ML20045G486
| ML20045G486 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/02/1993 |
| From: | Keimig R, King E, Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20045G482 | List: |
| References | |
| 50-289-93-12, NUDOCS 9307140031 | |
| Download: ML20045G486 (9) | |
See also: IR 05000289/1993012
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-289/93-12
Docket No.
50-289
License No.
Licensce:
GPU Nuclear Corooration
100 Interoace Parkway
Parsippany. New Jersev 07054
Facility Name:
Three Mile Island. Unit 1
Inspection At:
Middletown. Pennsylvania
Inspection Conducted:
May 17-21.1993
Inspectors:
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G. C. Smith, Seniorysical Security Specialist
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E. B. King, Physdecurity Inspector
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Approved by:
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[R. R. KeimIg, C
f, Safeguards Section
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Division of Rad 'on Safety and Safeguards
Areas Inspected:
Licensee and local law enforcement agency (LLEA) response to the
February 7,1993, forced intrusion into the protected area of TMI-1; the licensee's intrusion
protection strategy; contingency drills; safety / safeguards interface; assessment system; and land
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vehicle bomb procedure.
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Results:
Weaknesses were identified in the LLEA response and the licensee's intruJon
protection strategy. The licensee was aware of these weaknesses prior to the inspection and, J
the time of this inspection, was in the process of developing corrective actions. No violations
of the NRC-approved Physical Security program plans were identified.
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9307140031 930702
ADOCK 05000289
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DETAILS
1.
Key Persons Contacted
GPU Nuclear Corporation
- T. G. Broughton, Director, TMI-l
- M. A. Nelson, PRG Chairman, TMI-1
- R. E. Rogan, TMI Licensing Director
- M. K. Pastor, Nuclear Security Director
- J. F. Stacey, Site Security Manager
- S. P. Mervine, Support Training Manager
- R. G. Goodrich, Senior Security Supervisor
- S. E. Williams, Nuclear Safety Compliance
- D. F. Moyer, Lead Instructor, Protection Training
D. W. Atherholt, Lead Operations Engineer
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D. Barry, Security Engineer
D. Hassler, Licensing Engineer
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Pennsvivania Decartment of Environmental Resources
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- R. Janatti, Nuclear Engineer
U. S. Nuclear Reculatory Commission
- R. Cooper, Director, Division of Radiation Safety and Safeguards
- M. Evans, Senior Resident Inspector
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- F. Young, Senior Resident Inspector
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D. Beaulieu, Resident Inspector
R. Keimig, Chief, Safeguards Section
Pennsvivania State Police
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K. E. Doutt, Captain
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The inspectors also interviewed members of the licensee's security, operations,
maintenance and licensing staffs.
2.
Backcround
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On February 7,1993, an intruder drove a vehicle through a locked vehicle gate in the
TMI protected area (PA) fence and crashed through a metal roll-up door into the turbine
building. 'Ihe intruder remained in the PA for approximately four hours before being
apprehended.
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Because of the potential security significance and potential regulatory questions raised by-
the event, the NRC Executive Director for Operations established an Incident
Investigation Team (IIT). The IIT reviewed the event and issued NUREG-1485 in April
1993 to document its findings and conclusions. This inspection was conducted to review
the potential compliance issues identified by the IIT in the area of physical security.
3.
NRC Review of Potential Reculatory Compliance Issues
A.
Licensee Response to the Event
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The inspectors reviewed the licensee's NRC-approved Physical Security Plan,
Contingency Plan and Training and Qualification Plan (the Plans), Security
Procedure A420-IMP-1530.06, dated 12/16/92, " Physical Protection of Protected
and Vital Areas," chronologies developed by the licensee and the NRC after the
incident, and interviewed alarm station operators and response personnel. The
results of the reviews and interviews disclosed the following:
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Several of the Site Protection Officers (SPOs) who were on patrol when
the event began were near the response positions identified in procedure
A420-IMP-1530.06 and immediately responded to those positions.
The SPOs who initially went to those response positions did not have
shotguns because they were not carrying a shotgun and would have had
to leave their assigned response positions to obtain one. As other SPOs
who were called in from horne arrived onsite, shotguns were delivered to
those SPOs. The licensee recognized that a shotgun is preferred over a
handgun as a response weapon and, before the event, was in the process
of examining options to make response weapons more readily available to
response personnel.
The licensee's decision in this regard will be
reviewed during a subsequent inspection. (Inspector Follow-up Item
50-289/93-12-01)
SPOs acting as escorts and some SPOs acting as search officers were
dispatched, armed with shotguns. The SPOs who did not have shotguns
elected not to carry them because they would be cumbersome when
searching in close quarters and climbing ladders.
The applicable
procedure, A420-IMP-1530.06, did not require the SPOs to be armed with
shotguns. Additionally, the licensee's tactical training program did not
include close quarters training with long guns.
This is noted as a
weakness in the training program and will be reviewed in a subsequent
inspection. (Inspector Follow-up Item 50-289/93-12-02)
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At the time of the incident, a SPO, who was also designated as an armed
responder, was performing a patrol outside of the PA, and another SPO,
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also designated as an armed responder, was located just outside tue PA,
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in the Process Center. The location of these armed responders did not
conflict with the NRC-approved Physical Security Plan because the
locations of the armed responders and other security personnel on duty are
not specified in the Plan.
At the request of the licensee's Emergency Director, (the Director,
Operations and Maintenance) the patrols identified in procedure A420-
IMP-1530.06 were not conducted for several hours after the event began
because the SPOs who would have conducted those patrols were involved
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in other response activities. This departure from the procedure appeared
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to be appropriate under the circumstances.
Central and secondary alarm station (CAS/SAS) activities and actions
during the event were determined by the inspectors to be in accordance
with applicable procedures. However, due to the high level of activity in
the CAS during the event, the CAS operator's ability to perform all
required tasks was severely challenged. The licensee recognized this
problem, and, in an attempt to correct it, revised the response procedures
since the event to require a second operator in the CAS during an event.
The efficacy of this action will be reviewed during a subsequent
inspection. (Inspection Follow-up Item 50-289/93-12-03)
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B.
Local Law Enforcement Acency (LLEA) Resoonse to the Event
The inspectors reviewed the licensee's Plans, the Memorandum of Understanding
(MOU) with the Pennsylvania State . Police (PSP), and interviewed the
Commanding Officer of the local law enforcement ageng (LLEA) having
jurisdiction at TMI and licensee security management personnel. The results of
the inspectors' reviews and interviews were as follows:
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The then current (May 4,1992) MOU with the PSP identified the
numbers of PSP Troopers that would be able to respond within specified
time frames. During the event, the numbers of troopers identified in the
MOU did not arrive within the time frames specified.
This was
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considered a weakness.
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The Commanding Officer stated that the commitments in the 1992 MOU
were based on estimates and, when it was determined after the event that
the committed numbers of troopers could not be guaranteed within the
specified time frames, the MOU was revised by the PSP. The revised
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MOU reduces the number of trcyrs who would mitially respond and
extends the time for the remaining troopers to respond.
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The only LLEA personnel who had participated in contingency training
with the licensee's security organization were members of the PSP Special
Emergency Response Team (SERT). The SERT arrived approximately
three hours after the event began.
The inspectors determined through review of applicable procedures and
discussions with the licensee that the licensee had already initiated action
to revise its contingency response procedures to deal with a protracted
LLEA response time. The adequacy of the licensee's action in this regard
will be reviewed during a subsequent inspection. (Inspection Follow-up
Item 50-289/93-12-04).
C.
Licensee Intrusion Protection Strategy
Based on a review of U.S. NRC Regulatory Guide 5.54, the Plans, the
circumstances, and interviews with personnel, the inspectors determined that the
licensee's intrusion protection strategy was in compliance with the Plans.
However, the inspectors determined that the following conditions limited the
effectiveness of the licensee's response:
The responsibility matrices found in the licensee's Contingency Plan were
summarized, as required, in a procedures summary for each postulated
event.
The procedure summaries are intended to be simplified
presentations of the assigned security force responsibilities for use in
training and implementation of the Plan.
They do not have to be
submitted to the NRC for approval. The adequacy of the procedures
summaries for their intended uses appeared marginal based upon the
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following.
The CAS operator on duty during the event expressed frustration to the
inspectors over the lack of details in the Contingency Plan procedures
summaries with regard to command and control at the onset of the event.
The operator resorted to a recently developed and implemented procedure,
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A420-IMP-1530.06 (12/16/92), that contained specific response and
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protective strategy needed to mitigate the event. This procedure resulted
from tne licensee's change in protective and tactical strategies that
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occurred in late 1992. for all contingency events. Some confusion on the
part of the CAS operator apparently resulted from the limited amount of
training received since the new procedure was implemented.
Another weakness in command and control was identified during the
event. As a result of the limited initial LLEA response, the licensee's
planned response to such an event could not be carried out. Even though
the number of SPOs on site at the time of the event was as committed to
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in the Plan, there were not sufficient officers to establish and staff a
command post and conduct other operations until additional LLEA officers
and SPOs arrived onsite.
A weakness was also identified in search and clear operations. Initiation
of searches for the intruder was delayed because of limited initial LLEA
response and because the SPOs on duty remained at their response
locations, per procedure. As additional SPOs arrived on site, searches
began and continued until the intruder was apprehended.
The SPO who told the Control Room Operators to lock the fire doors did
so only because that action was always taken during previous security
drills; it was not required by security procedures. Locking the doors
inhibited implementation of the licensee's emergency callout procedures.
(This issue is being reviewed further by the Region I Emergency
Preparedness Section.)
To correct these specific weaknesses, the licensee was taking or had taken the
following actions:
Security procedure A420-IMP-i530.06, " Physical Protection of Protected
and Vital Areas," was revised to address the immediate establishment of
a command post when a security event occurs. Additionally, a new
procedure that integrates the LLEA and licensee security force response
activities was being developed.
New procedures were being developed for incorporation into the
Contingency Plan (CP).
The procedures will address the Security
Command and Control Center, Land Surface Vehicle Bomb Threat, Use
of 10 CFR 50.54 (x) and (y) (addresses reasonable departure from a
license condition or technical specification in an emergency if approved
by a licensed senior operator), Site Protection Force Contingency
Response, and the responsibilities of the Security Operations Shift
Supervisor, Central Alarm Station Operator and Secondary Alarm Station
Operator.
A call out process was being developed to ensure the availability of
additional SPOs to respond to an event, when required.
The licensee has taken or plans to take additional significant measures to enhance
the physical security of the station. These measures are exempt from public
disclosure under 10 CFR 73.21, Safeguards Information, and, therefore, are not
further discussed in this report.
However, they will be reviewed during
subsequent inspections. (Inspector Follow-up Item 50-289/93-12-05)
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D.
Licensee Contineency Drilh
Based on a review of records of drills conducted between 1991 and this
inspection, and interviews with appropriate Training Department and Security
Department personnel, the inspectors determined that the licensee was conducting
approximately 40 contingency event drills per year, that Security Department
management was actively involved in the conduct of these drills, and that the
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critiques of the drills were being utilized as an effective mechanism to provide
feedback for improvement. The inspectors also reviewed the effectiveness of the
licensee's corrective action program for the previous two years. They found only
a small number of repetitive weaknesses identified and a declining trend in those
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that were identified.
Additionally, shortly prior to the event, the licensee
developed enhanced protective strategies for the station, began to train its SPOs
in improved tactical response and conducted more comprehensive dril6 to
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exercise that training in conjunction with the new protective strategies.
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The inspectors reviewed the drill scenarios utilized over the past two years
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and found that the licensee was conducting drills that addressed the more
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sigmficant contingency events identified in the CP.
A review of training records indicated that a critique was conducted after
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cach drill and a copy of the critique forwarded to the Training Department
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for review and tracking. Drill weaknesses were analyzed and tracked and,
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if a repetitive weakness was identified, it was incorporated into the
training plans as a " lessons learned" issue.
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The licensee effectively used the training program, in lieu of procedural
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revisions, to correct weaknesses identified during drills.
This was
because the CP procedures summaries were not detailed procedures but
rather listings of actions to be taken and decisions to be made which did
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not lend themselves to meaningful revisions.
Regularly scheduled meetings were held between Security Department and
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Training Department management to discuss training issues and, if
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needed, to develop additional training to address security operations
concerns.
E.
Safetv-Safeeuards Interface - Emereency Access to Vital Areas (VM
The inspectors reviewed the Plans, the Vital Area (VA) key procedures and
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inventories, and interviewed security personnel, reactor operators and auxiliary
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operators. The results of the reviews and interviews were as follows:
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All security personnel on-shift at the time of the event carried VA hard
keys and also had access to the VAs via key cards and the " zap in"
system.
Five operations personnel carried VA hard keys at the time of the event.
They were the Shift Foreman, the Control Room operator, and three
auxiliary operators.
When interviewed during this inspection, all
operators and auxiliary operators could identify the VA keys on the key
rings.
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The licensee is revising its procedure for emergency access to vital areas.
It will be reviewed during a subsequent inspection. (Inspector Follow-up
Item 50-289/93-12-06)
F.
Assessment System
The inspectors reviewed the Plans, the preventive maintenance program for the
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assessment system, interviewed CAS and SAS operators and' the Security
Instrument and Control (I&C) technician who maintains the system, and observed
the system in operation.
The results of the reviews and interviews were as follows:
The assessment system was designed, installed, maintained, and operated
in accordance with the NRC-approved Security Plan. At the time of this
inspection, the licensee was evaluating the system for further possible
enhancements.
The system received routine, scheduled maintenance by a dedicated I&C
technician and was being monitored, on a daily basis, for clarity, contrast,
and operability.
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G.
Land Vehicle Bomb Procedure
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The inspectors conducted a review of the licensee's Land Vehicle Bomb-
Contingency Procedure contained in GPU Nuclear Security Department procedure
A400-PLN-1530-01, " Security Standby / Counter Measures", Rev. O, dated
1/29/93. That procedure was preceded by another Security Department procedure
which was reviewed by an NRC inspector in October 1990. The inspectors
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determined that the procedure satisfied the requirements of the NRC Generic Letter 89-07, which identified the requirements for land vehicle bomb
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contingency planning. The inspectors also determined, based on observations and
discussions with security supervisors, that they were knowledgeable of the
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procedure, its content and location. The licensee's procedure detailed short-term
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actions that could be taken to protect against attempted radiological sabotage
involving a land vehicle bomb if such a threat were anticipated.
4.
Exit Meetine
The inspector met with the licensee representatives identified in paragraph I at the
conclusion of the inspection on May 28, 1993. A representative of the Pennsylvania
Department of Environmental Resources and the Region I Director, Division of Radiation
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Safety and Safeguards also attended the exit meeting. At the exit meeting the purpose
and scope of the inspection were reviewed and the findings presented. The licensee
acknowledged the inspection findings.
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