ML20055C207
| ML20055C207 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/04/1988 |
| From: | Bangart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Partlow J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20055C208 | List: |
| References | |
| FOIA-89-540 NUDOCS 8802250266 | |
| Download: ML20055C207 (15) | |
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~'i . MEMORANDUM FOR: James G. Partlow, Director J$
[ Division of Reactor Inspection and Safeguards, NRR FROM:_ Richard L. Bangart, Director Division of Radiation Safety and Safeguards Region-IV
SUBJECT:
REFERRAL OF TECHNICAL ISSUES PROVIDED TO OIA DURING THE SOUTH TEXAS PROJECT INVESTIGATION
REFERENCE:
S. CONNELLY MEMO 0F NOVEMBER 25, 1987, TO V. STELLO; SUBJECT, SAME AS ABOVE-Enclosed is the Region IV response to the 11 issues forwarded by OIA to the EDO in the referenced memorandum. These responses are being provided based on your telephone request of December 3, 1987. This material was received for our action on or about December 10, 1987. We have endeavored to: provide as complete a response as possible to each item based on our understanding of the issue.
The broad allegation made by the former Manager, Nuclear Security at STP was that:
"The NRC Region IV security inspection team ratcheted Houston Lighting and Power Company (HL&P) into security plan commitments and unnecessary procedural practices by insisting upon their personally approved corrections of minor and pseudo deficiencies."
b.'< believe that our response to the 11 issues disproves that claim and under-scores Region IV's position that the preoperational inspection at STP was conducted in accordance with published NRC inspection procedures (IE Manual Chapter 2513 - 81000 series) to ensure that the plant's safeguards program and-security systems conformed to regulatory requirements and security _ plan commit-ments. The Region IV security inspectors performed their -task in a thorough, rigorous, and conscientious manner. During our initial dealings with the licensee,-Region IV had evidence in the fo_rm of internal memoranda and inter-views with licensee personnel that Security and Maintenance personnel had detected numerous inadequacies in the design and implementation of the STP security systems. Because of this situation and schedular problems, liceasee. Security line managers adopted a strategy of challenging many regula-tory positions raised by the NRC inspectors and providing systems whose perfor-mance was inadequate with the hope of meeting minimum requirements. Because of these circumstances, which became clear during the- early preoperational inspec-tions, the Regional Administrator directed me the first week in June,1987, to establish a close coordination with Headquarters to assure that substantive positions given to STP were fully concurred in by HQ personnel.
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Communication with headquarters staff occurred regularly since the fall of 1986, and essentially on a daily basis from the week of June 22 through the second week in August. In addition, the NRR security plan reviewer and his=
section chief were onsite for several days during the inspection period.. Any_
security plan changes proposed during this period were generated by the licensee and coordinated closely with the headquarters staff. Region IV management provided direction to the inspection effort by having the first-level supervisor-(Branch Chief 5 onsite with the inspection team during much of the period, by having mana;ement at the Division Director level in frequent communication-with HL&P at e Vice President level through telephonic and onsite contacts, and by having vaily briefings conducted for the Regional Administrator. Decisions of regional management < led to the extensive inspection coverage in order to be able to revuw licensee actions soon af ter they were completed. The Region IV inspectors did not operate independently, but instead worked closely with the !'
headquarters physical security staff and project organization, Region IV management, the 01 Investigative staff, and the onsite NRC resident inspectors '
to maintain balance and perspective.
lt is Region IV's position that Mr. Hill's allegation of over-regulation by the Region IV security inspectors, as articulated in the general _ statement and the 11 specific issues, is unsubstantiated and was motivated, to a large extent, by a desire on Mr. Hill's part to excuse his performance as the security 1 manager at STP. Mr. Hill was removed from his position on August 3, 1987, af ter two of his senior supervisors had been replaced in late July. We believe that the regulatory positions taken by the Region IV inspectors in coordination ,!
with HQ did not exceed established regulatory requirements or security plan commitments. We believe prompt resolution of-this matter is achievable and we wo'uld be pleased to meet with you for detailed discussions regarding this i-response if clarification is needed.
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R. L C\ Naut Richard L. Bangart, Director
- Division of Radiation Safety and Safeguards
Enclosure:
l-Region IV Responses to Over-Regulation Assertions D. Martin lJi l~
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. t ENCLOSURE REGION IV RESPONSE TO OVER-REGULATION ASSERTIONS General Comments:
In evaluating -the : broad allegation of over-regulation by Region IV, we felt that several factors illustrated this strategy or attitude demonstrated i by'the licensee. These factors included the following:
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- 1. The STP security program was being directed by a security manager with minimal experience at other nuclear plants that reflected a security knowledge level 3 to 5 years out of date, t
! 2. The licensee's-lack of knowledge of.the regulations and their own security plan, (As an example,. some licensee personnel were unaware that -
Regulatory Guide 5.44 was a requirement in their plan.)-
- 3. Funds to accomplish work were limited such that the licensee appeared L unwilling to make necessary improvements to security equipment to make it I acceptable. (See A. Hill's testimony on pages 46 and 47 regarding HL&P's-handling of the closed circuit television system problems.)
! 4. HL&P's reluctance-to do anything more than what they considered the l minimum required and their belief that anything additional- was 'over-regulation on the NRC's part. (This item was first evident to Region IV l inspectors in November 1986 when the interim fuel storage license had to '
i be delayed for over a month until HL&P upgraded the fuel storage security -
I' program to meet regulatory requirements. This~is discussed in report 50-498/86-37; 50-499/86-37, paragraph 15).
An' independent confirmation of the initial inadequacies in the HL&P physical l security program occurred as a result of a review of organization and. guard-qualificatior.s by the Texas Board of Private Investigators and Private Security Agencies, af ter NRC and State of Texas officials had met to discuss mutual concerns. That agency identified over 800 violations of Texas regulations by E both HL&P and Wackenhut, the con'.ract guard force company, and took independent- t L regulatory action. based on Texar regulation. As a matter of fact, the Wackenhut security officers were not qualified per Texas regulations to carry weapons. -This situation was not resolved until August 4, 1987, when the guards were recertified by the State of Texas.
As the preoperational inspection reached the fina, stages in July 1987, l licensee claims of over-regulation became more pronounced because of two l- additional factors. First, the inspection was revealing the scope of the licensee's-inadequacies in many safeguards areas, and extensive effort was required by HL&P to reach acceptable. levels. But the licensee viewed this
-extensive effort as unnecessary and an attempt by Region IV to force them to exceed regulatory requirements and security plan commitments. Second, during-the period of continual site coverage in July and August, issues were discussed
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c at= length and various options were considered on almost a daily basis. As1 these discussions occurred, it became apparent to Region-IV inspectors that-HL&P licensing personnel who were assisting security were operating in a
- reactive mode. They would take hold of something said and initiate action without appropriate review to implement corrective measures with the hope of '
satisfying the NRC and bringing STP closer to a license. Region IV personnel !
repeatedly stated that it was not their place to propose or recommend solutions to licensing issues, but to articulate only the regulatory requirements that "
needed to be met. It-seems that now as we look back on that process, Mr. 1:111-remembers only the numerous discussions and interactions and has forgotten the qualifying statements made by Region IV personnel. Also, it is important to ,
remember that the 2 month period before licensing was a '.ime of stress for both 1 the NRC and HL&P, and the licensee felt under pressure to do whatever was necessary to be recommended for a fuel load license, s
In addressing the manner in which Region IV conducted the preoperational' ;
inspection, we believe that a review of the inspection reports would show that ;
l the technical issues identified by Region IV did not fall outside regulatcry '
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bounds as claimed by Mr. Hill. Many of those items identified by the NRC inspqctors had already been found and documented by HL&P in their own punch '
lists and QA audits, but were not receiving action. This review would also show that the Region IV inspection effort was more.than'just a narrowly focused check of f of line by line items in the inspection modules. In a broader; sense,- :i the inspection effort addressed the issues of licensee performance and security program adequacy as evidenced by the substantial commitment of inspection resources in- the areas of the security plan and implementing procedures, management effectiveness, and the security organization. We recognize that h assessments made in these areas are, often of necessity, subjective and therefore might be viewed as ratcheting by the licensee, but we believe that
, the assessments and evaluations made by the Region IV inspectors were correct i . and fell within the regulatory bounds established by the regulations and the
- security plan. ,
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l Specific Commentsi
- 1. Issue:
-NRC inspectors required the utility to place additional barbed tape / razor wire at unnecessary fence location.
Response:.
Inspection Procedure 81052, Physical Barriers - Protected Area, is based-on the requiremencs of 10 CFDf51(c)(1) through (c)(3).
Paragraphs 03.02 b.5 and 6 state that the effective f.eight of the fence must not be decreased by objects close to the fence and that the' outer
. isolation zone must not contain anything that could provide a jumping or bridging path over the fence.
The NRC. inspectors identified r.umerous poles, camera towers, detection aids, and camera control b ues that reduced the effective height of the fence / barrier and in many nases provided a jumping or bridging path over the. fence; The licensee's :orrective action'to the open item was to install razor tape on the fence at the locations in question rather than relocate the poles, towers, boxes, etc. .The NRC inspectors concluded upon reinspection.that the addition of the barbed tape brought the barriers into compliance with the regulation, i
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- 2) . Issue: ,
Inspectors required the utility to add locking mechanismsf to protect .
A electronically alarmed security system features "inside" the protected-area.
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Response
Inspection Procedure 81066, Assessment Aids is based on the requirements of 10 CFR.73.55(a), (c)(3) and (4), and (bl(,4) and (6).. Paragraph 03.03 6 directs the inspector to evaluate the system integrity of the CCTV intrusion alarm assessment system by determining if tamper-indicating alarms will be displayed when the covers of the CCTV junction boxes are opened.
-The NRC inspectors determined that CCTV junctions boxes "inside the.
protected area" did not have tamper alarms on the covers but did have line ,
supervision for the cable. system. The NRC inspectors determined in 1 Section 6.7.1 b of the plan that HL&P was committed to enclosures a conforming to the requirements of Interim Federal Specificationt W-A-00450-8 and Regulatory Guide 5.44. Both types of alarms (tamper and - i line supervision) are required for security devices. For the licensee 1 to be in compliance, HL&P would-have had to install tamper alarms on the CCTV junction box enclosures. -The licensee was informed of the requirement to provide tamper alarms on the CCTV junction box enclosures, and they were-told that an acceptable alternative used at other sites would tue to seal the enclosures with epoxy as specified in'W-A-00450-8 or lock them. HL&P chose the easiest alternative and installed locks on the enclosures and- .j the Region IV inspectors evaluated this corrective: action as-acceptable. ;
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- 3. Issue:
Inspectors required the utility to write inspector " approved" Plant "
Manager policy letters on the access control of personnel, vehicles.- and packages. ,
Response
Plan _and Implementing Procedures, I NRC is basedInspection Procedure on the requirements 81018, of_10 CFR 73 Security _T55tb)(3)r and and 10 CF i 50.90 and provides direction concerning the review of the approved security plan and the implementing procedures. The plan and procedures are required by 10 CFR 50 as a part of the licer. sing process. HL&P organized their plan in accordance with the guidance provided in NUREG 0908, " Acceptance Criteria for the Evaluation of Nuclear Powers Reactor Security Plans," a id committed in the plan to meet the standards set in that NUREG. To achieve'that end and satisfy the license requirements, certain procedures are needed to guide the actions and !
responses of the onsite personnel. l HL&P had placed the preparation of sacurity program procedures as a low-priority item at STP, and the Region IV inspectors had identified this 3 situation early in the inspection process-under open items 498/8732-01, -
498/8714-03, and 498/8714-04.
The STP plant manager and the HL&P licensing personnel acknowledged that ',
procedures'would be necessary for site personnel to use in performing duties associated with the security progr.m. Because the security _
organization was behind schedule in prept-ing procedures, the plant manager began the practice of-issuing policy statements about specific actions to be implemented by plant personnel as they related to security.
Those. policies served as interim measures while. procedures were being
. developed and approved. These policy statements, mostly dealing with:
access practices, were not initiated or approved by the NRC. The fact .
that the Plant Manager.of Operations found-it necessary to write policy statements to allow his operations personnel to function in the security:
environment when there was a void in security procedures is an additional indication of program inadequacy.
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- 4. Issue: :
NRC inspectors required the utility to create vital area key control '
measures that go beyond the regulations, Response: t o
inspection Procedure 81046, Locks, Keys, and comb _i_ nations, is based on the requirements of 10 CFR 73.55[d)T7), Paragraph 02.01 states that it should be verified shat all locks, keys, combinations, and related equipment used to control access to protected and vital areas are protected and '
controlled. .
The licensee was unable to demonstrate a system which would provide '
e positive control of security keys by ensuring that the keys were issued only to personnel with authorized access and returned to the issuing point ,
prior to the individual leaving site. The NRC inspectors discovered during the preoperational inspection that HL&P's system allowed security keys to be taken offsite, that they were not being controlled by the person to whom issued, and that key cards were being issued to the wrong ;
persons. The lictnsee modified their procedures and caused a security program for the secerity computer to be created that prevented persons l with security keys f rom carding out of the site until the keys were turned in. The NRC inspector: concluded upon reinspection that the licensee instituted changes to the lock and key control system provided positive control and the licensee satisfied security plan commitments, ;
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NRC inspectors dictated the utility's test procedures.
Response
Inspection Procedure 81042, Testing and Maintenance, is based on the requirements of 10 CFR 73.55(a) and (g)(1) through (4).
Paragraph 03.03 c does contain the statement quoted by Mr. Hill. This quote is made out of context however, because Region IV was also inspecting under paragraph 03.07, Preoperational and Acceptance Testing, which requires the inspector to verify that the licensee has tested equipment af ter installation "to demonstrate effectiveness and ability:
(i) to meet manuf acturer's design criteria and performance specifications, and (ii) to meet the licensee's acceptance criteria for performance."
This specific allegation is related to the testing of the E-field intrusion detection system. In this circumstance, the licensee was committed to Regulatory Guide (RG) 5.44 in the security plan. The minimum qualification for the perimeter intrusion detection system is the detection of stimulus or a condition for which the system was to react.
RG 5.44, paragraph C.l.c.(1), E-field perimeter alarm system performance criteria require the E-field to have the ability to detect an individual crawling or rolling, stepping or jumping, or jumping over the top sensing wire. Proper detection is defined in RG 5.44, paragraph C.2.b (2) as the
'! ability" to detect an intruder with at least 90 percent probability in each segment of the isolation zone, with 95 percent confidence, under the conditions stated in the performance criteria of RG 5.44, paragraph C.I.e.(1). The document states that other testing methods may 1
be used if the methods are fully documented and approved by the N3 The testingNRC inspectorswith in accordance found RG that 5.44,STP was performing paragraph onlyis)the C.2. q 1 which specification manufacturer's recommended test and calibration procedures. The NRC inspectors found that no other testing method other than the required testing of RG 5.44, paragraph C.2.b.(2) performance testing had been approved by NRC. STP had failed to meet the two elements of performance testing of an E-field intrusion device as described in RG 5.44, paragraph C.2.b. The licensee claimed that they did not have to demonstrate compliance with detection probability and confidence levels as described in RG 5.44, paragraph C.2. In addition, Region IV determined ;
from a review of vendor / licensee correspondence that the E-field system at i STP did not meet the manufacturer's installation criteria. STP also !
failed to seek an approved NRC alternate testing method for per'ormance testing in accordance with RG paragraph 5.44 C.2.b.(2).
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- 6. Issue:
, NRC inspectors required the utility to establish special charts as aids for security shift supervisors.
Response
Organization, is based on the '
NRC Inspection requirements of 10 CFR Procedure 73.55(a)81022.
and (E) Security (1). 02.01 a., 02.02 c.
Paragraphs 02.03 b., and 02.03 c. instruct the inspector reviewing preoperating
- security program to verify organizational elements related to command and control, pursuant to meet the requirements of 10 CFR 73.55(a) and .(b)(1);
and 73.20(a) and 73.46(b)(1), t i
While inspecting the licensee's security organization and observing it in '
operation during routine and contingency activities, Region IV determined that HL&P secu-ity supervisors were lacking in command and control skills.
This issue was discussed in open items 498/8732-03 and 498/8732-11 and identified by the. licensee in HL&P Punch Lists A87-012 and A87-021. One of the resolutions. implemented by the licensee to enhance security shif t management was'to install status boards so that supervisors would be able-to identify personnel on duty and what posts they were assigned to man.
Although this was discusseo with the licensee as a tool to help manage security personnel, Region IV inspectors did not require HL&P to install ~
these status boards.
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- 7. Issue NRC inspectors insisted on a "two uinute" response time when the accepted security plan provides greater flexibility.
Response
J Inspection Procedure 81022, Security _ Organization, paragraph 02.06 c.3.,
requires the NRC inspector to verify that the licensee takes immediate concurrent measures to neutralize any threat upon detection of abnormal activity by interdiction of guards or armed responders. 10 CFR 73.55(a) requires the licensee to provide high assurance that activities in a
' nuclear plant are not inimical to the common defense and security and do not constitute an unreasonable risk to public health and safety. To do this, the licensee must meet the specific requirements of (b) through (h) of 10 CFR 73.55. Paragraph 9.1 of the STP Security Plan documents the licensee's commitment to the response requirements of 10 CFR 73.55(h)(4)(tii)( A).
In implementing this comraitment, the licensee had failed to understand the definition of "immediate" or "immediately." The licensee had made the mistaken application that the 10 minute interval for setting a compensatory post in accordance with 10 CFR 73.71(c), footnote 4, was equivalent to making an immediate response for. interposing or assessing a threat. Region IV inspectors explained that the 10-minutes was used in 10 CFR 73.7)(c) as the basis for establishing if proper compensation for an event had been made, which in turn dictated whether a 1-hour or a 24-hour notification was to be called to the Headquarters Operations Officer. Instead, it appears that "immediate response" was interpreted by STP as allowing up to 10 minutes (a) to determine whether or not a threat exists, (b) to assess the extent of the threat, and (c)_to take concurrent measures to neutralize the threat. The licensee interpreted all intrusion alarms to be the result of personnel error and not threat related; therefore, 10 minutes was considered an adequate interval of time to respond to intrusion alarms, The NRC inspectors informed the STP staff that 10 minutes was unacceptable and that 2 minutes was an attainable and reasonable response time.
HL&P reluctantly agreed to accept the definition of immediate as responding to an intrusion alarm within 2 minutes where assessment by CCTV was not possible. The licensee considered this a ratchet by Region IV.
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- 8. Issue:
l NRC inspectors dictated certain methods of tactical deployment and staff additions by the security force. This included an NRC inspector -
performing as theobserver drill scenario approver, aofmember of the agg'ressor :
force, evaluator, and scorekeeper "who shot whom.
Response
f Inspection Procedure 81022, Security Organization, paragraphs 03.04 a, c, and d states that the inspector will " select specific scenarios such as ,
attempted intrusion . -. . to determine if the tactics used were consistent with professionally recognized tactics . . . Response to intrusion may be
- evaluated by reviewing the PSP and procedures, by a test, or by review of '
test results, to assure that the response times of the response force to an intrusion, or suspected intrusion, is likely less than than the delay time imposed "by barriers and other elements of the physical protection system . . .
Inspection Procedure 81501, personnel Traininj_and Qualification, i paragraphs 03.03 a, b, and c states that the inspector will evaluate ,
demonstration of abilities by selecting " typical, safeguards contingency l scenarios . . . Observe the security personnel performing their tasks
. . . Request that special tests or exercises demonstrating the level of performance of security personnel be conducted" in his presence.
The NRC inspectors selected specific scenarios for the licensee to complete during the inspection using the above referenced modules.
Initially, the licensee was not only incapable of successfully completing a scenario by fulfilling the requirements of the Contingency Plan but was unable to develop a meaningful scenario as requested by the inspectors, i After much training, increased management 1_nvolvement, and the completion of a vulnerability analysis, the licensee was able to develop and run scenarios / drills that the NRC inspectors could evaluate in order to determine the adequacy of the security organization and its training. At ,
no time did the NRC inspectors direct the security force during their response to a drill, or direct methods of tactical deployment. During the initial contingency exercises, the NRC inspectors acted as scenario controllers / observers and accompanied the aggressor forces. They functioned as evaluators and served as scorekeepers of "who shot whom," in the words of Mr. Hill; but did not assume the role of the aggressor. The -
NRC inspectors discussed weaknesses in the tactics employed and pointed out vulnerabilities in the security system after each drill. The NRC inspector's primary functions during these drills were to observe the licensee's performance, to evaluate the adequacy of the security organization training, and to verify the licensee's capability to defend against the design basis threat as defined in his contingency plan.
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- 9. Issue:
An NRC inspector imposed subjective requirements on how the utility was to satisfy criteria for the electromagnetic field or E-field system. The inspector was only supposed to check to see if the utility followed the manufacturer's specifications. Instead, the inspector had utility personnel put themselves in physical risk to prove the system worked.
Response
Refer to response number 5 for Region IV's position on the criteria imposed to test the adequacy of the intrusion detection system. Region IV inspector $ were aware that as early as January 1987 the E-field vendor had identified potential weaknesses in the STP installation and that the licensee had been told by the vendor that the system was incorrectly installed. It appeared to us that HL&P concentrated their ef forts on circumventing the required testing procedure rather than correcting the inadequate system.
The alleger claims that the system testing "had. utility personnel put themselves in physical risk" and caused injuries. At no time did the NRC inspectors ever insist on the tester doing anything that the utility person considered dangerous. On the contrary, the NRC inspectors told the testers not to attempt anything that caused them any concern for their :
safety. No injuries occurred during NRC requested tests, although the -
licensee claimed that one person' received cuts from the rocks while testing the E-field without NRC presence. Region IV inspectors did not seek to put utility personnel "in physical risk," but did expect the licensee to perform a test that challenged obvious deficiencies in the '
system installation.
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- 10. Issue:
The NRC failed to acknowledge that 100 percent coverage with closed circuit T. V. cameras is dif ficult at certain points of the day because of the " wall effect,"
Response
Inspection Procedure 81066, Assessment Aids, paragraph 02.03 b states,
" Verify that means are provided for assessing intrusion alarms for possible threats occurring in the isolation zone . . ."
NUREG - 0908, Acceptance Criteria for the Evaluation of Nuclear Power L
Reactor Security }lans, paragraph 6.2 states fan acceptable securiti plan Eu~1d typicalTy af firin that the fixed CCTV system includes a field of view for the entire specified isolation zones (both sides of the PA barriers) as in 73.55(h)(6)."
The NRC inspectors pointed out to the licensee as early as October 1986 that the camera design for the facility would leave numerous gaps in coverage along the perimeter. Licensee representatives admitted that the design of the fixed camera system was inadequate af ter an April 1987 inspection that pointed out the same problems. Based on training and experience, the NRC inspectors were able to identify weaknesses and inadequacies prior to the cameras being activated. Upon activation, the licensee had to concede that the problems identified by the NRC inspectors did exist, The CCTV system had numerous holes in coverage and cameras attempting to shoot too far for good resolution. Additionally, the design j of the camera system caused a large percentage of the isolation zone on i the outside of the fence to be masked from assessment by fence buildup or i
" fence effect." The NRC inspectors did acknowledge that "100 percent coverage with CCTV camrras is dif ficult at certain points of the day because of the ' wall ef fect'," but they also recognized that the licensee had failed to implemert various options available to reduce the magnitude of this problem, After numerous tests and adjustments and the addition of some cameras, the licensee was able to delete the holes in coverage. The l fence effect problem was carried over as a license condition (see !
paragraph F of the license and HL&P letter of July 24,1987).
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- 11. Issue:
The NRC forced HL&P to go through a "lockdown" prior to securing its license, even though a lockdown was not explicitly required by the regulations.
Response
Temporary Instruction 2500/21, dated December 12, 1986, of the NRC Inspection and Enforcement Manual provides the direction for safeguard inspections during the preoperating phase, inspector responsibilities are described as providing reasonable assurance to NRC licensing officials that " licensee personnel, procedures, and equipment are acceptable and that the licensee is capable of operating the security program and systems in a manner that will protect the public health and safety." The instruction estimates the inspection should be conducted over an 18 month period.
IE Manual Chapter 2513 establishes the milestones and reference points for readiness to allow inspection and testing of the security program elements. The milestones are set out in terms of months prior to the operating license being issued. Appendix B of MC 2513 lists the security and safeguards inspection procedures with the expected lead times ranging from 1-month to 3-months before issuance of the operating license when the inspection should be complete.
When the Region IV inspectors began the preoperational inspection, it was determined immediately that the licensee's implementation of the security program was incomplete and that successful. lockdown could not be achieved prior to or at the time of initially scheduled fuel load. Region IV inspectors were aware that lockdown prior to licensing was not a regulatory requirement and stated this to HL&P on various occasions in the presence of other NRC personnel. Region IV did recommend that STP lockdown prior to licensing to enable the security systems and safeguards program to be " wrung out" by the licensee and to facilitate the completion of the NRC preoperational inspection program discussed above. This recommendation is uniform across all the NRC regions and was in line with HL&P's own position as stated in their meetings with us in May and June 1987, and described by Mr. Hill in his testimony on pages 58 through 60. Mr. Hill's request to lockdown early apparently was not acted upon, because STP did not achieve lockdown until the first week in August. This failure to achieve lockdown in a timely manner did hamper Region IV's efforts to complete the preoperational inspection program and make the required assessment called for in Temporary Instruction 2500/21.
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