ML20205Q113
| ML20205Q113 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/28/1988 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| EA-88-237, NUDOCS 8811090086 | |
| Download: ML20205Q113 (32) | |
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i 00T 2 8 1959
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Doctet Nos. 50-277 50-278 i
EA No.
88-237-l Philadelphia Electric Company
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ATTN: Mr. C. A. McNeill Executive Vice President-Nuclear i
Correspondence Control Desk P. O. Box 7520 Philadelphia, Pennsylvania 19101 Gentlemen:
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Subject:
September 22, 1988 Enforcement Conference The purpose of this letter is to document the Enforcement Conference held on i
September 22, 1988 in the Region I office concerning the security program at
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the Peach Bottom Atomic Power Station (PBAPS). A list of attendees is l
provided in Enclosure 1.
The Enforcement Conference was held to discuss the findings of two recent
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inspections of your security programs, other NRC concerns regarding l
implementation of the PBAPS security program, and the status of the PBAPS i
security program upgrades, as requested in my September 12, 1988, letter to
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you. The outline of your. presentation at the Conference is provided as Further documentation of the matters discussed at the Conference 3
is prohibited under 10 CFR 73.21 (Safeguards Information) since they concern l
details of your security program that must be protected from public disclosure.
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L J
The information you furnished at the Conference was responsive to our request and beneficial in assessing your progress in making program improvements. No i
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response to this letter is required. Our decision regarding the enforcement
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matters discussed during the Conference will be provided to you at a later date.
Your cooperation is appreciated, j
Sincerely, i
Crigind Signet ap l
j Stewcrt D. Ebneter
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i Stewart D. Ebneter, Director
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Division of Radiation Safety and Safeguards
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0FFICIAL RECORD COPY PB EC LETTER - 0001.0.0 I
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10/18/88 i
0811090086 881028
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PDR ADOCK 05000277 i
O PDC
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e Philadelphia Electric Company 2
"l 23 1953 cc w/ encl:
John S. Kemper, Sr., Senior Vice President - Nuclear E. C. Kistner, Chairman, Nuclear Review Board J. W. Gallagher, Vice President, Nuclear Services Jack Urban, General Manager, Fuels Department, Delmarva Power & Light Co.
Dickinson M. Smith, Vice President, Peach Bottom Atomic Power Station John F. Franz, Plant Manager, Peach Bottom Atomic Power Station J. O. McGoldrick, Manager, Claims Division, Legal Department W. H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric Bryan W. Gorman, Manager, External Affairs Trey B. Conner, Jr., Esquire Eugene J. Bradley, Esquire, Assistant General Counsel Raymond L. Hovis, Esquire Thomas Magette, Power Plant Siting, Nuclear Evaluations W. M. Alden, Director, Licensing Section Doris Poulsen, Secretary of Harford County Council Public Document Room (PDR) local Public Decument Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector-Commonwealth of Pennsylvania bec w/ enc 1:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
Section Chief, DRP Robert J. Bores, DRSS PA0 tu'M h
RI:
S RI:0RSS RI:E0 R
P RI RSS Ke mk/pmb Bellamy Holody (an "
Ebneter
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10//f/88 10/l'l/S8 10//P/88 10// /88 10/M/88 0FFICIAL RECORD COPY PB EC LETTER - 0002.0.0 10/18/88 i
n Enc sure 1 ATTENDANCE LIST PEACH BOTTOM ENFORCEMENT CONFERENCE September 22, 1988 Philadelphia Electric Company W. M. Alden Director, Licensing M. D. Berner, Chief, Security Coordinator, LGS J. W. Devlin, Nuclear Security Specialist (Acc PBAPS
- 0. R. Helwig General Manager, Nuclear Quality A3.urance M. C. Cray, Engineer, Licensing Section F. J. Larkin, Nuclear Security Specialist, LGS C. A. McNeill, Executive Vice President, Nuclear D. R. Meyers, Support Manager, PBAPS
- 0. M. Smith, Vice President, PBAFS R. J. Weindorfor. Director, Nuclear Plant Security Public Service Electric and Gas Company (N.J )
1, M. A. Phillips, Senior Engineer U. S. Nuclear _.1egulatory Commission D. F. Cameron, Reactor Engineer, Physical Security, RI B. Clayton, Regional Coordinator, OEDO S. D. Ebneter, Director, Division of Radiation Safety and Safeguards, RI J. Gadzala, Reactor Engineer, RI J. M. Gutierrez, Regional Counsel, RI D. J. Holody, Enforcement Officer, RI R. R. Keimig, Chief, Safeguards Section, RI J. C. Linville, Chief, Reactor Projects Section 2A, RI L. E. Meyers, Resident Inspector, PBAPS, RI J. A. Madden, Physical Security Inspector, RI E. C. Wenzinger, Chief, Reactor Projects Branch 2, RI
ENCLUSURE 2 O,
s PHILADELPHIA ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION Security Enforcement Conference September 22, 1988 11:00 a.m.
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AGENDA P
4 o Introduction / Remarks D. M. Smith Vice President Peach Bottom Atomic Power Station
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o Program Improvements /
F. J. Larkin f
Peach Bottom Atomic Power Station Nuclear Security Specialist Limerick Generating Station o Apparer? Violations M. O. Berner Chief Security Coordinator (Acting)
Peach Bottom Atomic Power Station 2
o Security Force Member Sleeping /
J. W. Devlin Inattention Nuclear Security Specialist (Acting) t i
Peach Bottom Atomic Power Station o Potentia) rogram Weaknesses D. R. Meyers l
Root Cause Assessment Actions Support Manager l
Peach Bottom Atomic Power Statior, f
o Summary D. M. Smith Vice President i
Peach Bottom Atomic Power Station l
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HCAEP
PEACH BOTTOM ATOMIC POWER STATION SECilRITY PROGRAM PAST PROBLEMS 0
PERFORMANCE 0
OVERVIEW I
0 INTERFACE 0
TEAM CONCEPT l
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PEACH BCTTOM ATOMIC POWER STATION SECURITY PROGRAM PRESENT IMPROVEMENTS 0
SECURITY ORGANIZATIONAL SUPPORT 0
LICENSEE / CONTRACTOR PERFORMANCE O
TEAM BUILDING 0
ADMINISTRATIVE ACCOMPLISHMENTS 0
OPERATIONAL ENHANCEMENTS 0
TRAINING 1
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PEACH BOTTOM ATOMIC POWER STATION SECURITY PROGRAM FUTURE ENHANCEMENTS 0
CONTINUE INITIATIVES TO FURTHER ENHANCE OUR PROGRAM
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PEACH BOTTOM ATOMIC POWER STATION a
SECURITY PROGRAM i
PAST - PROBLEMS j
i 0
PERFORMANCE j
LACK OF ENTHUSIASM, CAPABILITY, AGGRESSIVENESS INITIATIVE AND INNOVATIVENESS f
0 OVERVIEW LACK OF SECURITY CONTRACTOR MONITORING I
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FAILURE TO PROVIDE MORE THAN "ADE,UATE" DIRECTION t
i TO THE CONTRACTOR BY LICENSEE i
O INTERFACE FAILURE TO ESTABLISH AND MAINTAIN 4
i INTERDEPARTMENTAL COMMUNICATIONS i
l 0
TEAM CONCEPT I
NO EVIDENCE OF TEAM BUILDING l
FAILED TO PROJECT AND tH TILL A PROGRESSIVE f
l SECURITY PROGRAM CONCEPT.tND POSTURE i
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o PEACH BOTTOM ATOMIC POWER STATION SECURITY PROGRAM PRESENT - IMPROVEMENTS 0
SECURITY ORGANIZATIONAL SUPPORT LIMERICK NUCLEAR SECURITY SPECIALIST COMMITTED TO ESTABLISHING A MODERN, P,'.0GRESSIVE At4D ENTHUSIASTIC SECURIT" *ROGRAM NEW ACTING CHIEF SECu JTY COORDINATOR IN PLACE 5 JULY FROM THE LIMERICK GENERAT!!iG STATION STAFF, FULL TIME AT PBAPS PART-TIME ASSISTANCE FROM THE LIMERICK GENERATING STATION SECURITY-TECHillCAL ASSISTAtiT IN ORDER TO MODEL PBAPS TO THE LEVEL OF LGS SECURITY SYSTEM TESTING AND SUPPORT ACQUIRING OF A NUCLEAR SECURITY CONSULTANT 7tl A FULL-TIME BASIS WHO IS PRESEfJTLY ACTING AS THE NUCLEAR SECURITY SPECIALIST At4D IS IN-CHARGE OF THE PROGRAM STATION AND CORPORATE MANAGEMENT SUPPORT AND COMMITMEtiT TO IMPROVING THE NUCLEAR SECURITY PROGRAM SECURITY-TECHil! CAL ASSISTAf4T ON BOARD SINCE EARLY AUGUST.
ATTENDED SECURITY ENHANCEMENT TRAINING AND IS ACTIVELY lilVOLVED IN SECURITY SYSTEM TESTING AND MAINTENANCE ON-GOING ENHANCED INTERFACE WITH NQA IN ORDER TO MORE EFFECTIVELY MANAGE AND CONTROL PROGRAMMATIC CONCERNS, COMMITMENTS AND THE OVERALL ORGANIZATIONAL POSTURE 1
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e PEACH BOTTOM ATOMIC POWER STATION SECURITY PROGRAM 0
LICENSEE / CONTRACTOR PERFORMANCE LICENSEE AND CONTRACTOR WORKING TOGETHER AS A TEAM TOWARDS IMPROVING ALL ASPECTS OF THE SECURITY PROGRAM, WITH RESPONSIBILITY AND DIRECTION CLEARLY WITH THE LICENSEE ESTABLISHMENT OF A CONTRACTOR PERFORMANCE ANALYSIS GROUP (PAG) - ALL FOUR MEMBERS OF THIS GROUP ARE PRESENTLY ON BOARD, UNDERGOING SITE SPECIFIC TRAINING AND EXPECT THIS GROUP TO BE FULLY OPERATIONAL IN OCTOBER, APPROXIMATELY ONE MONTH EARLIER THAN ORIGINALLY COMMITTED 0
TEAM BUILDING BOTH CONTRACTOR AND LICENSEE MANAGEMENT PERSONNEL EMPHASIZE THROUGH TRAINING CLASSES, THE IMPORTANCE l
OF THE SECURITY FORCE AS AN ESSENTIAL ELEMENT OF THE TEAM PARTICIPATION IN DEPARTMENTAL MEETINGS TO DISCUSS AND ADDRESS SECURITY ISSUES
o PEACH BOTTOM ATOMIC POWER STATION SECURITY PROGRAM i
0 ADMINISTRATIVE ACCOMPLISHMENTS PLANT PROTECTION PROCEDURES HAVE BEEN REVISED TO REFLECT PROGRAM IMPROVEMENTS AND STRENGTHENING CONTROLS OF THE SECURITY i
PROGRAM AND ACTIVITIES SECURITYCONTRACJORHASPROVIDEDADMINISTRATIVE INSTRUCTIONS (Al S) WHICH PROVIDE GUIDANCE ASSOCIATED WITH IMPLEMENTING OPERATIONAL REQUIREMENTS l
ESTABLISHED AND IMPLEMENTED POLICIEb AND PROCEDURES TO ASSURE CONSISTENCY OF PER*0RMANCE REVISED AND IMPLEMENTCD LOCK AND KEY PROGRAh REVISED AND IMPLEMENTED ScCURITY INCIDENT REP 3RT PROCESS TO INCLUDE FORMAT, INSTRUCTION, INVESTIGATION AND REVIEW REDUCED LONG AND SHORT TERM LICENSEF DESIGNATED F
VEHICLE LIST (LDV'S) BY 40%
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REVISED AND IMPLEMENTED NEW BADGING AND SCREENING I
PROGRAM MODELED AFTER LGS l
ADDRESSING !&E NOTICES AND BULLEi!NS WITH OPERATIONS AND LICENSING PERS0W.EL l
FORMALIZED AND IMPLEMENTED CORPORATE / SITE SECURITY INTERFACE TO ENHANCE DIRECT CORPORATE SECURITY SUPPORT l
L REV!EWED ALL POST ORDER 3 AND REVISED AS
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REQUIRED.
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PEACH BOTTOM ATOMIC POWER STATION SECURITY PROGRAM 0
OPERATIONAL EN!!ANCEMENTS GUARD FORCE TRANSITION TO NEW SECURITY CONTRACTOR ON AUGUST 27, 1988 GUARD FORCE ' LACED ON A FIXED SHIFT SCHEDULE WITH SET DAYS OFF TO INCLUDE LONG RANGE PLANNING REDUCTION IN UNSCHEDULED SHORT NOTICE OVERTIME THROUGH MORE EFFECTIVE MANAGEMENT CONTINGENCY AND EMERGENCY PREPAREDNESS DRILLS CONDUCTED AT LEAST THREE TIMES PER WEEK ESTABLISHED A FORMALIZED VITAL AREA PATROL PROGRAM FORMALIZED SUPERVISORY POST VISITATION FOR BOTH CONTRACTOR AND LICENSEE PERSONflEL ESTABLISHED AND IMPLEMENTED A SECURITY INCIDENT REVIEW COMMITTEE (SIRC)
FORMALIZED POST ROTAT!0ft SYSTEM ACQUIRING OF ADDITIONAL SECURITY COMMUti! CATIONS EQUIPMENT SECURITY EQUIPMENT ACCOUNTABILITY PROCEDURE SECURITY EQUIPMENT PREVENTIVE MAINTENAflCE PROCEDURE COMPENSATORY POST REDUCTION IMPLEMENTATION OF A SUGGESTION PROGRAM FOR THE SECURITY FORCE - IF YOU KNOW OR PERCEIVE OF A BETTER WAY - TELL US - WITH FEEDBACK GUARANTEED ATTENDAtlCE AT DAILY OUTAGE MEETINGS-ATTEtlDANCE AT OPERATIONS SHIFT TURNOVER MEETINGS-THREE TIMES PER DAY 1
0 OPERATIONAL ENHANCEMENTS CONTINUED INCREASED INTERACTION WITH SHIFT OPERATIONS PERSONNEL TO INCREASE SECURITY AWARENESS REVISING ADMINISTRATIVE PROCEDURES TO INCLUDE A SECURITY REVIEW FOR MODIFICATIONS AND MAINTENANCE WORK DISPLAY OF SIGNS ON BARRIERS TO REQUIRE CONTACT WITH SECURITY BEFORE BEING BREACHED IMPLEMENTATION OF A DAILY MANPOWER MEETING TO REVIEW SECURITY MANPOWER AVAILABILITY VS SECURITY MANPOWER REQUIREMENTS
)
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PEACH BOTTOM ATOMIC POWER STATION SECURITY PROGRAM 0
TRAINING DEVELOPMENT OF NEW TRAINING LESSON PLANS DEVELOPMENT OF NEW TRAINING TESTS DEVELOPMENT OF ON-THE-JOB TRAINING PROGRAM DEVELOPMENT OF PERFORMANCE ORIENTED TRAINING AND QUALIFICATION TASK TEST FORMS DEVELOPMENT OF PHYSICAL FITNESS PROGRAM DEVELOPMENT OF CONTRACTOR QA PROGRAM (PAG)
ALL SECURITY FORCE MEMBERS HAVE RECEIVED A 12 HOUR SECURITY ENHANCEMENT COURSE ABOVE THE FORMAllZED TRAINING AND QUALIFICATION PROGRAM PRESENTLY REVISING ALL CAS/SAS LESSON PLANS AND TESTS DEVELOPED FORMALIZED SHlfT SECURITY ASSISTANT TRAINING PROGRAM - CLASSROOM TRAINING SCHEDULED FOR THE LATTER PART OF SEPTEMBER /EARLY OCTOBER INCREASED LICENSEE PARTICIPATION WITH CONTRACTOR t
TRAINING ACTIVITIES INITIATED LICENSEE ATTENDANCE AT SEMINARS UPDATED GET LESSON PLANS FOR EMPLOYEES ON SECURITY REQUIREMENTS (DISPLAY OF KEY CARD, VITAL AREA ACCESS, SEARCH REQUIREMENTS, REPORTING OF INCIDENTS /
EVENTS, FOLLOWING DIRECTION OF SECURITY PERSONNEL AND COOPERATION WITH SECURITY FORCE PERSONNEL)
ALL SHIFT SECURITY ASSISTANTS HAVE BEEN EP TRAINED AND QUALIFIED AS SECURITY TEAM LEADERS I
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PEACH BOTTOM ATOMIC POWER STATION SECURITY PROGRAM FUTURE - ENHANCEMENTS 0
CONTINUE INITIATIVES TO FURTHER ENHANCE OUR PROGRAM 0
ON-SITE EXPOSURE OF SHIFT SECURITY ASSISTANTS AND SHIFT SECURITY SUPERVISION BETWEEN SITES 0
PROVIDE CONTINGENCY CAPABILITIES BETWEEN THE LIMERICK GENERATING STATION AND THE PEACH BOTTOM ATOMIC POWER STATION THROUGH THE CROSS-TRAINING OF LICENSEE AND CONTRACTOR PERSONNEL 0
ADDRESSING LICENSED OPERATORS AND AUXILIARY OPERATORS DURING TRAINING CYCLE ON SECURITY PROCEDURES, PLANS AND ISSUES
PEACH BOTTOM ATOMIC POWER STATION 1
VIOLATIONS 0
DRYWELL HEAD REMOVAL SECURITY t10T
- RESENT AT REMOVAL 0
VITAL KEY l
IMPROPER C0flTROL IMPROPER COMPEtiSATORY MEASURES I
DELAYED COMPEllSATORY MEASURES 0
INEFFECTIVE ACCESS CONTROL SECURITY FORCE MEMBER IMPROPERLY POSIT 10t1ED 0
INSUFFICIENT COVERAGE TWO "DEAD" SPOTS IDEt1TIFIED 0
REMOVAL OF VITAL BARRIER SECURITY F10T PRESEttT Af REMOVAL t
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INATTENTIVENESS / SLEEPING ON POST INCIDENT flUMBER DATE OF INCIDENT LOCATION OF INCIDENT 87-1 29 PAY 1937 VA 87-2 21 Ju!!E 1987 VA 37 f4 6 JUNE 1987 VA 37-8 9 DECEMBER 1987 Eu!LDIfiG ROOF 38-2 9 JAtluARY 1988 BUILDI!!G 30-8 3 AucusT 1903 PROTECTED AREA BAP.RIER 88-24 August 1938 VA
PEACH BOTTOM ATOMIC POWER STATION SECURITY Identified Potential Wea<nesses Program Res3onsibility Clarification Communications Betw 3en Maintenance and Security Requirement or Procedura Compliance Contract Supervisors' Knowledge of Security Ob.'ectives Performance of Post Checks l
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Performance of Surveillance Tests Post Orders Preventive and Corrective Maintenance Overtime Management A
PEACH BOTTOM ATOMIC POWER STATION SECURITY Program Responsibiity Clarification Administrative Procedures Deve oped andIssued Security Plan Changes Security Assessment Nuclear Employee Data System Engineering Requests Granting Unescorted Access Security Investigations Review / Revise / Develop C1arters Nuclear Plant Security Claims / Security Division Station Security l
l Program Scope n A33rova Cyc e l
Position Descriptions Review in Progress 1
PEACH BOTTOM ATOMIC POWER STATION SECURITY Communication Between Mal % nance and Security Security Attends Outage Meetings Shift Security Assistants Attend Shift Turnover Meetings Security To Be Part of MOD Procedure Security To Be Part of Maintenance Request Procedures Feedback on Security Support Availability
B i
PEACF BOTTOM ATOMIC POWER STATION SECURITY Requirement for Procedural Compliance Part of PTl Training and Su3ervisor Meetings Part of Slift Security Assistant Enhancement Training
PEACH BOTTOM ATOMIC POWER STATION SECURITY Contract Supervisors' Know edge of Security Ob'ectives Addressed in PT Training Topic for Enhancement Sessions
e e
PEACH BOTTOM ATOMIC POWER STATION SECURITY Perormance of Post Chec<s PTl Supervisory Training Sessions
PEACH BOTTOM ATOMIC POWER STATION SECURITY Performance of Surveillance Tests Improved Coverage ST Review oy SSA and TA Trained PTl ST Coordinator Plan for Team of Survellance Testers STs Being Reviewed by Limerick and PBAPS Personne
PEACH BOTTOM ATOMIC POWER STATION SECURITY Post Orders All Post Orders Reviewed Against Plan and Procedures Revisions Made Issued
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PEACH BOTTOM ATOM C POWER STATION SECURITY Preventive and Corrective Maintenance Technical Assistant Trac <ing Maintenance and Repair PM Program Initiated for Security Force Member Ecui3 ment (Radios, Batteries, etc.)
I&C Imalementing Procedures for Security Equi 3 ment to Be Reviewed l
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3EACF BOTTOM ATOMIC POWER STATION SECURITY Overtime Management
- Set Sliis Preservation of Days Off Reduced Com3ensatory Posts Daily Review of Manoower Needs Post Rotation Better Managed
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PEACH BOTTOM ATOMIC POWER STATION SECURITY Team Approach To Problem Reso ution TA Attendance at Outage Meetings SSA Attendance at Shift Turnover Attendance at Activity Review Meeting Security on MOD pane Involvement in MOD and Maintenance Requests SSA at Guard Mount l
l PTl at Support Staf" Meetings Al Hands l
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- o PEACH BOTTOM ATOMIC POWER STATION SECU RITY SGA (nowledge of Security Objectives Enhancement Training by PTl Monitoring Groua Involvement Part o' Enlancement Training i
SSAs Problem Solvir.g and Coordination I
PEACH BOTTOM ATOMIC POWER STATION SECURITY t
1 Root Cause Assessment Action Plan l
l C arification of Program Sco3e -
l Distributed for Final Aparoval Clarification of Responsiblities -
Interface Agreements Develo3ed anc Approved in August Position Descriptions Review -
Changes in Progress Key 3ersonnel \\Aeeting - By 10/14/88 t
l Sets of Perormance Standards -
In Progress
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All Hands Meetings -
Held During Week of 8/27/88 Site Wide Activities - As Scheduled NSS To Address New SFM - When Held Expand SSA Training - Some finished, Additional by end of October Extend Watchman Training - PTl Complete
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Upgrade SFM OJT PTl Complete Role of Security; GET - INPO for Approval l
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