ML17251A358

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Partially Withheld Insp Rept 50-244/88-18 on 880912-16 (Ref 10CFR73.21).Violations Noted.Major Areas Inspected:Security Plan & Implementing Procedures,Mgt Effectiveness,Security Program Audits & Testing & Maint
ML17251A358
Person / Time
Site: Ginna Constellation icon.png
Issue date: 11/01/1988
From: Keimig R, Sylvester E, Tillman A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17251A356 List:
References
50-244-88-18, NUDOCS 8811210429
Download: ML17251A358 (26)


See also: IR 05000244/1988018

Text

( jiA~C.!i)

U,S.

NUCLEAR REGULATORY COMMISSION

REGION I

Report No.:

50-244/88-18

Licensee:

Rochester

Gas

and Electric Corporation

Docket No.:

50-244

Facility Name:

R.

E. Ginna Power Plant

Inspection

Conducted:

September

12-16,

1988

License

No.

DPR-18

Inspectors

A. Tillman

Physic

Se

ity Inspector,

Region II

C

.S'.

Sylvester,

Sr.

R actor Engineer,

Physical

Security

,Ir-r

-E8'ate

Signed

(< si aa

Date

S gned

Approved by:

R.

. Keimig,

Ch

eguards

Section

ivision of Radiation

S

ety and Safeguards

gr-y- 88

Date Signed

SUMMARY

Scope:

Resul ts:

This routine,

unannounced

inspection

was conducted

in the areas of:

security plan and implementing procedures;

management

effectiveness

security

program;

security

organization;

records

'and

reports;

security

program audit;

testing

and

maintenance;

locks,

keys

and

combinations;

physical barriers

protected

area;

physical barriers-

vital

areas;

security

system

power

supply;

lighting; compensatory

measures;

assessment

aids;

access

control

"

personnel;

access

control -

packages;

access

control

vehicles;

detection

aids

protected

area;

detection

aids - vital

areas;

alarm

stations;

communications;

personnel

training

and

qualification -

general

requirements;

safeguards

contingency plan implementation

review;

and

physical protection of safeguards

information.

In the

areas

inspected,

two violations of regulatory

requirements

were identified:

1.

Inadequate

procedure for testing intrusion detection

system;

and

2.

Inadequate 'vital area barriers.

PDR

ADGCK 050002

9

REPORT

DETAILS

1.

Persons

Contacted

Licensee

Employees

"R.

C. Mecredy,

General

Manager

Nuclear Production,

Rochester

Gas

and

Electric Corporation

(RGEE)

S,

M. Specter,

Superintendent,

R.

E. Ginna Nuclear Station,

(GNS)

  • R. E. Wood, Supervisor,

Nuclear Security,

GNS

  • M. J.

Fowler, Coordinator,

Nuclear Security Training,

GNS

"W. R. Borland, Electrical Engineer,

RGEE

Other

licensee

employees

contacted

during

this

inspection

included

engineers,

operators,

security

force

members,

technicians,

and

administrative personnel.

Other Organizations

R.

E.

Benne,

Major, Contract Security Supervisor,

The Wackenhut

Corporation

(TWC)

R.

C. Teed, Security Training Supervisor,

TWC

NRC Resident

Inspectors

C. Marschall,

Senior Resident

Inspector,

GNS

"N. Perry,

Resident

Inspector,

GNS

"Attended exit inter view

2.

Security Plan

and Implementing Procedures

(81018)

Review

and

observation

of security

force operational

activities during

the

course

of the

inspection

determined

that

adequate

implementing

procedures

had

been

provided

to

ensure

satisfactory

compliance

with

requirements

and

commitments

of the

Physical

Security

Plan,

except

as

noted in Section

7 of this report.

Review of the Physical

Security

Plan,

approved

through

change

No. 23,

revealed

that

changes

to

the

plan

submitted

in

accordance

with

10 CFR 50.54(p)

do

not

decrease

the

effectiveness

of the security

program relative to plan commitments.

The

Safeguards

Contingency

Plan

was

included

as

Chapter

8 of the

Physical

Security Plan.

Procedures

were detailed

and clearly written, and provided

adequate

guidance for the security force except

as noted.

During the

course

of the

inspection it was

noted that several

of the

current

provisions

of the

Physical

Security

Plan

require

updating

to

comply with

new

or

revised

regulatory

requiremerits,

and

to clarify

existing

commitments.

Included

were:

retention

period

for security

records,

amount

of

ammunition

provided

armed

security

personnel;

definition of Protected

Area Barrier at the primary access

portal,

and

compensatory

protection

provided

by defensive

positions

for assessment

degradations

on

the

protected

area

perimeter.

The

licensee

agreed

to

initiate the

necessary

changes

to the Physical

Security Plan in the next

scheduled

revision to be submitted in December

1988.

No violations of regulatory requirements

were identified in this area.

Management

Effectiveness

Security Program (81020)

Review of Security

Program functions

and observation

of security opera-

tional activities

revealed

that the

program

was effectively managed

and

that security

resources

were

being utilized

in

an efficient

manner.

The established

management

program

provided for development,

revision,

implementation

and

enforcement

of

physical

protection

procedures.

Licensee

management

demonstrated

an awareness

of, and supportive attitude

toward, physical protection requirements.

Based

on

observations

during

the

course

of the

inspection,

review of

security

related

documentation

and

assessment

of security

personnel

performance, it was determined

that the security

force is

managed

and

supervised

in accordance

with the Physical Security

Plan

and is capable of

providing an acceptable

level of security protection for the protected

and

vital areas

and security related

equipment.

No violations of regulatory requirements

were identified in this area.

Security Organization

(81022)

Review of security

operational

activities

and discussion

with security

management

personnel

revealed

that the

Ginna

Physical

Security organi-

zation

consisted

of

a proprietary

security

management

function

and

a

contract security force provided by the Wackenhut Corporation.

Security

personnel

contacted

appeared

to

be

knowledgeable

of security

duties

and

an acceptable

level of shift supervision

was provided.

Each

shift observed

during the inspection

was adequately

manned

to meet

the

security

plan

commitments.

Attitudes

and

performance

of

security

personnel

observed

during the inspection

were positive

and demonstrated

the capability to provide

an acceptable

level of protection for the plant

vital resources.

No violations of regulatory requirements

were identified in this area.

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5.

Security Program Audit (81034)

Review of security

records,

related

documentation,

and available audit

reports verified that the licensee

had established

a program for auditing

the security organization to assure

continued effectiveness.

The Physical

Security

Plan

commits to auditing the security program

a minimum of once

each

12 months by personnel

that are independent

of both security manage-

ment and supervision.

/

The

most

recent

audit of the

security

program

was

conducted

by the

licensee's

guality Assurance

staff during

the

period of August 16-19,

1988.

The

audit

report

concluded

that

security activities at

Ginna

station

are

effective

and

conducted

in

accordance

with established

requirements.

The report (No. 88-35) further reflected that

no deficien-

cies warranting issuance

of a request

for corrective action were noted.

A

previous audit,

Report

No. 87-45,

conducted

August 26-27,

1987, contained

similar comments with no deficiencies

noted.

No violations of regulatory requirements

were identified in this area.

6.

Records

and Reports

(81038)

Review of licensee

records

and related

documentation

and discussion

with

security

personnel

verified that

the licensee

documented

and maintained

records of security related activities

and occurrences

in accordance

with

commitments

and requirements

contained

in the Physical Security Plan

and

Training

and gualification

Plan.

Records

reviewed

were

detailed

and

complete

and reflected

review by security

management.

Physical

Security

Event

Logs for the

period of April-June

1988 reflected

a total

of

24

logged events.

Nineteen

events

were logged for the period July 1, through

September

12,

1988.

The

licensee

had

not

experienced

any

1-hour

reportable gtysical Security Events during the two periods

referenced.

. ~ '.. '.,

~

No violations'f r'eg81atory

requirements

were identi fied in thi s area.

7.

Testing

and Maintenance

(81042)

One violation of regulatory requirements

was identified in this area.

Oiscussion with security management

and maintenance

personnel

and observa-

tion of testing

and

repair activities

confirmed that

the

licensee

is

committed

to maintaining

security

systems

and

equipment

in operable

condition.

Operability. of the security

system

appeared

to be enhanced

by

the availability of dedicated

Instrument

and Calibration (ILC) technicians.

Observation

of licensee-conducted

tests

of randomly selected

components

of the protected

and vital

area

intrusion detection

system

and

other

security

systems

and

equipment

confirmed operability of all

systems

and

exponents,

with the following exceptions.

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10 CFR 73.55(g)(2)

requires

that

each

intrusion

alarm" be

tested

for

performance

at the beginning

and

end of any period that it is used for

security. If the period of continuous

use is longer than

seven days, the

intrusion

alarm shall

also

be tested

at least

once every

seven (7) days.

Section 3.1.4 of the Physical

Security Plan,

Intrusion Detection Hardware,

states

that

the

system

has

been

designed

to conform with the criteria

delineated

in

USNRC

Regulatory

Guide 5.44,

dated

June

1976,

10 CFR 73. 55(e) (1)(2) and

GSA Spec.

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Failure to provide

an adequate

procedure for testing intrusion alarms for

conformance with commitments of the Physical

Security Plan is a violation

of regulatory requirements

(50-244/88-18-01).

8.

Locks,

Keys and Combinations

(81046)

Discussion with the Security

Manager

responsible

for the security locks,

keys

and combination

program

and review of lock and

key control records

confirmed that the licensee

had established

a program to provide positive

control of security locks and keys.

The most recent lock core

and

key change

out was accomplished

December

1,

1987.

Keys are inventoried

each security shift tour.

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No violations of regulatory requirements

were identified in thi s area.

9.

Physical

Barr iers - Protected

Area (81052)

Tours of the protected

area during day and night hours confirmed that the

protected

area

perimeter

and associated

isolation

zones

were established

and maintained

in accordance

with commitments

in the

Physical

Security

Plan.

The perimeter

was clearly defined,

except

as noted below, isolation zones

were free of obstructions, with the exception of those identified in the

security plan,

and the perimeter

fencing

and gates

were in a good state

of repair.

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No violations of regulatory requirements, were identified in this area.

10.

Physical Barriers - Yital Areas

(81054)

One violation of regulatory requirements

was identified in this area.

Tours

of the

protected

area

and

several

of the designated

vital areas

confirmed

that vital

area

barriers

had

been

established

and

were

maintained

in accordance

with commitments

of the Physical Security Plan,

with the following exception.

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10 CFR 73.55(c)(1)

requires that the licensee

locate vital equipment only

within a vital area,

which in turn,

shall

be

located within a protected

area

such

that

access

to vital

equipment

requires

passage

through

at

least

two

physical

barriers

of sufficient

strength

to

meet

the

performance

requirements

of paragraph

(a) of this section.

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Failure

to

provide

equivalent

protection

for penetrations

in vital

barri ers i s

a violation of regulatory

requirements

(50-244/88-18-02)

.

11

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Security

System

Power Supply (81058)

Discussion with security management

and review of security

and maintenance

related

documentation

determined

that

backup

power

for all

security

systems

is provided by a dedicated

security diesel

generator

located in a

vital area.

The diesel

generator

is load tested at 31-day intervals.

No deficiencies

in operation or testing frequency were noted.

No violations of regulatory requirements

were identified in this area.

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l2.

Lighting (81062)

Tours of the protected

area

during the hours of dar kness verified that

adequate

lighting had

been

provided within the

protected

area

to meet

illumination requirements

for 'the protected

area

and perimeter isolation

zones

as committed to in the Physical Security Plan.

Lighting equipment consisted of permanent

high mast .lighting fixtures and

flood lighting installed

on buildings

and

in congested

areas.

Mobile

trailers

and temporary structures

were either underpenned

or were provided

with temporary lighting.

Security patrols

monitor lighting levels

on

a

nightly basis.

No violations of regulatory requirements

were identified in this area.

13.

Compensatory

Neasures

(81064)

Review of the

Physical

Security

Plan

and

Implementing

Procedures

and

discussion

with security

management

confirmed

that

the

licensee

has

developed

and

employs

compensatory

measures,

including

equipment,

additional

security

personnel,

and

specified

procedures

to ensure

that

the effectiveness

of the security

system is not

reduced

by failure or

other

contingencies

affecting

the

operation

of safety-related

systems,

equipment,

or

structures'ecurity

personnel

observed

in the

performance

of compensatory

duties

were

knowledgeable

of the duties

being

performed

and

related

security

response

requirements.

No violations of regulatory requirements

were identified in this area.

14.

Assessment

Aids (81066)

Tours

of the

protected

area,

review of the Physical

Security

Plan

and

1mplementing

Procedures,

and discussion with security

management

personnel

confirmed that the licensee

had established

a means of assessing

protected

area

and vital area intrusion detection

alarms.

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No violations of regulatory requirements

were identified in this area.

15.

Access Control,- Personnel

(Sl070)

Observations

of personnel

access

control activities at the Primary Access

Portal

during the period of the inspection

determined

that the licensee

was controlling access

to the

protected

and vital areas

in accordance

with commitments in the Physical

Security Plan.

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The licensee

had established

compensatory

measures

to be

implemen'ted

in

the event of access

control equipment degradation

or failure.

No violations of regulatory requirements

were identified in this area.

16.

Access

Control-Packages

(81072)

Observation

of access

control activities at

the

primary

access

portal

during the period of the inspection

confirmed that

packages

and

hand-

carried

items

were

searched

prior to being permitted into the protected

area.

All hand-carried

items were routinely searched

by X-ray scanning

equipment monitored by dedicated

security personnel.

Review of documentation

and procedures,

observation

of licensee

conducted

tests of detection

equipment,

and discussion with members of the security

force

determined

that

special

purpose

detection

equipment utilized for

search activities was tested

and maintained

in an operable condition.

The

licensee

had developed

and

employs

compensatory

measures

in the event of

equipment degradation

or failure.

No violations of regulatory requirements

were identified in this area.

8

17.

Access Control - Vehicles (81074)

Observation

of vehicle

access

control activities at the primary vehicle

access

gate to the protected

area

determined

that all vehicles,

except

under

emergency

conditions,

are

searched

for firearms,

explosives,

and

incendiary devices prior to being granted

access

to the protected

area.

The cab,

engine

compartment,

cargo area,

and undercarriage

are routinely

searched

by the security

force.

All vehicles

entkriag

the

protected

area,

with the exception of designated

vehicles,

are

escheated

by

a member

of the security force.

Unattended

vehicles

observed within the protected

area

were either secured,

or were under control of the security force.

No violations of regulatory requirements

were identified in this area.

18. Detection Aids - Protected

Area (81078)

Tours of the protected

area

and observation

of licensee

conducted

tests

of randomly selected

intrusion alarm components verified that the licensee

had established

an intrusion detection capability for the protected

area

perimeter in accordance

with commitments

in the Physical

Security Plan.

No violations of regulatory

requirements

were identified in this area,

with the exception of the

one addressed

in Paragraph

7.

19.

Detection Aids - Yital Areas (81080)

Tours of the Ginna Nuclear Station vital areas

and observation of licensee

conducted

testing

of

randomly

selected

intrusion

alarm

components

installed

on vital area

portals verified that

access

to the vital areas

was controlled in accordance

with comm'itments

in the

Physical

Security

Plan,

except

as noted in Section

10 of this report.

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No deficiencies

were noted dur ing licensee testing of vital area detection

equipment.

No violations of regulatory requirements

were identified in this area.

20.

Alarm Stations

(81084)

Tours of the Ginna Nuclear Station security facilities confirmed that the

licensee

maintains

Central, and

Secondary

alarm

stati.ons

in accordance

with commitments of the Physical

Security Plan.

No violations of regulatory requirements

were identified in this area.

21.

Communications

(81088)

Observation

of securi

The ability of the alarm stations

to communicate with the security force

effectively and maintain radio discipline during

response

activities

was

demonstrated

during

a licensee

conducted

response drill on the evening of

September

14,

1988.

The

inspectors

observed

communications

tests

conducted

by the

Central

Alarm Station

with the, local

law enforcement

agency

via radio

and

telephone.

No violations of regulatory requirements

were identified in this area.

22.

Personnel

Training and gualification - General

Requirements

(81501)

Review of the

licensee's

Training

and gualification Plan,

Revision

1,

dated April 23,

1981,

training

records

and

related

documentation,

and

discussion with the Wackenhut Security Training Staff confirmed that the

Security Training Program

had been fully implemented

and required training

and re-qualification

was current.

Training records

were detailed

and well

documented.

Training

requirements

had

been

computerized

for tracking

purposes

which appeared

to be

an effective

means

of maintaining training

ty force operational

activities

and discussion

with

security

personnel

verified that

the

security

force

was

provided with

adequate

communications

equipment

and capability to maintain communication

with all on-duty personnel

and off-site Law Enforcement Agencies.

8

11

requirements

current.

The computerized listing of training requirements

was

randomly cross-referenced

with several

individual training records,

all of which were found to be accurate

and current.

Observation

of requalification training

being

provided

to

members

of

the

security

force, their participation

in

an

armed

response

drill,

and

observations

and

interviews of security

personnel

involved in the

performance

of security duties

confirmed the effectiveness

and

adequacy

of the security training program.

23.

No violations of regulatory requirements

were identified in this area.

Safeguards

Contingency

Plan Implementation

Review (81601)

Review of the licensee's

Safeguards

Contingency Plan,

included

as Chapter

8

of the Physical

Security Plan,

and Implementing Procedures

confirmed that

the plan

had

been fully implemented.

It was

noted that

29 .individual

security

events

were defined

in the Contingency

Plan,

each of which was

addressed

by an Implementing Procedure.

Documentation

reflected that liaison

had

been

established

and

was

being

maintained with local, State

and other

Law Enforcement

Agencies

represented

in the surrounding

area.

The established

liaison was further verified by

attendance

at

the

Annual

Local

Law Enforcement

(LLEA) orientation

and

briefing presented

on-site

September

14,

1988.

Federal,

State,

and local

agencies

were in attendance.

The

Security

Force

demonstrated

the ability to

respond

effectively to

unauthorized

intrusion to the protected

area

during

a security

response

drill conducted

during

nonregular

hours

on

September

14,

1988.

The

pre-drill briefing, tactical

deployment,

and operational

control of the

armed

response

force were effectively demonstrated

and

no deficiencies

were noted.

24.

No violations of regulatory requirements

were identified in this area.

Physical

Protection of Safeguards

Information (81810)

Discussion

with security

management

personnel

and review of procedures

and related documentation

confirmed that the licensee

had implemented

and

maintains

a

program for the protection

of Safeguards

Information that

includes

proper identification, monitoring,

storage

and destruction

of

the information

and material.

The

program is administered

in accordance

with Ginna Security Procedure

No. GS-1.0, Classification

and Distribution

of Security Information, dated

December

16,

1981.

A combination of

GSA approved

safes

and lock bar cabinets

are utilized

for storage

of the

licensee's

Safeguards

Information.

Destruction

of

material is routinely accomplished

by shredding.

No violations of regulatory requirements

were identified in this area.

S

12

25.

Exit Interview

The inspection

scope

and results

were

summarized

on September

16,

1988,

with those

persons

indicated in paragraph

1.

The inspectors

described

the

areas

inspected

and

discussed

in detail

the

inspection

results

listed

below.

The

licensee

was

informed that

two potential

violations of regulatory

requirements,

relating to adequacy of procedures

and vital area barriers,

were identified.

No written materials

were provided to the licensee

during the inspection.