ML20138H101
| ML20138H101 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 04/30/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20138H073 | List: |
| References | |
| 50-282-97-07, 50-282-97-7, 50-306-97-07, 50-306-97-7, NUDOCS 9705070071 | |
| Download: ML20138H101 (9) | |
See also: IR 05000282/1997007
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION lli
Dockets Nos:
50-282: 50-306
Licenses No:
Report Nos:
50-282/97007(DRS); 50-306/97007(DRS)
Licensee:
Northern States Power Company
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Facility:
Prairie Island Nuclear Generating Plant
Location:
1717 Wakonade Dr. East
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Welch, MN 55089
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Dates:
April 7 & 8,1997 onsite
April 16,1997 in NRC Region lli Office
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inspector:
G. Pirtle, Physical Security inspector
Approved by:
James R. Creed, Chief, Plant Support Branch 1
Division of Reactor Safety
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9705070071 970430
ADOCK 05000282
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EXECUTIVE SUMMARY
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Prairie Island Nuclear Generating Plant
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NRC Inspection Reports 50-282/97007; 50-306/97007
This announced inspection included a review of the Vehicle Barrier System. Temporary
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instruction 2515/132 " Malevolent Use of Vehicles at Nuclear Power Plants" was used for
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inspection guidance.
No violations or deviations were noted. The features and structures that form the Vehicle
Barrier System (VBS) met the design characteristics established by the NRC. The vehicle
barrier components, or acceptable other barriers, and the location of the barriers were as
desedbed in the summary description of the VBS submitted by the licensee to the NRC, or
as described in the current security plan. Two unresolved items and three inspection
followup items were noted as described below:
An unresolved item was noted pertaining to a portion of the VBS not having
an engineering analysis completed to confirm that the barrier would be
effective against the design basis vehicle (Section S1.1.b(1)(a)).
An inspection followup item was noted pertaining to the need to revise the
security plan in response to NRC review comments for Revision 36 of the
plan which addressed the VBS (Section S1.1.b(1)(b)).
An inspection followup item was noted pertaining to some procedure
deficiencies noted during the inspection (Section S1.1.b(3)(b)).
An inspection followup item was noted pertaining to the need to prepare a
memorandum for record as part of the executive summary that was sent to
the NRC to describe the barrier designs finally installed and noting that the
correct barrier locations are described in the security plan (Section
S1.1.b(1)(c)).
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Report Details
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Conduct of Security and Safeguards Activities
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S1.1 Tamoorarv instruction 2515/132. "Y^volant use of vebiel== at Noetaar Power
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Plants"
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Insoection Scone (Tl 2515/132)
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Areas examined included the licensee's provisions for land vehicle control measures
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to protect against the malevolent use of a land vehicle and to determine compliance
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with regulatory and licenses commitments.
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b.
Observations and FiodjDE&
(1)
yghicle Barrier System
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The inspector found that the features and structures that form the Vehicle
Barrier System (VBS) met the design characteristics established by the NRC,
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except for a small portion of the VBS which did not have an engineering
analysis completed (See section a below). The vehicle barrier components
and the location of the barrier were as described in the summary description
of the VBS submitted by the licensee to the NRC or as described in the
security plan. Acceptable barriers that were not identified in the executive
summary were also used.
A visual walkdown performed by the inspector confirmed that the general
type of vehicle barrier described iri the VBS summary description or an
acceptable alternate type of barrier had been installed and that the barrier
was continuous. No significant signs of barrier damage was noted during
the walkdown of the VBS. The inspector also confirmed that the active
barriers (gates) at two locations had manufacturer's certifications that the
barriers would meet or exceed the maximum parameters of the design basis
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vehicle threat. One unresolved item and two inspection followup items were
noted during the review of the VBS and are addressed below:
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(a)
A portion of the VBS did not have an engineering analysis completed to
assure that the barrier could meet the maximum parameters of the design
basis vehicle threat (the exact location end construction characteristics of
that portion of the barrier system is considered safeguards information until
resolved). This issue will be monitored as an Unresolved item (50-
282/97007-01(DRS); 50-306/97007-01(DRS)). Resolution of this issue will
be addressed by separate correspondence.
(b)
Revision 36 of the licensee's security plan addressed the VBS. NRC Region
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lil review of Revision 36 to the security plan was completed and the licensee
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was advised of the review results by letter dated April 2,1997. The
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licensee had not received the April 2,1997 letter before the inspection
ended. The letter contained several review comments that the licensee
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needs to respond to. Resolution of this issue will be monitored as an
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inspection Followup item (50-282/97007-02(DRS): 50-306/97007-
02(DRS)).
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(c)
Barriers installed in some aspects are different than the barriors described or
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discussed in the executive summary provided to the NRC. All barriers
observed were considered acceptable based upon the engineering analysis
obtained or performed by the licensee. The licensee agreed to prepare a
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memorandum for the record which clarifies that (1) part of the VBS has been
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located differently than indicated in the executive summary sent to the NRC
and (2) identifies the design of the current barriers in use (Enhanced and
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Super Barriers). The memorandum for file would be maintained with the
executive summary that was sent to the NRC. This issue will be monitored
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as an inspection Followup item (50-282/97007-03(DRS); 50-306/97007-
03(DRS)).
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(2)
Bomb Blast Analysis
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inspector field observations of standoff distances were consistent with those
documented in the summary description. The licensee confirmed that
calculetion of minimum standoff distance was based on NUREG/CR-6190 or
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an independent engineering analysis. Five actual measurements were
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completed to confirm that the minimum standoff distances, as documented
in the summary description, were the actual or greater distances provided by
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the as-built VBS.
(3)
Procedural Controls
The licensee appropriately defined criteria for maintenance, surveillance, and
compensating for the VBS in appropriate procedures. The procedures were
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generally well written and detailed except as noted in (b) below. Discussions
with the Superintendent, Security (who is a licensed reactor operator)
confirmed that procedures necessary to safely shutdown the units after a
bomb blast were reviewed and found to be adequate. A specific procedure
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for damaged equipment by a bomb blast was not prepared, but the existing
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abnormal operation and emergency operating procedures were corsidered
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adequate to cope with loss of equipment because of a bomb blast.
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(a)
Dunng review of procedures, it was noted that the licensee's procedure for
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reporting and logging security incidents / events (SIP 5.1, " Guidelines For
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Reporting Events *) did not identify what degradations or vulnerabilities
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would be reported to the NRC or logged as security events / incidents in
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accordance with 10 CFR 73.71. Existing NRC guidance for reporting sad
logging security events / incidents does not describe examples of VBS
degradations or vulnerabilities that warrant reporting or logging. This issue
will be monitored as an Unresolved item (50-282/97007-04(DRS); 50-
306/97007-04(DRS)).
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(b)
During review of security procedures, the following weaknesses were noted
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and correction of the weaknesses will be monitored as an inspection
Followup item (50-282/97007-05(DRS); 50-306/97007-05(DRS)).
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The procedure for logging and reporting security events (SIP 5.1,
" Guidelines For Reporting Events") incorrectly' stated that secudty
event logs must be sent to the NRC on a quarterly basis. This
requirement has been terminated for several years.
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The procedure for Vehicle Barrier System compensatory measures
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(SIP 5.0, " Compensatory Measures") does not require the NRC
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Region Office to be contacted if compensatory measures for the VBS
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exceed 30 days as identified in section 4.2 of Nuclear Energy
institute (NEl) Document 96-01, which the licensee has committed to
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for compensatory measures.
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The tamper test acceptance criteria for the cable gate pole needs to
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be changed to conform with the existing adequate testing practices.
The tamper switch has the capability to detect movement well before
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the gate would be ineffective as a barrier. The acceptance criteria in
the procedure needs to be more descriptive of that capability.
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c.
Conclusions
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The iicensee's provisions for land vehicle control measures met regulatory
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requirements and licensee commitments. The VBS program was consistent with
the summary description submitted to the NRC (except as noted in this report) or
the security plan; installed components were identified in NUREG/CR 6190 or the
licensee's engineering analyses; and appropriate proceduras had been developed
and implemented. Unresolved items were noted pertaining to the lack of an
analysis for a portion of the VBS, and lack of licenses procedural guidance for
reporting or logging VBS degradations and vulnerabilities. Inspection followup items
were noted for administrative matters that required action.
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Miscellaneous Security and Safeguard issues
S8.1 A discovery of a licensee operating its facility in a manner contrary to the Updated
Final Safety Analysis Report (UFSAR) description highlighted the need for a special
focused review that compared plant practices, procedures, and/or parameters to the
UFSAR descriptions. The inspector verified that the wording of the UFSAR was
consistent with observed plant practices, procedures, and/or parameters within the
areas inspected.
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Exit Meeting Summary
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The inspector presented the inspection results to members of the licensee management at
the conclusion of the onsite inspection on April 8,1997. The licensee acknowledged the
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findings presented. The inspector requested the Superintendent, Security to mail identified
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security procedures to the NRC Region 111 Office for review. The documents were received
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April 16,1997.
The inspector asked the licensee whether any materials examined or inspection findings
discussed during the exit meeting should be considered as proprietary or safeguards
information. It was agreed that the specific location and specific construction criteria for
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the portion of the VBS that had not had an engineering analysis completed should be
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treated as safeguards information until the issue is resolved. No other proprietary or
safeguards information was identified.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee:
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D. Axt, Nuclear Security Program Coordinator
D. Dugstad, Engineering Associate
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T. Escher, Generation Quality Services Auditor
D. Hutchson, Nuclear Security Specialist
R. Oelschlager, Project Manager
S. Samson, Project Engineer
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D. Schlintz, Generation Quality Services
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M. Sleigh, Superintendent, Security
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J. Sorensen, Plant Manager
E. Timmer, Nuclear Security Specialist
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NB.C
Steven Ray, Senior Resident inspector
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INSPECTION PROCEDURE USED
Tl 2515/132
" Malevolent Use of Vehicles at Nuclear Power Plants" issued
January 18,1996
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ITEMS OPENED
Onened
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50-282/97007-01
A Portion of the Vehicle Barrier System Did Not Have an
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Engineering Analysis Completed.
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50-306/97007-01
A Port on of the Vehicle Barrier System Did Not Have an
Engineering Analysis Completed.
50-282/97007-02
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The Security Plan Requires Revision To Address NRC Review
Comments for Revision 36 of the Plan
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50-306/97007-02
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The Security Plan Requires Revision To Address NRC Review
Comments for Revision 36 of the Plan
50-282/97007-03
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Memorandum To File is Required to Clarify Information
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Contained in the Executive Summary Sent to the NRC
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50-306/97007-03
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Memorandum To File is Required to Clarify information
Cr ruined in the Executive Summary Sent to the NRC
50-282/97007-04
6. c.ria For Logging and Reporting Vehicle Barrier System
Degradations as Security Events
50-306/97007-04
Criteria For Logging and Reporting Vehicle Barrier System
Degradations as Security Events
50-282/97007-05
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Some Procedural Weaknesses Were Noted
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50-306/97007-05
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Some Procedural Weaknesses Were Noted
LIST OF ACRONYMS USED
Central Alarm Station
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inspection Followup item
Protected Area
Secondary Alarm Station
Updated Facility Safety Analysis Report
Unresolved item
Vital Area
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Vehicle Barrier System
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PARTIAL LISTING OF DOCUMENTS REVIEWED
Preliminary Engineering Study of the implementation of the NRC Final Rule Amending 10 CFR Part 73 Protection Against Malevolent Use of Land Vehicles, Undated
Submittal of Vehicle Barrier System Summary Description: dated February 24,1995
(Executive Summary)
Certificate of Conformance for the Model TT212 Series Cable Beam Barrier System,
undated, from Delta Scientific Corporation
Certificate of Conformance for the Model SC3000S Series Cable Reinforced Cantilever
Gate System, undated, from Delta Scientific Corporation
Surveillance Procedure humber 1648, " Vehicle Barrier System inspection Procedure"
Revision 0, Approved May 14,1996
Preventative Maintenance Procedure Number PM 3800-1," Security Fence Gates and
Guardhouse Turnstiles," Revision 14
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Surveillance Procedure Number 1604, " Annual PA/ISFSI Barrier inspection," Revision 15,
Approved June 20,1996 (Safeguards information)
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Surveillance Procedure Number 1651, " Weekly Perimeter intrusion Detection (PIDS)
System Test," Revision 17, Approved May 22,1996 (Safoguards information)
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Security implementing Procedure Number 1.3, " Vehicle Admittance / Control," Revision 8,
Approved February 27,1997 (Safeguards information)
Security implementing Procedure Number 1.6, " Site Area Description," Revision 3,
Approved February 29,1996 (Safeguards Information)
Security implementing Procedure Number 3.2, "CAS/SAS Operations," Revision 7,
Approved December 5,1996 (Safeguards Information)
Security implementing Procedure Number 3.4, " Security Patrols," Revision 4, Approved
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February 29,1996 (Safeguards Information)
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Security implementing Procedure Number 5.0, " Compensatory Measures," Revision 3,
Approved August 2,1996 (Safeguards Inf mation)
Security implementing Procedure Number 5.2, " Security Response to Site Emergencies,"
Revision 3, Approved November 1,1996
Security implementing Procedure Number 5.1, " Reporting of Security Events," Revision 4,
Approved ' January 23,1997
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Contingency Plan Implementing Procedure Number 3, " Bomb Threat / Discovery / Response,"
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Revision 6, Approved February 29,1996
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