ML20004A396
| ML20004A396 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/01/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20004A385 | List: |
| References | |
| FOIA-80-615 50-010-78-28, 50-10-78-28, 50-237-78-24, 50-249-78-26, NUDOCS 8105150060 | |
| Download: ML20004A396 (3) | |
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_EOTICE 07 v3 01.ATIO::
Co envralth Edi Docket No. 50-10 Company Docket No. 50-237 Docket No. 50-2L 9 i
Eased on the inspection conducted on 0:tober 10-13 and 16-19,1978, it appears that certain of your activities were in noncorpliance with ERC requirer,ents, as noted belov._ Iters I and 2 are infractions; itens 3 through 7 are deficiencies.
Since irrediate corrective action was taken where appropriate, and concitzents cade to rc-train guards in the applicable procedures, no responsa is required.
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a Contrary to the above, it was obse ved on October 10 and 13, 1978, that construction ret erial cealr.,ent, was stored within{, ca:able of providing con-
]on the inside of the p:otectec area barrier.
2.
10 CTE 73.55(g)(1) recuires that physical barriers be ceintained in operable conditien.
Contrary to the above, it was observed on October 13, 1978, that a section of the protected tras barrier was not rain-tained in an operable condition in that ]
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10 CTR 73.55(g)(2) andI
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] requires that each intrusic.: alarr be tested at least once every seven days during periods of centinuous use.
Contrary te the above, it vas ne:ed that on four occasions, between the persed of May 6,1975 and Gerober 12, 1976, the int erval between tests e>:ceeded the seven day requirenent.
S-T3--78-227 Copy d of 7
copies 2_ Pages.
THIS DOCUMENT IS NOT TO LE REPRODUCED WITdOZ7 SPECIFIC APPROVA1. OT RIII S t o f/ f00 an 2,mu trcrne:c=
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3 j 10 CFR 73'.55(b)(4) recuires that a person be properly trained prior to acti.ng as a guard.
Contrary to the above it was noted that a guard had not
[] prior to assignrent as an received training in
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arced guard.
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5.
i Contrary to the above, such cot unication verifications were not perforced fer tha :
iod under review, nanely, August 1977 e
to the present 6.
10 CFR 75. 'f(d)(4) recuires that all vehicles, except under ete rg en c-cor.ditions be searched for iters which could be useC fr-industrial sabotage perpeses prier to entry into the protected 3.rea.
1.reas to be searched in:1ude t~r+ cab, ensine corpartrent, undercarriags, and cargo area.
Contrary te the above, it was oiserved that on six instances on October 13 and IE,197E, the undercarriage of vehicles were not sear:hed prier to entry inte the protected aret.
7.
10 CTR 73.55'f) D) reouires that the licensee control all points of personnel access into the protected area.
Contrary to the above, a review of the records dis:lesed that tve visitors vers granted adrittance to the protected area ((_,
period of liy 1HE to the present. _
))}betweenthe This is a reycat ite: ef nonco ;1tance from the Septecher/
October physical. protection inspection.
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5-F3 7E-227
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THIS *OCD:D;T IS NOT TO BE Rrygop;CEE Cir,0UT SPICit'IC APPROYAL OF RIII
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SECrEIIT CONCIE.':S t
Daring the period April 24 to May 23,1978, aa investigation was con-3ucted concerning the falsification of pa:rol records and guard firearts qualif 4 cation records by the guard service contractor at Dresden.
The results of that investigation vere discussed with Coc >cavealth Edison Management in a neering held in the regional office on June 22, 1978.
During this meeting, concerns disclosal as a result of the investi-gation, spe cifically_ relating to([,
vere discussed.
As a result of the current inspection, our concerns have increased.
review of records and discussions with site security personnel dis-closed that the
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is in er.ess of?#~~~
, based on the nur.ber of guards required i
by r.ae guero contract.
The inspection also disclosed that morale continues to be lov.
Ihny of the iters of noncorpidance disclosed dtring the inspection can be attributed to the failure of security perse.nnel to follow established security procedures.
L'e feel that
-unless steps are taken to reduce I the effectiveness of the security organization cay be adversely affecte] i S-T3-78-22E Copy Y _ of 9 copics __ Page. W S DOCNI.NI IS NOT TO BE ELPROJ'."CgD WITHOUT SPECIT1C APPRO\\*AL OF E311 Jart 2,7E3(i itf*tr:-ti::
p U.S. 1.TCLEAR EEGri.AIO?.Y CO.T.3 SS105 i OTTJCE OF INSPICTION A';D D;TORCD:T_NT EEGION III Report No. 50-30/78-28; 50-237/7E-24; 50-249/78-26 Daclet No. 50-10; 50-237; 50-249 1.fcense No. DTT.-2; DPR-19; DPF,-25 Safeguards Group II, IV 1.icensee: Conzonvealth T2ison Cocpany Tost Off~ce Eox 767 Chicago, IL 60690 Tacility Name: Dresden Kuc3 ear Fever Station, Units 1, 2 and 3 Inspection At: Dres6en Sit e, }brris, T' Inspection Conducted: October 10-13 and 16-19,1978 J}.1;.Belange?. L.13 l= 99 M' Nf8 Inspectors: S l,f /. r. l0 sg . C. sju11 //- 20-7 e C. d.. kpm C. A. Schwan / //2(/7 fi f. l Approved By: J. A. Eind, Chief JJ ~.42, ~7( Safeguards Eranch Inspection Sucr.arv Inspection on October 10-13 and 16-11, 1978 (Report No. 50-10/78-281 50-237/75-24; 50-24 t/ 7 6-26) Ar eas,7 nspec t ed: Unannounced inspectien regarding i=plementerion of (a) a;preved security plan dated h*zy 6,197; (revised); (b) app 3feabie portions of 10 CTE 73.55 whic'n becare effect!.re May 25, 1977; (c) 10 CTR 73.70 l requirements. Specifically, the inspec:icn covered areas relative to the security organization, physical barriers, eccess cont rols, det ection eids. coc:nunication cont rols, testing and caintenance ef security egoipment, response controls and record requirerer.ts. The inspet: ors reviewed the licensee's corrective action relative te iters of nonctzpliance identified during the physical protection inspections conducted Septe:.ber 26-30 and 7((l Al100N
October-3, 1977; and March 27-28, 1978. Additionally, the inspect ors-revieved the licensee's progress toward full 10 CTR 73.55 f tplezentation. The inspec ion involved 165 hours onsite by tvo NRC inspectors and an inspection assistant. Of the areas inspected, seven iters of noncorpliance vere iden-Eesults: tified relative to the security organization (Paragraph.4), access controls ~ ![ (Paragraph 7), physical barriers (Paragraph 5), testing and caintenance .( Two of the ite=s (Paragraph 6) and response capability (Faragraph 8). .Tne f r e=s f are considered inf ractions; the remaini g five are deficiencier. of nonco:pliance noted during the previcus security inspections are elesed. Two of the three unresolved ite=s noted during the Septe:ber/ October 1977 inspection have been resolved by the Offica of Eucicar Reactor Regulation;. the third itec regarding vital areas vill remain open pending approval of. q j the licensee's revised Modified Arended Security Plan, i (Details Part 2.790(d) Inforcation) i e I i t i i n f S-P3-78-229 Copy _ff__of '7 copies j if.Pages. THIS DOCUMENT IS NOT TO Eg REPRODUCED L'2720'.'T S?ECITIC 2-APTROVAL OT RIII f t O - g e g e e et 4 e e
stri 2.7i' N}'I:ftrrttier ~ ~ DETAILE 1. Persons Centacted Consonvealth Edison Company B.3.Stergenson, Station Superintendent I J Cration Adrinistrative Assistant 1 i _iStatie: Security Adninis trator [ l {.JEntlpar Security Adninistrator (Corporate) , QC Engineer i Statica Of fice Supervisor i j ( Static: Technical Staff Supervisor s_Etesden QA j --. Secior QA Inspector, Dresden ?~ l Security Servites ~ __.,_. m 1 ( G_rou; K;elear Saf e;uaris lhnager __j Security [ Edre Suoervisor Security ~ tSteurity i NRC - Region III J. Earker, KRC Ee sident Inspector R. C. Knop, Operati:ns Eranch All of the abeve individuals were present at the exit rsecting. The inspectors aise conducted interviews with ten cenbers of the contract security force. 2. Licensee Action on Trevious Inspection Findings l r (Closed) E:cconpliance (50-010/77-2E; 50-237/77 25; 50-249/77-15) - Teilure to conduct required searches of individuals who required escort in the prot ected area. Obser ation of access control activ-ities disclesed tht: the licensee is cocplying with the Of fice of Nuclear Elector Iegulation (NT,E) staff position with respect to "pa t-down" sc ar ches. (Closed) Nonconpliance (50-010/77-2E; 50-237/77-25; 50-249/77-25) - j Teilure to positively control licent re designated vehicles. Several t ours of the protected area vere condu:ted in which vehicles were inspected for keys lef t in the ig,ition. None vere fcund. Guards [ ))( are required toF'
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Strl U 7t?li g L:r:ttic: f' (C2osed) Nancerp3f ance (50-010/78-21; 50-237/7E-10; 50-249/78-10) - lack of continuous corcunication by each guard, vat chran, or response individual on duty with the continuously canned alarr station. Inspection disclosed that additional radios have been purchased to All radios i provide ccn unication capability for each guard on duty. inspected were found to be in operable condition. (' Closed) Unresolved Iten (50-010/77-28; 50-237/77-25; 50-249/77-25) - require frequent access. Tai 3ure to audber badges for. persons who do not (10 CTE 73.55(d)(5) - Fu:bered Picture Badge Identification Syste=). the lice:see has since nu bered all tsdges Inspection disclosed that in the syster, thus they are in full cocpliance with the regulatory requirezent. lopen) Unreselved Item (50-010/77-25; 5D-237/77-25;.50-249/77-251 - JThe j ly ~ i '6?fice of Fuclear Icactor Aegulation has advised RIII that this issue I should recain unresolved until the Modified Amended Security Plan is reviewed and approved. Closed) Unresolved Ite: (p0_010/77-28; 50-237/77-25; 50-249/77-25) - to this requirement ud11 be l NF.I's position with respect forwardid to the licensee for their action. 3. 10 CTE 73.55 Irplementatien_ On Septedber 5,1976, several RIII security inspectors met with the CICo responsible project engineer and the nuclear security coordin-etor at corperate headquarters for the purpose of reviewing the inp2crentation schedule for all of the operating Cot:envealth Idison to tresden station, the inspecters nuclear stations. With respect the intent of the were advised that the licensee expects to reet I Tinal 23, 1979 by equivalent ceasures. regu3 ation by Tebruary 20, 1979. cocpletion of new constro tion iters is expected by July i The inspectors observed that the new gatehouse facility {lete. (([isstructurallycoup access contici point into the Use of the facility es cr.e caia 23, 1979. - The licensee prot ect ed area is expected by Tebruary int ends tc continue utilicing the prcsent f' ' ~ ~ Posts for the additicnal protected area barrier have been instfil led.,The licensee is avaiting delivery of the fence fabric. T, J 4_ 1srt 0.???(f) 1
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l _1 10 CTR 73.55(b)(4) states, in part: "The licensee shall not permit an individual to act as a guard, va:chran, or arred response indi-vidual unless such individual has been properly trained and quali fied........ " Contrary to (he above, a guard had not received the(p_. [ ~] The inspectors conductt/ a co plete audit of guard training anc oualificatior files. The audit disclosed a a nu ber of deficiencies, that if they are not corrected, vill result in iters of non:orp15 ante af ter a;;reval of the Modified A= ended Security plan. M:st of.the deficien: docu entation was rise noted in an audit conducted by the licensee it.:.ugust 1978. The above ites of noncocp1 dance resulted fro: corrittents cade in the existing approved security plar. The N?.1 a:dit also disclosed tha: at least /O e guards received approxins:ely six:een hours of their initial tra.'ning eight conths subsequent te si:e assignment. The latter had be-identified by the licensee and corrected prior to the inspectien. ~~ q, With respect to the guard lacking the recuired training in the licensee initiated irredia:e ccrrective action by ordering the particular individual suspended un:11 the training has been acco:- plished and docu ented. Te pre:1ude recurrence, the licensee has astablishec the policy that ne guard vill be accepted for assignment unless that individual has cc ;1ered a[1 training and corriete documentation of training and cualification is provided. This finding represents apperent n:nco:pliance (Deficiency) with the above stated requirecents. 5. Thysical terriers V S Jr.rt E.fi:[f)
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IErt 2.7.:0[ 'JN:f:rtti:: Contrary to the abeve, object s captble of concealing an individual vere found within the isoletion zone on two occasions. On October 10, 1978 at approxicately 1900 hours, the 1;RC inspectors, accocpanied by the Station Security Adninistrater, observed that stack of lutber, a gproxir.ately eight f eet in length ani five feet in vidth, was located i l j On the noted ces.asions, the objects vere found on the east side of the protected area, an arca of heavy construction activity. Irrediate corrective action was initiated by the removal of the mat erial the day it was discover -d. To preclude recurrence, the licensee cade a cornitnent to re-ltstruct guards regarding the isolation rene. Tnis findinE represents apperent ncnco pliance (Infraction) with the above stated requirement. 6. Testing anc Mainter.ance a. 10 CTF. 73.55(g)(2) states: "~e ch intrusion elarm shall be tested for perforrance at the Leginning and end of any period that it is used for security. If the period of continuous use is lonpr than seven days, the intrusion ala = shall also be tested at least once eve y seven (7) days." Contrary to the above, intrasion alem tests exceeded the seven day requ rerent on four o:casions. A review of the site " Security System Electronic Surveillance Test Checklists" fo: the peried of May 6 - October 12, %;S was conducted 0:to' er 17,197E. Intrusion alart t ests, exceeding the.cquired time I!:its, were doeurented for the f ollowing dates: Date of Tests Days Between Tests 5/26-27/78 and 6/4-5/78 L l 6/15/78 and 6/23/75 5 l 6/23/78 a ' 9/4/75 12 I 9/4/75 and 9/12/78 8 Tnese findings represent a; parent noncompliance (Deficiency) with the above stated require:ents. b. 10 CTR 73.55(g)(1) states in part: "All alarus, cor.nunication equip =ent, physical barriers, and other security r<1ated devices or equip =ent shall be caint a *ned in operable condit f or.." {srj 2,7i~ild) -i t rr t t i::.
~ IErt 2,7?O(,,/ Inf.r:tt$co i Cont rary to the abov'e, the physical barrier of the p; ot ect ed arca was not caintained in a,n operable condition. ~ ~ ~ ~ ~ ~ ~ ~ 1976, during a test ofthej ' ~ ~ ~ ~ ~ ~ ~ On October 13, i i k T,e den.onstra :f on was vitnessed by the Station Security Adtinis-trator. At the direction of the Statien Security Of ficer, the area affectedby[{,{ ~} A cotritnent was cade during the exit meeting to re-train guards in what to look for during barrier inspections. The finding represents appare:t nonco:pliance (Infraction) vith the above stated require:ent. 7. Access Controls ~ e. 10 CFR 73.55(d)(4) states in part: "All vehicles, except ender energency conditions, shall be searched for iters which could be used for sabotage purpeses prior to entry into the protected area. Vehicle areas tr be searchec shall inclu6e the cab, engine ec=partment, und ercarriage, and cargo c.r ea." i Contrary to the above, during the course of this inspection, vehic3 es ent ered the protected area without a cocplete search as required. The NRC inspectcrs conducted observations of protected area vehicle entry precedures during periods of 0700-0600 hours, Oct ober 13,1978 and 1500-1600 hours, 0:tober 18, 1978. During each occasion, three vehicles vere admitted to the protected area without a search of the vehicin undercarriage. Int erviews with(([ 'lsecurity personnel revealed this search require ent had been a subject of proce-dural training and was faniliar to thec. l This deficiency represents ap;arent noncompliance (Deficiency l vith the above stated require:ent. b. 10 CFL 73.55(d)(1) states, in part: "The licensee shall centrol all points of personnel.... access into the protected i ares. Ident; fication....of a:1 individus1s....and autheri-i zat ion shall be checked...." l k l ~7-j hart 2,71;[c)
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\\ / er stio: Itrt 2.750 sJ 4 ~ 1 1 I t 'I l I l s Contrary to the above, a revie. of records and int erviews with [ personnel shewed that visiters vare granted adrittance to the prot ect ed arca {~~ 7 An exar:ination of the "T,ecords cf Ad ittance" forcs for the period May I through October 12, 1978 vas conduct ed by the inspectors on 0:t ober 16,197E. 'The "Eecords of Adrittance" fore provides space for the nace cf the individual authorizing entry into the protected area. T..e guard reccrds the nace of the individual granting access to the protected aren The 4 .I inspectors noted that on Septe rer 8 and 16,1978,[a~ j It should be noted that ihFinspectors reviebed appresinately fivt thousand entrie.2 ~~ of adcittance. On the above Indica,t ed dat es, a tctal of two individuals were granted access by unauthorized individuals. j The above finding 2 epresents apparent nonco:pliance (Deficiency) l vith the above statec require ents. h . Isrt 2.7f0ii) Iftt: Silon
I 7Ert 1.7. ticr:r.'.1cn B. T.esponse Controls q i e Contrary to the above, on drills con Prior _t o the dat e of the inspec tio:,,d_uc t ed_fo_ r_one _ cal endar year._ r __- Inspection c.isclosed that at least _ A coczitment was c.ade to per-fer such cot unication verificati:ns on future security drills. l Tne finding represents nonco:plian:e (Defir br.cy) with the above stated require:ent. 9. Exit Meeting At the conclusien of the inspec!3o: on October 19, 1978, a meeting was held with statf or. r nagement and others noted in Paragraph 1 to discuss the results of the inspection. The senior ce:ber of the NRC security ir.spectics tea: reviewed each ite: of noncocpliance. No substantive rebuttels were offered. Tne licensee was advised that it ediate corrective action had been accomplished where appro-priate, but that in several iters, action to preclude recurrence vas required. Tne licensee noted that the it e=s of noncorpliance vere the result of hussn error, rather than a lack of adequete i procedures. Tne cen.itrent was caf e to retrain security force personnel in these areas of the se:urity progra= vhere noncoc-lia,ce vas found during the current inspettion. This commitment was acceptable te t.he NEC inspertors. The inspectors expressed concern with the existing personnel turn-o.yer within the_ security guard feret. It was not ed that e r4than b f g 4. t 8 -9_ P E: t 1,72 :( ~
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