ML20154L175
| ML20154L175 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/08/1988 |
| From: | Keimig R, Lancaster W, Madden J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20154L141 | List: |
| References | |
| 50-277-88-26, 50-278-88-26, NUDOCS 8809260116 | |
| Download: ML20154L175 (17) | |
See also: IR 05000277/1988026
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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Report Nos. 88-26
88-26
Docket Nos. 50-277
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50-278
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License Nos. OPR-44
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OPR-56
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Licensee:
Philadelphia Electric Company
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2301 Market Street
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Philadelphia, P57insylvania
19101
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Facility Name: _ Peach Bottom Atomic Power Station, Units 2 & 3
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Inspection At: Delta, Pennsylvania
Inspection Conducted: July 25-29, 1998
Type of Inspection: Routine, Unannounced Physical Security
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Date of Last Physical Security Inspection:
June 27-July 1, 1988
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Inspectors:
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W. K. Lancaster, Physical Security Inspector
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WA. Madden, Ph si
Security Inspector
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Approved by:
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9 8 -88
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Sichard R. Keimig, Cp %f, Safeguards Section,
date
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Facilities RadiologiGr'al Safety and Safeguards
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Branch, ORSS
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Inspection Summary:
Routine, Unannounced _ Physical Security Inspection on
July 25-29 1938 (Combined Report Nos. 50_-277/88-26 and 50-2 4/88-26)
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Areas Inspected:
.anagement Effectiveness; Assessment Aids - Protected Area;
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Access ContW- Personnel; onsite followup of two reports of non-routine
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events; and follow up on previous licensee commitments.
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Results: Apparent violations of the NRC-approved Physical Security Plan were
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identified in the following areas: Assessment Aids - Protected Area; Locks,
Keys, and Combinations; and Access Control of Personnel to Vital Areas.
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DETAILS
1.
Key Persons Contacted
a.
Licensee and Contractor Personnel:
- D. Smith, Vice President, Peach Bottom Atomic Power Station (PBAPS)
- D. Meyers, Support Manager, PBAPS
- R. Weindorfer, Corporate Director, Nuclear Plant Security
- J. Pratt, Manager, Quality Assurance
- F. Larkin, Nuclear Security Coordinator, Limerick Generating
Station (LGS)
- M. Berner, Acting Chief Security Coordinator, PBAPS
- R. Bixler, Corrorate Analyst, Nuclear Plant Security
- P. Supplee, Corporate Analyst, Nuclear Plant Security
- G. Bird, Senior Auditor, Nuclear Quality Assurance
- W. Bowers, Nuclear Security Coordinator, PBAPS
V. Vitale, Project Ninager, Protection Technology, Inc. (PTI)
S. Tharpe, Chief Coordinator, Nuclear Security, PBAPS
b.
V. S. Nuclear Regulatory Commission Personnel:
- R. Bellamy, Chief, Facilities Radiological Safety and Safeguards
Branch
- T. Johnson, Senior Resident Inspector
- L. Meyers, Resident Inspector
- Indicates those present at the exit interview
The inspectors also interviewed other licensee and contractor security
personnel.
2.
Management Effectiveness - Security Program
4.
Background
As a result of several allegations by a member of the security force
to the licensee regarding implementation of the security program at
Peach Bottom Units 2 and 3, the licensee's Claims / Security Division
conducted an investigation, starting in February,1988, into those
allegations.
Since shutdown of the plant on March 31, 1987, the NRC
had also received numerous similar allegations. Both the licensee's
investigation and the NRC's inspections into the allegations
confirmed the existence of programmatic weaknesses. Additionally,
an annual audit of the security program by the licensee's Nuclear
Quality Assurance (NQA) Division in April,1988, identified similar
programmatic weaknesses.
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On February 26, 1988, at a licensee requested management meeting
with NRC Region I personnel, the licensee discussed several general
actions it planned to correct previously identified problems. On
June 3, 1988, the licensee provided to NRC Region I, a copy of:
(1)
the Claims / Security Division Investigation Report, dated April 15,
1988; (2) the NQA report of the April,1988 annual security audit;
and (3) a Site Status Report that identified actions taken and
planned in response to the findings of (1) and (2).
NRC Region I
personnel reviewed the documents submitted on June 3, 1988 and held a
management meeting on June 9,1988 to obtain clarifying information
and to express concern about the magnitude of the program weaknesses
and the adequacy of the licensee's corrective actions. Documentation
of additional corrective actions was provided to NRC Region I by
licensee letters dated June 13 and June 17, 1988.
The June 17, 1988
letter also provided a commitment to perform a Root Cause Analysis of
the programmatic weaknesses identified and to submit the results of
the analysis to the NRC upon completion. A June 24, 1988 letter from
the licensee provided the status of the Root Cause Analysis and an
expected completion date of July 22, 1988 for it and a corrective
actien plan.
The analysis and corrective action plan was provided to
NRC Region I by letter dated July 27, 1988 and is under review and
evaluation.
On July 18, 1988, the licensee announced that it had awarded the
security contract for .oeach Bottom Units 2 and 3 to another
contractor, Protection Technology, Inc. (PTI), effective September
1, 1988.
This is the same security contractor that the licensee
uses at its Limerick Generating Station.
The licensee believes that
this change will contribute significantly to an improved security
program at Peach Bottom, along with other changes already underway
and proposed,
b.
Continuing Indications of Weaknesses _ Identified During this Inspection
During this inspection, the inspectors identified several problems
that are either directly or indirectly related to previously
identified orogram weaknesses.
They are as follows:
(1) Details concerning two licensee identified and reported events
(July 9 and 15,1988) involving vital area degradations were not
available to the inspectors from a single responsible source
until late in this inspection.
This indicates that responsibility
for the program is still fragmented,
(2) One of the events in b.(1) above resulted from a lack of
communications between maintenance and security personnel, a
recurring weakness.
The second event resulted from the failure
of two supervisory security personnel (one proprietary and one
contract) to follow an establi W d security procedure.
That
failure went undetected during two required, routine checks and
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when it was detected, the required compensatory measures were
not properly implemented. The second event is indicative of a
general indifference to established security program procedural
requirements.
(3) The inspectors found that a vital area access control post had
been established at r location where the posted guard could not
observe entry into this area and was not provided with orders
detailing the duties of the post.
Interviews by the inspectors
with licensee security personnel revealed that the post
location problem was identified by them and corrected on the
previous day. Somehow the post was physically returned to its
original location, and post checks by contract supervisors
every two hours, before and af ter its relocation, failed to
identify that the post was established in a location where the
guard could not carry out the intent of establishing the
post. This indicates that the contract supervisors lack
adequate knowledge of nuclear power plant security objectives
and that post checks by supervisors are perfunctory.
(4) The inspectors found Wo "dea * spots in the perimeter
intrusion detection system as.mment aids one day after a
Surveillance Test (ST) had bee minducted on the assessment
aids.
The ST failed to detect
"dead" spots.
This is
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indicative of either inadequate S't s, perfunctory conduct of the
STs, or inadequately trained personnel.
(5) The inspectors reviewed six post orders and found them to be
vague and inconsistent with the security plan implementing
procedure from which they were derived.
For example, Post
Order No. 54 lacked six requirements contained in the security
plan implementing procedure PP-27 (i.e., Sections 2.2.1,
2.2.2.1, 2.3, 2.3.1, 2.3.3 and 2.3.5) from which it was
derived.
This indicates that procedural requirements are
poorly translated into the instructions that security force
members are responsible for implementing.
(6) The inspectors identified four compeasatory posts that have
been in effect for up to one year, and in one that has been in
effect for two years.
Interviews with licensee security
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personnel revealed confusion regardin;l the status of maintenance
and modification projects 'that affect security equipment.
Therefore, man power intensive, long-term compensatory posts
continue to exist.
In addition, security equipment problems,
e.g., PIDS nuisance alarms and card reader failures, which
require short-term compensatory posts, appear to recur at a high
frequency.
This is indicative of a weak preventive and
corrective maintenance program, failure to track equipment
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maintenance and assign responsibility for this task to one
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individual, and possibly, indifference to the proper maintenance
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of security related equipment.
(7) The inspectors found that unscheduled and, at times, forced,
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excessive overtice and long periods on posts, without a break,
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are still impacting morale and, therefore, possibly
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performance. Work schedules for security force members are
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posted only one week in advance and are changed on a daily
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basis, as unanticipated requirements and "call-outs" occur. A
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review of records by the inspectors revealed that some members
of the security force are working twelve hours a day for eight
and nine consecutive days. Despite this having been identified
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as a serious probiem by the NRC during recent previous
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inspections, the licensee still has not been able to get the
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problem under control.
In addition, the turnover rate in the
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security force centinues to be high - fif teen mernbers resigned
in the month of July.
The overtime problem is indicative of a
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lack of adequate direction, or fragmenteo direction, on the part
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of the itcensee's on-site security management in combination
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with the excessive use of compensatory posts, as a result of
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previously mentioned factors, and inadequate oversight of the
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contractor,
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In addition to the specific weaknesses identified above, the
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inspectors also found that there is generally inadequate
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communications among other plant groups and the security force, a
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lack of "team" approach to resolving problems in the plant, and poor
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integration of security requirements in plant procedures. Also,
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while licensee Security Shift Assistants (SSAs) have been assigned
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to each shift to oversee the activities of the contract security
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force, the $$As do not appear to have sufficient kno.< ledge of
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nuclear power plant security objectives to be effective in
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identifying and correcting problems that occur.
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While the foregoing weaknesses were obvious during this inspection,
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the inspectors also found that the licensee had initiated actions in
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several areas in an effort to correct previously identified
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weaknesses and that some progress was apparent. Due to the number
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and magnitude of the programmatic weaknesses, strong and consistent
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direction and oversight, as well as time, will be required to
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re-establish a sound program.
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c.
The following major actions have been taken by the licenses since the
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last security inspection to initiate improvements in the security
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program:
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(1) A contract has been awarded to a new security force contractor
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to be effective September 1, 1988.
The new contractor had
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eleven personnel on site during this inspection for transition
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purposes. These personnel, and personnel from the existing
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contractor, were divided into transition teams to review
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operations, training, personnel and logistics.
The transition
teams were given goals by the licensee to be accomplished prior
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to September 1, 1988.
Comunications among team members,
including licensee security personnel, appeared to be effective
and proCress in meeting established goals was apparent.
(2) Licensee security personnel from Limerick Generating Station
(LGS) have been temporarily assigned to the Peach Bottom Power
Station (PBAPS) in order to upgrade the PBAPS security
program.
The licensee's LGS Nuclear Security Specialist has
been at PBAPS since July 11, 1988; a licensee LGS Shift
Security Assistant has been acting as Chief Security
Coordinator at FBAPS since July 4, 1988; and the LGS Technical
Assistant - Security is on-sita on a part-time basis.
The LGS security personnel have identified numerous areas where
the PBAPS security program can be improved to increase its
effectiveness. The inspectors found that dates had been
established to develop and implement these identified
improvements.
(3) A new Nuclear Security Specialist for PBAPS was hired, is on
site and is actively involved in the security contractor
transition. The LGS Nuclear Security Specialist is assisting
the PBAPS Nuclear Security Specialist.
A r.uclear security
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consultant is also expected to be on site by August 2, 1988, to
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assist in the training and orientation of the PBAPS Nuclear
Security Specialist.
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(4) A Security Incident Review Committee (SIRC) has been established
to review all security incidents and to determine root causes.
The SIRC will also review corrective actions taken to prevent
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recurrences of security incidents.
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(5) The inspectors noted ouring this physical security inspection
that operational security force supervision is no longer responsible
for both security and firewatch personnel. Since July 29, 1987,
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security force supervisors have not been responsible for
supervising firewatch personnel. Note:
This had been a concern
expressed to the licensee during a previous inspection conducted
June 28 -July 2,)1987 (Cocbined Inspection Report Nos.
50-277/87-20
and 50-278/87-20 .
3.
Onsite Follow-up of Two Reports of Non-Routine Events
a.
Unit 3 Drywell Head
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The inspector's determined that the licensee's fai'ure to comply
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with the above requirements in the NRC-approved Ph,> ical Security
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Plan, resulting in a vital area barrier degradation with no
compensatory action, is an apparent violation of NRC requirements
(50-277/88-26-01 and 50-278/88-26-01),
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Uncontrolled Vital Area Key
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The inspectors determined that the licensee's failure to comply
with the above requirements in the NRC-approvea Peach Bottom
Physical Security Plan, resulting to not positively controlling
access to a vital area, is an apparent violation of NRC
requirements (50-277/88-26-02 and 50-278/8b-26-02).
4.
Vital Area Access Control - Personnel
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The inspectors determined that the licensee's failure to comply with
the above requirements in the NRC-approved Physical Security Plan,
resulting in a vital area assess control post to be located such that
the guard could not observe or control access, is an apparent violation of
NRC requirements (50-277/88-26-03 and 50-278/88-26-03).
5.
Assessnent Aids (Protected Area)
The inspectors observed the use of assessment aids between approximately
1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br /> and 1430 hours0.0166 days <br />0.397 hours <br />0.00236 weeks <br />5.44115e-4 months <br /> on July 28, 1938, and other security equipment
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Failure to comply with the requirements in the NRC-approved Physical
Security Plan, in that assessment aids for two areas of the protected
area barrier and associated inner isolation zones had not been
identified as being unsatisfactory for alarm assessment and properly
compensated for, is an apparent violation of NRC requirements
(50-277/88-26-04 and 50-278/88-26-04).
6.
Follow-up on Previous NRC Commitments
The inspectors continued to review the status of licensee corrective
actions as identified in correspondence from PECo to the NRC that began in
Combined Inspection Nos. 50-277/88-23 and 50-278/88-23. References to
that correspondence, and the status of the items as determined by the
inspectors, are provided below. (Item designations correspond to those in
the refercaced letter),
a.
PECo letter dated June 13, 1988, concerning PECo corrective actions
as a resyt of the NQA Audit Report (AP88-48P6)
Attachment 1
AP83-48-01 - Shift Managers routinely tour the plant and are
expected to monitor Security Force Member activities.
(Closed)
The inspectors confirmed that shift managers were monitoring
security force member activities during routine tours of the
plant.
NOTE: All items in Attachment 1 are closed,
Attachment 2
AP88-48-02 - No formal program for training of SFMs on newly
issued security equipment by qualified instructors (ex:
new
weapons, gas masks, bullet-proof vests) exists.
(Closed) The
inspectors determined that in addition to the training on these
topics provided to current security force members, the topics
have been included in training lesson plans and will be given to
all future security force members undergoing armed responder
training.
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AP88-48-02 - No formalized training program exists for PBAPS
Safeguards Contingency Plan Training Drills. (Closed) The
inspectors confirmed that a tracking mechanism has been
developcd and implemented by the licensee to record participa-
tion of individual security force members on a regular basis.
AP88-48-02 - Search train SFMs failed to identify a 35mm camera
placed in the auditor's briefcase and did not routinely request
personnel to remove their hard hat when walking through the
metal detectors. (Closed) The inspectors confirmed that SFMs
were retrained and retested on proper search train procedures.
Inspectors' observations confirmed that search train operators
require personnel entering the Protected Area to remove their
head gear.
Ap88-48-0? - Four of four randomly selected armed responders
were unable to demonstrate to the audi, tors their weapons proficiency
and related knowledge of "use and care . All four armed guards
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failed to 7btain the required minimum score.
(Closed) The
inspectors, confirmed that the security force contractor had
retrained, requalified and retested all armed SFMs.
Attachment 3
AP88-48-03 - Maintenance and repair of security related
equipment is being tracked.
(Closed) The inspectors confirmed
that the PBAPS Security Maintenance Coordinator is tracking
maintenance and repair of security related equipment,
NOTE: All items in Attachment 3 are closed,
b.
PECo letter, dated June 24, 1988, concerning the status of a root
cause analysis of security program related problems. (Closed) The
completed report on the Root Cause Analysis was provided to the NRC
resident inspector and Region I security inspectors on July 27, 1988,
and was forwarded to NRC Region I on that date,
c.
PEco letter, dated June 30, 1988, addressing the Security Contractor
Transition Plan and special monitoring efforts.
A'ttachment 1
1.
Closed - See Combined Inspection Report Nos. 50-2/7-88-23 and
50-278/88-23.
2.
Any security personnel judged to be significantly lacking job
knowledge or performance will immediately be replaced on post
and retrained. (Closed) The inspectors confirmed that the PECo
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performance assessment group was testing security force members
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on their job knowledge and, when necessary, removed individuals
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from their posts until they were retrained and retested.
Random
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interviews with on-duty security force personnel by the inspectors
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verified that personnel were knowledgeable of their post orders
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and duties.
2.
A nuclear security consultant will be retained for a period of
at least 6 months beginning in August, 1988 to help oversee the
Security Force Contractor Transition and planned improvements.
(Closed) The inspectors confirmed that a nuclear security
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consultant had been retained and was scheduled to report to the
PBAPS on August 2, 1988.
4.
The LGS Technical Assistant - Security will coordinate with the
PBAPS Technical Assistant - Security, once he is aboard, to
assure that he receives the proper indoctrination training.
(Closed) The inspectors found that the LGS Technical Assistant
- Security, is temporarily filling this position at the PBAPS,
He will assist the nuclear security consultant and other
licensee personnel in overseeing the contractor transition and
in monitoring other security improvements.
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5.
PEco security supervision will interview key personnel of
leading bidders.
These interviews will be the first in a series
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of meetings, where PECo will coordinate requirements with the
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new contractor. (Closed) Protection Technology, Incorporated
was awarded the security contract for the PBAPS.
Transition
teams comprising contractor, PBAPS and LGS personnel are on
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site working on the transition details.
This transition team
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meets on a daily basis with PECo security management to help
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ensure a complete and efficient transition of the security force
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contractors.
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6.
PECo has notified the existing Burns contract employees that the
request for bids to which contractors are responding stated that
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the prope. sal shall contain a program whereby existing SFMs and
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firewatch personnel, if selected to be utilized by awarded
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contractor, may at the contractor's discretion, retain their
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currs it level and stature, or near equivalent, when commencing
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employment with awarded contractor. (Closed) PEco issued a
letter to Burns in mid-July, which in turn was distributed to
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all Burns personnel, explaining PECo's position that the
d
incoming security contractor should make every at wmpt to retain
existing security force personnel to augment their ranks upon
i
being awarded the contract.
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- - - - - - - - , - -.- ---- - -.- - - -
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. _ _ _ _ _ _ _ _ _ - _
_ _ _ _ _ _ - _ _ _
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,
,
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4
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16
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7.
Interviews by the contractor, of existing, suitable Burns
,
employees will begin within one week of award of the new
contract.
The selection process will place an emphasis on
candidate's knowledge of operation, attitude, and physical
i
fitness. (Closed) Interviews with existing Burns security force
,
members has been completed.
Protection Technology, Inc. is
currently in the process of making its final evaluation and
!
selection of personnel, with employment offers expected shortly,
t
8.
PECo will coordinate the following activities with the new
,
contractor's Training Transition Team Members:
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a).
Immediate transfer or duplicating of existing training
records from Burns to the new contractor. (Closed)
,
Interviews with on-site members of the Protection
Technology, Inc. transition team, by the inspectors,
!
,
indicates that this step in the transition process is
complete.
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b).
through g). - remain open.
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t
.
9.
through 12. - remain open.
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13.
The new contractor will immediately bring a trailer on site or
'
PECo will provide space for the contractor's site office.
Initially this space will be utilized by the contractor's
tr.nsition teams.
(Closed) A trailer, located just outside the
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protected area, has been provided to Prote: tion Technology, Inc.
for office space. The inspectors verified that the trailer
i
,
office space was adequate and was being utilized by the
transition team.
Attachaent 2 (Summary of Special Monitoring of the Security _ Force
atpBAPSJune16-June 28,1988)(Closedfihisattachmentdidnot
list any cerrective actions or open items.
Rather, it provided an
overview of the procedures and findings of the Performance Assessment
Group as it monitored security force members' performance.
d.
PEco letter, dated July 27, 1988, addressing the security problem
root cause analysis and providing an action plant to resolve the
identified problems. NOTE:
No items on the action plan were
revleued out during this inspection.
The following items in the aforementioned correspondence remained
open at the conclusion of this inspection.
The items are Itsted for
tracking purposes and will be reviewed during subsequent inspections
of the licensee's program.
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17
June 3, 1988 Letter:
Item D - Fitness for Duty Training
Item E - Firewatch
June 13, 1988 Letter:
Attachrent 2; AP88-48-02
Complete training of PBAPS Shift Security Assistants
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Require next successful security contract bidder to
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establish performance oriented training programs
June 30, 1988 Letter:
Attachnent 1
Page 1, item No. 1
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Page2,itemNos.8.b)through89)
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Page 2, item Nos. 9 and 10
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Page 3. item Nos. 11, 12, 14 and 15
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July 27, 1988 Letter: All action plan items
7.
Exit Interview
The inspectors met with the licensee representatives listed in paragraph
1 at the conclusion of the inspection on July 29, 198i. At that time,
the purpose and scope of the inspection was reviewed and the findings
were presented.
At no time during the inspection was written material provided to the
licensee by the inspectors.