ML14181A860
| ML14181A860 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/06/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14181A858 | List: |
| References | |
| 50-261-96-13, NUDOCS 9612230372 | |
| Download: ML14181A860 (10) | |
See also: IR 05000261/1996013
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION 11
Docket No:
50-261
License No:
Report No:
50-261/96-13
Licensee:
Carolina Power & Light Company
Facility:
H. B. Robinson Unit 1
Location:
2112 Old Camden Rd.
Hartsville, SC 29550
Dates:
November 4-8, 1996
Inspector:
D. H. Thompson, Safeguards Inspector
Approved by:
P. Fredrickson, Chief, Special Inspection Branch
Division of Reactor Safety
ENCLOSURE 2
9612230372 961206
ADOCK 05000261
G
EXECUTIVE SUMMARY
H. B. Robinson Power Plant, Unit 1
NRC Inspection Report 50-261/96-13
This routine announced inspection was conducted in the area of plant support by a regional
safeguards specialist. The specific area evaluated was the Physical Security Program for
Power Reactors.
The inspector determined that the licensee employed compensatory measures when
security equipment has failed or its performance has been impaired. The inspector
also noted that the compensatory measures that were employed did not reduce the
effectiveness of the security system that existed prior to the failure. Section (S.1.1).
Through observations, interviews, and documentation review, the inspector concluded
that the licensee's central and secondary alarm stations (CAS/SAS) were equipped to
support the site security function. Plans and procedures were provided which
contained clear guidance and the CAS/SAS operators were aware of performance
requirements. (Section S2.2).
Implementation of protected area access control of personnel was less than effective
because of the potential for authorized personnel to allow protected area access to
unauthorized personnel without the security force's knowledge. One violation of
regulatory requirements was noted (96-13-01). (Section S2).
The inspector determined that Security Procedure - 12 provided adequate guidance
for the security force to perform required testing on security equipmenty, however;
during discussion with security management and the shift supervisors, the inspector
noted that the licensee had not included in the procedure a checklist for recording the
performance test (30/30) results that are required to be performed quarterly; after
each inoperative state; or after major maintenance or repair to a security system.
This test is conducted to determine the ability of the equipment to detect individuals'
attempting to gain unauthorized entry.
The Training and Qualification program continued to be well managed and record
keeping continued to be a strength. The inspector noted that the annual test was
within requirements; however, to improve the security officer's knowledge the test
could be more specific of tasks to be performed to better evaluate the officers
knowledge of post and patrol requirements. (Section S6).
REPORT DETAILS
S1
Conduct of Security and Safeguards Action
S1.1
Compensatory Measures
a.
Inspection Scope (81700)
The inspector verified that the licensee employed compensatory measures when
security equipment failed or its performance had been impaired and that the
compensatory measures employed do not reduce the effectiveness of the security
system that existed prior to the failure.
b.
Observations and Findings
The inspector observed an officer posted as a compensatory measure for access
control on November 7, 1996 and determined that the officer was knowledgeable of
the reason for the compensatory measure and the required duties to be performed.
Events that required compensatory measures to be implemented were reviewed and
the inspector noted that in each event timely and adequate compensatory measures
were established. Procedures clearly defined the duties and responsibilities for
compensatory officers.
c.
Conclusion
The inspector determined that the licensee employed compensatory measures when
security equipment has failed or its performance has been impaired. The inspector
also noted that the compensatory measures that were employed did not reduce the
effectiveness of the security system that existed prior to the failure.
S2
Status of Security Facilities and Equipment
S2.2
Central and Secondary Alarm Station Operations
a.
Inspection Scope (81700)
The inspector evaluated the licensee's program for central alarm station (CAS)
operations and secondary alarm station (SAS) operations. This was to ensure that
the CAS/SAS was capable of responding to provide reliable physical protection of vital
equipment and that the licensee was in compliance with the criteria in Chapter 6 and
7 of the Industrial Security Plan (ISP), in addition to Security Procedure (SP-004),
Guard/Watchperson Duties, Responsibilities and Procedures, Revision 22, dated
March 13, 1996. The inspector evaluated the CAS/SAS operators on their specific
duties on November 4, 5, and 7, 1996.
2
b.
Observations and Findings
The inspector noted that the alarm station operators were provided procedures that
detailed specific guidance for contingencies or emergency situations and that the
alarm station operators were capable of performing their duties during normal day-to
day operation, and contingency operations.
c.
Conclusions
Through observations, interviews, and documentation review, the inspector concluded
that the licensee's CAS/SAS were equipped to support the site security function. The
licensee had prepared plans and procedures to detail the performance requirements
for the officers performing CAS/SAS duties. The operators were aware of the
guidance and the CAS/SAS operators were capable of performing their duties.
S2
Status of Security Facilities and Equipment
S2.1
Protected and Vital Area Access Controls - Personnel and Vehicles
a.
Inspection Scope (81700)
Based on the commitments in Chapters 1, 3, 5 and 6 of the current ISP, and Security
Procedures (SP)-003, Personnel Introduction, Revision 9, dated July, 19, 1996;
SP-005, Searches, Incoming Packages and Material Control, Revision 13, dated
September 3, 1996; SP-007, Access Control, Personnel Identification, and Badging,
Revision 47, dated August 16, 1996; and SP-008, Vehicular Access Control, Revision
21, November 5, 1996; the inspector evaluated the licensee's access control program
for protected/vital areas to verify that they were functionally effective, operationally
efficient and met licensee commitments. This evaluation was also to ensure that
there were no vulnerabilities that could be exploited to gain unauthorized access to
the protected and vital areas.
b.
Observation and Findings
The security force searched for firearms, explosives, and incendiary devices at the
protected area entrance. Personnel, hand-carried packages or material, delivered
packages or material, and vehicles were searched before being admitted to the
protected and vital areas. These searches were either by physical search or by
search equipment. Security personnel are responsible for searching materials which
are off loaded outside the protected area. Security personnel searched all non
exempt delivered packages and materials, specifically designated as such by the
licensee, outside the vital areas.
The inspector found the following circumstances concerning personnel access control.
The licensee has installed an acceptable hand geometry as an access control feature
to allow access at the protected area. Based on the inspector's review, determination
was made that the final access control (FAC) officer may have additional duties that
would preclude him from performing the primary duties as an access control monitor.
3
The inspector requested the Nuclear Assessment Section (NAS) to conduct a drill to
determine if the officer in the hardened enclosure charged with the duties of
controlling access to the PA was capable of detecting unauthorized access. On
November 7, 1996, at approximately 6:20 a.m. the inspector observed a NAS person
badge and use the hand geometry equipment to gain access to the PA. After the
NAS person was authorized access, the individual moved out of the area and allowed
another NAS individual to gain unauthorized access to the PA. The licensee's
security force failed to detect the unauthorized individual accessing into the PA. The
factors that contributed to the FAC officer in the hardened bullet resistant enclosure
failing to detect the unauthorized act was due to the location of the officer and the
numerous other duties that the officer was required to perform, which detracted from
his primary duties of controlling access. The licensee immediately established
compensatory measures and were in the process of reviewing possible corrective
actions for the deficiency.
Industrial Security Plan (ISP), Revision 32, dated April 26, 1996, Paragraph 1.6.2,
states that "turnstiles are located in the Personnel Access Points (east and west) and
are controlled by members of the security force from within bullet resistant structures."
Security Procedure - 003, Personnel Indoctrination, Revision 9, July 19, 1996,
paragraph 3.1.11 requires that personnel be alert to unauthorized. "tailgaters"
Paragraph 5.0 of the same procedure states that the security program ensures that
unauthorized persons cannot enter undetected into the protected or vital areas.
Security Procedure - 007, Access Control, Personnel Identification, and Badging,
Revision 47, dated August 16, 1996, Paragraph 6.1.1.2 states that personnel access
to the protected area (PA) will normally be controlled by electrically operated turnstiles
or gates. Access through the tumstile is normally accomplished by inserting a badge
into the cardreader and placing the user's hand in a hand geometry reader for
verification. If the security computer indicates that the badge data in the computer
matches the user's hand, the locking device on the tumstile will release allowing
access. Access into the PA is monitored by a member of the security force who is
located in the Access Control Station (ACS).
Access control program records were available for review and contained sufficient
information for identification of persons authorized access to the protected/vital areas.
c.
Conclusion
This evaluation of the access controls for personnel and vehicles revealed that the
criteria in Chapters 1, Paragraph 1.6.2 which states that "tumstiles located in the
personnel access points (east and west) and are controlled by members of the
security force from within bullet resistant structures," and the criteria of SP-007 which
states that "access into the PA is monitored by a member of the security force who is
located in the Access Control Station (ACS)" were not being met and is a violation of
regulatory requirements. (96-13-01). (Section S2)
4
S2.4
Testing and Maintenance
a.
Inspection Scope (81700)
The inspector verified that the licensee implements programs that will ensure the
reliability of physical protection-related equipment and security-related devices
including proper installation, testing and maintenance to promptly replace defective
equipment.
b.
Observations and Findings
The inspector reviewed the licensee's Security Procedure 12, Revision 44, dated
September 13, 1996, Verification of Security Component Operation, Chapter 12, Test,
Inspections, and Maintenance of the current ISP, Security Procedure (SP-12),
Revision 45, dated September 13, 1996 and Security Procedure (SP-021), Security
System Tamper and Line Supervision Test, provides the guidance for the scheduling,
documentation, and performance of inspections, maintenance, and testing of physical
security system.
In the procedures the licensee requires that the senior member of the security force,
upon notification of a discrepancy in the Intrusion Detection System, CCTV, Access
Control System, physical barriers, or other security component, to provide proper
compensatory measures, report the deficiencies and to request maintenance support
to fix the system.
Security Procedure 12 requires that an operability test be performed by making less
than 30 attempts to test a system detection capability, daily and weekly. The
procedure also states that performance tests are required to be conducted quarterly,
after each inoperative state, or after major maintenance or repair to a security system.
This test is conducted to determine the ability to detect individuals attempting to gain
unauthorized entry. The inspector reviewed the licensee's log entries to determine if
the 30/30 test was being conducted as required. The inspector determined that the
test could have been conducted as required; however, it was very difficult to
determine that the testing was accomplished through review of the logs, computer
print-outs and maintenance records. The licensee agreed and stated they would
create a form to log the 30/30 tests as they were accomplished. The form has been
created and included as part of the procedure.
The inspector reviewed the licensee's corrective action for violation 50/261/96-03-01,
and determined that the licensee as part of the corrective action had revised Security
Procedure (SP)-012, 'Verification of Security Component Operation", on February 29,
1996, to include the 30 consecutive tests for hand geometry. The hand geometry
units were successfully tested in accordance with SP-12 on March 1, 1996, and the
test results were included in the modification installation documentation.
Additionally as part of the corrective action the individuals involved in the engineering
aspects of this issue were counseled regarding the adequacy of reviews of
modifications which involve changes to the licensing basis of the plant.
_
5
c.
Conclusion
The inspector determined that SP-12 provided adequate guidance for the security
force to perform the required test; however, during discussion with security
management and the shift supervisors; the inspector noted that the licensee had not
included in the procedure a checklist for recording the performance test results that
are required to be performed quarterly; after each inoperative state; or after major
maintenance or repair to a security system. This test is conducted to determine the
ability of the equipment to detect individuals attempting to gain unauthorized entry.
S5
Security Safeguards Staff Training and Qualification
S5.1 Security Traininq and Qualification
a.
Inspection Scope (81700)
Based on the Training and Qualification (T&Q) Plan, Revision 5, September 29, 1993,
the inspector verified that before being permitted to act as a guard, watchperson,
armed response person, or member of the security organization, such individuals have
been trained, equipped and qualified to perform each assigned security-related job
task or duty in accordance with the approved T&Q Plan.
The inspector interviewed a sample of physical security personnel to determine if they
possess adequate knowledge and ability to carry out their assigned duties and
responsibilities.
The inspector verified during the inspection that the total number of trained officers
and armed personnel were immediately available at the facility to fulfil the response
role.
b.
Observation and Findings
The inspector verified through interviews and observation of officers performing their
duties that they were trained and qualified to perform their task as required. The
officers were observed performing patrol, CAS/SAS, access control, vehicle search
and compensatory duties.
The inspector noted that the individuals were properly armed and qualified as
necessary every 12 months. The inspector noted that the officers fire a combat
course both day and night. Hand gun qualification is 75%. Shotgun qualification is
50% of all pellets (36 of 72 pellets) within the black silhouettes. The semiautomatic
rifle qualification score is 80% of the total obtainable score which is 200 out of a
possible total of 250.
6
While reviewing the annual written examinations the inspector note that the exams
were not detailed in the specific task areas being evaluated, i.e., exams on response
duties contained more questions on access control or searching than on response
force duties. The licensee agreed to review the exams and make changes as
necessary.
c.
Conclusion
The Training and Qualification program continues to be well managed and records
keeping continues to be a strength. The inspector noted that the annual tests were
within requirements, however; to better evaluate the security officers knowledge on
post and patrol requirements the tests could be more specific to the task to be
performed. (Section S6).
S8
Miscellaneous Security and Safeguards Issues
Actions on Previous Inspection Findings (92904)
(CLOSED) VIO 50-261/96-03-01. The licensee's corrective action, as described in
Section S2.4 closes this violation.
(CLOSED) VIO 50-261/96-03-02. The licensee's corrective action for the failure to
control safeguards information was reviewed by the inspector. The licensee had
modified the control of safeguards procedures, implemented an aggressive review of
safeguards material to declassify material not considered safeguards, reduced the
number of areas for storage of safeguards material, placed stringent controls on
access to safeguards material, and developed one of the best training films that the
inspector has reviewed to train employees on the handling, storage and marking of
safeguards information.
(CLOSED) VIO 50-261/96-10-02. The licensee's corrective action for the failure to
maintain at least 0.2 footcandles of lighting under two railcars was reviewed and
considered adequate to close the violation. The licensee had taken disciplinary action
on the personnel involved, and revised the security procedures to include
compensatory measures in the event that illumination decreases below the
established requirements. The security force lesson plans were revised and training
was conducted to highlight that security officers maintain cognizance of the area
illumination.
7
Management Meetings
X1
Exit Meeting Summary
The inspector presented the inspection results to members of licensee management
at the conclusion of the inspection on November 8, 1996. The licensee acknowledged
the findings presented.
The inspector asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was
identified.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
H. Chernoff, Regulatory Programs
T. Eaddy, Jr., Superintendent Engineering and Chemical
A. Geanoa, Project Analyst Licensing
J. Harriston, Nuclear Assessment Section
P. Jenny, Nuclear Assessment Section
J. Morris, Superintendent l&C/Electrical Maintenance
O B.
Myer, Manager Operations
R. Newman, Peer Assessor, Nuclear Assessment Section
D. Taylor, Controller
R. Warden, Manager Nuclear Assessment Section
S. Young, Superintendent Security
NRC
J. Zeiler, Resident Inspector
INSPECTION PROCEDURES USED
IP 81700:
Physical Security Program for Power Reactors
8
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
e
Item Number
Status
Description and Reference
50-390/96-13-01
Open
Failure to Properly Control Access to the
Protected Area.
Closed
e
Item Number
Status
Description and Reference
50-390/96-03-01
Closed
Failure to Properly Test Newly Installed
Equipment.
50-390/96-03-02
Closed
Failure to Properly Control Safeguards
Information
50-390/96-10-02
Closed
Failure to Maintain Proper Lighting