ML20140C328

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Forwards Special Safeguards Insp 50-352/86-01 on 860102-04 & 08-09.Violations Noted:Degraded Protected Area/Vital Area Barriers & Failure to Meet Security Plan Posting Commitments & Report Loss of Security Effectiveness
ML20140C328
Person / Time
Site: Limerick 
Issue date: 01/17/1986
From: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Daltroff S
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML19302H276 List:
References
NUDOCS 8601270319
Download: ML20140C328 (2)


See also: IR 05000352/1986001

Text

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IGSIGNATED ORIGINAL

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certitta sn.h YhchAn

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JAN 171986

Docket No. 50-352

License No. NPF-27

Philadelphia Electric Company

ATTN: Mr. S. L. Daltroff

Vice President, Electric Production

2301 Market Street

Philadelphia, Pennsylvania 19101

Gentlemen:

Subject:

Inspection No. 50-352/86-01

This refers to the special safeguards inspection conducted by Mr. G. C. Smith

of this office on January 2-4 and 8-9, 1986, of activities authorized by NRC

License No. NPF-27 at the Limerick Generating Station and to t

of our findings held by Mr. Smith with Mr. G. Leitch of your y$e discussions

taff on

January 8,1986.

The inspection findings were also discussed on January 16,

1986 during a telephone conversation between Mr. M. J. Cooney and Messrs.

S. Collins and J. Joyner of this officu.

The purpose of this inspection was

to review the circumstances surrounding the identification, by members of the

plant security staff, of openings and degradations of protected area / vital area

barriers and to review allegations relative to security officers leaving their

po:ts without being relieved. Our findings are described in the Region I

Inspection Report which is enclosed with this letter.

The inspection consisted

of interviews with personnel, and observations by the inspector.

Our inspection identified three apparent violations of NRC requirements involv-

ing degraded protected area / vital area barriers, failure to meet security plan

posting commitments and failure to report a loss of security effectiveness.

We are concerned about these apparent violations, especially because barrier

deficiencies were identified in the past and reported to the NRC, but the

previous barriers surveys were inadequate as evidenced by the most recent

discoveries. For this reason, we have scheduled an enforcement conference in

our offices in King of Prussia, Pennsylvania, at 11:00 a.m. on

February 7,1986 to discuss the causal factors which led to the apparent

violations, as well as the measures you have taken or plan to take to ensure

the adequacy and completeness of your corrective actions when violations of

NRC requirements are identified. Our decision concerning the appropriate

enforcement action concerning this matter will be communicated to you

following the conference by separate correspondence.

Paragraphs in the enclosed inspection report contain details of your security

program that have been determined to be exempt from public disclosure in

i

accordance with 10 CFR 73.21 (Safeguards Information).

Therefore, the para-

graphs so identified in the inspection report will not be placed in the NRC

Public Document Room and will receive limited distribution. The inspection

report cover sheet and the remaining portions of the inspection report will

be placed in the Public Document Room, in accordance with 10 CFR 2.790(a).

OFFICIAL RECORD COPY

IR LIMERICK 8601 - 0001.0.0

01/14/86

8601270319 860117

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Philadelphia Electric Company

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JAN 171986

Your cooperation with us in this matter is appreciated.

Sincerely,

Original Signed B71

Jaces H. Joyner

Thomas T. Martin, Director

Division of Radiation Safety

and Safeguards

Enclosure: NRC Region I Inspection Report No. 50-352/86-01

(Contains Safeguards Information (SGI))

cc w/ encl (w/o portions of Paragraphs 3 and 4 that contain SGI):

G. Leitch, Station Superintendent

J. D. McGoldrick, Manager, Claims Division, Legal Department

John S. Kemper, Vice President, Engineering and Research

Troy B. Conner, Jr. , Esquire

V. S. Boyer, Senior Vice President, Nuclear Power

Eugene J. Bradley, Esquire, Assistant General Counsel

W. M. Alden, Engineer in Charge, Licensing Section

Limerick Hearing Service List

Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Connonwealth of Pennsylvania

bec w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

Section Chief, DRP

Shoreham, SRI

Section Chief, TPS, DRS

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IR LIMERICK 8601 - 0002.0.0

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U.S. NUCLEAR REGULATORY COMISSION

REGION I

,

Report No.

50-352/86-01

Docket No.

50-552

License No.

NPF-27

Licensee:

Philadelphia Electric Company

23C1 Market Street

Philadelphia, Pennsylvania 19101

Facility Name:

Limerick Generating Station

Inspection At:

Limerick, Pennsylvania

Inspection Conducted:

January 2-4 and 8-9,1986

Date of Last Physical Security Inspection:

November 19, 1985

Type of Inspection:

Special Physical Security

Inspector:

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Approved by:

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feguards Section

date

Inspection Summary: Special Physical Security Inspection on January 2-4 and

8-9, 1986 (Inspection No. 50-352/86-01)

Areas Inspected: Special inspection to review licensee's action relative to a

iicensee identified degraded protected area / vital area barrier and to follow

up on an allegation regarding two security guards leaving their posts. The

inspection involved 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> onsite and one hour offsite by a region-based

inspector.

Results: The following apparent violations were identified:

1.

Failure to maintain protected area / vital area barrier in

accordance with the security plan.

2.

Failure to maintain NRC approved compensatory measures for

an unalarmed vital area barrier.

3.

Failure to report a security violation in accordance with

security plan and NRC regulatory requirements.

8601270324 860117

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1.

Key Persons Contacted

G. Leitch, Plant Manager

J. Basilio, Administrative Engineer

R. Weindorfer, Assistant Director of Security

D. Clohecy, Quality Assurance Engineer

R. Hennessey, Quality Control Supervisor

C. Endriss, Regulatory Engineer

J. Spinelli, Project Engineer

J. Nagle, Licensing Engineer

P. Supplee, Administrative Assistant, Security

F. Larkin, Nuclear Security Specialist

J. McElwain, Quality Assurance Auditor

M. Berner, Y0H Security, Captain

The inspector also interviewed other licensee employees, current YOH

Security employees and a former Y0H employee.

2.

MC 30703 - Exit Interview

The inspector met with the licensee representatives listed in paragraph 1

on January 8, 1986, and discussed with them the scope and results of the

inspection.

No written material was provided to the licensee during the inspection.

3.

MC 92700 - Onsite Followup of a Nonroutine Event

a.

Background

THIS PARAGRAPil CONTAlHS SAFEGUAR05

lHF02 MAT!Gil AND IS NOT FOR PUBilC

DISCLOSURE,liIS INTENTIONALLY

LEFT BLANK.

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THIS PARAGRAPil CONTAINS SAFEGUAR05

INFORf3AI!GM AND 15 HOT FOR PUBLIC

DISCLOSURE, ITIS INTENTIONALLY

LEFT 8 LANK.

THIS PARAGRAPH CONTAINS SAFEGUAR0g

INF09MATION AND IS NOT FOR PURIC

DISCLOSURE, ITIS INTENTIONALLY

LEFT BLANK.

b.

NRC Inspection Findings

On January 2,1986, NRC Region I inspected the licensee's actions

relative to the barrier problems.

The inspector, accompanied by

security management, observed the areas in the Unit 1/ Unit 2 inter-

face where the openings and degradations were found.

The inspector determined that the openings did not result from

recent work, but rather were the result of incomplete construction

on the Unit 2 side of the interface, which apparently had not been

detected by the licensee when barriers were installed at the

interface. The inspector also determined that the licensee had con-

ducted additional inspections of the interface on January 1 and 2,

and that no additional problems were identified. On January 4,1986,

another interface inspection was conducted in which licensee Quality

1

Assurance and Construction Engineering personnel participated.

Por-

tions of that. inspection were observed by the NRC inspector. That

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inspection icentified two additional degraded barriers and two

openings that could have afforded access to the Unit I cable spread-

ing room.

THIS PARAGRAPH CONTAINS SAFEGUARDS

INFORMATION AND IS NOT FOR PUBLIC

UlSCLOSURE, ITIS INTENil0NALLY

LEFT BLANK.

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Failure to insure that all openings which penetrate the protected

area and vital area boundaries are alarmed and blocked with two

physical barriers to prevent access to these areas is an apparent

violation of the licensee's NRC-approved physical security plan and

10 CFR 73.2(f).

4.

MC 93700 - Inspector Dispatched to Site

a.

Background

During this special inspection, the inspector reviewed an anonynous

allegation received by NRC Region I on December 11, 1985 regarding a

violation of the licensee's security plan and implementing procedures

which was not documented and not reported to NRC. Specifically, it

was alleged that on December 8, 1985, two security personnel left

their posts at a vital area barrier, without being relieved, and held

conversations with another security force member at another post. A

corporal in the security force noted the absence of these personnel

and reported the incident to the shift sergeant.

The shift sergeant

allegedly decided not to document or report the incident to higher

supervision.

b.

NRC Inspection Finding

The inspector interviewed the involved corporal and the sergeant (who

had since been terminated by the security contractor for an unrelated

reason) on January 3,1986, and January 9,1986, respectively.

THIS PARAGRAPH CONTAINS SAFEGUARDS

INFORMAT;0H AND IS NOT FOR PU9 tlc

DISCLOSilRE, ITIS INTENTIONALLY

LEFT BLANK.

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Failure to maintain.these posts in accordance with the NRC approved

security plan, Chapter 10, and its implementing procedures is an

apparent violation of NRC requirements.

(50-353/86-01-02)

The inspector's interviews of the corporal and the terminated

sergeant also disclosed that the corporal immediately directed the

security personnel to return to their posts, which they did. Both

the corporal and the sergeant stated that they had counseled the

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involved security personnel at some time later in the shift. However,

the sergeant stated that it was a personal decision not to document

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and report the incident to higher security force supervision, contrary

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to the licensee's security procedures. The sergeant provided no

further reason for failing to follow procedures.

The inspector determined that the incident constituted a moderate

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loss of physical security effectiveness in that a major loss of

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effectiveness occurred but it was properly compensated within ten

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minutes by manning the posts. The licensee's NRC approved Contin-

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gency Plan (Events 11 and 20) and NRC regulation 10 CFR 73.71(c)

require reporting such matters to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

,

Failure to report this incident is an apparent violation of the

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licensee's NRC-approved Contingency Plan and NRC regulations.

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(50-353-86-01-03)

Based on interviews with the corporal and sergeant involved in this

incident, other members of the security force and a review, by the

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ir.spector, of documented security incidents, there was no indication

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that the failure to document and report this security violation is

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a common or widespread practice. All personnel interviewed, including

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those involved in this incident, stated that both contractor and

licensee management encouraged reporting of all incidents. The review

of the security reports, conducted by the inspector for the period

of October 1,1985, through January 8,1986, disclosed a number of

incidents, ranging from insignificant to significant, that, when

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appropriate, had been reported to the NRC in accordance with the

requirements of the Security / Contingency Plan and in compliance with

10 CFR 73.71.

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The inspector also noted that when he apprised the licensee of the

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incident, the licensee, who was previously unaware of the incident,

immediately initiated an investigation.

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