IR 05000352/1987020

Physical Security Insp Rept 50-352/87-20 on 870727-30. Violation Noted.Major Areas Inspected:Followup on Security Event Rept,Implementing Procedures,Organization,Personnel Access Control & Training & Qualifications

ML20196A572
Person / Time
Site:	Limerick
Issue date:	12/03/1987
From:	Bailey R, Keimig R, Lancaster W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20196A556	List: IR 05000352/1987020 ML20196A552 ML20196A566
References
50-352-87-20, NUDOCS 8802050098
Download: ML20196A572 (6)

Text

-. .

, , - - _ . - - . . . .

_

- _

_ _ - . . . - _ _- . . . _ . _ - . . .____-__...

BMWD M I l2 n >~ , , , ,

f fe in) $ 9 '

.l .:$- l ~

~(sns) (510.N M 2

' /J /jfi,,/f X __ _ ..Lc24Ilb 1m (OMANIZ ATI'Zi) (UAN)

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-20 Docket N License No. NPF-77 Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name: Limerick Generating Station Inspection At: Limerick, Pennsgivania Inspection Conducted: July 27-30, 1987 Type of Inspection: Routine, Unannounced Physical Security

.

Inspectors: // - /O - 87 R~. J. Baile fiysicalVSecurity Inspector date

-

• b h CAA W. K. Lancaster, Physical Security Inspector IS-I-$~7 date Approved by: .

E.^! //3 17 R. R. Keimig, tniet feguards Section, date Division of Radiati Safety and Safeguards

,

Inspection Summary: Routine, Unannounced Phys _ical Security Inspection on July 27-30,1987 (Inspection No. 50-352/87-20) l Areas Inspected: Follow-up on a security event repert; Implementing Procedures; Organization; Access Control (Personnel); Training and Qualifi-cations Records; Contingency Plan (Response Drills); and the protection of Safeguards Information (SGI).

Results: The licensee was in compliance with NRC requirements in the areas inspected except that the security contractor was not storing Safeguards Information in an approved storage containe l

PDR DO DR O

,c ,, ,

. - - .. . . . . . .

.

.

.

OETAILS Key Personnel Contacted Philadelphia Electric Company (PECO)

J. Doering - Superintendent of Operations D. Neff - Compliance Engineer J. Burke - Quality Assurance J. Robert - Supervisor, Quality Assurance K. Mandl - Supervisor, Corporate Auditing R. Weindorfer - Director, Nuclear Security P. Supplee - Nuclear Security Analyst R. Carter - Corporate Security Investigator W. Skych - Chief, Security Coordinator V. Vitale - PTI Program Manager T. Straub - PTI Security Force Captain C. Mannila - PTI Performance Analysis Group U.S. Nuclear Regulatory Commission (NRC)

i E. Kelly - Senior Resident Inspector S. Kucharski - Resident Inspector The inspector also interviewed other Philadelphia Electric Company personnel and members of the Protection Technology, Inc., contract security forc . Follow-up on a Security Program Event The inspectors reviewed records and discussed a security event which occurred on July 3,1987 and was reported to the NRC in accordance with 10 CFR 73.71, on ' July 8,1987. The event involved the discovery of an unlicensed, loaded handgun, and extra ammunition, in a gym bag belonging to a construction company employee, who was attempting to enter the Unit 1 protected area. The weapon and the individual were turned over to local law enforcement authorities (LLEA). The licensee informed the inspectors that no charges were brought against the individual by LLEA and the hand- 4 gun was returned. The licensee withdrew the individual's access to the protected are . Security Procedures The inspectors reviewed eight of thirty-seven security procedures, selected randomly, for adequacy and completeness. In addition, the lesson plans used to conduct security force training in these procedures were reviewed. The results of the review are as follows:

. _ . . __ . _ _ _ _ _ -

_ _ _ _ _ . - _ - _ _ . --

- - - -

. : .

. .

.

Procedure Results THIS PAGE CONTAINS SAFEGUARDS INFORMAT10H AND IS NOT FOR PUBLIC DISCLOSURE, ITIS INTENT 10NALLY LEFT BLAN !

l l

l

- , . - --. .

_- .

.

.

.

. 4 THIS PARAC05PH CONTA!NS SAFEGUA!!0$

INF0 PAT?ON td:0 IS HGT .':0R PUBLIC DISCLUSURE,liIS INTEHT10HALL LEfIBLANX, THIS FARIF'A?!' CONTMNS S!;iEGUA!!DS INF0;T AT:0N ',1:0 ri HDT FOR PUBLIC DISCLOSURE,lils INTENT!0NALLY bN bAPH CONTAINS SAFE 0VARD5 HiFDC/473M !G 15 HOT FOR PUBLIC DISCLUSUP.E. If 13 INTENTIONALLY LEf T BLAN The identified inconsistencies were discussed with the licensee. While no deficiencies in actual practices were noted, the inspectors stated that a review of the security procedures and lesson plans should be conducted to ensure that they are consistent and accurately reflect what is expected of SFM The licensee agree Security Organization During a review of the security force manpower status, the inspectors determined that 57 individuals lef t the contract security force since January 198 In reviewing the reasons given by those who terminated, the inspectors did not identify any security program deficiencie . Access Control (personnel)

The inspectors observed that the licensee was maintaining, in an active status, twenty-eight security identification badges that had been assigned to employees who are no longer employed or affiliated with PECO. The inspectors determined that the badges had not been used after the ex-employees' access was withdrawn. Security procedures prohibit the issuance of security identification badges without health physics personal monitoring devices and these devices had been immediately removed by health physics staff personnel upon timely oral and written notification that unescorted access to the Limerick Station for these individuals had been withdr' awn. The inspectors determined, through a review of records and procedures, that personnel who are authorized to request unescorted access to protected and vital areas were not prompt in orally notifying the Chief, Security Coordinator, when an employee's unescorted access to the Limerick Station was no longer required. Also, written notification from these employing personnel was not being received by the Chief, Security Coordinator, in some cases, until several days after access was no longer required. The inspectors verified that the !

licensee invalidated the identification badges on July 29, 1987. The licensee informed the inspectors that the procedures on terminating unescorted access to Limerick will be reemphasized to employing personnel within PECO and with all contractors. Also, administrative methods to ensure the prompt notification and invalidation of security badges for terminated employees will be reviewe _ _

, ,

'

.

.

. 5 Maintenance of Training and Qualification Records The inspectors observed that the training records continue to be maintained in good order and information concerning qualification and requalification is easily retrievabl . Security Contingency Plan (Response Drills)

The licensee informed the inspectors of the actions taken as a result of previous inspector observations that are identified in NRC Inspection Report No. 50-352/87-1 The actions are summarized as follows: Security supervisors were briefed on March 31, 1987, on the importance of following written security procedures and the dangers associated with conducting unapproved activities; Security instructions 33 and 37 were revised to require PEC0 management approval before a drill or exercise can be conducted; A Security Incident Review Committee (SIRC) was established to provide management overview and to analyze all security events for safeguards significance and possible degradations of security program effectivenes The inspectors reviewed the SIRC meeting minutes of May 1, 1987 and found that the committee had discussed a problem concerning the lock and key progra The supplier of locks and keys went out of business and, therefore, maintenance support was no longer available. The licensee was in the process of seeking a new supplier. The SIRC committee determined that there are sufficient reserves of locks and keys and that in-house maintenance can provide adequate support; therefore, no degradation of the security program should resul : physical Protection of Safeguards Information

On July 28, 1987, the inspector observed that a licensee designated q storage container safe containing Safeguards Information, located outside i of the protected / vital areas of the Limerick Generating Station, was not l approved by the GSA (General Services Administration). The licensee took l immediate corrective action and removed the contents to other approved storage facilitie CFR 73.21(d)(2) states, in part, that when Safeguard Information is left unattended, it shall be stored in a locked security storage container. Philadelphia Electric Company Corporate Procedure 5-3(6)A states, in part, that Safeguards Information located in an uncontrolled area is required to be stored in a GSA approved security container (Class 6 or equivalent).

J l

l I

l

, .. _ . _ - -

'

.

l ,' 6 Protection Technology, Inc. Limerick Generating Station' procedure states, in part, "when Safeguards Information is stored outside of the Protected /

Vital area at Limerick Generating Station, it will be locked -in a GSA approved storage container safe."

The licensee was advised that this was an apparent violation of NRC requirements. 50-352/87-20-01 9. Exit Interview The inspectors met with the licensee representatives listed in paragraph 1 on July 30,1987, and di1 cussed the scope and results of the inspectio No written material was provided to the licensee during this inspectio ,