ML20196B721

Partially Deleted Memorandum Re Stop Work Order at Util.Encl Info Re Events Leading to Licensee Decision to Stop Certain Work Being Performed by Contractor Employees at Plant Include Deterioration in Radiation Protection & Security

ML20196B721
Person / Time
Site:	Pilgrim
Issue date:	11/11/1988
From:	Gwynn P NRC
To:	Ader C, Elsasser T, Chris Miller NRC
Shared Package
ML20196B715	List: ML20196B708 ML20196B721
References
FOIA-88-198 NUDOCS 8812070016
Download: ML20196B721 (116)

Text

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- November it. 1987 NOTE TO: C. Ader. OCM/TR

.C. Mt11er. OCM/FB T. Elsasser. OCM/VC '

J. Scarborough, CCM/LR FROM Fat Gwynn. OCM/L2 DY i

SUBJECT:

INFORMATION CONCERNING STCF WCFK ORDER AT_ PILGRIM, e

I understand that Boston Edison Company stopped certain Pilgrim work yesterday being performed by contractor employees at j Tho basis f or the stop work, according to the NRR Licensing Froject Manager. was a destre on the part of BECo (11/9/87). i l

1 management to assure they had firm control of work being l'

per-f ormed by contr actors af ter a sect es of 8 minor events that .

occurred recently at the plant. '

Attached is a copy of i nf or* mat t on recei ved f r'om Region I  ;

concorning each of the events lesdtrg up to the BECo dectston l to stop work for y out- use.

4 Attachment As stated.

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l 8012070016 FOfA 881201 s ,, ;

PDR PDR .  !

JOHNSON 00-198 l

I Information in tt.. record was deleted in accordance with the reedom of Information  !

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Pilgrim Events leading to BECo Decision to Stop Work Overview ,

There were a serie.' of events at the Pilgrim Station that occurred during the last several days I. hat NRC is following clostly. Although each of the events is of relatively minor significance and not unique to nuclear power plant operations, collectively they are of concern to us because they occurred over a relatively short period and are similar to other problems that have occurred over the past . year.

We believe that BEco's decision to shutdown activities until it could assess the overall root causes of the problems is positive. This is significant to us in that it represents a distinct shif t in the senior management approach to control of activities at the plant as opposed to reacting to NRC observations.

We will continue to monitor these activities closely, t

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i . blind 2 2 0FFICIAL RECORD COPY PILGRIM EVENT - 0001.0.0 11/10/87

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2 Pilgrim Events t.eading to BCCo Decision to Stop L'ork t

1. Locked High Radiation Area Door Latch Taped 30 a.m., a contractor security guard accessing

.. On ember 8, at,y:dentified 5

that the latch on the door to the area the had een .

.. The door was considered a locked high rad door at the time of the incidents. Based on licensee surveys, it appears that the area may not have been required to be posted this conservatively.

t chips reading greater than IR were

-- A CR0 unlatchin tool and two Hewt'ier, the licensee stated that present on the tool cage requiring HP clea, ance for they were store in a ,

access.

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-- A contractor security guard was posted near the door in vesti n with The a second guard posted inside the area on the on the ensee's i tigation indicates that security guar s pos taped the door latch to allow easy access for their wate re .

licensee health physics personnel

-- On November 9 at about 4:45 a.m.,

identified tnat security guards were routinely opening this same to admit watch relief for the g_uard stationed

- locked hi h rad d This was being done without H.P. permission

!- on the .

and cons ituted an additional violation of locked high rad area centrols.

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" PILGRIM EVENT - 0002.0.0 0FFICIAL RECORD COPY 11/10/87

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3 Pilgrim Events Leading to BEco Decision to Stop ilork

2. Intake Structure Security Degradation tilation

.. At about 4:00 p.m. 11/8/87, securt ard noted that a ad been f an and duct work inside the arr er a e ven on intake.

rernoved, degrading the securi Only a ' bird screen" remained in place.

-. Appropriate response was made after discovery.

.. Event had been caused by contractor maintenance personnel starting work without a security review, this violated licensee procedures.

-- No unauthorized access occurred.

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. blind 2 2 0FFICIAL RECORD COPY P!LGRIN EVENT - 0003.0.0 11/10/87 I .end l

4 Pilgrim Events leading to BEco Decision to Stop Work

3. Possible Missed Surveillance Test

- A reactor protection system surveillance test scheduled for comple-tion by BECo no later than November 7 was not performed until November 9 due to surveillance tracking program weaknesses.

-- The test is required to be performed once per refueling outage by Technical Specifications. The licensee's scheduling system required performance once per week. The test had been performed last on October 30, so that it appears that no Technical Specification violation occurred and the problem is of minor safety significance.

-- The scheduled test however, was not consciously deferred. It was missed due to failure of several of the checks and controls built into the licensee's tracking program which has been a problem in the past.

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OFFICIAL RECORD COPY PILGRIM EVENT - 0004.0.0

' 11/10/87

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5 Pilgrim Events Leading to BECo Decision to Stop Work

4. Reassembly Problem of 'A' Recirc MG Sit

.. GE reworked HG sets during outage.

-- During initial runs of ' A' HG set on 11H, set was damaged apparently due to improper asse41y (e.g., inadequate clearances, improper installation of cooling water and lube oil lines).

.. 'B' MG has not been run (sets are non-safety related).

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'I" 0FFICIAL RECORD COPY Plt. GRIM EVENT . 0005.0.0 11/10/87

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6 Pilgrim Events leading to BEco Decision to Stop Work

5. Chemical Vaste Pump Contamination

- On November 6 two A priority maintenance requests were written to These MRs were cogleted by SEco repair the chemical waste pumps.

maintenance on November 6.

l.icensee

-- On November 7, at about 1:00 a.m., the A pump was run.

investigations indicated that plugs were not installed in the pump r.echanical seal as required. When the pump was run, fluid sprayed out of the area of the missing plugs, contaminating the pump room.

Two operators may have been slightly contaminated at this time.

-- On November 7 sometime between 1:00 a.m. and 3:00 a.m., a health physics technician performed a survey of the chee waste pump room and identified general area radiation levels had increased by a factor of 5 to 10 and contamination levels had also significantly increased from previous surveys. No air samples were taken and the nealth physics technician entered the room without a RWP contrary to pro-cedures which censtitutes a potential violation.

- On November 7, at about 3:30 a.m., contamination of 1 to 10K dpm was '

identified in the hallway just outside the cheetcal waste pump roce.

On November 7, the two operators and the health physics technician

("

t mentioned above were given whole body counts.

of the increased contamination levels in the room, uncertaint/

This was done because as to No uptake was the s)ecific cause and the lack of air samle data.

ident'fied. Seven other individuals were identified as having been No in the general area at the time and were required to have WBC.

results of these have been received.

- On November 8, at about 14:20, a maintenance worker repairing the A pump received minor contamination to his shorts to 3K dpm. 1 i

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. blind 2 2 0FFICIAL RECORD COPY PlLGRIN EVENT - 0006.0.0 11/10/87

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7 Pilgrim Events leading to SEco Decision to Stop Work

6. Spills From RHR/ Fire Water Tie-in

-- At 2:00 p.m. , 11/8, licensee was attempting to letdown torus water to rad waste. Water leaked in two places:

(1) From the open drain valves, via drain hose -- sprayed two BECo operators slightly, contaminating skin and clothes.

(2) From valve (recently installed as an SEP mod) which had not been repacked.

-- Event recurred early on 11/9. when operators tried evolution again after shutting all valves (packing still leaked).

Contamination of area led to about . *minor personnel contaminations f

(BECo and contractor's).

-- Event involved poor control of work and system turnovers, probably in violation of BEco procedures.

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. blind 2 2 0FFICIAL RECORD COPY PILGRIM EVENT - 0007.0.0 11/10/87

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8 Pilgrim Events leading to BECo Decision to 5 top Work

7. Flatbed Area Contamination

-- About Noon, 11/8, BEco rad waste operators wanted to dump flatbed filter media to a hich integrity cask, but noticed the Attempted chute was to clogged with diatemaceous earth from previous work.

wash chute with water which resulted in diatomaceous earth and water on floor and then thru floor drain system.

-- Floor contamination was 500 mR/hr contact (area is normally highly contaminated).

-- Chute washing may have been normal work practice; was poorly controlled.

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I ' blind 2 2 0FFICIAl. RECORD COPY PILGRIM EVENT - 0006.0.0 11/10/87 l

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..- 9 Pilgrim tvents leading to BEco Decision to Stop Work

8. ynexplainedContaminationintheRadVasteCorridor On November 8,1987, between 3:00 and 4:00 p.m.,12 to 14 people were e the radiological control point with detectableBECo shoe identified at HP contamination ranging frcm less than 1K to 10K dpm/100 cm review found areas near the chemical waste pump room.

identified contaminated but the events do

-- The safety significance of this issue is low, Weaknesses in indicate weaknesses in radiological work practices.

these practices and in ALARA controls were the subject of a 1984 Radiological Improvecent Order.

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, blind 2 2 0FFICIAL RECORD COPY PILGRIM EVENT - 0009.0.0 11/10/87

0FFICE MEMORANDWT l'6304262 Boston Edison Company

• RMG Control Number To: A. Pedersen from: E fe ki Record Type A4.08 Date: 9/5/86 " 7 ep5 7 NMS3 B6 7 6 -Safety Related Subfe/ y ct:_ Security Program Improvements Status Report #8

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Distribution:

E.T. Graham T. Nicholson P. Hamilton H.N. Brosee R. Swanson J. McEachern M. McBride 0.L. Myers Attached is the eighth monthly status report on planned security program improvements. It is recommended that this report be forwarded to Messrs.

Oxsen and Lydon for review and ccernent.

EXECUTIVE

SUMMARY

The Security Program Improvements listed in Attachment I and 2 of this report were developed in response to the civil penalty resulting from events of August 1985, concerning vital area barriers. Attachment 3 is a list of Security Program Augmentations. Many of these items in Attachment 3 have been discussed with Regional NRC Security Management.

PJH/al Attachments: 1. Plan and Schedule of Security Program Improvements

2. Compensatory Heasure on Loss of Security Cceputer

3. Augmentations to Security Improvement Plan

'" pOCvWLht 15 LEASED.

I o SEP 11 1986 ,

Information lit this record was deleted s pg in accordan:e with th freedom of Information eg, a ug g,t g :

Act, extrjn tions --

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SUMMARY

OF STATUS

. ITEMS ON ATTACHMENT I STATUS

• Additional BEco oversight of Security 4 of 5 individuals on Force, board. One remaining is pending medical clearance.

• Establish a Corrective Action System to Procedure in place - 48 address Security Deviations. deviations reported.

• Perform Regulatory Requirements Analysis. On schedule - Plan to meet with NRC in Mid November to discussed proposed plan changes.

• Evaluate Security Training Methods. Complete

• Increase Oversight by Corporate Security. Cceplete - 1 person added to staff.

• Establish a program for Corporate Security Cceplete to audit the Security Plan on a regular basis.

• Proceduralize Existing Surveillance Cceplete Program.

ITEMS ON ATTACHMENT 2 STATUS

• Perform Requirements Analysis Estimated Ccepletion -

of Security Ceeputer System. Hay 1987 Establish Interim corrective action Cceplete on loss of Security Cceputer, i

ITEMS ON ATTACHMENT 3 STATUS

• Vital Area Barriers - modify Scheduled Ceepletion 12/86

• Intrusion Detection System - rnodify In Progress

• In Progress Lighting - modify In Progress

• Fact 11tles - supplement / upgrade. In Progress Training In Progress Security Program Objectives-establish in Progress Interccepany visits In Progress

• Ccepensatory Heasures - establish In Progress evaluation process.

ATTACHMENT 1 Plan and Schedule of Security Program Improvements ADDITIONAL BECo OVERSIGHT OF SECURITY FORCE Plan to hire five (5) Boston Edison security supervisors to provide shif t coverage of the contract security force.

Original Scheduled Current Completion Status Planned Milestones

- Develop job description and approve Jan. 1986 Complete

- Commence hiring process for Boston Feb. 1986 Complete Edison site security supervisors.

- First Additional Boston Edison site April 1986 Complete security supervisors on board.

(4 hired - 1 to 90)

- Remaining Boston Edison site security July 1986 Offer accepted supervisors on board, pending Medical clear-ance CORRECTIVE ACTIONS SYSTEM Plan to develop a procedure to standardize the reporting of security deviations and to initiate thorough and effective corrective actions.

The procedure will include a form for reporting deviations and will require a trend analysis of deviations to identify recurring problems.

Original Scheduled Current Completion Status Planned Milestones

- Identify and evaluate requirements Mar. 1986 Complete the corrective action system.

- Develop and approve procedure, June 1986 Complete including form for reporting July 3. 1986 deviations.

- Incorporate into NOP 83A9 Complete Complete 8/1/86 Effective 9/1/86 Page 1 of 3

Original CORRECTIVE ACTIONS SYSTEN (continued) Scheduled Current Completion Status

, Planned Milestones (con't)

- Indoctrination and Imp:ementation July 1986 Complete - 48 of process. deviations identified on new form as of 8/26/86

- Perform first trend analysis of Jan. 1986 a U hedule deviations to identify recurring problems.

REGULATORY REQUIREMENTS ANALYSIS Plan to perform a regulatory requirements analysis of the Modified Amended Security Plan (MASP). Safeguards Contingency Plan, and Training and Qualification (T&Q) Plan vis-a-vis the Code of Federal Regulations.

This analysis is to assure that the regulatory requirements are met by existing programs and procedures.

Original Scheduled Current Completion Status Planned Milestones

- Obtain resources to perform analysis. Jan. 1986 Complete

- Determine methodology of performing Feb. 1986 Complete analysts.

- Perform regulatory requirements Oct. 1986 On schedule analysis. 9 of 10 nodules Complete

- Prepare changes to Security Plan. Oct. 1986

- Incorp proposed changes Reg'd by Oct. 1986 8/4/86 Fed. Register into Plan.

- Finalize 10CFR50.54p Evaluation. Nov. 2, 1986

- ORC Review Security Plan. Nov. 5,1986

- Heet with NRC on proposed plan Nov. 12, 1986 changes.

- Incorp. NRC ccenents & final type. Nov. 18, 1986

- Final ORC Review. Nov. 19, 1986

- Prepare 50.54p evaluation on To be Determined T&Q and Contingency Plans.

Page 2 of 3

STATUS o Training Plan to evaluate the present approach to training such that:

(1) Security force personnel have a greater sense Complete of awaroness of tho bases behind their duties (i.e. why they are here).

(2) Security force personnel understand the need to initiate aggressive corrective action and to follow-up thoroughly.

Increased Management Oversight - Corporate Security Plan to establish a Corporate Security Representative Complete to strengthen the interface between site and corporate sccurity personnel. This individual will be respon-51ble to perform audits in accordance with a structured audit plan, review program document changes, and maintain a state-of-the-art knowledge of security methodologies. This change will be reflected in the Corporate Bulletin Book.

Self-Audits Plan to audit the sections of the security plan on a Complete regular basis such that the entire plan is addressed by corporate security once/ year.

Proceduralize Existing Programs Plan to establish procedures for the existing internal Complete surveillance effort and include the scheduling of these surveillances in the Master Surveillance Tracking Program.

Page 3 of 3

ATTACHMENT 2 Compensatory Measure on loss of Security Computer t

A concern was raised by our Senior NRC Resident Inspector, Dr. M. McBride regarding establishment of compensatory measure within 10 minutes if the security computer becomes inoperable. The concern is that in 1985, six security event reports were flied because full compensatory limits were not i established within 10 minutas after loss of the security computer.

The following corrective actions have been taken or are planned:

Original Scheduled Current Completion Status Planne Q lestones l

- Evaluate the reliability of the Complete  !

secyrity computer l

- hvelop recommendations for computer Complete improvement.

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- Decision on optimal recommendation. Mar. 1986 May 1987 (Pending requirements analysis by ,

NEO.)

- Implement optimal recommendation Pending NED regt's analysis As stated in our November 27, 1985 letter, Boston Edison reviewed the situation and implemented the following corrective actions:

- Reviewed and revised the response methodology allowing security personnel to man the required posts within 10 minutes.

- Temporarily increased staffing levels as an interim measure to ensure the 10-minute response time can be met.  :

' - Provided pre-established compensatory zone assignments on each shift  !

in the event the cceputer becomes inoperable. '

- Trained security force on the revised methodology of rnoonse.

- Conducted del 11s and vertfled that less than 10-minute response is achieved.

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, ATTACHMENT 3 Attachmert 3 is a list of Augmentations to the Security Improvement Plan. l Hany of these items have been periodically discussed with NRC Regional Security Management.

Scheduled Current Completion Status BARRIERS

. 12 86 ess

- Protected Area

- Incorp Fence Survey into 9/86 In Progress Halntenance PH Program.

- Install Bottom Rail on Fence. 12/86 In Progress

- Implement NED Recomendation 10/86 In Progress '

on Wash Concern.

INTRUSION DETECTION

- Obtain Response to ESR 86-253, 9/86 Complete

- Develop (Maintenance) 10/86 In Progress l Repair Schedule.

- Develop Eng. Modtficat1on Schedule 5/87 Bids Due to j (Integrating with Requirements NED on 9/15/86

Analysis for Computer).  ;

- Issue FRN to PDC 82-200. 7/86 Cceple te l - Evaluate Technical Adequacs 11/86 In Progress l of Surveillance Procedure for Intrusion Detection Equipment.

Obtain Response to ESR's 9/86 In Progress86-212 and 86-305.

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Develop Implementation Plan 5/87 Bids due te (Integrating vl 9 require- NED 9/15/86 rants Analysis i.>r Cmputer)

Achieve resolJtion with NRC 9/86 NRC reviewing regarding Interim Compensatory 8ECo proposal Measures.

LIGHTING Restore yard lighting to original - Cceplete design requirements.

Revise OHG work Instruction to - Complete include yard lighting considera-t'ons on trailers.

• Obtain response to ESR 86-252. 8/86 Complete Schedule completion of codif t- 9/86 In Progress cations (PDC 83-09).

• Perform lighting edequacy survey. (after PDC)

FACILITIES Establish private office location - Cceplete for BEco security management.

• Request additional office / working 9/86 In Progress lunchroom space for Security force.

• Request upgrade of Security fac111ttes 9/86 In Progress at Bechtel Warehouse Gate, Alternate Access Gate, (i.e., heat, light, a/c, furniture, painting).

AD0!TIONAL TRAINING r

• Establish overview training 9/86 In Progress sodule for BECo senior manage-i ment.

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• 1/87 In Progress Estabitsh initial technical training module for Security management.

I SECURITY PRCCRAM L 'JECTIVES 7/86 Comptete

• Develop initial plan.

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• Estabilt 'tittal objectives 9/86 Cceplete includ';c ecomendations.

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SECURITY PROGRAM 06]ECTIVES (continued)

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• Final decision on key objectives. 10/86 -

Develop Implementation Plan. 12/86 -

INTERCONPANY COMPARISONS Develop schedule for security shift 10/86 In Progress supervisors to visit other sites.

COMPENSATORY MEASURES Revised Procedure 3.10 to include the - Complete (7) seven criteria of NUREG 1045.

• Establish formal, regular re-evaluation 1/87 In Progress of compensatory measures to determire alternative methods of achieving compil-ance.

• Security perform a periodic review of 10/86 In Progress open HR's & Issue Report to management.

Initiate attendance of Security manage- 9/66 Complete ment personriel at seminars (e.g. indus-trial security) on state-of-the-art security equipment / compensatory measures.

I NOTE 1: Original verbal commitment to NRC was given as 11/1/86. '

Schedule was impacted by fire protection damper modifications.

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f .' 0FFICE MEMORAN01)H gg s RMG Control Number Boston Edison Company F,om: E..TNm,w lanskt/.v-To: A. Pedersen Record Type A4.08

</

Dept. NHS$ 86 218 Non-Safety Related Date: 10/14/86 Report #9 Subje ( , p - _ -Security Program Impravement -

x __

Distribution: P. Hamilton M,N. Broste E.T. Graham T. Nicholson J. McEachern M. McBride 0.L. Myers R. Swanson D.L. Bryant Attached is the ninth monthly status report on planned security program inprovements. It is recommended that this report be forwarded to Messrs.

0xsen and Lyden for review and comment.

EXECUTIVE

SUMMARY

The Security Program Improvements listed in Attachment 1 and 2 of this report were developed in response to the civil penalty resulting from events of August 1985, concerning vital area barriers. Attachment 3 is a list of Security Program Angmentations. Many of these items in Attachment 3 have been discussed with Regional NRv Security Management.

PJH/la Attachments: 1. Plan and Schedule of Security Program Improvements

2. Coe.pensatory Heasure on loss of Security Computer

3. Augmentations to Security Improvement Plan sYft, Y h _'

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i ATTACHMENT 1 l Plan and Schedule of Security _ Program Improvements j i A00!TIONAL BECo OVERS!GHT Or SECURITY FORCE i

Plan to hire five (5) Boston Edison security supervisors to provide  !

' shift coverage of the contract security force.

Original .

Scheduled Current  !

3 Completten Status [

r Planned Milestones

- Develop job description and approve Jan. 1986 Complete

- Commence hiring process for Boston Feb. 1986 Complete  :

Edison site security supervisors.

April 1986 Cotplete

- First Additional Boston Edison site

, security supervisors on board. I I (4 hired - 1 to go) e j - Remaining Bo' ton Edison site security July 1986 Failed Medical supervisors on board. Reinitiating search with

rofessional l firm.

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CORRECTIVE aCTIOWS SYSTEM i

Plan to deselop a procedure to standardize the reporting of security l deviations and to initiate thorough and effective corrective actions, l

i The procedure will include a form for reporting deviations and will i

require a trend analysis of deviations to identify recurring problems.

$ ' Original ,

Scheduled Current t l Complet M Status l l

l 1

Planned Milestones l Complete  !

- Identify and evaluate requirements Mar. 1986 f the corrective action system.  !

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- Develop and approve procedure, June 1986 Complete  :

l July 3, 1986 l

including form for reporting r

deviations. l i

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- Incorporate into NOP 83A9 Complete Complete 8/l/86 i l

Effective 9/1/86  !

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- N CORRECTIVE ACTIONS SYSTEM (continued)

Original Scheduled Current Completion Status Planned Milestone $

July 1986 Complete ,

- Indoctrination and implementation of proctss.

Jan. 1987 Complete

- Perform first trend analysis of deviations to identify recurring problems.

REGULATORY REQUIREMENTS ANALYSl$

Plan to perform a regulatory requirements analysis of the Modified Amenceo Security Plan (MASP). Safeguards Contingency Plan, and Training and Qualification (T!.Q) Plan vis-a-vis the Code of Federal Regulatio9s.

This analysis is to assure that the regulatory requirements are met by existing programs and procedures.

- Obtain resources to perform analysis. Jan. 1986 Complete ,

Feb. 1986 Complete

- Cetermine methodology of performing analysis.

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- Perform regulatory requirements Oct. 1986 On schedule  :

analysis. 9 of 10 modules .

l Complete

- Prepare changes to Security Flan. Oct. 1986 On schedule l draft in typing

- Incorp. proposed changes rea'd by Oct. 1986 On schedule l draft complete

' 8/4/86 Fed. Register into Plan.

l (Histellaneous Amendmeats)

' Note (1) t I - Finalize 10CFR50.54p Evaluation. Nov. 2. 1986 On schedule for changes to security plan. after submittal of draft On schedule [

I - ORC Review Security Plan changes. Nov. 5. 1986 i

j required by Federal Register l (Hiscellaneous Amendment) '

Note (1) i I - Heet with NRC on proposed plan Nov. 19. 1986 On schedule

! changes.(not those required l

by Federal Register) 4 i t Page 2 of 3 t i

e

Original Scheduled Current Cccoletion Status Planned Milestones

- Submit proposed changes to Dec. 2, 1986 On schedule NRC (Miscellaneous Amendments)

Note (1)

Dec. 2, 1986 Dependent upon

- Incorp. NRC comments & final type.

, extent of NRC comments Dec. 17, 1986 On schedule

- Final ORC Review.

- Prepare draft changes to T&Q To be determined and Contingency Plans after Security Plan submittal

- Prepare 50.54p evaluation on To be Cetermined T&Q and Contingency Plans.

TrainB Plan to evaluate the present approach to training such that:

Com;Iete (1) Security force personnel have a greater sense of awareness of the bases behind their duties (i.e. why they ate here).

l Security force personnel understand the need lesson plan (s)

(2) to be delivered to initiate aggressive corrective action and to follow-up thoroughly. to TJN for evaluation November, 1966

• Increased Management 0verstaht - Corporate Security Plan to establish a Corporate Security Representative Complete to strengthen the interface between site and Corporate security personnel. This individual will be ret on-sible to perform audits in accordance with a structured audit plan, review program document changes, and reintain a state-of-the-art knowledge of security rethodologies. This ch6nge will be reflected in the Corporate Bulletin Bcek.

Self-Audits Cceptete Plan to audit the sections of the security plan on &

regular basis such that the entire plan is addressed by corporate security once/ year, NOTE: (1) This submittal is of a scope different from the original commitment, it is shown here for the purpose of issuing a single, coeprehensive report. ,

Page 3 of 3

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• ATTACHHlN7 2

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• Proceduralize Existing Programs Plan to estabitsh procedures for the existing internal Complete surveillance effort and include the scheduling of these surveillances in the Master Surveillance Tracking Program.

Compensatory Measure on Loss of Security Computer A concern was raised by our Senior NRC Resident Inspector, Dr. M. McBride I

regarding establishment of compensator measure within 10 minutes if the security cecouter becomes inoperable l

i The following corrective actions have been taken or are planned:

Original Scheduled Current Completion Status 1

j Planned Milestones

- Evaluate the reliability of the Complete j security computer

- Develop recommendations for computer Complete irrprov eme nt .

- Decision on optimal recommendation. Mar. 1986 Feb. 1987 -

(Pending recuirements analysis by based on NED inpv*.s and NED.)

)

as comm.anicated I

to N Z via '

j telecon on  !

l (10/20/86 ,

- Implement optimal recommendation Pending NED reat' s (ref Attachment 3) .

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' As stated in our November 27, 1985 letter, Boston Edison reviewed the

)

' situation and implem:nted the folicwing corrective tctions:

I i

- Reylewed and revised the response methodology allc ing security personnel to man the required posts within 10 minutes.

J

- Temporarily increased staffing levels as an interim measure to ensure

! the 10-minute response time can be met. l

- Provided pre-established compensatory zone assignments on each shift in the event the computer becomes inoperable.

I

- Trained security force on the revised methodology of response, i

- Conducted drills and verified that less than 10-minute response is achieved.

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u _-- . _ _ _ _ _ _ _ _ _ _ _____ ___ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - - _ _

ATTACHMENT 3 4

Attachment 3 is a list of Augmentations to the Security Improvement Plan.

Many of these items have been periodically discussed with NRC Regional Security Management.

Scheduled Current Coepletion Status 81ERIERS oN as follcw-up to phone call (entending completion to 1/87).

4 l - Protected Area

- Incorp Fence Survey into 9/86 Complete Maintenance PH Program.

- Install Bottom Rail on Fence. 12/86 On schedule started 9/22

- Implerent NED Recomendation 10/86 On schedule on Wash Concern, started 9/30 l

!ATRUSION DEiECT10_N

- Obtain Response to ESR 86-253, 9/86 Complete

- HNB Develop (Maintenance) 10/86 On schedule repair schedule. Initiated short-term repairs in conjunction with fence work.. ,,m .

' On schedule

- Develop Eng. Modification Schedule 2/87 .

(Integrating with Requirements (ieproved Analysis for Computer), original sched.

j ule of 5/87)

- Issue FRN to PDC 82-200. 7/86 Installation co9plete but (This installation was 6 still getting considered temporary because it was unknown if the system false alarms would be effective in this ~.

unique application). ._,,

Page I of 4

~

. Vendor adjustment of hardrare/ 10/86 . Hard:are shipped installation. NED (John Turner) to vendor 10/86.

providing followup. .

- Evaluate Technical Adequacy 11/86 On schedule -

of Surveillance Procedure for obtaining Intrusion Detection Equipment. vendor recommendation for testing equipment.

Obtain Response to ESR's 9/86 Have received 86-212 and 86-305, response to 86-212.

) . Espect

-~ mresponse

• to 86-305 by .

10/86 (to D utilize -

consultant 1 input). ~

'w. .. ..

• Develop Implementation Plan 2/87 On schedule P.O. placed (Integrating with require-ments Analysis for Computter) 10/86 with consultant.

• 9/86 NRC reviewing Achieve resolution with NRC SEco verbal regarding Interim Compensatory proposal.

Measures.

• 10/17/86 Complete -

Issue formal letter to NRC letter issued.

regarding Interim Compensatory Heasures. (W. Lobo)

L]LHTING Cceplete

• Restore yard lighting to original -

design requirements.

- Complete Revise OHG work instruction to j include yard lighting considera-tions on trat ters.

• Obtain response to ESR 86-252. 8/86 Cocplete ,

• Schedule corapletion of modif t- 10/86 Delayed one 5 month. <

cations (PDC 83-09) Maintenance reviewing ,.

schedule sub-mitted by '

Bechtet.

Pagt 2 of 4 ' M ,, .~

l

r s

Perforo lighting adequar.y survey. After PDC On schedule

.' as part of NED comprehensive review

• /  %

FACILITIES h

• Establish private office location - Complete "

for BEco security management.

9/86 Complete i Request additional office / working lunchroom space for Security Force. trailer l request re- t submitted  :

(outside pro.  !

I tected area)

OMG has been requested to evaluate labor impact ,

on use of l f alternate  ;

l access Gate. j i

• Confirming request maintenance upgrade 9/86 Coeplete

! r

! of Security Facilitiet. at Bechtel Warehouse Gate, Alternati Access Gate, (i.e., heat, l l

light, a/c, furniture, painting). ,

• 3 J -

f 10/86 . ' Comp l e t e . l

' Inform NED of Security long-term space ' Verbally .** i j needs.

communicated

i I

to C.).

Minott. ..

! m l t

l ADDITIONAL TRAINING

' Estabitsh overview training 11/86 Final coments  !

l module for BECo sentor manage- resubmitted l

! to Training l

! ment. Group i l Implementation l I

celayed one  !

(

month (to  !

Novemter) i 1/87 On schedule l f

Establish initial technical learning i l

training module for Security objectives in >

! management, preparation;  ;

l to be i submitted

! to training f

10/86 Page 3 of 4 l

r v - - ,-- - , ~=- , -n. - . - - -----,n,-------,-n wm x--->- - ~ ~ - - - - - - - - -,,e,. -

na, - - - - ~ ,

SECURITY PROGRAM O6JECTIVES

• Develop initial plan. 7/86 Complete

• Establish initial objectives 9/86 Complete including recommendations.

• Final decision en key objectives. 10/86 With E.J.

Ziemlanski for decision Develop Implementation Plan. 12/86 Pending final decision INTERCOMPANY COMPARISONS

• Develop schedule for security shift 10/86 On schedule -

supervisors to visit other sites. Have had discussion

, with about

• eight other plants.

COMPENSATORY MEASURES

• Complete Revised Procedure 3.10 to include the -

(7) seven criteria of NUREG 1045.

• Establish formal, regular re-evaluation 1/87 On schedule -

of coepensatory measures to determine Procedure in alternative methods of achieving compli- preparation ance.

• Security perform a periodic review of 1/87 Changed open MR's & Issue Report to management. schedule -

will need work instruction.

' Initiate attendance of Security manage- 9/86 Complete ment personnel at seminars (e.g. indus- (will trial security) on state-of-the-art continue) security equipment / compensatory measures.

l .

! Page 4 of 4

. 0 0FFICE MEMORANDUM

- e I '

d 1 ('

' Boston Edison Ceepany , RMG Centrol Number To: A. Pedersen Free: E.J / , 1anski Record Type A4.08 Date: 1/12/86 Dept. NHS86-218 Non-Safety Related

Subject:

ity Program Improve :atus Report #10 a

Olstribution:

E.T. Graham T. Nicholson P. Hamilton H.N. Brosee R. Swanson R.V. Fairbank M. McBride 0.L. Myers 0.A. Bryant C.E. Higgins Attached is the tenth monthly status report on planned security program improvements. It is recommended that this report be forwarded to Messrs.

Oisen and Lydon for review and comment.

EXEnlTIVE

SUMMARY

The Security Program Improvements listed in Attachment I and 2 of this report were developed in response to the civil penalty resulting from events of August 1985, concerning vital area barriers. Attachment 3 is a list of ,

SecJrity Program Augmentations. Many of these items in Attachment 3 have been discussed with Regional NRC Security Management.

PJH/la

1. Plan and Schedule of Security Program Improvements  !

Attachments:

2. Ceepensatory Measure on Loss of Security Computer

3. Augmentations to Security Improvement Plan i

l 1

I L 1  :

r,  ; ,

\ l i

J AN 13 yg7 )

\N .

g hFG - Vid<./

/

n. u :. q-Inictmation in this record was deleted in accord 3nce with th Freedom of Inictmation -

' Act, exemetions .

F01A h S *- l $ -

/ /R

ATTACHMENT 1 Plan and Schedule of Security Prograa Improvements ADDITIONAL. BEco OVERSIGHT OF SECURITY FORCE Plan to hire five (5) Boston Edison security supervisors to provide shift coverage of the contract security force.

Original Scheduled Current Coepletion Status Planned Milestones

- Develop job description and approve Jan. 1986 Complete

,- Commence hiring process for Boston Feb. 1986 Complete Edison site security supervisors.

- First Additional Boston Edison site April 1986 Complete security supervisors on board. -

- Remaining Boston Edison site security July 1986 Search for supervisors on board (4 hired to date). last hire continues.

Espect offer to be made to minority candidate

, Cecember CORRECTIVE ACTIONS SYSTEM Plan to develop a procedure to standardize the reporting of security deviations and to initiate thorough and effective corrective actions.

The procedure will include a form for reperting deviations and will require a trend analysis of deviations to identify recurring problems.

Original Scheduled Current CE pletion Status r

Planned Milestones

- Identify and evaluate requirements Mar. 1986 Complete j the corrective action system, i - Develop and approve procedure, June 1986 Complete including form for reporting July 3, 1986 deviations,

- Incorporate into NOP 83A9 Complete Complete 8/1/86 j

i Effective 9/1/86 i

Page 1 of 4 f

l r

CORRECTIVE ACTIONS SYSTEM (continued)

Original Scheduled Current Planned Milestones Completion Status _

- Indoctrination and implementation July 1986 Complete

)

of process.

- Establish enthly trends ------ Complete 1 - Perform first trend analysis of Jan. 1987 On Schedule deviations to identify recurring security defic!.Tncies from SOR.

• REGULATORY REQUIREMENTS ANALYS!$

Plan to perform a regulatory requirements analysis of the Modified Amended Security Plan (MASP), Safeguards Contingency Plan, and Training

' and Qualification (T&Q) Plan vis-a-vis the Code of Federal Regulations.

This analysis is to assure that the regulatory requirements are met by entsting programs and procedures, t

- Obtain resources to perform analysis. Jan. 1986 Complete

- Determine methodology of performing Feb. 1986 Cceplete

! analysis.

- Perform regulatory requirements Oct. 1986 Cceplete l Summary Report

! analysis.

i Issued

' - Prepare changes to Security Plan Oct. 1986 Ceeplete j

(rev. 19) based on regulatory regts analysts.

- Incorp. proposed changes rea'd by Oct. 1986 Complete 8/4/86 Fed. Register into Plan. Sent to

! Licensing (Rev.18) (Miscellaneous Amendments) i Note (1) 1

- Finalize 10CFR50.54p Evaluation. Nov. 2, 1986 Not required l

i for (Rev.18) changes to security plan.

- ORC Review Security Plan (Rev.18) Nov. 12. 1986 Coeplete

! changes required by Federal l Register (Miscellaneous Amendment) i Note (1) (Rev. 18) l

! - Meet with NRC on proposed plan See current Meeting held

! changes.(not those required status on Dec. 4. 1986 by Federal Register) at NRC offices.

(Rev. 19) l l

\

Page 2 of 4 l

(

l.

Original Scheduled Current Planned Milestones Completion Status

- Submtt proposed changes to Dec. 2. 1986 Complete NRC (Miscellaneous A.T.end.ments)

Note (1) (Rev. 18)

- Incorp. NRC coments & final type. Revised to Informal after NRC comments are receives our being incorporated transmittal

- Final ORC Review. Feb. 18, 1987 Revised to accomodate unanticipated workload

- Submit Revision 19 to NRC Feb. 27, 1987 On schedule

- Prepare draft changes to TLQ , To be determined and Contingency Plans after Security Plan submittal

- Prepare 50.54p evaluation on To be Determined TLQ and Contingency Plans.

• Training Plan to evaluate the present approach to training such that:

(1) Security force personnel have a greater sense Complete of awareness of the bases behind their duties (i.e. why they are here).

(2) Security force personnel understand the need Evaluation to initiate aggressive corrective action and to be completed to follow-up thoroughly, in January 1987

• Increated Management Oversteh_t - Corporate Security Plan to establish a Corporate Security Representative Coeplete to strengthen the interface between site and corporate security personnel. This individual will be respon-sible to perform audits in accordance with s structured audit plan, review program document changes, and maintain a state-of-the-art knowledge of security methodologies, This change will be reflected in the Corporate Bulletin Book.

Page 3 of 4

Self-Audtts Plan to audit the sections of the security plan on a Complete regular basis such that the entire plan is addressed by corporate security once/ year.

Note (1): This submittal is of a scope different from the original .

comi tment. It is shown here for the purpose of issuing a single, comprehensive report.

Page 4 of 4

. l ATTACHHENT 2

• ProceduralizeEntstingPrograms Plan to establish procedures for the existing internal Complete surveillance effort and include the scheduling of these surveillances in the Master Surveillance Tracking Program.

Compensatory Neasure on loss of Security Ceeputer A concern was raised by our Senior NRC Resident Inspector, Dr. M. McBride regarding estabitshment of compensatory measure within 10 minutes if the security co puter becomes inoperable. The concern is that in 1985, six 1 security event reports were flied because full compensatory limits were not estabitsbed within 10 minutes after loss of the security cceputer.

The following corrective actions have been taken or are planned:

Original 5:heduled Current Ccepletion Status Planned Milestones

- Evaluate the reliability of the Complete security computer

- Deveico recceendations for computer Complete improvement.

- Decision on optimal recceendation. Har. 1986 Feb. 1987 (Pending requirements analysis by based on NED inputs and NED.)

as comunicated to NRC via telecon on 10/20/86

- Implerent optimal reccenmendation Pending NED regt's analysis (ref Attachment 3)

• As stated in our November 27, 1985 letter Boston Edison reviewed the situation and implemented the following corrective actions:

. Revie.ed and revised the response methodology 411 ewing security personnel to man the required posts within 10 minutes.

. Temporarily increased staffing levels as an Interim measure to ensure the 10-minute response time can be met.

. Provided pre-established compensatory zone assignments on each shift in the event the computer beccces inoperable.

- Trained security force on the revised methodology of response.

- Conducted drills and vertfled that less than 10-minute response is achieved.

Page 1 of 1

AfiACHMENT 3 Attachment 3 15 a list of Augeentations to the Security Improvement Plan.

Many of these items have been periodically discussed with NRC Regional Security Management.

Scheduled Current CceDietion Status BARRI E RS 1/87 1t

- Protected Area

- Incorp Fence Survey into 9/86 Complete Maintenance PM Program, .

1

- Install Bottcc Rail on rence, 12/86 Schedule changed to be completed January, 1987

- Implement NED RecomTendation 10/86 Specific

on Wash Concern. concern and corrective action mas addressed and ccepleted.

Mcwever, long term fix is still required l and will be incorporated into PDC 86-74 l

INTRUSION DETECTION l ,

- Obtain Response to ESR 86-253, 9/86 Cceptete l

- leplement short-term repairs 10/86 in conjuction with fence work, or ccep etton in January 1987.

- Develop Eng. Kodification Schedule 2/87 On schedule (Integrating with Requirements factored Analysis for Coraputer), into PDC 86-77 Issue FRN to PDC 82-200. 7/86 Installation l -

cceplete but I (This installation was still getting l

l considered temporary tecause lt was unknown if the system false alarms ,

l I would be effective in this l unique application).

Page 1 of 4

- Install vsndor adjusted hard:are 10/86 Ccepleted in December, 1986.

. Evaluate Technical Adequacy 11/86 Still k;&lting vendor of Surveillance Procedure for test recomendation.

Intruston,0etection Equipment.  !&C has been requested and has agreed to assist in resolving this issue.

New completion will be scheduled.

~

Obtain Response to ESR's 9/86 Coeplete 86-212 and 86-305.

Develop Implementation Plan 2/87 On schedule (Integrating with require- factored '

ments Analysts for Computer) into PDC 86-78 Achieve resolution with NRC 9/86 Letter issued regarding Interim Coepensatory in October.

l Heasures. Still awaiting

' NRC feedback.

LIGHT!iG Restore yard lighting to original - Cceptete design requirements.

Revise OMG work instruction to - Ccepl e t e include yard lighting tonsidera-tions on trallers, 1

i

• Obtain response to ESR 86-252, 8/86 Cceplete i

• Schedule ccepletion of mcdif t- 10/86 Revised preliminary cations (PDC 83-09). schedule under review and indicates teepletion  :

during RF0 7 t i

r i

Page 2 of 4 l

I

i I

r i -. . ___ -. _

Perfora lighting adequacy survey. After PDC NUS survey l results t

., submitted to <

NED on  :

12/10/86 FACILITIES  ;

Establish private office location - Cceplete ,

for BEco security shift supervisors.  ;

Request additional office /worktfig 9/86 Traller lunchroom space for Securtty Force. 1s now j available

• and assigned in contractor  ;

parking lots.

Plan to move into fact 11ty in January.

Existing administration ,

trailer to be  !

! used for locker and lunchroom space.  ;

• Complete

Confirming request maintenance upgrade 9/86  !

i of Security Facilities at Bechtel Warehouse ,

1 Gate. Alternate Access Gate. G.e., heat.

light. 4/c. furniture painting). ,

1 Completion of facility upgrades - Complete i  !

Inform NED of Security long-term space 10/86 Complete, f 4 needs. Verbally l i communicated  ;

i to C.J. l l Minott. '

i i

ADDITIONAL TRAINING

• Establish overview training 11/86 Trial run  !

j mdule for BEco senior manage- session  !

ment. scheduled for i February. 1987  !

I Establish initial technical 1/87 Learning [

training rodule for Security objectives  !

management, were in I

, preparation.  !

Task post-poned until l

i efter Senior  !

l Level  !

Management  !

training i module is '

l ready for {

l presentation l Page 3 of 4 j

i

, ,$fC1.ItttY PROGRAM 06]ECT1vt$

- 0 Develop initial plan. 7/86 Complete

• Establish initial objectives 9/86 Complete including recommendations, Final decision on key objectives. 10/86 Twelve key performance objectives have been approved in January, 1987

• Develop Implementation Plan. 12/86 Postponed untti second quarter 1987 INTERCCNPANY COMPARISONS Develop schedule for security shift 10/86 7hree (3) supervisors to visit other sites, supervisors scheduled to visit Sequoyoh in -

January, 1967 COMPENSATORY MEASURES Revised Procedure 3.10 to include the - Comp!ste (7) seven criteria of NUREG 1045.

Initiate attendance of Security manage- 9/86 Complete ment personnel at seminars (e.g. indus- (vill trial security) on state-of-the-art continue) security equipment /ccepensatory measures.

Estabitsh formal. regular re-evaluation 1/87 Procedure of compensatory measures to determine completion alternative methods of achieving compil- was pre-empted ance. by unanticipated workload increases resulting f rom audits and self-identified findings.

Effort will be factored into overall procedure rewrite effort Security perform a periodic review of 1/87 Process is in open MR's & Issue Report to management. place; planning to prepare

. vork Instructions Page 4 of 4

o RMG Control Number

', Boston Edison Coepany .

. To: A.L. Onsen From: C.E. ggins Record Type A4.08 Date: 2/12/87 Dept. NMSS 87-35 kon-Safety Related

Subject:

Security Program Improvements Status Report #11 Distribution:

J.M. Lydon E.T. Graham T. Nicholson P. Hamilton K. Roberts M.N. Brosee R. Swanson R.V..Fairbank M. McBride (NRC) 0 L. Myers 0.A. Bryant C.E. Higgins E.J. Ziemlanski J. Joyner (NRC Region 1)

Attached is the tenth monthly status report on planned security program ,

improvements. It is recommended that tht? report be forwarded to Mr. Lydon for review and ccment.

EXECUTIVE

SUMMARY

The Security Program improvements listed in Attachment 1 and 2 of this report tore developed in response to the civil penalty resulting from events of August 1985, concerning vital area barriers. Attachttent 3 is a list of Security Program Augmentations. Many of these items in Attachment 3 have been discussed with Regional NRC Security Management. In our March report, closed items will be taken out of this report and included as a separate "close-out" report.

CEH/la  ;

Attachments: 1. Plan and Schedule of Security Program Improvements

2. Compensatory Measure on loss of Security Computer l

. 3. Augmentations to Secarity Improvement Plan l

w .VMkNI LEASED ,

I i FEB 11887 I FOR US  ;

-Qt r o t si mo informatbn in tMs record was deleted in acccrdance with tha Freedom of information Act, exemgtbns __

F0I A .__12'. ._/_ff _

f/d

l'an and Schedule of Security Progran improvements A00!TIO'<Al. BECo OVERS!GHT or SECtJRITY FORCE Plan to hire five (5) Boston Edison security supervisors to provide shift coverage of the contract security force.

Original Scheduled Current Completion Status.

l Planned Milestones

- Develop job description and approve Jan. 1986 Complete

- Commence hiring process for Boston Feb. 1986 Complete Edison site security supervisors.

- First Additional Boston Edison site April 1936 Cceple te security supervisors on board.

- Boston Edison site security July 1986 Complete l; Feb. 2. 1987 supervisors on board.

CORRECTIVE ACTIONS SYSTEM Plan to develop a procedure to standardire the reporting of security deviations and to initiate thorough and effective corrective actions, i The procedure will include a form for reporting deviations and will l require a trend analysts of deviations to identify recurring problems.

Original Scheduled Current i Completion Status l

. Planned Milestones

- Identify and evaluate requirements Mar. 1986 Complete j

1 - the corrective action system.

! June 1986 Complete

- Develop and approve procedure.

including form for reporting July 3. 1986

]

i deviations.

( Complete 8/1/86

- Incorporate into NOP 83A9 Complete Effective 9/1/86 Page 1 of 4

. CORRECTIVE ACTIONS SYST(N (continued)

- Original Scheduled Current Planned Milestones Completion Status-

- Indoctrination and implementation July 1986 Complete of process.

- Establish monthly trends ------ Complete

- Perform first trend analysis of Jan. 1987 Compleie deviatlens to 1dentify recurring Jan. 1987 security deficiencies frun 50R.

REGULATORY REQUIREMENTS ANALYSIS Plan to perform a regulatory requirements analysis of the Modified Amended Security Plan (MASP), Safeguards Contingency Plan, and Training and Qualtftcation (T&Q) Plt.n vis-a-vis the Code of Federal Regulations.

This analysis is to assure that the regulatory requirements are met by existing programs and procedures.

- Obtain resources to perform analysts. Jan. 1986 Complete

- Determine methodology of performing Feb. 1986 Complete analysis.

- Perform regulatory requirements Oct. 1986 Complete analysis. Sumary Report Issued

- Prepare changes to Security Plan Oct. 1986 Complete (rev.19) based on regulatory regts analysis.

- Incorp, proposed changes rea'd by Oct. 1986 Cceplete 8/4/86 Fed. Register into Plan. Sent to (Rev.18) (Miscellaneous Amendments) Licensing

. Note (i)

- Finalize 10CFR50.54p Evaluation. Nov. 2, 1986 Not required for (Rev. 18) changes to security plan.

- ORC Review Security Plan (Rev.18) Nov. 12, 1986 Complete changes required by Federal Register (Miscellaneous Amendment)

Note (1) (Rev. 18)

- Hett with NRC on proposed plan See Current Meeting held changes.(not those required status on Dec. 4, 1986 by Federal Register) at WRC offices.

(Rev. 19)

Page 2 of 4

d Current

. Planned Milestones Completion Status

- Submit proposed changes to Dec. 2, 1986 Complete NRC (Miscellaneous Amendments)

Note (1) (Rev. 14)

- Incorp. NRC coments & final type. Revised to Informal after NRC coments are receives our being transmittal incorporated

- Complete Independent Review of Rev.19 March 16, 1987 On schedule

- Final ORC Review, March 25, 1987 Revised to accowodate unanticipated wrkload

~

- Submit Revision 19 to NRC March 30, 1987 On schedule

- Prepare draft changes to TM To be determined and Contingency Plans after Security Plan submittal

- Prepare 50.54p evaluation on To be Determined T M and Contingency Plans.

• Training Plan to evaluate the present approach to training such that:

(1) Security force personnel have a greater sense Coeplete of amareness of the bases behind their duties (i.e. why they are here).

(2) Security force personnel understand the need Ccepleted l to initiate aggressive corrective action and January 1987

. to follow-up thoroughly.

Increased Mananceent 0versteh_t - Corporate Security

! Plan to establish a Corporate Security Representative Cyplete to strengthen the interface between site and corporate i security personnel. This individual will be respon-slble to perform audits *n accordance with a structured audit plan, review program document changes, and

maintain a state-of-the-art knowledge of security methodologies. ints change will be reflected in the Corporate Bulletin Ibok.

i f

i Page 3 of 4 I

. .o self-Audits Plan t3 audit the sections Cf the security plan on a Couplete regular basis such that the entire plan is addressed I i

by corporate security once/ year.

%te (1): This submittal is of a scope different from the original commi tment. It is shown here for the purpose of issuing a single, l comprehensive report.  ;

i l

L l

l l

l i

i  !

i t

1 1

i o l I  !

• i I

1 i

I Page 4 of 4 l

• r j -

ATTACHMENT 2 l 1

Procedurallre fitstine Programs

!I' Plan to estabitsh procedures for the entiting internal Complete [

i surveillance effort and include the scheduling of these

survel11ances in the Master Surveillance Tracking {

g Program, '

a Concensatory Measure on I.oss of Security Cceouter ,

4 A concern was raised by our Senior NRC Resident Inspector Dr. M. McBride regarding estabitshment of compensatory M asure within 10 minutes if the security computer becomes inoperable. The concern is that in 1985, sta i

security event reports were filed because full coepensatory limits were not estabitshed within 10 minutes af ter loss of the security cceputer. l

i l:

The following corr 1ctive actions have been taken or are planned:

Origd,31 I l Scheduled Current

) Cecoletion 5tatus [

, f i Planned Milestones u

- Evaluate the reliability of the Cceplete j

! security cceputer i l

4

- Develep recom endations for computer Cotplete

) leproverent, i

i

- Dectston on optimal recomendation. Har. 1986 Closed l

(Pending requirements analysts by Dec. 22, 1986 i

j NED.)

- Implerent optimal reccceendation Cceplett l

i o l

• As stated in our November 27, 1985 letter, Boston (dison reviewed the I situation and implemented the following corrective actions *

• l

- Reviewed and revised the response methodology allowing security I J

personnel to man the required posts within 10 minutes.

f l - Temporarily increased staffing levels as an interim measure to ensure I

the 10-minute response time can be mee.

'1 l

- Provided pre-estabitsbed ccepensatory zone assignments on eash shif t t i

in the event the cceputer beccees inocerable. l

.) I

- Trained security force on the revised rethodology of response, f - Conducted drt115 and vertfled that less than 10-minute response is  !

achieved.

Page 1 of 1  ;

l

ATTACHMENT 3 Attachment 3 is a list of Augmentations to the Security Improvement Plan.

Many of these items have been periodically discussed with NRC Regional ,

Security Management.

Scheduled Current Completion Status BARRIERS 1/ 7 omp ete

- Protected Area

- Incorp Fence Survey into 9/86 Complete i Maintenance PH Program.

Rescheduled Schedule

- Install Bcttom Rail on Fence. changed to March 1987 i be completed l

March, 1987 l

- Implement NED Recommendation 10/86 Complete .

on Wash Concern. l INTRUSION DETECTION Obtain Response to ESR 86-253. 9/86 Complete l Implement short-term repairs Rescheduled [

B-!

in conjuction with fence work, to March 1987  ;

r

- Develcs Eng. Modification Schedule 2/87 On schedule  :

(Integrating with Requirements factored into PDCd6-77 Analysis for Computer), ,

- Issue FRN 33 to PDC 82-200. 7/86 Installation complete but (This installation was still getting l considered temporary because lt was unknown if the system false alarms ,

would be effective in this unique application). -

Page 1 of 4 l

l L

,-,.,--,n--.. ..n. ---w . . _ - - . - _ _

F

. - ' Install vendor adjusted hardoare tR77UG CompVeTeY'd n

' December, 1986.

- Evaluate Technical Adequacy 11/86 Still Aval!!ng vendor

. of Surveillance Procedure for test reccernendation Intrusion Detection Equipment. I&C has been requested and has agreed to assist in resolving this issus.

New completion will be scheduled.

Obtain Response to ESR's 9/86 Complete 86-212 and 86-305.

Develop Implementation Plan 2/87 On schedule (Integrating with require- factored ments Analysis for Computer) into PDC 86-78 Achieve resolution with NRC 9/86 Letter issued regarding Interim Compensatory in October.

Measures. Still awaiting NRC feedback.

LIGHTING

• Restore yard lighting to original - Complete design requ1rements.

Revise OMG work instruction to - Complete include yard lighting considera-tions on trailers.

• Obtain response to ESR 86-252. 8/86 Complete Schedule coepletion of modlf t- 10/86 Revised preliminary cations (PDC 83-09). schedule under review and

- indicates completion during RF0 7 CCNPUTER AND ACCESS CONTROL

• Obtain response to ESR 86-253 9/86 Complete Develope co voter specification 2/87 On schedule Obtain bids 4/87 On schedule Issue purchais arder 5/87 On schedule Schedule completion of ecolfication 6/87 Revise as needed Page 2 of 4

• Perfora lighting adequacy survey.. Af ter PDC NUS survey results 1

. sub21tted to l NED on

. 12/10/86 FACILITIES

• Establish private office location - Comolete for BECo security shift supervisors.

Request additional office / working 9/86 Co,T,pi s te lunchroom space for Security Force. .2/6/87 Confirming request maintenance upgrade 9/86 Complete of Security Facilities at Bechtel Warehouse Gate, Alternate Access Gate, (i.e., heat, light, a/c, furniture, painting).

Completion of facility upgrades --- Complete Inform NED of Security long-term space 10/86 Complete.

needs. Verbally communicated to C.J.

Hinott.

ADDITIONAL TRAINING

• Establish overview training 11/86 Trial run module for BECo senior manage- session ment, scheduled for February, 1987 Establish initial technical 1/87 Post-poned training module for Security untti 3rd management, quarter 1987 Page 3 of 4 t

I,

SECURITY PROGRAM 06]ECTIVES .

-

• Develop initial plan. 7/86 Complete Establish initial objectives 9/86 Complete including recommendations.

• Final decision on key objectives. 10/86 Twelve key performance objectives have been approved in January, 1987 Develop Implementation Plan. 12/86 Postponed until second quarter 1987 INTERCOMPANY COMPARISONS

• Develop schedule for security shift' 10/86 January, 1987 supervisors to visit other sites. Complete COMPENSATORY HEASURES Revised Procedure 3.10 to include the - Complete (7) seven criteria of NUREG 1045.

• Initiate attendance of Security manage- 9/86 Complete ment personnel at seminars (e.g. Indus- (will trial security) on state-of-the-art continue) security equipment / compensatory measures.

• Establish formal, regular re-evaluation 1/87 Complete of compensatory measures to determine (will alternative methods of achieving compli- continue) ance.

• Security perform a periodic review of 1/87 Proct < is in open HR's & Issue Report to management. place; planning

' to prepare work instructions Page 4 of 4 1

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J^'W y OFFICE MEMORANDUM

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[* Bo'ston Edison Company . . RMG C rol Number

. OE To: A. L. Oxsen From: C. E. gins ecord Type A4.08 Date: 3/9/87 Dept. Doc. NSCL-87-68 ,

Non-Safety Related

Subject:

Security Program Improvements. CloMens Status Report iio. 12 Distributions J. M. Lydon M.N.Brosh- T. Nicholson P. Hamilton K. Roberts D. L. Myers R. Swanson R. Fairbank M. McBride (NRC) D. A. Bryant NSGL-File E. J. Ziemianski egion I)

Attached is the monthly status report on planned security program improve =ents.

It is recom= ended that this report be forwarded to Mr. Lydon for review and cocnents.

EXECUTIVE

SUMMARY

The Security Program Improvements listed in Attach =ents 1 and 2 of this report were developed in response to the civil penalty resulting from events of August 1985, concerning vital area barriers. Attach =ent 3 is a list of Security Program Augmentations. Many of the items in Attach =ent 3 have been discussed with Regional NRC Security Management. Closed items only are in this report. A second report for this month includes only those open ite=s.

This report will not be published conthly, s

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Attachments: (1) Plan and Schedule of Security Program Improveme'nts (2) Compensatory Measure on Loss of Security Computer (3) Augeentations to security Improvement Plan Information in this record Wal deleted in act;rdance with the reedom 0f Information Act, exemptions - . - -

FOIA. Kf'l91

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ATTACHMENT 1 Page 1 of 2 P.lon and Sch-dule of Sscurity Program Ieprov2 mints - Tha following itens cro s closed out.

ADDITIONAL BECO OVERSICHT OF SECURITY FORCE Plan to hire five (5) Boston Edison security supervisors to provide shift coverage of the contract security force.

Original Scheduled Current Completion Status Planned Milestones ,

- Develop job description and approve. January 1986 Complete

- Commence hiring process for Boston February 1986 Complete Edison security supervisors.

First additional Boston Edison site April 1986 Complete

, security supervisors on board.

- Boston Edison site security July 1986 Complete supervisors on board. February 2, 1987 CORRECTIVE ACTIONS SYSTEM ,

Plan to develop a procedure to standardize the reporting of security deviations and to initiate thorough and effective corrective actions. The procedure will include a form for reporting deviations and will require a trend analysis of deviations to identify recurring problems.

'l Original Scheduled Current i

completion Status Planned Milestones

- Identify and evaluate requirements March 1986 Complete .

of the corrective action system.

- Develop and approve procedure June 1986 Complete including form for reporting July 3,1986 i

deviations.

- Incorporate into NOP 83A9. Complete Complete 8/1/86 l

i Effective 9/1/86

- Indoctrination and implementation July 1986 Complete of process. l Establish monthly trends. Complete

( - ---

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- Perform first trend analysis of January 1987 Complete l deviations to identify recurring January 1987 security deficiencies from SDR.

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

ATTACRMENT 1

. Pags 2 of 2 J

Current Status Increased Management Oversight - Corporate Security Plan to establish a Corporate Security Representative to Complete strengthen the interface between site and corporate security personnel. This individual will be responsible to perform audits in accordance with a structured audit plan, review program document changes, and maintain a state-of-the-art knowledge of security methodologies.

This change will be reflected in the Corporate Bulletin Book.

Self-Audits Plan to audit the sections of the security plan on a Complete regular basis such that the entire plan is addressed by corporate security once/ year.

Note (1): This submittal is of a scope different from the original commitment. It is shown here for the purpose of issuing a single, comprehensive report.

i

ATTACRMENT 2 Page 1 of 1 Current

. Status Proceduralize Existing Programs Plan to establish procedures for the existing internal Complete surveillance ef fort and include the scheduling of these surveillances in the Master Surveillance Tracking Program.

Compensatory Measure on toss of Security Computer A concern was raised by our Senior NRC Resident Inspector, Dr. M. McBride, regarding establishment of compensator measure within 10 minutes if the security computer becomes inoperable The following corrective actions hr.: been taken or are planned:

Original Scheduled Current Completion Status Planned Milestones

- Evaluate the reliability of the Complete security computer.

l

- Develop recocnendations for computer Complete improvement.

- Decision on optical recoc=endation. March 1986 Closed (Pending requirements analysis by NED.) 12/22/86

- Implement optical recom=endation. Complete l

l As stated in our November 27, 1985 letter, Boston Edison reviewed the situation and impiceented the following corrective actions .

1 i

- Reviewed and revised the response methodology allowing security personnel

! to man the required posts within 10 minutes.

- Tenporarily increased staffing levels as an interim measure to ensure the 10-minute reponse time can be met, f

- Provided pre-established compensatory zone assignments on each shif t in I the event the computer becomes inoperable.

- Trained security force on the revised methodology of response, l

- Conducted drills and verified that less than 10-minute response is achieved, l

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ATTACHMENT 3 Pogs 1 of 1 i

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Attachment 3 is a list of Augmentations to the Security Improvement Plan. Many of these items have been periodically discussed with NRC Regional Security l Management. '

Scheduled Current Completion Status FACILITIES Establish private office location Complete for BECo security shift supervisors. ---

Request additional office / working 9/86 Complete lunchroom space for Security Force. 2/6/87 Confirming request maintenance urgrade 9/86 Co=plete of Security Facilities at Bechtel l k'arehouse Gate, Alternate Access Cate (i.e., heat, light, a/c, furniture, painting). '

Completion of facility upgrades. ---

Complete

• Inform NED of Security long-term - Complete, l 10/86 spaca needs. Verbally ,

communicated to C.J. Hinott.

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OFFICE MEMORANDUM

/

Boston Edison Cc pany

/ RNG Contrs1 Nu-bar

. tE. I gins

/

• To: A. L. Oxsen From:

Record Type A4.08 Date: 3/9/87 Dept. Doc. NSCL 9 Non-Safety Related

Subject:

Security Program Improvemen - Open tems Status Report No. 12 Distribution: ,

J. M. Lydon M.N.Broseg[/ T. Nicholson P. Hamilton K. Roberts D. L. Myers R. Swanson R. Fairbank M. McBride (S D. A. Bryant NSGL-File '

E. J. Ziemians ion 1)

Attached is the monthly status reporc on planned security program i=provements.

It is recoc= ended that this report be forwarded to Mr. Lydon for review and comment.

EXECUTIVE

SUMMARY

The Security Program I= pro'vements listed in Attach =ents 1 and 2 of this report were developed in response to the civil penalty resulting from events of August 1985, concerning vital area barriers. Attachment 3 is a list of Security Program Aug=entations. Many of.these itees in Attach =ent 3 have been ciscussed with Regional SRC Security Managecent. A similar ceeting is scheduled for March 11, 1987, in King-of-Prussia. This report only contains open items.

Closed items have been taken out of this report and are included as a separate "close-out" report. ,e

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Attach =ents: (1) Plan and Schedule of Security Program Ieprovements (2) Co:pensatory Measure on Loss of Security Computer (3) Aug-entations to Security Improvc=ent Plan Information in this record was deleted in accordance with the reedom of Information Act, exemptions FOIA II"/9

/4 _

ATTACHFINT 1 Pege 1 of 2

. Plan end Schsdulo of Sscurity Progrra Inprovenants RECULATORY REQUIREMENTS ANALYSIS Plan to perform a regulatory requirements analysis of the Modified Amended Security Plan (MASP), Safeguards Contingency Plan, and Training and Qualifications (T&Q) Plan vis-a-vis the Code of Federal Regulations. This analysis is to assure that the regulatory requirements are met by existing programs and procedures.

Original Scheduled Current Planned Milestones Completion Status Obtain resources to perform analysis. January 1986 Complete Determine methodology of performing February 1986 Complete analysis.

Perform regulatory requirements October 1986 Complete - Summary analysis. Report Issued Prepare changes to Security Plan October 1986 Complete (Rev. 19) based on regulatory reqts analysis.

Incorp. proposed changes required October 1986 Complete - Sent i by 8/4/86 Fed. Register into Plan, to Licensing (Rev. 18) (Miscellaneous Amendments) ,

i Note (1).

Finalize 10CRF50.54p Evaluation for November 2, 1986 Not Required (Rev. 18) changes to security plan.

- ORC Review Security Plan (Rev. 18) November 12, 1986 Co=plete changes required by Federal Register (Miscellaneous A=endment)

Note (1) (Rev. 18)

- Meet with NRC on proposed plan See current Meeting held on changes (not those required by status December 4, 1986 Federal Register) (Rev.19) at NRC offices

- Submit proposed changes to NRC Dece=ber 2, 1986 Complete (Miscellaneous A=endments)

Note (1) (Rev. 18)

- Incorp. NRC comments & final type. Revise after NRC Informal comments approves our are being incor-transmittal. porated.

- Complete Independent Review of Rev. 19 March 16, 1987 On schedule

F~

ATTACRMENT 1

, Paga 2 of 2 Original Scheduled Current Completion Status Planned Milestones (cont'd)

Final ORC Review. March 25, 1987 Revised to accommodate unanticipated workload.

Submit Revision 19 to RRC March 30, 1987 on schedule Prepare draft changes to T&Q To be determined and Contingency Plans after Security Plan submittal.

- Prepare 50.54p evaluation on To be determined.

T&Q and Contingency Plans.

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ATTACHMENT 2

. Coopensatory Measure on Loss of Security Computer

- CLOSED OUT -

4 1

ATTACHMENT 3 Pago 1 of 6

.Attta'chment 3 is a list of Augmentations to the Security Improvement Plan.

Kiny of these items have been periodically discussed with NRC Regional Security Management.

Scheduled Current Completion Status BARRIERS 7 o te

- Protected Area

- Incorporate Fence Survey into 9/86 Complete Maintenance PM Program.

- Install Bottom Rail on Fence. Rescheduled Schedule changed March 1987 to be completed March 1987.

- Impicment NED Recommendation 10/86 Complete on Wash Concern.

ISTRUSION DETECTION

- Obtain Response to ESR 86-253. 9/86 Complete

- Imple:ent short-term repairs Rescheduled in conjunction with fence work. en March 1987 comp March 1987.

- Develop Engineering Modification 2/87 On schedule -

Schedule (Integrating with Require- factored into m nts Analysis for Computer). PDC 86-77.

- Issue FRN 35 to PDC 82-20D. 7/86 Installation (This installation was considered complete but temporary because it was unknown if still getting the spten would be ef fective in false alarms.

this unique application.)

- Install vendor adjusted hardware 10/86 Completed in December 1986

. ATTACHMENT 3 Page 2 of 4 i

Scheduled Current Completion Status l

IKIRUSION DETECTION (cont'd) l l - Evaluate Technical Adequacy 11/86 Still avaiting of Surveillance Pro:edure for vendor test Intrusion Detection Equipment. recommendation.

I6C has been requested and has agreed to assist in resolving this issue. New comple-tion will be scheduled.

O tain Response to ESR's86-212 and 9/86 complete 86'305.

. Develop Implementation Plan ,

2/87 On schedule -

(Integrating with requirements factored into Analysis for Computer). PDC 86-78.

• 9/86 Achieve resolution with NRC Letter issued in regarding Interim Compensatory October. Still Measures, awaiting NRC feedback.

LIGHTING Restore yard lighting to original ---

Complete design requirements.

• Complete Revise OMG vork instruction to ---

include yard lighting considerations on trailers.

• Obtain response to ESR 86-252. 8/86 Complete

• Schedule completion of modifications 10/86 Revised preliminary (PDC 83-09). schedule under review and indicates completion during RF0 7.

ATTACIDENT 3 Pcte 3 of 4 ,

Scheduled Current t

, Completion Status i

COMPUTER AND ACCESS CONTROL t

• Obtain response to ESR 86-253 9/06 Complete ,

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• Develop computer specification 1/87 On schedule ,

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Obtain bids 4/87 On schedule ,

• Issue purchase order 5/87 on schedule

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• Schedule completion of modification 6/87 Revise as needed l

• Perform lighting adequacy survey After PDC NUS survey results submitted to NED on 12/10/86.

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ADDITIONAL TRAINING I

' Establish overview training module 11/86 Trial run session (

for BEco senior management. scheduled for .

I February 1987. [

• Establish initial technical training 1/87 Postponed until

• module for Security management, until 3rd quarter 1987. l l

SECURITY PROCRAM OBJECTIVES r

• Develop initial plan 7/86 Complete .

i

)

• Establish initial objectives 9/86 Complete -

r

including recom=endations.

' Tinal decision on key objectives. 10/86 Twelve key I

performance l

objectives have l l been approved in i l

January 1987. [

Develop implementation Plan. 12/86 Posponed until  !

3 2nd quarter 1987 l i

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INTERCOMPANY COMPARISONS  !

• Develop schedule for security shift 10/86 January 1987  ;

supervisors to visit other sites. Complete <

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.'* ATTACHMENT 3 Pcge 4 of 4

. l Scheduled Current Completion Status COMPENSATORY MEASURES  ;

Revised Procedure 3.10 to include the ---

Complete 7 criteria of NUREG 1045.

Initiate attendance of Security 9/86 Complete (will management personnel at seminars continue)

(e.g., industrial security) on state- ,

of-the-art security equipment / l compensatory measures.

Establish formal, regular re-evaluation 1/87 Complete (will (

of compensatory measures to determine continue)  !

t alternative methods of achieving compliance.

• Security perform a periodic review of -1/87 Process is in I

open MR's and issue report to place; planning '

management, to prepare work instructions.

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OFFICE HEMORANDUM Boston Edison Company .. RHG Control Nusber To: R. G. Bird From: C. E .Wi g gins Record Type A4.08 Date: 4/10/87 Dept. Doc. NSGL87-105 Non-Safety Related Eub.ie c t : Security Program Impresements - Open Items Status Report #13 Distribution:

K. P. Roberts H. N. Brosee T. Nicholson P. Hamilton A. V. Morisi D. L. Myers R. Swanson R. Fairbank H. McBride (NRC) R. Andrew D. A. Bryant C. Minot E. J. Ziemianski P. Ondash S. Dascupta R. Hird E. HacCormack J. Joyner (NRC Region f) J. Kehoe NSGL-File Attached is the monthly status report for the month of March 1987 on planned security program improvements.

EXEMUXE_S3MMAR1 The Security Program Improvements listed in Attachment 1 of this report were developed in response to the civil penalty resulting from events of August 1985, concerning vital area barriers. Attachment 2 is a list of Security Program Augmentations. Many of these items in Attachment 2 have been discussed with Regional NRC Security Management. Closed items have been taken out of this report.

CEH/mep Attachments: (1) Plan and Schedule of Security Program Improvements (2) Augmentations to Security Improvement Plan v_c u v u. 7 ELEASE I

APR 16 887 l OR USE Informstlon in this record was delt t in accordance with th freedom --

of information Act, exemtions _

F01A JIld--

A/s

ATTACHMENT 1 Pago 1 of 2

~

plan and Schedule of Security program Improvements REGULATORY REQUIREMENTS ANALYSIS Plan to perform a regulatory requirements analysis of the Modified Amended Security Plan (MASP), Safeguards Contingency Plan, and Training and Qualifications (T&Q) Plan vis-a-vis the Code of Federal Regulations. This cnalysis is to assure that the regulatory requirements are met by existing programs and procedures.

ORIGINAL SCHEDULED CURRENT ELANNED M_ILESTONES QQMPLETION STATUS

- Obtain resources to perform January 1986 Complete analysis.

- Dotermine methodology of performing February 1986 Complete analysis.

Complete -

- Perform regulatory requirements October 1986 Summary Report analysis. Issued

- Prepare changes to Security Plan October 1986 Complete (Rev. 19) based on regulatory regts.

analysis.

- Incorp. proposed changes required by October 1986 Complete -

8/4/86 Fed. Register into Plan. Sent to (Rev. 18) (Hiscellaneous Amendments) Licensing Note (1).

l

- Finalizd 10CRF50.54p Evaluation for Novcmber 2 Not Required j (Rev. 18) changes to Security Plan. 1986

- ORC Review Security Plan (Rev.18) November 12, complete changes required by Federal Register 1986 l (Hiscellaneous Amendment) i Note (1) (Rev. 18).

j Complete -

- Meet with NRC on proposed plan See current Meeting held changes (not those required by status on December 4, l Federal Register) (Issue 2 Rev. O) 1986 and on March 11, 1987 l at NRC Offices I

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• ATTACHMENT 1

• Pcgo 2 of 2 ORIGINAL SCHEDULED CURRENT PLANNED MILESTONES COMPLETIQH STATUS

- Submit proposed Security December 2, Complete Plan changes to NRC 1986 (Miscellaneous Amendments)

(Rev. 18)

Note (1)

- Incorporate NRC comments & Revise after Informal comments final type. NRC approves are being our incorporated.

transmittal.

- Complete Independent Review of March 16, 1987 Complete Security Plan, Issue 2, Rev. O Final ORC Review. March 25, April 1, 1987 1987 Revised to accommodate unanticipated workload.

- Submit Security Plan, March 31 On schedule Issue 2, Rev. O to NRC 1987 April 6, 1987

- Prepare draft changes to T&Q To be determined and Contingency Plans after Security Plan submittal.

- Prepare 50.54p evaluation on To be T&Q and contingency Plans. determined.

)

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• Note (1): There were two separate tasks to be completed concerning the Security Plan. The first, Revision 18, was to satisfy the Miscellaneous Amendments to be submitted to the NRC by December 2, 1986. The other was a complete l

i reissue of the Security Plan, identified as Issue 2, Revision 0.

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Pago 1 of 5

• ATTACHMENT 2 Attachment 2 is a list of Augmentations to the Security Improvement Plan.

Many of these items have been periodically discussed with NRC Regional Security Management.

SCHEDULED CURRENT COMPLETION STATUS BARRIERS

- Protected Area incorporate Fence Survey into 9/86 Complete Haintenance PH Program.

Rescheduled Completed Install Bottom Rail on Fence. March 1987 Harch 1987 10/86 Complete Implement NED Recommendation un Wash Concern.

INTRUSION DETECILQH

- Obtain Response to ESR 86-253. 9/86 Complete Rescheduled Completed

- Implement short-term repairs in March 1987 con unction with nce work. to March 1987

< - Develop Engineering Modification 2/87 On schedule -

Schedule (Integrating with factored into Requirements Analysis for PDC 86-77.

Computer).

7/86 Completed

- Issue FRN 35 to PDC P March 1987 (This installation w e dered temporary because it aown i f the system would .cive

' in this unique application. )

Install vendor adjusted hardware 10/86 C>mpleted in December 1986 l

ATTACHMENT 2 Page 2 of 5 LCHEDULED CURRENT QQhptETION STATUS INTRUSION DETECTION (con't)

Evaluate Technical Adequacy of 11/86 Still awaiting vendor test Surveillance Procedure for recommendation.

Intrusion Detection Equipment.

I&C has been requested and has agreed to assist in resolvins this issue. New completion date will be scheduled.

i Obtain Response to ESR's86-212 9/86 Complete and 86-305.

Develop Implementation Plan 2/87 On schedule -

(Integrating with factored into requirements Analysis PDC 86-78.

for Computer). Scheduled for ORC April 87 9/86 , Letter issued in

• Achieve resolution with NRC regarding Interim Compensatory \ * (,\ October. Still awaiting NRC (g FA ^dj\i Hessures, feedback.

9 ,\ G g b . u  % .

LIGliTlRQ rO

• Restore yard lighting to --- Complete original design requirements.  :

--- Complete

• Revise OHG work instruction to include yard lighting considerations on trailers.

• Obtain response to ESR 86-252. 8/86 Complete I

• Schedule completion of 10/86 Revised ,

preliminary

modifications (PDC 83-09). schedule under review and indicates  ;

i completion during RF0 7 l

I

ATTA9HMENT 2 Page 3 of 5 S.CJiEDULED CURRENT NODIFICATJ_QNS TO GATEHOUSES AND CLMpLETION STATUS _

SECURITY DIESEL GENERATOR

• Obtain Response to ESR 86-516 9/86 Complete (PDC 87-17) 9/87 On Schedule

• Added x-rcy machines and full 9/87 On Schedule length turnstiles Dec. 2, 1986

• Hodifications to Contractor 9/87 On Schedule Gatehouse

• S J A Approved 3/87 Complete

• Schedule Completion of RFO 7 On Schedule Modification

• Requested Reassessment of 6/87 On Schedule Vital Areas as a response to IE Bulletin 86-91.

(Add to ESR 86-516) l COMPUTER _AND ACCESS CONTROL

• Obtain response to 9/86 Complete ESR 86-253 l

• Develop computer March 27. Complete specification 1987 4/87 On Schedule I

• Obtain bids

• Issue purchase order 5/87 On Schedule

• Schedule completicn of 6/87 Revise as needed modification After PDC NUS Survey

• Perform lighting adequacy l survey results submitted to NED

ATTACHMENT 2 Page 4 of 5 SCHEDULEQ CURRENT PERIMETE8_ FENCE AND GRADEL COHpLETION STATUS UNDERGPQVE_D PASSAGER

• Obtained Responses to 9/86 Complete ESR-86-212 and 86-305

• Completed PDC 86-77 February Complete (ORC) 1987

• Install Hodifications June '987 On Schedule ADDIT LQNAWAINING

• Establish overview training 11/86 Complete module for BEco Senior March 1987 Hanagement.

• Establish initial technical 1/87 Postponed until 3rd quarter, 1987 training module for Security Hanagement.

DECURITY PRQ.QBAN OBJECTI_y_El

• Develop initial plan 7/86 Complete

• Establish initial 9/86 Complete objectives including recommendations.

• Final decision on key 10/86 Twelve key objectives. performance objectives have been approved in January 1987

• Develop Implementation Plan 12/86 Posponed until 3rd quarter 1987 4

1RIEhCOHpANY_ COBP_ARISONS

• Develop schedule for Security 10/86 On Going Shift Supervisors to visit other sites.

c

• ATTACHMENT 2

. Page 5 of 5 ECHEDULED CURRENT COMPLETION STATUS CQ11PJNSATORY MEASURES

• Revised Procedure 3.10 to --- Complete include the 7 criteria of NUREG 1045.

• Initiate attendance of Security 9/86 Complete (will Management Personnel at Seminars continue)

(e.g., industrial security) on state-of-the-art security equi? ment / compensatory measures.

• Establish formal, regular re- 1/87 Complete (will evaluation of compensatory continue) measures to determine alternative methods of achieving compliance.

• Security perform a periodic 1/87 Process is in review of open MR's and issue place; planning report to management. to prepare work instructions.

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[" FFICE HEHOR ANDL'fi

_ q 4-v 4. Cp Bsston Edison Company RHG Control Number

. .E To:

R. G. Bird F"om: . i. . ggins __ _

Record Type A4.0h Date: 5/5/87 Dept. Loc. NSGL87-188 Non-Safety Related Sttb_.i.e.gi:

e Securit Prograr, Improvements - Open Items Status Rer .t s14 Distribution:

K. P. Roher H. N. Brosee T. Nicholson P. Hamilton A. V. Mori D. L. Myers R. Swanson R. Fairbank ,

M. McBrid (NRC) R. Anc rew J. Kehoe C. Hinott E. MacCo sack P. Ondash S. Dasgupta R. Hird NSGL File 2%ww-<t Attached is the monthly status report for the month of April 1987 on planned security program improvements.

EXEG1111..SXMillRY

e Security Program Improvements listed in Attachment 1 of this repost te developed in response to the civil peria l t y resultar. from events c

August 1985, concerning vital area barriers. Attachment 't i s .. 125: ct S e c a r . *. '. pr o g r a rr. Augmentations. Nato c. ! these item tr. Attachment 2 ha'.*

been c.seussed w1th Regional NRC Security Mannement. Closed items h.tvo been taxen out of this report.

ti/ me p At t ache.en t s : (1) Plan and Schedule of Security program improvements (2) Augmentations to Security Improvement flan 7.w., p

, RD.' a ;w s M/ I IOR GOE exo,A, QT- . .o n '

information in this record was deleted in actordance with l Freedom of Information Act, exem3tiens F01A T M - ~

f/9

1 ATTACHMENT 1 Page 1 of 2  !

RJ3A 3nd SchA ule d o LS.ec u ri t y P r ott.a m_Lm_gt o v e m e n td R EG U L A TORY,J191!J.REffEE[S A NALY S I S  ;

j Plan to perform a regulatory requirements analysis of the Modified Amended

' Security Plan (MASP), Safeguards contingency Plan, and Training and Qualif.catioris (76Q) Plan vis-a-vis the Code of Federal Regulations. This i onalys2s is to assure that the regulatory requirements are met by existing i programs and procedures. l i

j QRISINAL

] SCHE _D1LIR CURRENT

] EkM_h10 M111.Sl9hE.1 CQMELETION STATUS

) - Ferform regulatory requirements October 1986 Complete -

i analysis. Summary Report Issued i

- trepare changes to Security Plan October 1960 Complete

e . - e tt on regulators rents.

j anaj) sis, tissuo ' . ' . Fes. 01 i

j - *neorp. proposed chantes required by October 19?6 Ccmplete -

i 4/80 Fed. Register into Plan. Sent to j F e '. . 18) (Miscellaneous Amendments) SRt N

t e (ll.

- h v ea t with NRC on proposed plan See current Complete -

c r.a n g e s (not those required by status Meetint held Faderal Register) (Issue 2 Rev. 01 on Decemt>er 4.

1980 and on March 11, 1987 at SRC Offices

- Submit proposed Security December 2. r s mplete.

Finn chanten to NRC 1Y36.

( M t seellaneous Amendmerit s )

!"ev. 18)

.t* 11)

- Incorporate NHC i Hes . 18) enmments IPsase atter Intermal 6 11 rial type. . tR appreses commerit s ar e our being transmittal. incorporated.

- .. p l e t

• Independent heriev cf Na t c h 10 Ir t on.pl e t v .

eentat) Plan. Issue ' . ' . Res, o

ATTACHMENT 1 Page 2 of 2 ORIGINAL

.iCHEDQ Q CJDrz,qI ,

PLANNED _HJLESTONES COMPLETION STATtlS Final ORC Review. March 25 Complete as of l b

1987. 4/3/8,.  ;

- Submit Security Plan, March 31. Complete.  ;

Issue 2, Rev. O to NRC. 1!s87. April 27, 1987.

(

Prepare draft changes to T&Q July 31, Started.

and Contingency Plans. 1987. 5/4/87.  !

I y

- Frepare 50.54p evaluation on July 31 Started.

-l T60 and Contingency Plans. 1987. 5/4/87. i 4  !

- Submittal of Contingency Plan Oct. 1. 1987. Startad.

and T&Q to .NRC. 5/4/e,. [

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, Note (1) There were two separate tasks to be completed concernthe [

tlw Security Plan. The first, Revi s i c.n 18, wa s to  ;

satisfy t h e .hls s c e l l a n e o u s Amendmerit s to be submittc1 1 c. j

! the NHC by Dec ember 2. 19 8 ti . The et har was a campacte s I

l reissue of the sceurity Plan, identafled as Issue ': . .

! hevision 0.

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61IAGjiD2 1 Pogo 1 of 4 Attachment 2 is a list of Augmentations to the Security Improvement Plan.

Many of these items have been periodically discussed with NRC Regional '

Securaty Management.

S.EGB 1 TY S1SlIMSERDA'AB EZEACIL I T I ES :

A. Protected and Vital Area Barriers

1) Modify the protected area perimeter fence.

A_Ction Status PDC 86-74 issued. Started -

1/21/87.

CMG Projected Completion 10/21/87,

2) Re..;Sess Vital Areas per IE Notice 86-91.

M..t_ lf D Stat _us.

Add to EsR 80-516. Schedulec fcr 8/15/87 l Completion l .

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PDC 86-77 issued. CMG Pro,iec t ed Start -

5/11/87 Scheduled Completion -

12/4/87. j C. Improse the protected area and perimeter lighting system.

A q.t .i .o.n SAh ta!o Schedule complet2on of modifications. To complete try

( PDt.83-09i s t art -up free RF0 7.

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A1TAcilMEPT 2 Page 2 of 4

' $1.C,1,J,lli P_Rm>33 IMEROXEMDIS I e on ' t )

Engineering to evaluate use of high mast High Mast study lighting to support and Intrusion Complete.

Detection System. (4 Possible Areas).

- Detailed design in progress: to complete 6/15/87.

Pending Town of Plymouth Permit.s.

2 ACt19n S_t_n3 u; PDC 80-78 issued. Start -

4/30/87 CMG Pro,iected Completion 12/lb/e1. ,

E. T<edessen the Security Haar; Access Point and Alternate Access Point.

A.J.O oh h.t a t 93 l Obtain response t o E S ."< 6 6 - $ 10 . Complete (PDC E!-li) 9/-'.. i

"" ,f3 ~. . . . . '

.- 4 . .. ..

,EI '

'*) ou schedule g

9/8I' 09 f g .

[ .. .

Added x-ray mac hi nes and full lencth On Schedule turnstiles. (PDr: 87-171 9/87.

i Modifications to Contractor Gatehouse. On Schedule i

(Post RFO sil (pdc-87-171 9/87.

Fl C te P.\Pd Ior appaesal On Schedule.

5/87, i

Schedule Cortpletson of Modafacatith Or. Sebecule.

RFti si ( Pa t '. 2. 1:

1 Post RFO ::

Ilotal).

i t

I

't,

.ATTAC,HMENT 2 Pogo 3 of 4

[ HCFAi.Il P.ROERAtUi 1 MPROVEMERIS ( con ' t 1

F. Replace the Security Computer and Access Control System.

I Attl211 SAA,tdia Obtain response to ESR 86-253. Complete.

i 9/86.

Develop computer specification. Complete.

, March 23, 1987.

1 Obtain bids. Rescheduled to 5/87.

! Issue purchase order Rescheduled l to 6/87.

! . u.110%it IF AINIXG

=

Establish initial technical 1/87 Po s t i.o n ed training module for Security ur.tal 3rd Management, quarter. 1987 i

j sin Ul_Y 11tQ.qkid QhLErIJ KD i S.CilCDLLE D CLRRE.tT

COMELEILQS E11TD

• Establish initial objectives i including recommendations. 9/86 Complete.

l l

• Final decision on key i ob.j ec t is e s . 10/86 Twelve key

! performance

{ objectives

! have been j approved in

January 1987.

l

= Develop Implementation Plan. 12/86 Postponed until .i r rt l quarter 19F7 l

l j lb.Tibi,9.!!351_CQ311Rl_S_OXS l

• Deselop schedule for Security 10/86 On Goinc.

l Shift Supervisors to visit I

c,ther sites.

{

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, ATTACHMENT 2 Ptte 4 of 4 ELtOLLTl PROGJW11 LMPROVEMENT_$ ( con ' t )

EgliXDULED C1'R R ENT CQMPENSAIQFY >JXASMBEE CQtiPJ.ETION STATUS 4

• Revised Procedure 3.10 to ---

Complete.

3 include the 7 criteria of NL. REG 1045.

• Initiate attendance of Security 9/86 Complete.

Management Personnel ct Seminars On-Going.

le.g., industrial security) on J state-of-the-art security equipment / compensatory measures.

!

• Establish formal. regular re- 1/87 Complete.

i- evaluation of compensatory (will

?

measures to determine continue).

alternative methods of achieving c on.pl i a n c e .

) = Security perform a periodie 1/87 Proce>+ ;5 li.

review of open MF's and issue placc;

r e ;.c.,1 t t. m.nia t e n.< r. t . pl ai.n l n g to a

prepare work

! in s t ru e t ivt.3.

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'___.,_-_..____.~. _ . .__. _ _ ,,_ _ . . _ _ , _ _ _ _ _ _ _ _ , _ _ . _ _ _ . _ _ _ , _ . _ _ _ . _ . . _ . _ , , - _ . . _ _ . . - ,

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Booton Edison Company . . RMG Control Numbol To: .R. 0.. Bird From: . .I gins Record Type A4.08 Date: 6/1/87 Dept. Doc. NSGL87-247 Non-Safety Related Sy_bbs.1: Security Program Improvements - Open Items Status Report #15 Distribution:

K. P. Roberts H. N. Brosee T. Nicholson P. Hamilton A. V. Morisi D. L. Myers R. Swanson R. Fairbank M. McBride (NRC) R. Andrew J. Kehoe C. Minott E. MacCormack P. Ondash S. Dasgupta R. Hird 4 ,'n - - -M MR97ttitMM44 NSGL Fi1e Attached is the monthly status report for the month of May 1987 on planned oocurity program improvements.

GEf1'IJXE_SDiMARX The Security Program Improvements listed in At tachinent 1 of this report were developed in response to the civil penalt.v resulting from events of August 1985, concerning vital area barriers. Attachment 2 is a list of Secu ri t y F rog ram Au stment a t ivns . Many of these items in Attachment 2 have been discussed with Regional NRC Security Management. Closed items have been taken out of this report.

CEH/mer Attachments: (1) plan and Schedule of Security Program Improvements (2) Augmentations to Security Improvement Plan L. '. c t U g g ,

' RELEASED .

.x 7 5p

%t 'Uf f

, su no~

Infonnation in this record was deleted in accordance with the reedom of Information Act, exemntions _ -

FOIA- * /$ I

//9

_ _ __ _ _ _ _ -.- ----- -------------------------- -- w u u w e w w e w u u--- - - - - - - -vuuv o wu o-Elan and__ Schedule of Sec_qrity P r o g rm __I epf_o ve m e n t s i

REQL'l#IQRL.RE@_LBEllENTS ANAIJSJS Plan to perform a regulatory requirements analysis of the Modified Amended Security Plan (MASP). Safeguards Contingency Plan, and Training and Qualifications (T&Q) Plan vis-a-vis the Code of Federal Regulations. This onalysis is to assure that the regulatory requirements are act by existing programs and procedures.

i QRLGJXR i ECHEDULED CtRRESI ELAbHU1LilS10NES C91tELLILQS S_ TAI _t1

- Perform regulatory requirements October 1986 Complete -

j analysis. Summary Report i Issued b

- Prepare changes to Security Plan October 1986 Complete j

based on regulatory reqts.

analysis. (Issue 2 Rev. 0)

- Incorp. proposed changes required by October 1986 Complete -

8/4/86 Fed. Register into Plan. Sent to (Rev. 191 (Miscellaneous Amendments) NRC 5;te (1).

f - Meet with NRC on proposed plan See current Complete -

, changes (not those required by status Meeting held

! Federal Register) (Issue 2. Rev. O) on December 4 1986 and on

!l March 11. 1987 l at NRC Offices l

- Submit proposed Security December 2. Complete.

l Plan changes to NRC 1986.

! (Miscellaneous Amendments) l (Rev. 18)

Note (1)

Incorporate NRC (Rev. 18) comments Revise after k'a l t i n g NRC

) -

NRC approves approval,

' & final type.

our transmittal.

Complete Independent Review of March 10, 1987 Complete.

f -

Security Plan. Issue 2. Rev. O

Pogo 2 of 2 A,TTACHkENT 1

- QRLQJ.S.AL ECHKpVLED CURRENT G.OMPLETION STATUS EkARMED MILESTONES

- Final ORC Review. March 25, complete as of 1987. 4/3/87.

- Submit Security Plan, March 31 Complete.

Issue 2, Rev. O to NRC. 1987. April 27, 1987.

- Prepare draft changes to T&Q July 31. Started, and Contingency Plans. 1987. 5/4/87.

- Prepare 50.54p evaluation on July 31 Started.

T&Q and Contingency Plans. 1987. 5/4/87.

- Submittal of Contingency Plan Oct. 1, 1987. On schedule.

and T&Q to NRC.

Note (1) There were two separate tasks to be completed concerning the Security Plan. The first. Revision 18, was to satisfy the Miscellaneous Amendments to be submitted to the NRC by December 2, 1986. The other was a complete reissue of the Security Plan, identified as Issue 2.

Revision O.

. ATIACJJHEEI 1 Page 1 of 4 Attachment 2 is a list of Augmentations to the Security Iaprovement Plon.

Many of these items have been periodically discussed with .NRC Regional Securit'r Management.

SXCL'RITX_JISI ERS_HAR DJiAREZEACJJJ11_ES :

A. Protected and Vital Area Barriers 11 Modify the protected area perimeter fence.

ActiCD S1Blul PDC 86-74 issued. Started -

4/21/87.

CHG Projected Completion 10/21/87,

2) Reassess Vital Areas per IE Notice 86-91.

Act}_on $1atua Add to ESR 80-516. Scheduled for 4

8/15/87 Completion y' q;_* ~

.: g2 g _

-[e

! F. We n,

e .. ,

e .

g A tt.i_qD S.t h y a PDC 86-77 issued. Long lead materials -

Delivery date l

7/1/87.

' Iaik Re_aA l 7/1/87.

' Scheduled completion l 12/4/87.

Achie.e resolution with NRC regarding Letter issued in Inter'.m Compensatory Hensures. 10/86. Still awaiting .NRC feedback.

C. Improse the protected area and perimeter lighting system.

M ien 11AIME Schedulo completion of modifications. To complete by (PDC 83-09) start-up from RF0 7.

ATTACllMENT 2 Poge 2 of 4 i SEcllRJ U ER.0QRSMS IBE8.Q1EMESIS ( con ' t )

Engineering to evalua of high mast High Hast Study lighting to support and Intrusion Complete, Detection System. Detailed design in progress: to complete 6/15/87.

Pending Town of i' Plymouth Permits.

3 minor FRN's (ORC not required). Task ready 7/31/87.

D.

Ac_t.Lon Sl aA u.g 3

l PDC 86-78 issued. Start -

! 4/30/87 l CMG Pro,iee ted I Completion 12/10/87.

l Material delisery l bv 6/15/87. Task I ready 6/15/87.

l Fu 514.

E. hedesign the Security Main Access Point and Alternate Access Point.

Aet,}of) S tat,.m Obtain response to ESR 86-516. Complete iPDC 87-17) 9/86.

8 u

l Added x-ray machines and full length on Schedule  :

turnstiles. (PDC 87-17) 9/87.

Modifications to Contractor Gatehouse. On Schedule l (Post RF0 7) (PDC-87-171 9/87.

PDC to PSPS for approval On Schedule.

5/87.

Schedule Completion of Modification Design completed 5/11/87. Due for ORC 6/18/87.

Long lead l

i materials IX-Ray I and protective l sheilding). ,

PO 514 delivery l l

8/1/87. Task ready 8/1/87.

l l . . - -- .- -_ _-_____ - .- _ __. -.

ATTACHMENT 2 Pago 3 of 4

. .SIf[RlIX PROG 8AMS UtPROJEMENJ1 (con' t)

F. Replace the Security computer and Access control System. .

Action Slpl_qt Obtain response to ESR 86-253., Complete.

9/86.

Develop computer specification. Complete.

March 23, 1987.

Obtain bids. Bids received Bid evaluation in progress.

Issue purchase order Rescheduled ,

to 6/87. l ADDIT _IONAL TRAINING Establish initial technical 1/87 Postponed a training module for Security until 3rd Management, quarter, 1987

$_ECLfnY ER.QHRAM QME_tT.u11 SffiE01'J.EQ CJlE8f_%T l COMP _1.IllQS STATUS i - Establish initial objectives

{

including recommendations. 9/86 Complete.

1

' - Final decision on key i objectives. 10/86 Twelve ke,s

' performance

! objectives i-were approved e in January

> 1987. <

l

- Develop Implementation Plan. 12/86 Postponed  :

i until 3rd  !

quarter 1987. [

h JXIIfLC_Q11EASX__f 0tl P.AR_11QS.5

- Develop schedule for Security 10/86 On Going.  ;

Shift Supervisors to visit  !

other sites.

j

Pogo 4 of 4 ATTACHMENT 2 SECURllY PROG _RA45 J MpROVEMENTS ( con ' t )

SCHEPA'kED CUB &EEI Cp,9EES1GQRXEAjlVRES 9_QtiPLETION STATUS

- Revised Procedure 3.10 to --- Complete.

include the 7 criteria of NUREG 1045.

- Initiate attendance of Security 9/86 Complete.

Management Personnel at Seminars On-Going.

(e.g., industrial security) on state-of-the-art security equipment / compensatory measures.

- Establish formal, regular re- 1/87 Complete.

evaluation of compensatory (will measures to determine continue).

alternative methods of achieving compliance.

- Security perform a periodic 1/87 Process is in review of open MR's and issue place; report to management. planning to prepare work instructions.

h----em-mm-w-mm---. .... . _.

. OFFICE MEMORANDUM ggg,pj B:ston Edison Company s RHG Control Number h Tc: R. G. Bird From: E. Hb _

Record Type A4.08 Date: 7/3/87 Dept. Doc. NSOL87-325 Non-Safety Related gyb.ie c t : Security Program Improvements - Opet. Items Status Report #16 Distribution:

K. P. Roberts M. N. Brosee T. Nicholson P. Hamilton A. V. Morisi D. L. Myers R. Swanson R. Fairbank M. McBride (NRC) R. Andrew J. Kehoe C. Minott E. HacCormack P. Ondash S. Dasgupta R. Hird J. Joyner (NRC Region I) NSGL File Attached is the monthly status report for the month of May 1987 on planned coeurity program improvements.

LUCGXE

SUMMARY

The Security Program Improvements listed in Attachment 1 of this report were developed in response to the civil penalty resulting from events of August 1985, concerning vital area barriers. Attachment 2 is a list of Socurity program Augmentations. Many of these items in Attachment 2 have been discussed with Regional NRC Security Management. Closed items have bsen taken out of this report.

CEH/mep Attachments: (1) Plan and Schedule of Security Program Improvements (2) Augmentations to Security Improvement Plan cvwen ELEASED

' 1 JUL 6 D67 1 \

e ' FOR USE

' k sruion 2 Information in this record,ys deleted in accord 3nce with th fleedom Of Inform 3 tion Act, exemp!st _ -

F0IA _ f f * ..

l l//

• ATTACHMENT 1 Pogo 1 of 1 Plan an_d_ Schedule of Security Program Imorovements REGULATORY REQMIREMENTS ANALYSIS, Plan to perform a regulatory requirements analysis of the Modified Amended Security Plan (HASP), Safeguards Contingency Plan, and Training and This Qualifications (T&Q) Plan vis-a-vis the Code of Federal Regulations.

onalysis is to assure that the regulatory requirements are met by existing programs and procedures.

ORIGINAL PLANNED MILESTONES SCHEDULED CURRENT COMPLETION STATUS March 31 Complete.

- Submit Security Plan, April 27, 1987.

Issue 2 Rev. O to NRC. 1987.

Waiting NRC Approval / Comments.

July 31, Complete

- Prepare draft changes to T&Q 1987. C/25/87.

and Contingency Plans.

July 31 Started.

- Prepare 50.54p evaluation on 1987. o/4/87.

T&Q and Contingency Plans.

- Submittal of Contingency Plan Oct. 1, 1987. On schedule.

and T&Q to NRC.

t l

i l

Note (1) There were two separate tasks to be completed concerning the Security Plan. The first, Revision 18, was to l satisfy the Miscellaneous Amendments to be submitted to the NRC by December 2, 1986. The other was a complete l

reissue of the Security Plan, identified as Issue 2 Revision O. 3 j 4

?.

ATTACHMENT 1 pago 1 of 4 l

Attachment 2 is a list of Augmentations to the Security Improvemsat Plan.

H0ny of these items have been periodically discussed with NRC Regional i

Socurity Management.

MRITY _ SYSTEMS H ARDWABE/FACILlJJ11 A. Protected and Vital Area Barriers

1) Modify the protected area perimeter fence.

Actiqn Status Started -

PDC 86-74 issued. 4/21/87.

CMG Projected Completion 12/87.

Hilestones for completion by 9/30/87. On Schedule.

- Construction 90%

Fence work 90%

- IDS cutover/ tie-in 5

2) Reassess Protected and Vital Areas per IE Notice 86-91.

Status Atlian Add to ESR 86-516. (protected Area) Complete.

Vital Area Analysis Scheduled for 8/15/87 Completion.

B.

LLaty1 ACALon Long lead PDC 86-77 issued. materials -

Delivery date 7/1/87.

Ittk Readr 7/1/87.

Scheduled completion 12/87.

Achieve resolution with NRC regardLn" Complete.

Interim Compensator.v Heasures.

C. Improve the protected area and peri eter lighting system.

7 Pogo 2 of 4 ATTA'CHHENT 2 SECURITY PROGRAHS 111pROVEMENTS (con't)

Engineering to eval te use f high mast High Mast Study lighting to support and Intrusion Complete.

Detection System. Problems obtaining permits for high mast lighting resulted in a new design using 40 ft. roadway lighting. Design is in process.

Schedule to be developed.

A_clinn 51Atui Issue PDC 86-78 . PDC issued on 4/30/87 CMG Projected Completion 12/15/87.

Received partial delivery.

Preliminary schedule issued.

E. Redesign the Security Main Access Point and Alter. tate Access Point.

6C_t.ifn S!.A1M1 Obtain response to ESR 86-516. Complete (PDC 87-17)

PDC to PNPS for approval Awaiting submittal

, pp v1 Added x-ray machines and full length Pending PDC turnstiles. (PDC 87-17) approval Modifications to Contractor Gatehouse. Awaiting submittal (Post RFO #7) (PDC-87-17)

Design completed Schedule Completion of Hodification 5/11/87. Long lead r.aterials (X-Ray and protective

. g sheilding).

delivery 8/1/87.

Task ready 8/1/87.

-]

pago 3 of 4

• ATTAdHMENT 2

[KCURITY PROGRAMS IMPROVEMENTS (con't)

r. Replace the Security Computer and Access Control System.

Action Status Obtain response to ESR 86-253. Complete.

9/86.

Develop computer specification. Complete.

March 23, 1987.

Obtain bids. Bids received Bid evaluation complete.

Issue purchase order Rescheduled to 7/87.

ADDITIONAL TRAINING

- Establish initial technical 1/87 postponed training module for Security until 3rd Management, quarter, 1987 SECT'RITY PROGRAM OBJECTIVES SCHEDULED CURRENT COMPLETION STATUS

- Establish initial objectives including recommendations. 9/86 Complete.

- Final decision on ker Twelve key objectives. 10/86 performance objectives were approved in January 1987.

- Develop Implementation Plan. 12/86 postponed until 4th quarter 1987.

INTERCQBfANY COMPARISONS

- Develop schedule for Security 10/86 Complete.

Shift Supervisors to visit other sites. )

Pogo 4 of 4 A,TTACHMENT 2 i SECURITY P_ROGRANS IMPROVEMENTS (con't) l SCHEDULED CURRENT '

CQifPLETION STATUS COMPENSATORY MEASURES

- Establish formal, regular re- 1/87 Complete. 1 evaluation of compensatory (will continue),

measures to determine alternative methods of achieving compliance.

- Security perform a periodic 1/87 Completed.

review of open MR's and issue Continuing.

report to management.

l I i i

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~- --- - - - - - - - - - - - - - - - - - - -- -- - - ------------- - _ _

g ---

" QEFICE HEHORANDUM j i,

, , (4 /5.R wt$._ w.

RHGCptrolNusbor

) stop Edison Company ,

s ro: R. G. Bird From: E. s , , _ , ,

s Record Type A4.08 Dept. Doc. NSGL87-423 Non-Safety Related 4

Dato: 8/10/87 ,

S.Wh.itq1: Security Program Improvements - Open I'tems Status Report #17 r

Distributton: P. llamilton K. P. Roberts M. N. Drosee T. Nicholson A. Y. Morisi D. L. Myers R. Swanson R. Fairbank McBride (NRC) R. Andrew J. Kehoe C. Minott H.  :

E. MacCormack P, Ondash S. Dasgupta R. Hird J. Joyner (NRC Region Il NSGL File .

Attached is the monthly status report for the month of July 1987 on planne.d .

cocurity program improvements.

flLG.THE__dC1M01 The Security Program Improvements listed in Attachment 1 of this report were developed in response to the civil penalt.v resulting from events of August 1985, concerning vital area barriers. Attachment 2 is a list of Security Program Augmentations. Many of these items in Attachment 2 have been discussed with Regional NRC Security Management. Closed items have

,; been taken out of this report.

J

) C Ell /me p Attachments: 11) Plan and Schedule of Security Program Improvements (2) Augmentations to Security Improvement plan l r

-. .. t

j I

I t

I I

, t 3 I L

i Information in this record W25 dt!!!fd in acccid3.'Ct with th IItedom of information Act, exe.ajticns M F0tA _J f *-

ll//

" ATTACllMENT 1 Pago I of 1 Plnn sad _ftshed q1_.e o f Sig u r i t y Proiran ImprovepeDia LE9MLAlQflY. RE@,L8EMMILMAkySJS Plan to p.erform a regulatory requirements analysis of the Modified Amended Socurity Plan (HASP). Safeguards Cont.ingency Plan, and Training and This Qualifications IT&Q1 Plan vis-a-vis the Code of Federal Regulations.

nnalysis is to assure that the regulatory requirements are met by existing programs and procedures.

08.LQ1.N AJ.

SRMDRED CMBBE81 CSMPM, TION 5.TAIk'S ELASMUL HLKSl0XE$

- Submit Security Plan. March 31. Complete.

1987. April 27, 1987.

Issue 2 Rev. O to NRC. til Waiting NRC Approval / Comments.

- Prepare draft changes to T&Q July 31. Final comments and Contingency Plans. 1987. received on dra f t.

- nlans. T&Q being prepared for final typing. Review of final comments on T&Q complete.

Final comments review for Contingency Plan scheduled for A/12/87.

July 31. Started.

Prepare 50.54p evaluation on 5/4/87.

T&Q and Contingency Plans. 1987.

Completion date requires extension. To be completed after review-of final product but prior to submittal to

' NRC.

- Submittal of Contingency Plan Oct. 1, 1987. On schedule.

and T&Q to NRC.

Note !!) There were two separate tasks to be completed concerning the Security Plan. The first. Revision 18, was to satisfy the Hiscellaneous Amendments to be submitted to the NRC by December 2, 1986. The other was a complete reissue of the Security Plan, identified as Issue 2 Revision O.

9

ATTACHMENI 2 Pogo 1 of 3 tttachment 2 is a list of Augmentations to the Security laprove:aent Plon.

'. inny of these items have been periodically discussed with NRC Regional security Hanagement.

SECQltlTY_ S.YftTXH_S_ llARTMARE/FAC.lillIES:

A. Protected and Vital Area Barriers S_ta,t u g

.ic t.1 o n (Perimeter Fencel Working and on l

PDC 80-71 issued. schedule. CHG j

(CCTV) projected l PDC 86-77 issued completion date I

PDC 86-78 issued (Intrusion Detection on all three .

l i

Systemi PDC's 12/87.

CCTV long lead I items delivered.

I 1

Projected milestene for completion by 9/30/87. On Schedule.

Const ruction 90%

)

! - Fence w o rl: 90%

01 Reassess Protected and Vital Areas i; per IE Notice 86-91.

i S_tatug i Aq t t o_rt 1

(Protected Areal Complete.

i Add to ESR 86-516.

l Scheduled for Vital Area Analysis l 8/l$/87__ . ..

l Completion.

j I

J B. Improve the protected area and perimeter lighting cystem.

S t.a tu s l Action i

Implement PDC 83-09 Problems obtaining permits for high mast Design is in Schedule i

I lighting resulted in a new design using 40 process.

to be developed.

it, roadway lighting, t

Pogo 2 of 3 AYTACHHENT 2 (con't)

$1fURITY PAQGRAM IMPROVEMENls, Point.

C. Redesign the Security Main Access Point and Alternate Access 6 LSlu AC11911 Obtain response to ESR 86-516. Complete tPDC 87-17)

PDC to PNPS for approval Awaltinq submittal  !

I app al Added x-ray machines and full length Pending PDC (PDC 87-17) approval turnstiles.

Awaiting submittal Hodifications to Contractor Gatehouse. .

(Post RF0 s7) (PDC-87-17) Design completed Schedule Completion of Hodifiestion 5/11/87. Long lead materials (X-Ray and protective sheilding).

deli \ery 8/l/87.

Task

! ready 8/1/87.

) D. Replace the Security Computer and Access Control System.

S1 M.L!1 I atllon

Complete.

j Obtain response to ESR 86-253.

9/86.

Com ple te . .

Develop computer speci f teation. March 23, 1987.

Obtain bids. Bids received Bid evaluation complete.

Issue purchase order Rescheduled to 8/10/87

&DPIT_IDNAL TRAIRIEQ 1/87 Postponed

- Establish initial technical until 3rd training module for Security quarter. 1987.

Hanagement, Working.

Pcga 3 of 3

[ffACHNENT2(cen't) gggyA11Y_lBQGRAM_J MPROyJNENTS REGWU.T.Y PAQGBAtt 001EC.TJ VES

' ECHEQVLFJD CMRBEN.T COBf111LQH EIATU1

- Establish initial ob.jectives including recommendations. 9/86 complete,

- Final decision on key ,

10/86 Twelve key

oblectives. performance ob.lectives I

were approved in January 1987.

- Develop Implementation Plan. 12/86 Postponed i

until 4th ,

' quarter 1987.

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OFFICE MEMORANQQj 83 sten , Edison Company ,

RMGlbntrol Number Toi R. G. Bird From: C . s Record Type A4.os Date: 9/15/87 Dept. Doc. NSSM87-478 Non-Safety Related juAies.1: Security Program Improvements - Open Items -Status Report c18 Distribution:

K. P. Roberts M. N. Brosee T. Nicholson P. Hamilton A. V. Morist D. L. Myers R. Swanson J. D. Keyes J. Kehce C. Hinott J. Lyssh (NRC) R. Andrew E. MacCormack P. Ondash S. Dasgupta R. Hird G. M. Deacy J. Joyner (NRC Region I) ' ,

R. A. Ledgett NSSit File Attached is the monthly status report for the month of August 1987 on planned security program improvements.

EXECMllXLSVHMARY

! The Security Program Improvements listed in Attachment 1 of this repcrt were developed in response to the civil penalty resulting from eve:its of August 1905, concerning vital area barriers. Attachment 2 is a list of Socurity Program Augmentations. Many of these items in attachment 2 have boen ciscussed witn Regional NRC Security Management. C1csed items nave

! boen taken eut of this report.

t hTJN/meo

, Attachments: (1) Plan and Schedule of Security Procram Imorevements (2) Augmentations to Security Improvement Plan cc v w a ri RELEASED ,

1 : I SEP 15987 I I FOR USE raot si m o Informstlen h this re: erd wss deleted in accerdance with the Freekm of Informatic6 Act, eten';tions FOIA_ff-/fI-J/n

Plan and Schedule _of Sicy h Prooram Imoroveg ats RESV[AIOQY QEqVJQg!!ENTS ANALYS!j Plan to perform a regulatory requirements analysis of the Modified Amended Security Plan (MASP), Safeguards Contingency Plan, and Training and Qualifications (T&Q) Plan vis-a-vis the Code of Federal . Regulations. This analysis is to assure that the regulatory requirements are met by existing programs and procedures.

- QRjj]!LA(

S25DVLED qufLREN]

g ANNgD E kg$1QNE) (CMPLETION $TATUS I

- Submit Security Plan, March 31 Complete.

I Issue 2, Rev. O to NRC. (1) 1981. April 27, 1987.

NRC comments received. Rev, to issue 2 beint prepared.

- Incorp. proposed changes required October 1966 Complete -

by 8/4/86 Fed. Register into sent to NRC,

.: Security Plan. (Rev.18)

Hiscellaneous Amendments (1) Comments rec'd from NRC - Add'*

info reautred.

i

! - Prepare and submit add'1 comments October 1987 Comments i to address miscellaneous formulated. ORC Amendments. approved 9/9/87, I - Prepare draft changes to T&Q July 31 Completed. Rev-and Contingency Plans. 1987. of final comment completed and j

incorporated in l

final form.

! - Prepare 50.54p evaluation on July 31 Started.

T&O and Contingency Plans. 1987. 5/4/87.

l Completion date requires I

extension. To t

! completed after review of final l product but prit l to submittal to l NRC.

i i

Submittal of Contingency Plan Oct. 1, 1987. On schedule.

Meeting with

( and T&Q to NRC. Region 1 schedul for 9/24/87

t concerning both

! Plans, i

l Note (1) There were two separate tasks to be completed concerning the Security Plan. The firet. Revision 18, was to satisfy the r

Hiscellaneous Amendments to be submitted to the NRC by Decemoer 2, l

1986. The other was a complete reissue of the Security Plan, l

I identified as !ssue 2. Revision O.

N N Attachment 2 is a list of Augmentations to tho Socurity Improvement Plan.

Many of those stoms have been poriodically discussed with NRC Regional Security Management.

SE.Qt)P ] T Y $Y S T E M S__H A R DW A R E/ F A C U._I TJJ.S :

A. Protected and Vital Area Barriers

_ :q y ,

(AJ I.g j.,Kl".hy'.)y;d;_*f.,

'~

? /(, $. ?

.N e c319D $1Atua PDC 86-74 issued. (Perimeter Fence) Working and on m,e -

q schedule. CMG

(.#hof.*.'

r. g .

/ projected e, f ,. - * '

completion date PDC 86-7e issued (Intrusion Detection on all three System) PDC's 12/87.

CCTV long leac items celiverea.

Projected milestone for completion by 9/30/87 On Schedule.

- Construction 90%

Fence work 90%

- CCTV cutover/ tie-in 50%

IDS cutover/ tie-in 50%

2) Reassess Protected anc V1tal Areas per IE Notice 86-91.

ACA LQO S.La.t ua Add to ESR 86-516. (Protected Area) Complete, vital Area Analysis Rescheduled for 9/30/87 Completion.

B. Improve the protected area and perimeter lighting system.

A t ioO Sta_ tug Implement PDC 63-09 Preblems obtaining permits for high mast Design is in lighting resulted in a new design using 40 process.

ft, roac ay lighting. Schecule to be developed.

~

AT1ACHMENT 2 (con't) Pag 3 2 Of 3

$1(Vf ! T Y PROGR AM IMPROVQdi.G Redesign the Security Main Access Point and Alternate Access Point.

C.

! A C_LLOD ,

3141MJ Obtain response to ESR 86-516. Complete (PDC 87-17)

' PDC to PNPS for approval Awaiting sutmittal p 1 Added x-ray machines and full length Pending POC i tarnstiles. (PDC 87-17 ) approval

, Modifications to Contractor Gatehouse. Awaiting submittal d

(Post RF0 s7) (PDC-87-17) Cesign completed l

l Schedule Completion of Modification 5/11/87. Long lead materials (X-Ray and protective She11dtng).

l delivery 8/1/87, Task ready 8/1/87.

I i

j C. Replace the Security Computer and Access Control System.

I

$Laigg l AC1WO l

Obtain response to ESR 86-253. Complete.

' 9/86.

i Cevelop computer specification. Complete.

l March 23, 1 1987.

J Obtain bids. Bids received Bid evaluation i

complete.

4 l !ssue purchase order P.O. 1ssued to

' Kidde Auto-I eated Systems Inc. en l

' 4/17/87.

i.

i eQQlllONAL TRAINING i

Establish initial technical 1/87 Pescheduled I training module for Security until Ath Management. Quarter, 1987 RFC issued by NTO on l

8/21/87.

1

~

AT1ACHMEN9 2 (con VOD LIC0JTCVT '

SECURITY PRQQBAM IMP 3Qy_(MEF_T._$

l 1ECURITY E!QGBAM QtJECTIVES , j SCEIDMLED CURRENT l C.OMPLETION $TATQ1

- Establish initial objectives 9/86 including recommendations. Complete.

j  ;

t

- ' Final decision on key  !

cDjectives. 10/86 Twelve key l 4 performance j objeGilves 4 were scorovec in January l 1987. i

- Develop Implementation Plan. 12/86 Postponed J until 4th Quarter 1987 [

NOTE: Initial evaluation was concucted in August 1987. The approved t

. Security Objectives were initially believed to be in conformance l with the PNPS Security Plan.  :

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3ostoc Edison Company RHU7't.ntrol NEmTer l b ,- m i

Tot R. G. Bird Trom: @C.@41991ns i Record Type A4.08 l Date: 10/9/87 Dept. Doc. NSSH87-540 Non-Safety Related ;

Sykjigt: Security Program I.mprovements - Open Items Status Report #19 f i

Distributions  !

. K. P. Roberts M. N. Brosee T. Nicholson P. Hamilton  !

, A. V. Morisi D. L. Myers R. Swanson J. D. Keyes )

J. Lyash (NRC) R. Andrew J. Kehoe C. Minott  !

, E. HacCormack F. Ondash S. Dargupta D. D. Zinter ('

R. H. Deacy J. Joyner (NRC Region I) R. A. Ledgett NSSH File Attached is the monthly status report for the month of September 1987 on planned security program in provements. (

EXECRTlYE_M MMARY The Security Program Improvements listed in Attachment 1 of this report l were developed in response to the civil penalty resulting from events of

August 1985, concerning vital area barriers. Attachment 2 is a list of I Security program Augmentations. Many of these items in Attachment 2 have 4

been discussed with Regional NRC Sacurity Management. Closed items have '

l been taken out of this report. i l

i N/mep  :

I 4

Attachments: (1) Plan and Schedule of Security Frogram improvements i

i (2) Augmentations to Security Improvement Plan -

i

{

t r

I 90c0*to f RELEASEC i 1

0C713 9p l (chs FOR USE l

l oc sur, ,. S e  :

l  !

Informatica in this record was deleted l il a::ctdance with tha freshm of Information  :

A:t. eremnt'ons j rp._fh277 f yhA i '

1

ATTACHMENT 1 Pag 0 1 Cf 1

. 3

- Elan and Schedule of Security Program Improvements l

. REGULATORY REQUIREMENTS __ ANALYSIS Plan to perform a regulatory requirements analysis of the Modified Amended Security Plan (MASP), Safeguards Contingency Plan, and Training and i Qualifications (T&Q) Plan vis-a-vis the Code of Federal Regulations. This I analysis is to assure that the regulatory requirements are met by existing I programs and procedures. l l'~-IiML i

• 'lLED CURRENT I

P_ LAM.ED_liI1ESTONES Ct ,

JION S_ TAT _U_S

- Submit Security Plan, F at 31, Complete.

Issue 2, Rev. O to NRC. (1) 1987. April 27, 1987.

NRC ccmments rec 619ed. Rev.

to issue 2 submitted to address comment

- Incorp. proposed changes required October 1986 Complete -

by 8/4/66 sei. Register into sent tv HRC.

Security Plan. (Rev.18)

Miscellanecus Amandments (1) Comments rec'd from NRC - Add'.

info required.

- Prepare and submit add'l comments Octoter 1987 Complete.

to address miscellaneous Amendments.

- Prepare draf t changes to T&Q July 31, Completed. .E e '. .

and Contingency Plans. 1987. of final commen completed and incorporated 17 final form.

- Prepare 50.54p evaluation on July 31, Started.

T&Q and contingency Plans. 1987. 5/4/87.

Completion date requires extension. To i completed after '

review of final product but prit to submittal to NRC.

- Submittal of Contingency Plan Oct. 1, 1987. Reschedule to and T&Q to NRC. 10/23/87. Net with Region I or.

9/23/87 for revi of both plans.

l Note (1) There were two separate tasks to be completed concerning the i Security Plan. The first, Revision 18, was to satisfy the l Hiscellaneous Amendments to be submitted to the NRC by December 2, l 1986. The other was a comp 1.?te reissue of the Security Plan, I identified as Issue 2, Revision 0.

,, s ATTACHMENT 2 page 1 of 3 Attachment 2 is a list of Augmentations to the Security Improvement Plan.

Hany of these items have been periodically discussed with NRC Regional Security Management.

_S_ECURITY SYSTEM _SEDWARE/ FACILITIES :

A. Protected and Vital Area Barriers L. "bTfhk_f$kh?h_ill;!- ?l - .l ' "'? ' - - ~

c.i;hh;MM d'Iht ~u i.' 21

~

&ct.i_oD Status PDC 86-74 issued. (Perimeter Fence) Working and on f com on da e PDC 86-78 issued (Intrusion Detection on all three System)

M Projected milestone for completion by 9/30/87. Reschedule to

- Construction 90% prior to start-

- Fence work 90% up.

2) Reassess Protected and Vital Areas per IE Notice 86-91.

beli2D Stalug Add to ESR 86-516. (Protected Area) Complate.

Vital Area Analysis redirected to verify Rescheduled for Barrier Integrity. prior to start-up i

Submit ESR (87-688) Complete on 9/22/87.

l I

B. Improve the protected area and perimeter lighting system.

Ac.t. ion Status Implement PDC 83-09 Problems obtaining permits for high mast 'a~ is lighting resulted in a new design using 40

. Work j ft. roadway lighting. .a. ecorted on i

pole foundation.

Schedule to be developed, l

l

, ATTACRMENT 2 (con't) Page 2 of 3 EEC'URIT_y PROGRAM IMPROVEMENTS C. Redesign the Security Main Access Point and Alternate Access Point. i Action Status Obtain response to ESR 66-516. Complete (PDC 87-17)

PDC to PNPS for apprcval Cc nplete. Under security review.

ap al and completion.

Added x-ray machines and full length Pending PDC 87-17 turnstiles. (PDC 87-17) approval and completion.

i Hodifications to Contractor Gatehouse. Pending final Hgt.

l (Pect RFO !7) (PDC-97-17) dacinion (Post RFO

1. 7).

Schedule Completion of Modification Design completed S/11/87. Long lead materials (X-Ray and protective sheilding) on site.

l Implementation of PDC 87-17 pending station approval.

D. Replace the Security Computer and Access Control System.

Ac_t19D Slajus Obtain response to 1/h 06-253. Complete.

9/86.

Develop computer specification. Co.mplete.

March 23, 1987.

Obtain bids. Complete Issue purchase order Complete Ap_DJ1LOJAL IRAIEIEQ Establish initial technical 1/87 Rescheduled training module for Security until 4th i Management, quarter, 1987.

RFQ issued by

. NTD on 8/21/87.

_SECU_RITY PROGRAM __ IMPROVEMENTS

. SECURITY PROGRAM OBJECTIVES

.S18EDULED CURR_EN_T COMF '..ET I ON Q STAT _UH

- Establish initial objectives including recommendations. 9/86 Complete.

- Final decision on key objectives. 10/86 Twelve key performance objectives were approved in January 1987.

- Develop Implementation Plan, 12/06 Postponed until 4th quarter 1987.

NOTE: Initial evaluation was conducted in August 1987. The approved Occurity Objectivcc were initially beliavad to be in confntmence with the PNPS Security Plan.

1 l

l l

t

, OFFICE MEMORANDM}i B20 ton Edison CoapOny ,

RMG Control Nu;bar

• To: R. G. Bird From: . E. gins Record Type A4.08 Date: 11/17/87 Dept. Doc. NSSH87-626 Non-Safety Related Sub.ie c t : Security Program Improvements - Open Items Status Report #20 Eistribution: -

K. P. Roberts M. N. Brosce T. Nicholson P. Hamilton A. V. Morisi D. L. Myers R. Swanson J. D. Keyes J. Lyash (NRC) R. Andrew J. Kehoe C. Minott S. MacCormack P. Ondash S. Dasgupta D. D. Zinter R. M. Deacy W. Russell (NRC Region I) R. A. Ledgett NSSM File Attached is the monthly status report for the month of October 1987 on planned security program improvements.

EXECUTIXE_SUMMARl The Security Program Improvements listed in Attachment 1 of this report were developed in response to the civil penalty resulting from events of August 1985. concerning vital area barriers. Attachment 2 is a list of Security Program Augmentations. Many of these items in Attachment 2 have been discussed with Regional NRC Security Management. Closed items have been taken out of this report.

TJN/mep Attachments: (1) Plan and Schedule of Security Program Improvements (2) Augmentations to Security Improvement Plan l

occui e r ELEASE i NOV 181987 I l EOR US ovrwsm# -

Information in this record was deleted in acccrdance with the reedom of Information Act, exemptions __.

FOIA. f$'/f$

D/n

ATTACHMENT 1 Pago 1 ef 1 EJan and Sch9dule of Security Progren Improvements

. REGULATORY REQUIREMENTS ANALYSIS Plan to perform a regulatory requirements analysis of the Modified Amended Security Plan (MASP), Safeguards Contingency Plan, and Traini '9d Qualifications (T&Q) Plan vis-a-vis the Code of Federal Regut . . This analysis is to assure that the regulatory requirements art >+ sting programs and procedures.

ORIGINAL SCHED.Q!JD ~

E.LANNED MILESTONES COMPLETION ,

- Submit Security Plan, March 31, cumplete.

Issue 2. Rev. O to NRC. (1) 1987. April 27, 1987.

NRC comments received. Rev.

to issue 2 submitted to address comments

- Incorp. proposed changes

• required October 1986 Complete -

oy s/4/so Fed. Regi tcr ,nte cent tc NDC.

Security Plcn. (Rev.18)

Hiscellaneous Amendments (1) Comments rec'd from NRC - Add'1 info required.

- Prepare and submit add'l comments October 1987 Complete.

to address miscellaneous Amendments.

- Prepare draft changes to T&Q July 31 Initial review and Contingency Plans. 1987. completed. Fina comments being incorporated.

i Final draft rescheduled to 1/30/87.

- Prepare 50.54p evaluation on July 31, Started.

T&Q and Contingency Plans. 1987. 5/4/87.

Completion date requires extension. To b completed af ter review of final

' product but prio to submittal to NRC.

Pago 2 of 2 ATTACHMENT 1 Rogulatory R2quirenants Anclycio (con't)

• • ORIGINAL SCHEDULED CURRENT PLANNED MILESTONES COHpLETION STATUS

- Submittal of Contingency Plan Oct. 1, 1987. Reschedule to and T&Q to NRC. 12/15/87. Met with Region I on 9/23/87 for revie of both plans.

Note (1) There were two separate tasks to be completed concerning the Security Plan. The first, Revision 18, was to satisfy the Miscellaneous Amendments to be submitted to the NRC by December 2, 1986. The other was a complete reissue of the Security Plan, identified as Issue 2, Revision O. ,

P F

l l

4 l

l I

l

A_TTACHMENT 2. Page 1 of 2 Attachment 2 is a list of Augmentations to the Security Improvement Plan.

Many of these items have been periodically discussed with NRC Regional Security Management.

EL QUJLIly _51S TRisAR.DWARE_LEAC U,I T I E_S :

A. Protected and Vital Area Barriers ' '

3 .. .

.,1+ -

N-  : h :l // .? ..

• J pf. ; . .,

~. ' t.' .l.~..;.

• ~ ?_Y. .f .) ; )k' . }. 7 ., ,

~

,..j Astion b_t.u2 PDC 86-74 issued. (Perimeter Fence) 85% Complete Working and on

> com e on d e PDC 86-78 issued (Intrusion Detection on all three System) 65% Complete ,RDC's 12/87.

Projected milestone for completion by 11/16/87. Reschedule to

- Construction 90% prior to start-

- Fence work 90% up.

2) Reassess Protected and Vital Areas per IE Notice 86-91.

Ac1L9n 11atum l

Add to ESR 86-516. (Protected Area) Complete.

l Vital Area Analysis re. directed to verify Rescheduled for l

Barrier Integrity. prior to

! start-up t

ESR (87-688) - Scheduled to begin work on Complete on 11/23/87. 12/23/87.

l D. Improve 'he protected area and perimeter lighting system.

Aatton Et_alul u

impl ement PDC 83-09 50% complete Problems obtaining permits for high mast Design is l

lighting resulted in a new design using 40 complete. Work ft. roadway lighting. has started and schedule is sequenced with

(

! CCTV schedule for PDC 86-77.

1 _- --_. _ - - _ _ _ _ . _ - ..

Page 2 of 2 ATTACHMENT 2 (con't)

Sigj)A]TYPRdGRAMIHpROVEMENTS C. Redesign the Security Main Access Point and Alternate Access Point.

Status Action Obtain response to ESR 86-516. Complete (PDC 87-17) ORC approved on 10/14/87.

Complete.

PDC to PNPS for approval.

m t o Added x-ray machines and full length Pending PDC 87-17 turnstiles. (PDC 87-17). ORC approved on approval and completion.

10/14/87.

Pending final Hgt.

Modifications to Contractor Gatehouse. decision (Post RFC (Post DFO 87) ( PDF.-8 ? - 17 ) #7).

Schedule Completion of Hodification Design completed 5/11/87. Long lead materials (X-Ray and protective sheilding) on site.

t Implementation of PDC 87-17 pending station approval.

D. Replace the Security Computer and Access Control System.

61alujii 8Cli.911 Obtain response to ESR 86-253. Complete.

9/86.

Develop computer speci fication. Complete.

March 23, 1987.

Complete Obtain bids.

Complete - P.O.

Issue purchase order.

1. 63784 immued 1

Kidde Automated I

Systems.

i Preliminary schedule being developed by HED.

}

ADDIIlPNAL IRAININ_Q 1/88 Ongoing -

i Establish initial technical Scheduled training module for Security completion date Management. .,ee

g

• OFFICE MEMORANDUM Boston Edison Company ,

RMG Control Number E. S. Kraft From: DL J. g To: Record Type A4.08 Dept. Doc. NS M88-020 Non-Safety Related D2te 1/19/88

$_ubi ect : Security Program Improvements - Open Items Status Report #22 Distribution:

X. P. Roberts M. N. Brosee T. Nicholson P. Hamilton R. Swanson J. D. Keyes P. Lord-Ondash L A ssell.. (NRC Region 1)'

J. Lyash (NRC) R. Andrew J. Kehoe NSSM File Attached is the monthly status report for the month of December 1987 on planned security program improvements.

EXECUTIVE

SUMMARY

The Security Program Improvements listed in Attachment 1 of this report were developed in response to the civil penalty resulting from events of August 1985, concerning vital area barriers. Attachment 2 is a list of Security Program Augmentations. Many of these items in Attachment 2 have beenClosed items have been take discussed with Regional NRC Security Management.

out of this report.

N/atf Attachments: (1) Plan and Schedule of Security Program Improvements (2) Augmentations to Security Improvement Plan ocues,,r g El. EASED l

i'd JAN 2 519 8 s

FOR USE Nm go,3 Intermam in tNs n:ord m ofwas W

~

in a;;ordance with Act, exemptions -

F01A _

A/i.

i

I

~

ATTACHMENT 1 Pag 3 1 of 1 Plan an_d Schedule of Security Program Improvements REGULATORY REQUIBEMENTS ANALYSIS Plan to perform a regulatory requirements analysis of the Modified Amended Sccurity Plan (MASP), Categuards Contingency Plan, and Training and Qualifications (T&Q) Plan vis-a-vis the Code of Federal Regulations. This cnalysis is to assure that the regulatory requirements are met by existing programs and procedures.

ORIGINAL SCHEDULED CURRENT COMPLETION STATUS PLANNED MILESTONES

- Submit Security Plan, March 31, complete.

Issue 2, Rev. O to NRC. (1) 1987. April 27, 1987.

NRC comments received. Rev. I to issue 2 submitted to address comments.

- Incorporate proposed changes October 1986 Complete -

required by 8/4/86 Fed. Register sent to NRC.

into Security Plan. (Rev.18) Commen ';s rec 'd Miscellaneous Amendments (1) f rom Na'.C - Add 'l info required and resubmitted.

- Prepare and submit add'l comments October 1987 Complete.

to address miscellaneous Amendments.

- Prepare draft changes to T&Q July 31, T&Q delivered to and Contingency Plans. 1987. RA&P on 1/19/88.

Contingency Plan i

scheduled to be i delivered to RA&P on 1/20/88.

- Prepare 50.54p evaluation on July 31, Estimated T&Q and Contingency Plans. 1987. completion date is 1/22/88.

- Submittal of Contingency Plan Rescheduled to and T&Q to NRC. Oct. 1, 1987. 1/30/88.

Note (1) There were two separate tasks to be completed concerning the I

Security Plan. The first, Revision 18, was to satisfy the Miscellaneous Amendments to be submitted to the NRC by December 2, 1986. The other was a complete reissue of the Security Plan, identified as Issue 2, Revision O.

l

,, ATTACHMENT 2 Pago 1 of 2 At chment 2 is a list of Augmentations to the Security Improvement Plan.

Many of these items have been periodically discussed with NRC Regional security Management.

SIf0RITY SYSTEMS HARDWARE / FACILITIES:

A. Protected and Vital Area Barriers

. , . . . p . .. . . . y ,, y. - _ w .. , ;. , . 4 y- a h

y. . . . , . -..; .

t . V

. . .' 4% , . . '.j .

gy . . , ,

. i 7 Action Status PDC 86-74 issued. (Perimeter Fence) 85% Complete Working and on schedule. CMG g.

~

f J'. . #}.L : -n '

. k 50% Complete projected

.y% w . .. ' 4 ' '

completion date PDC 86-78 issued (Intrusina Detection on all thrce System) 65% Complete PDC's 12/87.

Projected milestone for completion by 11/16/87. Rescheduled

- Construction 90% to 2/7/88 ence work 90%

- IDS cutover/ tie-in 50%

2) Reassess Protected and Vital Areas per IE Notice 86-91.

Action status Add to ESP 86-516. (Protected Area) Complete.

Vital Area Analysis redirected to verify Rescheduled Barrier Integrity. to 2/7/88 start-up ESR (87-688) - Rescheduled to begin work on Projected 12/15/87. completion 2/7/88.

B. Improve the protected area and perimeter lighting system.

AcliqD SAAIMa Implement PDC 83-09 50% Complete Problems obtaining permits for high mast Design is lighting resulted in a new design using 40 conplete. Work ft. roadway lighting. has started and schedule is sequenced with CCTV schedule for PDC 86-77.

Page 2 of 2 A CHMENT 2 (con't)

SECURITY PROGRAM IMPROVEMEETE C. Redesign the Security Main Access Point and Alternate Access Point.

1 Action Status )

obtain response to ESR 86-516. Complete (PDC 87-17) ORC approved on 10/14/87.

PDC to PNPS for approval. Completo.

c o Added x-ray machinec and full length Pending PDC 87-17 turnstiles. (PDC 87-17). ORC approved on approval and completion.

10/14/87.

Modifications to Contractor Gatehouse. Pe0 ding final Mgt.

(Post RFO #7) (PDC-87-17) decib!cn (Post RFO

1. 7).

Schedule Completion of Modification Design completed 5/11/87. Long lead materials ,

(X-Ray and protective shielding) on site.

Implementation of PDC 87-17 pending station approval.

D. Replace the Security Computer and Access Control System.

AcliQD Status l Complete 9/86.

l Obtain response to ESR 86-253.

l Develop computer specification. Complete 3/23/87.

Obtain bids. Complete.

Issue purchase order. Complete - P.O.

! 063784 issued Xidde Automated l

l Systems.

l Preliminary schedule being developed by NED.

ADDITlDHAL TRAINING

- Establish initial technical 1/88 Module complete.

training module for Security Training scheduled '

Management. for completion February 1988.

14 *1 i, .. -

'W.ED'E .21bMs*C )?DI Boston Edison Company RHG Control Number lo: E. S. Kraft From: D J. ng ,,, _ ,,,,,, _ _ _ _ _

Record Type A4.08 ,

Date: h/2/88 Dept. Doc. 'M M8-122 Non-Safety Related hib,jrpt: Securi!v Program improveme'113 -

Open 1tems Status Heport *26 Di s t ri bu t. l on:

i C. harren (NRC) NsSM ylle T. Nicholson ,

k. Russell (NRC Region 1) .

't Attached is the status report ior the month of May 1988 on planned security program improvements.

EN.E9k.II M..S(LHMARl -

Ine attached are augmentations to the Security Program Improvements ,

which were developed in response to a civil penalty due to events of '

, August 1985, concerning vital areas. These planned improvements have l

been discussed with Regional NRC Security Management at length.  :'

i completed items are not included in this report. f i

i TJN:he I B

! l l Attachments: (1) Augmentations to Security improvement Plan >

t i l

I i i l i

l .

, t i  ;

i t

( ;9  :

4 f Information in this record was deleted in accordance with thgreedom of Information Act.

FOIAexemptions ff ~. /- i-[ -

//N ! .

s AITAfHHhbl J Page 1 of 2 lhas Attachment is a list of .\ugmentations to the Security Improvement Plan. These items are periodically discussed with NRC Regional Security Management.

$1sik.R.!ll_#.lSJ1MLS. Jid R Rh3 I.t E / f AC J J.,1 :i,1 F4 :

A. Protected and Vital Area Barriers s .

~~~

g3 p,q 3 . g- .s 4 ,.

-e .< , .

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_-l~; . ( :.;. ' b : ' #D & - .' - ' %, . .

• dc.t.ign C.ofts, t r u g .t t o n S t.al y s

. PDC 86-74 issued. (Perimeter Fence) 99% Complete.

• 80% Complete.

PDC 86-78 issued. (1DS) 95% complete.

Target for 100%

operability is p 8/88. ~~..

'W.-.

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ph ,, ;, _ .j'.

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d. ' _. ; -' . . .

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' ' 'ff6br ' ja, : ' ~ , h ~ .3 #:Je:. , L i : ..y l 7,....-

l 21 Reassess Protected and Vital Areas l per IE Notice 86-91.

1 ALU 00 S tAlua

\ ital Area Analysis redirected to verify Walkdown i

Barrier Integrity. (ESR 87-688) omplete. Report I issued. No d3screpancies noted.

1

4 y-0

\ l',T \t'll't E.Yl, L .3 cvn 8 .) page 2 of g

B. I m r.ro v e 1he protect.ed a f'v H Hud p(* t'i me Le r i l i g h t i fig system.

dM).010 Sta118E implement PDC 83-09. 95% Complete.

I ' (Four potes

- remain to ho installed.

C. Modify Areas at Main and Alternate i Access Points.

i M_tio_p SJ.a_t.y.p 1

l Obtain response to'ESR 8G-516. Complete.

'i ORC approve PDC 87-17 and issue for complete.

construction.

E Schedule Completion ,f Modi fication Scheduled for

, associated with PDC 87-17. completion 2

4 9/30/88.

j - X-ray Machines

- New Explosive and Metal Detectors

- Full-length Turnstiles at Main

Access Point

- Upgrade of Barriers for Security Back-up f

i power h

j D. Replace the Security Computer and Access Control System 1

Milan Status

)

Obtain response to ESR 86-253. Complete 9/86.

r Develop computer specifiention. Complete J/23/87.

Obtain bids. Complete.

I

1ssue purchase order. Complete - P.O.

j s03784 1ssued hic:t 1

Automated S,sstems.

l Preliminary schedu; l being developed hv NED.

l i

• Conceptual construction st.udy, in progress.

l

! Estimated completic i date 9/88.

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