ML17201M285

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Partially Deleted Response to Security Allegations RIII-88-0123 (Ref 10CFR73.21)
ML17201M285
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 12/02/1988
From: Bliss H
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML17201M283 List:
References
NUDOCS 8901180393
Download: ML17201M285 (8)


Text

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CommonweaA=dison One First National~ Chicago, Illinois Address Reply to: Post Ottlce Box 767 Chicago, Illinois 60690

  • 0767 Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Commission December 2, 1988

Subject:

Dresden Station Units 1, 2 and 3 Security All~gation e

I NRC Docket Nos.50-010. 231 and 50-249

  • Referepce (a):

Letter from C.E. N~r~iius to Cordell Reed dated October 14; 19~8.

Dear Mr. Davis:

Reference (a) informed Commonwealth Edison of a Security allegation received by the Nuclear Regulatory Commission, Region III (Ref: RIII-88"'-0123).

An investigation was performed and is contained in Attachment "'A.".

In ~ telephone conversation on October 21, 1988 between J. Silady, CECo, and J. Creed, NRC, the agreement of a forty-five (45) day response period for security allegations was confirmed.resulting in a response due date of December 2, 1988.

The attachment to this letter contains Safeguards Information as defined in 10 CFR 73.21.

Accord.ingly,.the inform?tion i'n the Attachment should be withheld.from public disclosure.

If you have any further questions regarding this matter, please direct them to Commonwealth Edison's Licensing Department.

Very truly yours,

. Bliss ing Manager lm 5367K SECURITY MARKING DOES HOT APPLY WHEN THIS LETTER IS SEPARATE FROM THE ENCLOSURE

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ALLEGATION REPORT #RIII-88~A-0123

. INTRODUCTION On September 7, 1988, the Dresden Statio~ Security Administrator was.

contacted via telephone by a Region III Safeguards Section Inspector.

The conversation swnmary* follows:

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stated that the NRC received an allegation that

~Door~as not being properly locked and/or alarmed.

The Security Administrator explained to the Inspector that Dresden's Door[illilis located within the**** Building and that there is no Door['~for the~!lll***llil The Inspec~or requested that a¥nvestigation of all {j****

~doors, as well as Door

  • ,Jbe conducted.

. Doors and Door~were inspected by knowledgeable security force personnel within fifteen (15) minutes of receiving the telephone inquiry and all of the doors were found to be functioning as established by procedure.

This information was transmitted* to the Inspector (supra) within one hour of his call.

On October 17, 1988, the Station Security Administrator received a telephone communication from the Region III Safeguards.Section advising the Station Security Administrator that a formal written report was being transmitted to Ores.den for response to the subject allegation.

The Inspector.

requested that the issue ~oncerning welded shut doors be addressed even though this concern would not be clearly indicated in the report.* The.Inspector offered to cl~rify this request after th~ Station's M~nagement h~d an opportunity to review the report.

NRC Allegation Report UII-88-A-0123 was received on October 24, 1988 at Dresden Station.

On October 31, 1988, the Station Security Administrator contacted Region I~I Safeguards Section to discuss the issues of this allegation.

The contacted Inspector stated that the w*lded door aspect of this allegation needed to be specifically addressed.

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INVESTIGATION DETAILS An analysis of existing documentation as well as* interviews were conducted.from October 24, 1988 through October 31, 1988.

1.

The following documentation was reviewed:

1.

Security computer generated alarm.histories.

2.

Security computer generated alarmtest histories.

3.

Security Event Reports.

4.

Security Incident Reports *

. 5.

Equipment I rregulati ty Reports;

6.

Pinkerton Incident Reports.

  • 7.

Security Maintenance Logs.

8.

PA/VA Barrier Inspection Logs.

9.

Weekly Preventative Maintenance Logs.

10.

CAS/SAS Operators Log Book.*

Interviews were conducted with:

1.

, CPP/Pinkerton Security Force Supervisor

2.

CPP/Pinkerton Operations Coordinator

3.

~ CPP/Pinkerton Security Maintenance Supervisor

4.

CPP/Pinkerton Security Computer Coordinator

5.

CECo Nuclear Security Administrator (previous

~Dresden Security Administrator)

Specific responses to the allegation concerns. follow.

"A d~ermination of whether or not the (

~door or Door~if it is not the door and Door~ ~.

before it was welded shut closes all the way."

Res.gonse:

Door~Jis a [

~door and Doors~] and

~jhave never been welded shut.

Both doors are active, "full featured" Vital Area Security doors.

Documentation reviews for the period of July 1 1988 through Septe~ber 30, 1988,. demonstrate Do?rs~Jand~were closin? an_d alarming properly, in accordance with the aesign.of the security computer system.

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If you find that these doors do not close all the way, provide the reason for the malfunction."

Response

allegation.

verified.

The -analysis of the reviewed data QQ.~~_J}.Q_t_ support the No malfunction, as described in the allegation, could.be

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"A.~escription of mea~ures being taken or taken to correct the door problem".

Response

No corrective measures were taken or are being taken for Doors because malfunctions, as described in the Allegation, were not verified.

4.

"If the computer aid not show these as open and if, in.fact, they were open; the reason for the malfunction."

Response

The security computer is designed to annunciate, *******

i iii5iiiiE'~w=h~e~n~a~V:i:t~a~l~A~r~e~a 1

  • s~e~c~uri ty door is improperly This capability exists due to the installation of...

One* sensor is a sensor is a Verification that the security computer alarm functions when a door.

is left includes:

1. Functional Tests:

The.alarm sensors This is performed

2. Routine Inspections:

Knowledgeable personnel routinelyllilllllllll' 3*. Alarm Annunciations and Response:

are verified vi.a a

Documentation of the door alarm functional tests from July 1, 1988 through September 30, 1988 indicates that the alarm functions for Doorg

            • rwere acceptable and alarm histories for Doors ********

reveal that their alarm functions were recorded in the security computer.

Routine roving door patrol inspections during the time period.

did not identify any malfunctions for Doors as described in the allegation;.

The investigation confirms that between July 1, 1988 through September 30, 1988, the computer was operating as designed and alarm annunciations occurred when Doors were accessed other than as designed.

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5.

"A description of measures being taken or taken to correct the door problem."

  • ~o co.rrective measures were taken or are being taken for *Doors

~ecause malfunctions, as ~escribed i~ the allegatiori, were not verified;

6.

"A description of compensatory measures required to be implemented when the door described does not close and/or the computer does. not show t'hese, doors as open."

~esponse:

Compen~atory measures required tb be implemented for a door that does not close or a* door which does not aiarm due to alarm sensor malfunction are as follows:

1.
2.
3.

If the computer is not annunciating the alarm indication due to a malfunction in the computer in lieu of an alarm sensor malfunction, the tomputer is arid fuil system failure compensator~

measures are initiated as follows:

2.

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8.

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"An anal~f *your review of alarm records for the Door and Door~

for the period July l, 1988 through September 30, 1988."

Responses:

Door~is a Door.

The security co~r generat arm ~ries revealed that there were a total of-alarms rom July 1, 1988 through September 30, 1988.

The alarm rate was per day.

The alarm data are delineated as fol1ows:

alarms <::a used by s.ecur i ty force personnel per for~ing roving inspections.

,,.. J.,,

alarms with unknown causes; howeyer, the door was found in a locked state and the alarm sensors~ere "rearmed". {reset condition) when security personnel responded at the door

  • alarms caus~d by authorized non-security employees during use of door.

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The analysis reffects normal conditions with ac~eptable alarm rate levels and supports proper operation.during the Juli I, 1988 through September 30, 1988 ti~e period.

8. * "An analysis of your review of alarm records fo-r Door. for the thre~

months prior to it.being welded shut."

Re~ponse:. Door ~has never been welded shut; however, a:n analysis of this door's alarm history was performed for July 1, 1988 through September 30;. 1988.

The security generated alarm }listories* revealed that there.were a totai of.ala~s at Door~during this time period.

The alarm rate ~as -alarms per day.

The alarm data are delineated as follows:

lllalarms caused by security force*personnel performing' roving inspections.

lalarms caused by authorized non-security employees during use of

. the door.

  • .alarms with unk.nown causes; however*, the door ~as f.ound. _in a locked state and the alarm sensors were "rearmed" (reset condition) when.security personnel responded to the door.

Analysis reflects normal _conditions with acceptable alarm rate levels _and supports proper operation during the July 1 -

September 30, 1988 time period.

9.

"A description_ of training given to employees regarding their responsibilities for ensuring that security do0 rs are pr6perly closed.**

Response

All employees having unescorted access authorization receive training on their responsibilities to security.

Specifically, employees are instructed not to hold or block open security doors and are infqrmed that any security problem must be reported immediately to.the Station Security organization.

Th.is training is accomplished during annual Nuclear General Employee Training (N-GET).

Additionally, security topics are shared with employees via weekly "tailgate" meeti"ngs and iri Dresden

  • Station Monthly Newsletter articles.

These reinforcements. are a p'art of the. Station's formal "Security Awareness Program."

fommomvealth Edison

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"Information compiled froin.reviewin9 other pertinent aocumentation."

Response

Several items of information were.compiled during this review.

Only one Vital Area*se~urity door has ever been welded shut at Dref::2..en Station.

This door is identified as Doo and is located in th~

interview with the former Station Security Administrator, it was determined that this door was welded shut in late~ Door~was welded shut for radiological concerns rather than any indication of recu~. malfunction with the security equipment featu.res *of the door..

. Door~_fs inspected at leas~

  • by knowledgeable

,security force members.

No.alar~ history was avai~le for this door because alarm h1story is maintained for three years.

The document review does not support any ~se, maifunction, breaking of welds or any other possible problem.

en Station has,_-,active v.ital Area security doors for the Thes~e identified as Door~.... ~nd

. Analysis* of the documentation was also perfo~ for-*

Doors... -and c No evidence of.malfunction, as described in the allegation, was found for.these doors.

  • A review of work requests from July 1, 1988 th~ September 30, 1988, revealed that no malfunction occurred at Door~ Three equipment malfunctions *occurred at Doorml\\ The dates of occurrence were 8/05188, 9/15188 and 9/28188.

The 8/5nrn ~lfunction involved broken door knobs however; the door remained locked and alarmable.

The September..

malfunctions were associated with card 'reader failure.

Alarm operability was not degraded.

CONCLUSION A review of documentation associated with the performance of Doors

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and llllill]fails to substantiate the allegation as set forth in Allegation Report iRIII-88-A-0123 dated October 14, 1988.

5367K