ML17251A532
| ML17251A532 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/25/1989 |
| From: | Keimig R, Lancaster W, Sylvester E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17251A530 | List: |
| References | |
| 50-244-89-08, 50-244-89-8, NUDOCS 8906070041 | |
| Download: ML17251A532 (26) | |
See also: IR 05000244/1989008
Text
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NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
50-244/89-08
Docket No.
50-244
License
No.
OPR-18
Licensee:
Rochester
Gas
and Electric Cor oration
Facility Name:
R.
E. Ginna
Power Plant
Inspection At:
Ontario
Irspection
Conducted:
A ril 17-21
1989
Type of Inspection:
Routine
Unannounced
Ph sical Securit
Irspector s: &'
'.
K. Lancaster,
Physical Security Inspector
date
E.
D.
Sy
,
S
or
tor Engineer,
Physical Security
date
Approved by:
.
R. Keimig,
ief,
S
guards
Section
Division of Radiation
afety and Safeguards
date
Ins ection
Summar
Routine
Unannounced
Ph sical Securit
Ins ection
Re ort No. 50-244/89-08
Areas
Ins ected:
Onsite Follow-up of Previously Identified Items;
Management
Support,
Security
Program Plans
and Audits; Protected
Area and Vital Area
Physical Barriers,
Detection
and Assessment
Aids; Protected
and Vital Area
Access Control of Personnel,
Packages
and Vehicles; Alarm Stations
and
Communications;
Power Supply; Testing,
Maintenance
and Compensatory
Measures;
and Security Training and qualifications.
Results:
Th'e licensee
was found in noncompliance with the NRC-approved
Physical
Security Plan in the areas
of Physical Barriers - Vital Areas,
and
Protected
Area Assessment
Aids.
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6
DETAILS
1.
Ke
Personnel
Contacted
I
Licensee
and Contractor Personnel
- R. Smith, Vice President - Engineering
and, Production
"S. Spector,
Plant Manager
"T. Powell,
Manager - Risk Management
Department
"R. Marchionda, Director of Outage
Planning
"W. Borland, Electrical
Engineer
"R. Wood, Supervisor - Nuclear Security
"M. Fowler, Coordinator - Nuclear Security Training
T. Porter, Acting Foreman - Instrumentation
and Controls ( I&C)
R.
Benne,
Project Manager - Wackenhut
U.S. Nuclear
Re viator
Commission
NRC
"N. Perry,
Resident
Inspector
"Indicates those present at the Exit Interview
2.
Onsite Follow-u
of Previousl
Identified Items
a
~
(Closed)
VIO 88-18-01.
The licensee failed to provide test
procedures
for the protected
area
(PA) intrusion detection
system
( IDS).
The licensee's
response
to the Notice of Violation, as
documented
in
a letter to the
NRC dated
December
5,
1988,
was
verified and corrective actions
were found to be satisfactory.
The
inspectors
observed
tests of the
April 17-21,
1989,
and found no discrepancies.
(Open)
VIO 88-12-02.
The licensee
was found with inadequate
barriers
at
a certain vital area.
The licensee
estimates
that the barriers
on
this vital area
would be upgraded
by August
1,
1989.
The inspectors
verified that compensatory
security measures
for the degraded
barrier s were in place.
3.
Mana ement
Su
ort
Securit
Pro
ram Plans
and Audits
a.
Mana
ement
Su
ort Management
support for, and attention to, the
physical security program appeared
to have decreased
in certain
areas.
This is based
upon the inspectors'eview
of various aspects
of the licensee's
program,
and the nature of the apparent violations
and security concerns identified during the inspection.
The inspectors
observed
that the licensee's
physical security program
has
some notable strengths;
however, it also
has
some
weaknesses
that
are in need of attention.
The following are examples
of program
strengths:
~ A very professional,
performance
oriented,
and effective
security force;
~A positive attitude toward security is displayed
by all plant
personnel;
~ Enhanced barriers at key locations
on the protected
area
(PA)
perimeter to protect against
by unauthorized
vehicles;
~ Large clear isolation
zones
and
a double
PA fence barrier system
to aid alarm station operators
in detection
and assessment;
~ An excellent fixed security lighting system;
~Strategically located defensive positions for the response
teams;
and,
~ Excellent armament
(types, distribution and locations) for the
response
teams.
The following are
examples of weaknesses
observed:
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The inspectors
expressed
the concern that, while most aspects
of the
program appeared
to be performance-oriented
and received appropriate
attention,
some aspects,
notably equipment
and systems,
have
been
neglected
to the, point that they are only marginally effective.
The
licensee
indicated that
a bid specification
was being prepared for a
consultant
to evaluate
the program and expected
the evaluation to be
conducted
in 'the near future.
The inspectors
indicated interest in
reviewing the evaluation results after the licensee's
review and
assessment.
b.
Securit
Pro
ram Plans - The inspectors
reviewed the NRC-approved
security plan (the Plan)
and met with licensee
representatives
to
discuss
several
inconsistencies
in the Plan.
The following are
some
representative
examples:
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Subsequent
to these discussions,
which included
a review of the above
examples with the licensee,
the inspectors
stated that the Plan
and
implementing
procedures
need to be reviewed to identify and resolve
any
additional
inconsistencies
and to ensure
that the implementing procedures
reflect the commitments
in the Plan.
The licensee
committed to include
a section
on security plan and plan
implementing
procedures
review in the consultant's
evaluation of the
licensee's
program.
Audits - The inspectors
reviewed the report of the
1988 annual
security
program aud'it,
conducted
by Quality Assurance
(QA), and
verified that the audit
had
been conducted
in accordance
with the
Plan.
The inspectors
noted that there
were
no adverse
findings,
concerns
or recommendations
made in the official transmittal of the
audit report.
Apparently,
the
QA auditors
found all aspects
of the
security
program to be satisfactory.
Based
on the
inspectors'indings
during this inspection
and
an interview of a
QA auditor who
participated
in the
1988 audit, the inspectors
questioned
the depth
of the audit and/or the security expertise of the auditors.
The licensee
agreed to look into the inspectors'oncern
in this
area.
The licensee's
audit program will be reviewed further during
the next inspections
Protected
and Vital Area
Ph sical Barriers
Detection
and Assessment
Aids
a.
Protected
Area Barriers
The inspectors
conducted
a physical
inspection of the
PA barrier
on April 17,
1989.
The inspectors
determined,
by observation,
that the barriers
were installed
and
maintained
as described
in the Plan.
b.
Protected
Area Detection Aids - The inspectors
tested
the
perimeter intrusion detection
system
( IDS) on April 18,
1989,
and
determined that it was installed,
maintained
and operated
as
committed to in the Plan.
C.
Isolation Zones - The inspectors verified that isolation zones
were
very well maintained
and free of obstructions.
However,
as discussed
in paragraph
4'.e., obstructions
outside of the isolation zones
obscured
assessment
capabilities
in two areas.
d.
Protected
Area
and Isolation
Zone Li htin
- The inspectors
conducted
a lighting survey of the
PA and isolation zones
on April 17 and
19,
1989.
The inspectors
determined,
by observation,
that lighting
in the isolation
zones
was adequate.
However,
elsewhere within the
PA, the inspectors
identified several
isolated
areas
where lighting
was marginal
due to on-going outage activities.
While these lighting
deficiencies
did not represent
a violation of the Plan,
the
inspectors
noted that their existence
was not indicative of an
aggressive
security lighting program.
Security force post orders
and the Plan
implementing
procedures
were
reviewed
by the inspectors.
They noted that these
documents did not
specifically require security force members
to be alert for and
identify potential lighting deficiencies.
The inspectors
also
determined
through interviews with security force members that the
security shift supervisors
do not have ready
access
to
a light meter
with which to quantitatively assess
security force identified
potential lighting deficiencies.
The licensee
committed to revise post orders
and procedure's
to
specifically address
the responsibilities of security force members
to be alert for areas
of marginal lighting.
The licensee
also stated
that shift supervisors
would be provided with a light meter.
lighting will be reviewed during subsequent
inspections.
e.
Assessment
Aids - The inspectors
observed
the
use of assessment
aids,
and other security equipment in operation at the Central Alarm
Station
(CAS) on April 18,
1989.
The inspectors
found that two
portions of the
PA barrier and associated
isolation zones could not
be adequately
assessed.
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The inspectors
interviewed security
and
I&C personnel
about this
matter ard determined that the problem
has existed for over two
years.
However,
when the matter
was discussed
with licensee
security
management
personnel,
they disclaimed
knowledge of the problem and
could offer no explanation of how the problem could exist for that
period of time without it coming to their attention.
The inspectors
expressed
the following concerns
to the licensee:
1)
Why was there not
a deficiency report written concerning
the problem when it was first identified?
(The inspectors
could not find one nor was
one offered by the licensee.)
2)
If a deficiency report was written,
why was the problem not
corrected?
3)
Why was security management
not aware of an apparent
system
problem that existed for over two years
when it was general
knowledge
among security
and
ICC personnel?
4)
How could the problem exist for over
two years without
being corrected,
especially
since
the
NRC had given the
licensee credit for the system during the security plan
approval
process?
5)
Why were compensatory
measures
not implemented
when the
problem first occurred?
6)
If a conscious
decision
was
made
by someone
not to correct
the problem,
who made that decision
and why was the
NRC not
notified and
a security plan change
submitted7
The inspectors
reviewed the
Plan, and found the following
requirements:
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The inspectors
determined that the licensee's
failure to comply with
commitments
in the Plan is
an apparent violation of NRC requirements
(50-244/89-08-0j).
The inspectors
also observed
the
use of assessment
aids during the
hours of darkness
on April l7,
1989.
The licensee
implemented
compensatory
security measures
for these
potential
weaknesses
and committed to review the entire
CCTV system
in the near future.
The licensee's
actions to resolve
these matters
will be reviewed during the next inspection.
f.
Vital Area Barrier - The inspectors
conducted
a physical inspection
of Vital Area
(VA barriers
on
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, The licensee
agreed
to correct
these deficiencies
by the end of the
current outage.
This will be reviewed Muring subsequent
inspections.
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The inspectors
reviewed
the Plan
and found the following require-
ments:
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The inspectors
determined 'that the licensee's
failure to comply with
the above requirements
in the Plan is an apparent violation of NRC
requirements.
(50-244/89-08-02).
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NOT FOR PIISUC
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g.
Vital Area Oetection Aids - The inspectors
observed
and witnessed
testing of the
VA intrusion detection
aids
and determined that they
were installed, maintained
and operated
as committed to in the Plan.
5.
Protected
and Vital Area Access Control of Personnel
Packa
es
and Vehicles
a.
Personnel
Assess
Control
The inspectors
determined
that the licensee
was exercising positive
control over personnel
access
to the
PA and
VAs.
This determination
was based
on the following:
1)
The inspectors verified, by observation,
that personnel
are
properly identified and authorization is checked prior to
issuance
of badges
and key-cards.
2)
The inspectors verified that the licensee
has
program in place.
A drug testing
program
has
been
implemented
and includes:
~All prospective
licensee
employees
(who would be assigned
to the plant) are tested prior to employment;
~All consultants
and contractors
must certify to the
licensee
that their employees
have
been drug tested;
and,
~ Testing for cause.
The inspectors
noted that the testing
program does
not include
annual testing of licensee,
consultants
or contractor
employees
who have
access
to the
PA and
VAs at the station.
3)
The inspectors verified that the licensee
has
a search
program,
as
committed to in the Plan, for firearms,
explosives,
incendiary devices
and other unauthorized material.
The
inspectors
observed
plant per'sonnel
and visitor access
processing
several
times during the inspection
and interviewed
members
of the security force and the licensee's security'taff
regarding
personnel
access
procedures.
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4)
The inspectors
determined,
by observation,
that individuals in
the
PA and
VAs display their access
badges
as required.
10
5)
The inspectors verified that the licensee
has escort procedures
for visitors to the
6)
7)
The inspectors verified, by a review of security procedures
and
records,
that the licensee
has
a program to confirm the
trustworthiness
and reliability of employees.
This program
includes
checks
on employment history, criminal history,
physical examination,
and
a psychological
examination.
The inspectors
reviewed the procedures
for the control of
security locks and
keys
and determined
that they were consistent
with commitments
in the Plan.
The inspectors
also reviewed the
PA and
VA key inventory logs,
and discussed
lock and key control
procedures
with members of the security force and the licensee's
security staff.
No deficiencies
were identified.
8)
The inspectors verified that-the
licensee
has provisions for
expediting
prompt access
to vital equipment during emergencies,
and that the provisions
are
adequate
for that purpose.
9)
The inspectors verified that unescorted
access
to
VAs is limited
to authorized individuals.
The
VA access list is revalidated at
least
once every
31 days
as committed to in the Plan.
'I
Packa
e Access Control
The inspectors
determined that the licensee
was exercising positive
control over hand-carried
items that are brought into the
PA via the
main gatehouse.
The inspectors
reviewed the search
procedures
for
the main gatehouse
and found
them consistent with commitments
in the
Plan.
i
11
The licensee
agreed to assess
and re-evaluate
this area of the Plan
~
The
NRC considers
the licensee's
practices
regarding
searches
of
packages
and materials
entering the
PA to be
a Unresolved
Item
(50-244/89-08-01).
c.
Vehicle Access Control
The inspectors
determined that the licensee
properly controls vehicle
access
to and within the
PA.
The inspectors verified that vehicles
are properly processed
prior to entering
the
PA.
The process
was
consistent with commitments
in the Plan.
The inspectors
also
reviewed the vehicle search
procedures
and determined that they were
consistent with commitments
in the Plan.
This determination
was
made
by observing vehicle processing
and search,
inspection of vehicle
logs,
and by interviewing members of the security force and
licensee's
security staff about vehicle processing
and search
procedures.
6.
Alarm Station
and Communications
The inspectors
observed
the operations
of the
CAS and
SAS and determined
that they were maintained
and operated
as committed to in the Plan.
and
SAS operators
were interviewed
by the inspectors
and found to be
knowledgeable
of their duties
and responsibilities.
The inspectors
verified that the
CAS and
SAS do not contain
any operational activities
that would interfere with the assessment
and response
functions.
The inspectors
also observed
tests of all communication capabilities
in
both the
CAS and the
SAS and reviewed the testing
records for the
communications channels'll
were found to be as committed to in the
Plan.
7.
Emer enc
Power
Su
1
The inspectors verified that there are several
systems (batteries,
dedicated
diesel
generator within a VA, and plant on-site
AC power) that
provide backup
power to the security systems.
The inspectors
reviewed the
test
and maintenance
records
and procedures
for these
systems
and found
that they were consistent with the Plan.
The inspectors
also verified that the door
access
control
system for VAs
will permit emergency
ingress
and egress
when the system's
normal
power is
lost.
8.
Testin
Maintenance
and
Com ensator
Measures
The inspectors
reviewed testing
and maintenance
records
and confirmed that
the records
committed to in the Plan were
on file and readily available
for review.
The station
uses
experienced
instrumentation
and controls
12
(IAC) technicians
to repair/replace
and test
any security equipment which
requires. preventive or corrective maintenance.
A check of repair records
indicated that repairs,
replacements
and testing is being accomplished
in
a timely manner.
The review also included the 1988/1989 quarterly
Security
Event
Logs and tlI~EtQQ+~)gaqrygggqgequest
records.
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The licensee
agreed
to review the maintenance
history for these
components
in an effort to determine
the reliability of this equipment.
This matter
will be reviewed during subsequent
inspections.
The inspectors
also reviewed the licensee's
use of compensatory
security
measures
and determined
that they were being
implemented
as committed to
in the Plan.
9.
Securit
Trainin
and
uglification
Several
Security Officers (SOs)
were interviewed to determine if they
possess
the requisite
knowledge
and ability to carry out their assigned
duties.
The interview results
indicated that they were very professional
and knowledgeable
of their job requirements.
The licensee's
contract security force consists of forty-seven
and
watchmen,
ten supervisory
personnel
and
one project manager.
The
inspectors
verified that the
armed
response
force meets
the commitments
in
the Plan
and that there is always
one full-time member of the security
organization on-site
who has
the authority to direct security activities.
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The licensee
agreed
to review this matter.
This matter will be reviewed
aga.in during subsequent
inspections.
On April 20,
1989,
at, 12: 19 a.m.,
the security shift supervisor
found
a
security force member asleep
on-post at
a
VA access
point.
The licensee
properly reported
the incident to the
NRC in accordance
with 10 CFR 73.71.
The inspectors,
who were
on site at the time,
reviewed the incident and
determined that the security force member could have
been
asleep for only
approximately
seven minutest
The licensee
took immediate
and appropriate
compensatory
security measures.
The inspectors
determined that all
appropriate
actions
had
been
taken.
The inspectors
also
found that the
licensee
has
an effective program in place to guard against
members of t,he
security force being inattentive while on duty for a length of time that
would de'grade
security.
1C.
Exit Interview
The inspectors
met with the licensee
representatives
indicated in
paragraph
1 at the conclusion of the inspection
on April 21,
1989.
At the
time, the purpose
and
scope of the inspection
were reviewed
and the
findings were presented.
At no time during this inspection
was written material
provided to the
licensee
by the inspectors.
W