical protection system was sufficient to protect against a design basis threat of radiological sabotage.

7 LIST OF INSPECTION PROCEDURES USED IP 81110 Operational Safeguards Response Evaluation LIST OF ACRONYMS OSRE Operational Safeguards Response Evaluation LIST OF DOCUMENTS REVIEWED Oyster Creek Physical Security Plan, Revision 41, April 19, 2001 Oyster Creek Target Set listing, May 7, 2001 Oyster Creek Tactical Defensive Response Policy 39, Revision A-02, May 7, 2001