ML20199E886
| ML20199E886 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/15/1999 |
| From: | Creed J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kingsley O COMMONWEALTH EDISON CO. |
| References | |
| 50-454-98-03, 50-454-98-3, 50-455-98-03, 50-455-98-3, NUDOCS 9901210111 | |
| Download: ML20199E886 (3) | |
See also: IR 05000454/1998003
Text
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January 15, 1999
Mr. Oliver D. Kingsley
President, Nuclear Generation Group
Commonwealth Edison Company
ATTN: Regulatory Services
Executive Towers West lll
1400 Opus Place, Suite 500
Downers Grove, IL 60515
SUBJECT:
BYRON STATION SECURITY ISSUE RESOLVED
Dear Mr. Kingsley:
Sections S3.b1 and S3.b2 of Inspection Reports No. 50-454/98003; 50-455/98003, dated
February 11,1998, identified two unresolved security items. One of the items pertained to the
adequacy of compensatory measures implemented for a section of the vehicle barrier system.
The other item pertained to the adequacy of alarm system testing when two alarm zones were
returned to service. These issues have been reviewed and resolved by the Safeguards
Branch, Division of Reactor Program Management, Office of Nuclear Reactor Regulation.
Both issues are briefly described below.
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a.
A security officer with a contingency weapon was used to compensate for
approximately 30 feet of a degraded portion of the Vehicle Barrier System (VBS)
between December 8-21,1997. The compensatory measures were in effect to allow
fence and VBS removal for exit of the old steam generators. When discussed with
your security staff, their position was that three unanchored jersey barriers were in
position during this period and that the unanchored barriers were adequate temporary
barriers as described in Nuclear Energy Institute (NEI) Document 96-01," Guidance For
Operational Planning and Maintaining Integrity of Vehicle Barrier Systems", dated
February 1990, and therefore an armed officer was not necessary for the degraded
VBS. Both options for passive VBS barriers were allowed by the station security
procedure (Sections 5.3.2.a and b of procedure CNSG No. 4, Revision 1," Operational
Planning and Maintaining Integrity of Vehicle Barrier Systems", dated August 1996).
We were unsure if the compensatory measures implemented were adequate, although
they did comply with the station security procedure.
NRC Headquarters has concluded that the combination of compensatory measures
(armed security officer and unanchored jersey barriers) met the intent of NEl Document
96-1 and were adequate.
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b.
10 CFR 73.55(g)(2) requires each intrusion alarm to be tested for performance at the
beginning and end of any period that it is used for security. Section 2.b of NRC
Regulatory Guide 5.44, " Perimeter intrusion Alarm Systems", which the introduction to
210002
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9901210111 990115
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ADOCK 05000454
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O
O. Kingsley
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the Byron Security Plan states was used for guidance, recommends that inoperative
alarm zones be tested upon return to service against manufacturer's specifications and
detection probability to include line supervision and tamper testing. Section 13.2 of the
Byron Security Plan states an alarm zone will be " functionally tested" when placed into
service. However, only two types of alarm system testing are described in the security
plan. One of the tests is a weekly test for alarm systems in continuous use; the other
test (which includes multiple tests and tamper and line supervision testing) is for annual
testing purposes .
On December 21,1997, two alarm zones were placed back into service from an
inoperative state. A test was not performed before taking the zones out-of-service, and
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only a single alarm test (which did not include tamper and line supervision testing) was
performed on each zone when retumed to service. This test methodology was the
same test procedure performed for alarm zones in continuous use for seven or more
days. The unresolved item was if such testing was adequate for retuming an
inoperative alarm zone back to service.
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NRC Headquarters has concluded that the more extensive testing described above
(annual test criteria) was appropriate for inoperative alarm systems retumed to service,
and an operational test is appropriate prior to taking an alarm system out-of-service.
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Resolution of these issues is being provided so your staff can assure adequate security
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procedures exist for testing alarm systems prior to taking them out-of-service and upon
retuming them to service.
In accordance with 10 CFR 2.790 of the NRC's * Rules of Practice," a copy of this letter will be
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placed in the NRC Public Document Room (PDR).
Sincerely,
Original Signed by Thomas J. Ploski (for)
James R. Creed, Chief
Plant Support Branch 1
Docket Nos.: 50-454;50-455
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O. Kingsley
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cc:
D. Helwig, Senior Vice President
H. Stanley, PWR Vice President
C. Crane, BWR Vice President
R. Krich, Vice President, Regulatory Services
DCD - Licensing
K. Graesser, Site Vice President
W. Levis, Station Manager
B. Adams, Regulatory Assurance Manager
R. Hubbard, MHB Technical Associates
M. Aguilar, Assistant Attorney General
State Liaison Officer
State Liaison Officer, Wisconsin
Chairman, Illinois Commerce Commission
Distribution:
SAR (E-Mail)
RPC (E-Mail)
Project Mgr., NRR w/enci
J. Caldwell, Rill w/enct
C. Pederson, Rlll w/enci
B. Clayton, Rill w/enci
SRI Byron w/enci
DRP w/ encl
TSS w/ encl
DRS (2) w/enct
Rlli PRR w/enci
G
PUBLlQ4E41 w/enci [h /
Docket File w/enci
GREENS
LEO (E-Mail)
DOCDESK (E-Mail)
/
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