ML20154C912

Insp Repts 50-456/88-20 & 50-457/88-20 on 880620.Violation Noted.Major Areas Inspected:Compensatory Measures & Access Control Re NRC Identified Incident Involving Inattentiveness to Duty Issue of Security Officers

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: ML20154C831 ML20154C847 ML20154C912
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 !!!

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Report Nos. 50-456/88020(DRSS); S0-457/88020(DRSS)

Oceket Nos. 50-456; 50 457 License Nos. NPF-72; NPF-77

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

Date

T. J. Madeda /

Physical Security Inspector ,

Reviewed By: kA bWk

Emes R. Creed,' Chief

7-/ ~ 8

Date

Safeguards Section

Approved By: !fm&M

Bruce 5. Mallett, Ph.D. Chief

7[#

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 i

adequate implementation of vital area compensatory measures. (Section 4

of Report Details). ,

inspection activities showed a decline in the licensee's ir.plementation of l

their security program. gne urs Con ns

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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)

a. At the beginning of the inspection, the Stetion Security Administrator

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

1 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

] ranagccent's response to each finding.

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Licensee per'tenei ackncwledged the inspector's coments that a

potential violation existed for the licensee's failure to adequately

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) l

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" as applicable (Section

to the security 02) ofplan.

the applicable NRC Inspection

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.

4 Ccepensatory Measures PP 81064) l

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, I

which includes

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Contrary to the above, on June 16, 1988, NRC personeel observed on two ,

separate occasions guards' inattentiveness to duty (ejes closed and i

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 ,

of the plant with two NRC Headquarters (HQ) rvpreser.tatives. At  !

approxinately 10:40 a.m., while walking dcwn s metal grating stairwell to I

the 383'0" elevation, the R1 observed a security guard who was sitting  !

with his feet up on the lower rung of a safety walhay rail. The guard

appeared to be

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designated by the licensee as beino a vital area door that controls

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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

R1 observed no rnovement from the guard and it appeared hD eyes were

l 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

! 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

! were red "bloodshot" and he looked drowsy. During the period of

l 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

l (ho. 1211). The RI felt that the guard was now in a condition to

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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

("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,the guard

guard's in question as was

site access removed

revoked frombythethepost (12:15

licensee p.m.).

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

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

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notified the licensee of his findings and the guard was replaced and his

site access was revoked pending licensee investigation results,

i 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

l until they were physically touched, because of the general area

vibrations.

l Prior to our onsite instection ictivities, the licersee initiated an

investigation into the RI's findings. The investigation included

I interviews with the 1ccused security guards and the RI, and observation

] of the area by

] Licensee interview results s W ed the following:

Event No. 1,:

The security officer posted at the door to the

i Roon stated that he saw three individuals coming de.n the stairs but did

! not know they were hRC rersonnel. He stated that be turned his head away,

j 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

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

j 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

l stated that he saw the legs of a person walk by but that he did not look

i up because the person did not attempt to go into the .

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

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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

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the RJ and anther hRC individual who was with the R1 during the

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

actionsprier to ourrecurrence:

to prevent arrival onsite,1)

( all on-duty security guards werethe lice

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

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stated that personnel walk past guards on door posts every day, and

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

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ventilation was installed in the doorway into the

I Room. The fan was not operating; however, a person must work their way

j arourd' the fan, or push it aside to get into the room. The card reader

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cn the door was functional and is the control device that the security

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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q 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

l acknowledge the prescre of two NRC inspectors. No specific cause could

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be developed to explain the reason for the inattentiveness issue.

. Environmental conditions, even though a factor, appear to have limited

j 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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