ML20154C912
| ML20154C912 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/01/1988 |
| From: | Creed J, Madeda T, Mallett B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20154C835 | List: |
| References | |
| 50-456-88-20-01, 50-456-88-20-1, 50-457-88-20, NUDOCS 8809150081 | |
| Download: ML20154C912 (7) | |
See also: IR 05000456/1988020
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U.S. NUCLEAR REGULATORY C0FMISSION
REGION !!!
Report Nos. 50-456/88020(DRSS); S0-457/88020(DRSS)
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Oceket Nos. 50-456; 50 457
Licensee: Comonwealth Edison Cogany
Post Office Box 767
Chicago, IL 60690
Facility Name: Braidwood Nuclear Power Station, Units 1 and 2
Inspection At:
Braidwood Station
Inspection Conducted: June 20, 1988
Cate of Previous Security inspection:
June 6-10, 1988
Type of Inspection: Announced Special Physical Security inspection
Inspector:
S' bd*T' A
7-/~1NI
T. J. Madeda
/
Date
Physical Security Inspector
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Reviewed By:
kA bWk
7-/ ~ 8
Emes R. Creed,' Chief
Date
Safeguards Section
Approved By:
!fm&M
7[#
Bruce 5. Mallett, Ph.D. Chief
Date
Nuclear Materials Safety and
Safeguards Branch
Ins ection on June 20, 1988 (Report Nos. 50-456/88020(DRSS);
o.
D'E7/88020(DR55?)
Areas Inspected: Included a review of Compensatory Measures and Access
,
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Control - Personnel as they related to an NRC identified incident involving
an inattentiveness to duty issue of two security officers.
Results:
The licensee was found to be in violation of hRC requirements
'noted below:
Compensatory Measures: The licensee failed on two occasions to ensure
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adequate implementation of vital area compensatory measures.
(Section 4
of Report Details).
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inspection activities showed a decline in the licensee's ir.plementation of
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their security program.
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DETAILS
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Key Persons Contacted
. vil And crir.!r.al Sat
,
In addition to the key merbers of the licensee's staff listed below, the
inspectors interviewed other licensee employees and trembers of the
security organization. The asterisk (*) denotes those present at the
Exit Interview conducted on June 20, 1988.
- R. Querio, Station Manager
- 0. O'Brien, Services Superintendent
- F. Willaford, Station Security Administrator
- B. Saunders Corporate Nuclear Security Administrator
- S. Roth, Assistant Station Security Administrator
- P. Barnes, Supervisor, Regulatory Assurance
- H. Walker, Assistant Security Forces Manager, Burn's Contract Security
- T. Tongue, Senior Resident Inspector, NRC
- T. Taylor, Resident inspector, NRC
S. Sands, Project inspector, MC H.Q. (Telephonic)
2.
Entrance and Exit Interviews (IP 30703)
At the beginning of the inspection, the Stetion Security Administrator
a.
of the licensee 5 staff was informed of the purpose of this visit and
the functional areas to be examined.
b.
The inspector met with the licensee representatives denoted in
Section 1 at the conclusion of the inspection on June 20, 1988.
No written raterial pertaining to the inspection was lef t with
the licensee or contractor representatwes. A general description
of the scope of the inspection was provided. Briefly listed below
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are the findings discussed during the exit interview. The details
of these findings are referenced, as noted, in this report.
Included below is a staterera provided by or describing licensee
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ranagccent's response to each finding.
Licensee per'tenei ackncwledged the inspector's coments that a
potential violation existed for the licensee's failure to adequately
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implement compensatory measures for a vital area door that was open
and unalarred in that, ce two occasions, guards assigned to monitor
an 'out-of-service' vital area door were observed to be inattentive
to duty (eyes closed and failure to ackntwledge personnel) by
several NRC personnel. (Section 4)
Licensee management's position was that the to guards were alert
and cognizant during the period the NRC inspector observed the
guards.
,
The inspectors stated that, the licensee will be advised of any
enforcement action af ter hRC management revie .
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2.
Clear Functional / Program Areas Inspected (MC0610)
Listed below are the areas which were examined by the inspector within
the scope of these inspection activities.
These areas were reviewed and
evaluated as deemed necessary by the inspector (s) te meet the specified
"Inspection Re
Procedure (!P)quirements" (Section 02) of the applicable NRC Inspection
as applicable to the security plan. Sampling reviews
included interviews, observations, testing of equip ent, documentation
review and at times drills or exercises that provide independent
verification of your ability to meet security commitments. The depth
and scope of activities were conducted as deemed appropriate and
necessary for the Program Area and operational statas of the security
system.
Number
Program Area and Inspection Requirements Reviewed
81064
Compensatory Measures:
(02) Employment c' Compensatory Measures;
[63J Effectiveness of Compensatory Measures.
81070
Access Control - Personnel:
(03) Vital Area Access Control;
[04) Control of Activities and Conditions in Vital Areas.
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Ccepensatory Measures PP 81064)
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One violation was identified and is described below:
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Section 7.3.3 of the approved Braidwood Security Plan requires that all
points of personnel access to vital areas are controlled. Access daors
to vital areas
A guard is posted at any
or
Figure 5-9 and Table 51 of the approved Braidwt d Security Plan
identifies the
...
Braidwood Security procedure BS-P!
'2, titled Post Instructions -
Compensatory Me65ures, requires that for a dearaded vital area barrier,
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which includes
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Contrary to the above, on June 16, 1988, NRC personeel observed on two
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separate occasions guards' inattentiveness to duty (ejes closed and
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failure to acknowledge the presence cf the insoect:rs) at vital area
(50-456/88020-01; 50-457/88020-01).
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On June 16, 1988, the NRC Resident Inspector l't!) was conducting a tour
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of the plant with two NRC Headquarters (HQ) rvpreser.tatives. At
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approxinately 10:40 a.m., while walking dcwn s metal grating stairwell to
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the 383'0" elevation, the R1 observed a security guard who was sitting
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with his feet up on the lower rung of a safety walhay rail. The guard
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appeared to be
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designated by the licensee as beino a vital area door that controls
access to the
The R1 stated that
he stood at the bottom of the stairs,.a distance of approximttely 20 feet
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fron the guard, and observed the guard for approxicately one minute.
The
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R1 observed no rnovement from the guard and it appeared hD eyes were
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closed.
The RI then approached the guard to a distance of two to three
feet and stood and observed the guard fer approximately another minute.
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The RI stated that during this period of observation, the guard's eyes
were closed and the guard did not acknowledge his presence. The R1 also
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stated that he did not hear any radio transmissions, nor did it appear
that the guard was monitoring the racio. As the R1 was observing the
guard, the guard opened his eyes and appeared to be startled. His eyes
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were red "bloodshot" and he looked drowsy. During the period of
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observation, the RI made no attempt te enter the
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He indicated it would heve been possible to bypass the guard by crawlina
under or climbing around the guard.
When the guard did acknowledge the
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presence of the R1, the inspector asked the guard for his badge number
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(ho. 1211). The RI felt that the guard was now in a condition to
adequately nan the post and left the area to report the observation to the
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licensee. Wen leaving the area, the RI observed another guard
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("Rover-2"). He told the approaching guard to keep the other guard awake.
The RI informed the licensee of his observation at 11:05 a.m., and the
licensee reported the event to the NRC in the required time period,
inspection results also confirned that, in addition to the RI's
observation, one of the hRC HQ individuals confirrec the RI's account of
the event.
(Note: this individual was irrediately behind the RI during
the period of observation. The third HQ individual was further back and,
due to space limitations in the area, was not in a good position to
observetheguard.)
When licensee security manageent personnel were ad ised of the RI's
findings, the
Subsequently, guard in question as removed from the post (12:15 p.m.).
the guard's site access was revoked by the licensee pending
security investigation results.
At approximately 12:30 p.m., the RI, accompanied by the sane HQ
personnel, returned to the sare area as part of the tour and to assure
that adequate corrective action was taken by the licensee for the
inattentive guard, At this tire, the RI observed that another guard had
been assigned tc '.he post. Observation from a distance of approximately
20 feet showed that the cuard was leaning against a scaffolding ladder
with his head leaning against his hand and had his eyes closed. The
R1 stated that he observed the guard for an estimated 30 seconds to
one minute time period from a position standing in front of the guard
(approximtely 10 to 12 inches from the guards face), and that during
this time, the guard did not show any any signs of a.areness to indicate
that he knew the R1 was there. At this point, the RI walked passed the
guard to the door of the
a distance of approximately
four feet and stood in frent of the open vital area door. The RI stated
that he did not enter the vital area; howevei, since the guard was not
alert, the RI felt that he could have entered withewt being challenged by
the guard. The R1 further stated after standing in front of the vital area
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door for a period of approximately five to ter. Seconds, the guard did
become aware of the RI. As stated in the first evert, an NRC HQ
personnel confinned the observation of the RI.
Prior to the NRC
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personnel leaving the area to report their findings to the licensee, the
guard opened his eyes. Before leaving the area. the RI assurer, ' hat the
guard was alert.
In addition, the RI asked the guard if he was asleep.
He responded "hv. I was listening to the radio."
The RI imediately
notified the licensee of his findings and the guard was replaced and his
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site access was revoked pending licensee investigation results,
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During inspection efforts on June 20, 1988, the inspectors determined by
observation that the environment at
was very noisy; very warm and
the general area does esperience a level of vibration from plant
equipment. The licensee did not have specific figures regarding the
environmental factors. However, the licensee stated that it is very
unluely a person would be aware of someone approac*ing the immediate area
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until they were physically touched, because of the general area
vibrations.
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Prior to our onsite instection ictivities, the licersee initiated an
investigation into the RI's findings.
The investigation included
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interviews with the 1ccused security guards and the RI, and observation
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of the area by
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Licensee interview results s W ed the following:
Event No. 1,:
The security officer posted at the door to the
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Roon stated that he saw three individuals coming de.n the stairs but did
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not know they were hRC rersonnel. He stated that be turned his head away,
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leaning his head on his left shoulder so he could renitor radio traffic.
The mike (receiver) for the radio was clipped to the lapel of his shirt on
his left shoulder. He said he was not aware of the RI's approar;h until he
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looked up and he was standing beside him, at which tire the RI asked for
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his badge number.
Event No. 2:
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The security officer pested at the door to the
Room stated that he was standing with his left arm (elbow) on the rung of
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a ladder and was holdir.; the radio mike to his lef t ear 50 that he could
monitor radio traffic. His job fcr that morning was to provide relief
1or posts and this was his fi'th post since coming on duty.
He said he
was listening to the radio so he would know where to go for his next post.
He stated that his head was down, and that his eyes were cast down. He
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stated that he saw the legs of a person walk by but that he did not look
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up because the person did not attempt to go into the
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Room, which he could see since he was facing the door. When the
NRC asked him if he was asleep, he stated "No, I was listening to the
radio *
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The licensee also stated that an independent polygraph operator (employed
by the secur'ty contractor) had interviewed both guards regarding their
inattentiveress to duty as observed by the NRC.
These interview results
stated that if a polygraph test were given to both guards, the test
results for the first guard would be inconclusive, and the test results
of the seconc guard would show that the guard was not asleep. Neither
guard has taken or has been rcquested to take a polygraph test.
On June 17, 1988, the licensee's Site Security Administrator and a senior
managecent irdividual from the contract security organitation interviewed
the RJ and anther hRC individual who was with the R1 during the
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observations. During this interview, the RI stated that he was in the
area for five minutes during each evel.t observation.
During the first
event, the F: said he rade the initial observation front the stairs as he
was coming d:.n, and that the guard's head was down and there was no
movement.
It further conversation with licensee personnel, the RI stated
that he did rot say that the security officer's head wr.s down.
He said
he then observed the cuard from the bottom of the stairs for a couple of
ninutes and trere was no novement by the guard.
Fe then arproached to a
location near the guard and continued the observation.
He said the guard
must have sersed him being there because he woke up.
During the second
event, he stated that the guard was standing and leaning with an elbow on
the rung of a ladder with his head in his hand.
He stated that he stood
in front of the guard and the guard did not look up and that he walke.,
past the officer to the door for the tank room and looked back at the
officer. He said the officer had his eyes closed and did not look up as
he walked by.
Also prier to our arrival onsite,1) all on-duty security guards werethe lice
actions to prevent recurrence:
(
briefed on the events, and it was emphasized that if guards do not appear
to be alert, then the perception forred by others is that guards are, in
fact, not alert. This was ccepleted by June 17,198E; (2)
posts will be checked by
on an
and(3)
checks will te rade with fixed posts on the
by the
items 2 and 3 were implemented oy 2:00 p.m. on June 16,
1988.
During our orsite inspection activities, the inspector interviewed the R!
and telephonically contacted the NRC inspector in Headquarters to review
their observations and findings regarding the two events.
Their position
in both cases, was that the guards eyes were closed; the guards failed to
acknowledge the presence of the inspectors; and they were not attentive
to duty.
Interviews with licensee senior security personnel confimed that the
licensee's pcsition was that the guards eyes were open, that they were
alert, and if the R1 had attenpted to enter the vital area in an
unauthorized ranner, the guards would have taken appropriate action.
This position was based on their interviews of the two guards.
The
licensee also developed a sequence of events as documented by the fecurity
computer and frca
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reports that were written by security officers who had first-hand
knowledge cf infonnation concerning the events.
The licensee's sequence
showed that the RI's corrent that he was in the area for five minutes
for the first event was in error.
Licensee documentation supported the
position that the R1 was in the area for approximately two minutes. When
confronted with the licensee findings the RI reconsidered the time period
and agreed that he was in the area for only approximately two minutes,
not the five Pinutes he originally thought.
The licensee also expressed
the position that a person walking by a security officer posted at
in the direction of
(located adjacent to
would not necessarily be a concern to the officer at
is locked and alarmed. The licensee Station Security Administrator
stated that personnel walk past guards on door posts every day, and
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unless they attempt to enter the door under guard, they are not
challenged or otherwise given much attention.
The licensee also thought
it is importart to note that throughout both events, a fan for room
ventilation was installed in the doorway into the
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Room.
The fan was not operating; however, a person must work their way
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arourd' the fan, or push it aside to get into the room.
The card reader
cn the door was functional and is the control device that the security
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officer is responsible for observing to assure that all personnel using
it get the ap;ropriate
for access.
The guard would not be
required to take any action to deny access unless a
was received
on a key card.
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Our inspection results did not identify any undetected or unauthorized
accesi to the vital area in question.
The operational status of the
)
plant at the time of the events was such that tampering with the
equipment to the vital area had the potential to inhibit safe shutdown,
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Based on infomation obtained during our inspection activities, the
guards we'e inattentive to duty.
These failures (inattentiveness) to
maintain positive access control to a vital area constitute a violation of
the licensee's security plan. The failures were caused when, on two
separate occasions, a guard posted to control access at an inoperative
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vital area dcor was observed to have his eyes closed and failed to
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acknowledge the prescre of two NRC inspectors.
No specific cause could
be developed to explain the reason for the inattentiveness issue.
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Environmental conditions, even though a factor, appear to have limited
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impact, and beth guards had been working a routine shif t (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per day)
for several days prior to the events.
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