ML20133N808
| ML20133N808 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/01/1985 |
| From: | Bailey R, Keimig R, Martin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20133N805 | List: |
| References | |
| 50-352-85-22, NUDOCS 8508140009 | |
| Download: ML20133N808 (14) | |
See also: IR 05000352/1985022
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-352/85-22
Docket No.
50-352
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License No. NPF-27 .
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Licensee:
Philadelphia Electric Company
2301 Market Street
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Philadelphia, Pennsylvania 19101
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Facility Name:
Limerick Generating Station
Inspection At: Limerick, Pennsylvania
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Inspection Conducted: April 17 - 19 and 22, 1985
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Date of Last Physica'l Security Inspection:
February 4 - 8, 1985
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Type of Inspection
Special Physical Security Inspection
Inspectors:
[h4
8'/ '8[
R. J Baile ' Ph sic
$6curity
date
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to
L
.Ms
P/45
f W. G. Martin, pfy'sical Se(frity
date
nspector
Approved by:
uo M
C& ,w
h//8f
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R./R. Keimig(, Chief,
/ / date
SafeguardMection, DRSS
Inspection Summary:
Special Physical Security Inspection on April 17 - 19,
and 22, 1985 (Inspection Report No. 50-352/85-22)
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Areas Inspected:
Special inspection to determine the state of training of se-
curity force personnel at the licensee's facility and their ability to carry
out their assigned duties. The inspection consisted of:
reexaminations of a
statistically selected sample of security force personnel in qualification /re-
qualification tasks; observations of examination administration; interviews of
security personnel; reviews and evaluations of examination results; and,
followup on previous violations and inspector concerns. Additionally, a review
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of a PECO letter dated April 3, 1985, which outlined planned improvements in
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the implementation of the security program for Limerick, was conducted. These
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plans for improvement were submitted in response to several security violations
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identified in a routine physical security inspection conducted on February 4-8,
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1985, and to the licensee's commitments for corrective actions discussed at an
Enforcement Conference held at Region I on March 11, 1985.
In addition, a
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review of security events which was conducted during Inspection No. 85-12
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8508140009 850802
ADOCK 05000352
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(February 4-8,1985) is included in this report. The inspection involved 64
manhours on site by two region-based inspectors and began during regular hours;
4 inspection manhours were accomplished during off shift periods.
Results: The inspectors determined that security force personnel are suffi-
ciently knowledgeable to carry out their assigned duties.
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DETAILS
1.
Persons Contacted
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G. Leitch, Station Superintendent
J. Franz, Assistant Station Superintendent
J. Basilio, Administrative Engineer
J. Larkin, Nuclear Security Specialist
P. Supplee, Site Security Supervisor
R. Weindorfer, Assistant Corporate Security Directei
J. Wiggins, NRC Senior Resident Inspector
The inspectors also interviewed other licensee personnel and members of
the YOH Contract Security Guard Force.
2.
MC 30703 - Exit Interview
The inspectors met with the licensee representatives listed in paragraph 1
at the conclusion of the inspection on April 22, 1985. At that time, the
purpose, scope and results of the inspection were reviewed.
During this
meeting, the licensee provided a status of security personnel reexamina-
tions and requalification and stated that all testing would be completed
by May 1, 1985. The licensee further stated that this would be confirmed
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in a letter to Region I.
(By letter of April 30, 1985, PECO confirmed the
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commitments made during the exit interview and stated that all security
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personnel had been successfully requalified.)
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At no time during this inspection was written material provided to the
licensee by the inspectors.
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3.
Inspection Objective
The objective of this special inspection was to have the licensee
demonstrate that individuals in the security force are trained to perform
the security related tasks, identified in the licensee's physical security
and/or contingency plan, to which they are assigned. To meet this objec-
tive, the inspectors utilized a statistical sampling plan, based upon
Military Standard -105 D, " Sampling Procedures and Tables for Inspection
by Attributes," to achieve results at a 95% confidence level.
The
inspectors requested the licensee to test a statistical sample of security
force members in the tasks to which they were assigned, using the testing
criteria by which they were previously deemed qualified for those tasks.
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The individuals who were to be tested were randomly selected by the
inspectors from the roster of personnel qualified in each of three job
categories: Supervisors / Armed Personnel; Watch Personnel; and, Central /
Secondary Alarm Station (CAS/SAS) Operators. One hundred and fourteen
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examinations were administered by the licensee and monitored, on a random
basis, by the inspectors. The inspectors reviewed and evaluated the
examination results and interviewed examiners, other security force
personnel, and licensee and security force contractor management
representatives.
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The inspection also included routine follow-up on licensee commitments
contained in an April 3, 1985 letter to NRC Region I regarding improve-
ments in the security program (Paragraph 7) and documents routine
.nspector follow-up on Security Event Reports which was inadvertently
omitted from Inspection No. 85-12, February 4-8, 1985.
4.
Testing Program
Following is a description of the testing program directed by the
inspectors and carried out by the licensee for the three job categories.
a.
Basic Qualifications for Supervisors / Armed Personnel and Watch
Personnel
Nine basic, task specific tests are used by the licensee to qualify
individuals for assignment to the job categories of Supervisors / Armed
Personnel and Watch Personnel.
Eighty-six individuals were randomly
selected by the inspectors from the total number of individuals in
these two job categories and a total of 109 tests were administered
by the licensee. Ten individuals failed a total of eleven tests.
This indicated statistically that 85% of security force members in
these two categories are able to carry out the duties and responsi-
bilities associated with those nine tasks.
b.
Additional Qualification for Supervisors / Armed Personnel
In addition to the nine basic, task specific tests discussed above,
Supervisors / Armed Personnel are required to qualify in weapons
through written and firing range testing.
(1) Weapons Qualification
All armed personnel were previously tested at a firing range
on October 23, 1984. This testing was witnessed by an NRC
inspector. There were no failures.
(2) Other Qualification
The written portion of the qualification in this job category
was administered by the licensee during this inspection.
Eight
individuals were randomly selected by the inspectors from the
total number of individuals in this category for testing. After
four of the eight failed the test, further testing was discon-
tinued since that indicated a statistically unacceptable failure
rate and all individuals in that job category would have to be
retrained and requalified. The licensee agreed to carry this
out prior to May 1, 1985.
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c.
Qualification for CAS/SAS Operators
Five individuals were randomly selected by the inspectors from the
total number of individuals in this job category.
Each was tested
and met the licensee's established qualification standard.
5.
Testing Program Results
The inspectors determined that the security force members are adequately
trained to carry out their assigned duties and responsibilities, with the
exception of those in one job category (Supervisors / Armed Personnel) who
are required to demonstrate certain additional qualification beyond the
nine basic tasks.
Compensatory measures were immediately initiated and remedial training was
promptly administered for all individuals who failed any portion of the
tests included in the testing program.
With regard to the Supervisors / Armed Personnel job category, where
statistical results of the written test indicated that personnel were not
adequately trained to carry out the additional duties and responsibilities
of their job assignment, the inspectors interviewed and monitored the
on-the-job performance of several individuals carrying out those duties
and responsibilities.
The inspectors determined that these individuals
were sufficiently capable of carrying out their assigned tasks to be
permitted to remain on the job without adversely affecting the physical
protection of the facility.
The inspectors advised the licensee to
reevaluate the training program and written test to determine their
effectiveness in qualifying individuals for those additional duties and
responsibilities.
6.
MC 92700-Followup on Security Program Event Reports
During a routine safeguards inspection conducted on February 4-8, 1985 the
inspector reviewed numerous security event reports that had been submitted
by the licensee to Region I as reportable events in accordance with 10 CFR 73.71 (c). The inspector conducted an in-office and onsite review of
Security Event Report Numbers 84-08 through 84-18 and 85-01 through 85-07.
The inspector verified that adequate compensatory measures had been taken
for each event. The licensee had provided adequate security force
response to and documentation of the events. One generic problem was
identified in that the majority of reportable events for 1984 and 1985
were as a result of computer failures,
i.e., disk drive failure and trans-
fer problems associated with the redundant security computer. The compu-
ter contractor was trying to isolate the problems.
To date, the licensee
has demonstrated they can provide adequate compensatory security measures
when they experience computer problems.
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7.
MC 92703-Followup on PECO Correspondence dated April 3, 1985, Relating to
Security Program Improvements
The following inspector findings address the licensee's short and long
term security program improvement commitments as contained in a letter
to Region I, dated April 3, 1985.
PART I - PECO INTERIM IMPROVEMENT PROGRAM
PECO QUALITY CONTROL INVOLVEMENT
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A.
Post Instructions
Inspector Findings:
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The inspector verified that:
(1) the post instruction format is a
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computer generated standardized form that can be changed to respond to
various changes and contingencies; (2)
security Instruction 001, dated
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March 13, 1985, establishes guidelines for the preparation, control and
distribution of post orders (the terms security instruction and post
order can be used interchangeably); (3) twenty-eight post orders were
revised and distributed between March 15 and April 11, 1985; (4)
currently, the PEC0 Quality Control Group is responsible for the monitoring
of post orders. This responsibility will be transferred to the YOH
Security Inc., corporate staff performance analysis group when it is
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formed.
B.
Key Control
Inspector Findings:
The inspector verified that a revised itdtructional level document
(SI-002) on Key Control was distributed on March 11, 1985. The security
instruction provides clear and concise direction for key issue and inven-
tory control . Monitoring by PECO Quality Control resulted in the revi-
sion. The licensee intends to transfer the monitoring function to the
Y0H Security, Inc., corporate staff performance analysis group when it is
formed.
C.
Personnel Qualifications
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Inspector Findings:
The inspector verified by review that the YOH Security Force Duty Roster
had been revised. The roster provides guard force supervision with a list
of qualified individuals to perform various post duties. The duty roster
is computerized which eases its updating and maintenance. Additionally,
no individual is allowed to perform security duties until all phases of
the employment process are completed.
Review by the inspector of Quality
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Control Audit L-85-QC-008, dated March 1,1985, revealed that auditors
were monitoring post assignments to ensure that only fully qualified
personnel were performing security duties.
D.
Security Plant Procedures
Inspector Findings:
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The inspector verified that Quality Control Audit L-85-0C-007, dated
March 1, 1985, supported commitments made by the licensee that plant pro-
cedures were being reviewed against actual operational security methods.
For example, the QC auditors observed that the security organization was
recording key control on an unapproved form. As a result, Plant Proce-
dures PP-031-1 (CAS/SAS System) and PP-028-1 (Lock and Key Control) were
revised to reflect current operating procedures.
Security instructions
SI-002 (Lock and Key Control), dated March 11, 1985, SI-005 (Performance
of Security Surveillance Testing), dated March 26, 1985 arid SI-006 (Site
Security CAS/SAS Implementation), dated March 27, 1985, were cited as not
being definitive. These instructions were subsequently revised to reflect
current operating procedures. The revised procedures and instructions
appeared adequate.
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E.
Surveillance Testing
Inspector Findings:
The inspector verified that Security Instruction SI-005 - Performance of
Security Surveillance Testing was distributed on March 26, 1985. This
document was developed to coordinate the surveillance testing activities.
YOH Security, Inc. conducted a training session on March-18, 1985 for YOH
security supervisors to make them aware of the enhanced surveillance
testing instruction.
YOH Security has identified a supervisor to
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coordinate and manage performance testing and surveillance of all security
related equipment on a scheduled basis.
F.
Central / Secondary Alarm Stations
Inspector Findings:
The inspector verified that Security Instruction SI-006 (Site Security
CAS/SAS Implementation) dated March 27, 1985, was distributed to consoli-
date program requirements for routine operations in the CAS/SAS.
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G.
Weapons and Miscellaneous Security Equipment
Inspector Findings:
The inspector verified that security supplies were procured and were
in the equipment room. A draft of Security Instruction SI-014 (Weapon
Control) had been developed by the Quality Control Section on
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April 15,1985.
Interim instructions were posted in the armory until
approval of the instruction. The licensee expected this to occur by
May 3, 1985.
In a telephone discussion on May 9, 1985, the licensee
informed the inspector that SI-014 (Weapon Control) was distributed
for use on April 30, 1985 and that a copy was posted in the armory.
H.
Delegation of Authority
Inspector Findings:
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The inspector verified that job responsibilities for supervisory personnel
were clarified and were included in each appropriate security instruction.
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In addition, the inspector reviewed proposed job descriptions for each
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position within the security organization.
These appeared to include
the required crucial task identified in the Training and Qualification
Plan. The Physical Security Plan describes the authority and
responsibility assigned to each supervisory level within the security
organization.
In a telephone discussion on May 7,1985, the licensee
informed the inspector that job descriptions for all jobs within the
security organization will be published on May 13, 1985.
In a telephone
discussion on May 22, 1985, the licensee informed the inspector that this
task was completed on May 9, 1985.
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I.
Communications
Inspector Findings:
The inspector verified that during the month of March,1985, a review of
the different types of communication devices and capabilities was con-
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ducted by Quality Control personnel along the barrier interface of Units 1
and 2.
The purpose of the review was to determine if there were adequate
communication capabilities available to security officers. The review
revealed that additional equipment was required. The inspector confirmed
that this equipment had been installed.
J.
Summary Statement
Inspector Findings:
The inspector observed that the Quality Assurance Audit completed on
April 15, 1985, identified five administrative procedural deficiencies
and no operational deficiencies. The Administrative Engineer was in the
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process of replying to the audit. The security program deficiencies
identified by an earlier Quality Control Audit were also in the process
of being answered by the Administrative Engineer.
K.
YOH Security Consultant
Inspector Findings:
The inspector observed Mr. M. Annast, a consultant to YOH Security, Inc.,
on site. The consultant had proposed several changes to strengthen imple-
mentation of the security program by YOH Security.
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PART II - PERSONNEL TURNOVER REDUCTION
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A.
Reduce Scheduled Overtime
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Inspector Findings:
The inspector reviewed payroll records for the period December 28 -
January 3, for sergeants, corporals and CAS/SAS operators and observed
that these personnel had their hours, including overtime, reduced from an
average of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> to 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> per week. Guards continued to work 60
hours per week until April 15, 1985, at which time they were placed on
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three eight hour shifts. Total hours, including overtime, were 45.
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During the week of April 15, 1985, the licensee had to alter the work
hours of the guard force in order to respond to NRC security inspectors
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who observed the licensee reexamining a sample of the force. The licensee
stated that long delays were being experienced in receiving the
Pennsylvania Lethal Weapons Act Firearms Certification. This delay has
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had an impact on the number of qualified armed personnel available and,
therefore, the amount of overtime they must work.
B.
Improved Working Conditions
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Inspector Findings:
The inspector verified that the licensee had constructed a special
ready room for security force personnel located across from the Main
Guard House. The area includes communications, toilet facilities and
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individual lockers. Startup problems with certain security equipment
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required manning compensatory posts during inclement weather which was
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partly responsible for a high personnel attrition rate. The licensee
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had installed weatherized guard booths and they were observed at several
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compensatory posts throughout the site. The equipment problems are
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currently being corrected and work is expected to be completed in
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July, 1985.
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C.
Wage and Benefit Package
Inspector Findings:
The inspector reviewed a PECO letter to Y0H Security, Inc. dated
February 28, 1985, relative to the results of a wage and benefit com-
parative analysis with other industries and similar work forces in the
region. The results indicated that with the exception of one item in
which improvement could be made (medical benefits), the remaining pay
rates and compensation package appears equitable for the region.
D.
Resignation Interviews
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Inspector Findings:
The inspector verified that during interviews with Y0H Security staff per-
sonnel, the security force Captain conducted approximately 20 resignation
interviews since January, 1985. With the exception of personnel citing
working conditions and long working hours as the cause for resignation,
there appeared to be no one predominant cause for the high rate of
resignations.
E.
Screening
Inspector Findings:
Because of a finding that a member of the security force had falsified
his employment history record, NRC Region I issued a Confirmatory Action
Letter (CAL No. 84-24) on November 9,1984, requiring the licensee to
review the screening program for security personnel and to ensure that
an adequate background investigation was conducted on each member of the
guard force, with particular emphasis on covering all periods of past
employment and personal history. The inspector verified that the licensee
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notified the security force contractor by letter on March 13, 1985, to
completely screen all guard force personnel before they are sent to
training and to ensure that all periods of employment were validated.
To
reinforce this procedure, the licensee submitted a revision to the Train-
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ing and Qualification Plan (Revision 3), dated April 19, 1985, to NRC
Region I outlining new background screening requirements for employment
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and guard qualification. The inspector verified that since January 1,
1985 all personnel accepted for employment with the security force have
had their background information verified for completeness by key PECO
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staff personnel.
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F.
Performance Evaluations
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Inspector Findings:
The inspector verified that a performance rating system was in effect.
However, the performance rating system was undergoing review to make
improvements.
G.
Classroom Training
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Inspector Findings:
The inspector verified that classroom training lesson plans on lock and
key control, the security contingency plan, and notification of security
events to NRC were revised by March 28, 1985.
Security force supervision
attended a remedial training session involving security awareness and key
control on March 18, 1985. The inspector verified that the remainder of
the security force was trained on those topics by April 5, 1985.
Four
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individuals initially failed their examinations, were retested and passed
on April 10, 1985.
Expanded security training on security program
deficiencies identified by NRC has been included in appropriate annual
security requalification training.
H.
Security Awareness Information
Inspector Findings:
The inspector verified that security awareness information was published
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by the security force contractor in the form of notices and daily
bulletins.
In addition, the inspector reviewed special checklists that
contained security awareness information. This information was being
presented at each guardmount.
I.
YOH Corporate Performance Analysis Group
Inspector Findings:
The inspector verified that three individuals were assigned to the
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corporate performance analysis group and a fourth was in process of being
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selected. The inspector reviewed the resumes of the four individuals and
found that they have a minimum of three years training and experience in
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supervision, management, or quality assurance at a nuclear facility. The
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three assigned individuals had been making periodic visits to the site,
lasting two to three days, for orientation. On May 10, 1985, in a tele-
phone conversation, the licensee stated that the fourth member of the
group had been selected.
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Site Performance Analysis Group
Inspector Findings:
During discussion with a licensee representative, the inspector was
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informed that five individuals have been selected to form a site
performance analysis group under YOH Security. This matter will be
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reviewed in a subsequent inspection.
(IFI 85-22-01)
K.
Security Organization
Inspector Findings:
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In discussions with security representatives, the inspector was provided a
security organizational and functional chart which reflected the existing
structure of the Limerick security organization.
(See Attachment 1 to
this report). The chart reflected those changes and commitments made to
NRC Region I at the Enforcement Conference held on March 11, 1985.
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L.
Quality Assurance / Quality Control Activities
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Inspector Findings:
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The inspector verified that a Quality Assurance audit, AL 85-19-PL, was
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performed on March 21, 1985. The licensee stated that after the security
contractor implements the five man site performance analysis group,
the PECO Quality Control Section will conduct a minimum of three days
of monitoring of the security force on a quarterly basis.
M.
Audits
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Inspector Findings:
The inspector verified that, since November, 1984, the licensee had ini-
tiated security program audits by two professional security organizations,
Burns International Security Agency and J. Devlin Associates,
in an ef-
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fort to strengthen the program in several operational security areas.
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Additionally, the inspector verified that the Quality Assurance Audit for
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1985 was completed on March 21, 1985, and that the annual independent au-
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dit by the PECO Claims Security Division was completed by April 15, 1985.
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PHILADELPHIA ELECTRIC COMPANY
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ATTACHMENT 1
UEANT7ATIONAL & FUNCTIONAL CHART
ITCUlriTY 0EANi7ATIM
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VICE PRESIDENT
VICE PRESIDENT
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ELECTRIC
LEGAL
PRODUCTION
DEPARTMENT
PLANT
ASSOCIATE
MANAGER
GENERAL
COUNSEL
SUPERINTENDENT
CLAIMS-SECURITY
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0F OPERATIONS
DIVISION MANAGE' -
SUPERINTENDENT
DIRECTOR OF
0F SERVICES
SECURITY
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ADMINISTRATIVE - - - - - !
ENGINEER
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NUCLEAR
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ALARM
SPECIALIST
REVIEWER
SITE SECURITY
SUPERVISOR
MANAGERIAL RESPONSIBILITY
,., , _ ADVISORY AND CONSULTING RESPONSIBILITY
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SECURITY
COORDINATOR
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SECURITY
COORDINATOR
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SCREENING
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YOH CONTRACT SECURITY ORGANIZATION
_ PRESIDENT
CORPORATE
Y0H SECURITY.
PERFORMANCE
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INCORPORATED
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ANALYSIS
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SITE
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MANAGER
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PERFORMANCE
ANALYSIS
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CAPTAIN
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TRAINING
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SITE SECURITY
DEPARTMENT
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LIEUTENANT
SHIFT
SHIFT
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OPERATIONS
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SUPERVISOR
SUPERVISOR
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ADMINIS M TION
=
U RVISOR
U RVISOR
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SUPERVISOR
- AS/SAS OEPRATOR$
MANAGERIAL RESPONSIBILITY
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,,, ,, ADVISORY, CONSULTING & QUALITY ASSURANCE
RESPONSIBILITY
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SERGEANT
SURVEILLANCE
TESTING
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