ML20207G016
| ML20207G016 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 05/01/1986 |
| From: | Agosti F DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20207F722 | List: |
| References | |
| FOIA-86-430 VP-86-0052, VP-86-52, NUDOCS 8607220666 | |
| Download: ML20207G016 (15) | |
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Operat ons May 1, 1986 VP-66-0052 Mr. James G. Keppler Regional Administrator Region III U.
S.
Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Reference:
(1)
Fermi 2 NRC Docket No. 50-341 NRC License No. MPF-43 (2)
NRC Inspection Report 50-341/85047 dated February 11, 1986
Subject:
Detroit Edison Nuclear Security Imorovement Plan As previously discussed with members of your staf f, at tached is the Nuclear Security Improvement Plan (NSIP).
This plan augments the specific corrective actions being taken in
- response to the violations noted in Reference 2 and provides a broad approach to improving the long-term effectiveness of security at Fermi 2.
The scope of this plan is not limited to the Nuclear Security Organization; it involves all of Nuclear Operations and represents Detroit Edison's commitment to a successful security program at Termi 2.
The details of the NSIP are dynamic and will be revi.ewed and changed with notifica tion of the NRC, as the needs and accomplishments in the area of security evolve.
The major elements of this plan are intended to be completed by December 31, 1986.
Documentation mentioned in this plan will be maintained for the duration of the plan and for one year following its completion for inspection by your staff.
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Mr. James G. Keppler May 1, 1986 VP-86-0052 Page 2 We trust this plan satisfactorily addresses your concerns reCarding security performance at Fermi 2.
Please contact Mr.
Joseph Conen, (313) 586-5083 if you have any questions on this matter.
Sincerely, Wk [ /.nb
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cc:
J.
R.
Creed M.
D.
Lynch W.
G.
Rogers USNRC Docur.ent Centrol Desk Washington, D.
C.
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,e-Mr. James G. Keppler May 1, 1986 VP-86-0052 Page 3 bec:
F. E.'Agosti J. H.
Flynn L. W.
Hastings J. D. Leman R. S. Lenart L. Martin S.
H. Noetzel G. R. Overbeck J. L. Piana T. Randazzo G. M.
Trahey A. E. Wegele R. L. Woolley Approval Control MRC Follow-up Book /NRC File Region III Chron File Secretary's-Office (2412 WCB)
'C
IUCLFJG SELURITI IMPFGD'ENT PLAN II:rnediate and Long 'Mm Improverents To Be Ccrpleted before 12/31/86 GOAL A:
Inplenent a management systcm to Met survnillmw-required by cerrmitments.
OBJECTIVES:
1.
Irplenent process for verifying door checks utilizing security ccrputer.
i a.
'A Shift Lieutenant rarricmly selects one shift per Trzough week and verifies door check utilizing security NSIP ccrputer data.
Cmpletion b.
Ibclear Security Chief independently ensures dcor Wrough checks are performed on each shift by selecting NSIP one sa@le per Inonth and verifying the door checks Ccrpletion utilizing the security ccrputer data.
c.
Conduct a surveillance of this effort during the May review of the Physical Barriers - Vital Areas.
July Octcber d.
Follcw up as required to resolve surveillance
'Ihrough findings.
NSIP Ccrpletion 2.
Assure all Physical Security Plan requirenents for reports a xi operability tests are met.
a.
List all required reports and crerability tests.
Ccrplete b.
- Monitor ccrpletion of required reports and Cpera-DJCUgh bility tests. (Manthly)
USIP Ccrpletion c.
Ccnduct a surveillance of this effort during the May review of the Security Plan and Inplenenting Pro-July cedures.
Octcber d.
Follcw up as required to resolve surveillance Thrcogh fi:xlings.
NSIP Ccrpletion 3.
Provide officers with current and ccrplete fixed ;cs:
checklists.
a.
Shift LieuterrJ.t renitors every shift for ccrpli-Trroirh ince.
NEIP CCGletiCO i
NSIP - 1986 Pay 1,1986 Page 2 b.
Ibclear Security 011ef independently ensures by Through cc: ducting a rardan quarterly check.
NSIP Cmpletion c.
Cbnduct a surveillance of this effort during the May review of the Security Plan ard Inplementing Pro-July cedures.
Octcber d.
Follow up as required to resolve surveillance Through findings.
NSIP Ca@letion 4.
Cbnduct interral surveillance review on all 22 applicable IEC Inspection Prccedure Ibdules by:
a.
Fonrally training 10 lbclear personnel in Ccrplete surveillance techniques thrcogh the use of a certified generic quality assurance training course corducted for Detroit Fdison by Bechtel Pcwer Corporation.
b.
Expand the scope of the Physical Security Plan Ca@lete audit by organizations not controlled by !bclear PSP Rev 9 Security ramgerent to ratch 10CFR and Detroit Edison com.itrents, c.
Corduct the annual audit of Nuclear Security by an Ca@lete outside organization (10A).
d.
Upgrade lhclear Security surveillance activities April by including iteras fran prior surveillances, audits ard inspections.
e.
Ctrplete first round of surveillance on all June racdules.
f.
Verify the effectiveness of the corrective actions Through being taken in other NSIP cbjectives.
NSIP Carpletion 5.
Clarify procedural cardtrents and reaintenance require-raents.
a.
Su'x.it Physical Security Plan changes fcr :ncre Ca plete effective cycration.
PSP Ree 9 b.
Veriff the Physica' Securit; Plar cha gs: are in-
';ril Cc!? Crated into prCCOdures.
c.
Orduct a surveillance of this effcrt du-ing the Fay reties of the Security Plan and ~:glerenting Prc-July cedures.
Octcher
IEIP - 1986 b'ay 1, 1986 Page 3 d.
Follow up as required to resolve surveillance Trrou;;h findings.
NSIP Ccupletion 6.
Correct the process for authorizing terporary access to zones not pemanently accessed, including sirplifying the record keeping.
a.
Take i:tradiate corrcctive acticn to ensure that Ccnplete all tepary zones are prcperly authorized.
b.
Sinplify the record keeping and reiiew terporary Through zone deviations in existence on every shift, to IEIP ensure that all are authorized.
Carpletion c.
Conduct a surveillance of this effort during the May reiiew of Access Control - Personnel.
July Octcber d.
Follcw up as required to resolve surveillance Wrough findings.
NS P Ccrpletion 7.
Ensure that all access authorization background irfoma-tion files contain all require 3 documnts, a.
Conduct a 100% rwiea of the files to ensure April requirei dccunentation is contained in each.
b.
Conduct a surveillance of this effort during the b'ay refiea of Access Control - Personnel.
July Octcher c.
Follcw up as required to resolve surveillance Wrough findings.
NSIP Ccnpletion 8.
Consolidate access authorization zone groups by organi-zational unit arxi jcb title to limit access on a generic basis to those having a jcb need to access a zone.
a.
Conduct a 100% refiea of the authorized =cnes for Ccrplete all keycard holders and irplcnent cc-~;tive action for required access in the plant.
h.
Conduct a surveillance cf Sis effort d ring $s
.%y retica cf Access Ccntrci - Persc=el.
Ju' y Oc:cter c.
Folicw up as required to resolve surveillance Wrough findings.
NS:F Ccrpletion
NSIP -~1986 bhy 1,1986 Page 4 9.
Conduct a 100% review of the vehicles perranently autho-rized inside the Protected Area.
a.
Inventory all vehicles inside the Protected Arca and Ccrplete ccrpare the actual vehicles with the authorizing re-cords, and take corrective action so that every vehicle is properly authorized.
b.
Conduct a surveillance of this effort during the May re/iew of Access Control - Vehicles.
July Octcber c.
Follcw up as required to resolve surveillance
'Ihrough findings.
NSIP Carpletion 4
- 10. Ensure Security Officers have ret all SPT&Q Plan criteria.
t a.
Shif t Lieutenant conducts weekly qualification re-Thrcragh view of all shif t personnel to ensure that all cffi-NSIP cers' training is current.
Ccrpleticn b.
Nuclear Security Chief co: ducts a renthly review
'Ihrough to ensure shift perscnnel n.eet SPT&Q Plan criteria.
NSIP Ca:pletion c.
Cbnduct a surveillance of this effort during the May revies of Personnel T&Q - General.
Aupst Ncreccher d.
Follcw up as reqaired to resolve surveillance
'Ihrcragh l
findings.
NSIP Ccrpletion
- 11. Upgrade Ibclear Security work instraction for Conduct April of Intemal Ccrpliance Evaluaticn (NS2008).
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NSIP - 1985 May 1, 1986
- Page 5 GOAL B:
CarrECt adVOISe trerrin.
OBJECI'IVES:
1.
Reduce personnel errors resulting frcm inproper use of keycards and doors to less than 10 per month, without changing the definition.
a.
Assign two officers during peak periods at each Ccrplete portal to minimize potential for keycards leaving the Protected Area.
b.
Ibnitor personnel errors weekly for irproper use Cceplete of doors and keycards until the cbjective is ret.
Ibnthly ccrnunication to senior Fermi 2 t'aragenent Tnrough c.
personnel on nu: er of personnel errors resulting NSIP frcra inproper use of doors and keycards.
Ccepletion d.
Fbnitor (quarterly) corrective action taken on IKRs h ough and revies results with senicr Fem.i 2 Paragenent.
NSIP Ccrpletion e.
Include infomation on Security corrective actions Through in two weekly Plant.liessletters (Mcderator) per IEIP Jnanth.
Ccrpletion f.
Regularly include infomation on Security corrective Through action cbjectives in the daily Plant Status Report.
IEIP Ccrpletion g.
Conduct a surveillance of this effort during the Fay review of banagement Effectiveness.
Septerber Deceber h.
Follcw up as required to resolve surveillance h ough findings.
NSIP Ccrpletion T
2.
Issue a discipline clarification policy for Security Ccrplete rules (IID 38) frcr. the Vice President - Nuclear Operations.
3.
Paragment neetings.id 3a:~ gaining '? nit Cf ficen to
~.rcufr r
eghasize ccq liance wi S Security rules.
SSIP C o letion
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NSIP - 1986 Pay 1, 1986 Page 6 4.
Inprove mainterance of x-ray, metal and explosive detection equi p t to achieve an in-service rate of 50% or nore on each type of equignent in each portal, a.
Inprove monitoring and tracking systcm.
Ccnplete b.
Initiate ccupensatory measures in a timely mnner.
Thrcogh NSIP Ccrpletion l
c.
Conduct a surveillance of this effort during the Fay h
review of Testing and Paintenance.
July Octcber d.
Follcw up as required to resolve surveillance Through findings.
NSIP l
Ccrpleticn 5.
Inprove rainterance of equignent requiring ccrpsatory neasures.
a.
Inprove monitoring and tracking system.
CCup1Gte b.
Record causes for equipaent out of service tP2t
'Ihrough reTaire ccrmsatcry measures in excess of 5 days.
NSIP C%rpletion c.
Paintain Security equignent so that less than three Through unplanned ccrpensatorf measures will be in effect NSIP for equipt out of service due to rainterance at Ccupleticn least 90% cf the tine, d.
Institute corrective actions through senior Femi 2 Through Management when equipTnt rainterance fails to neet NSIP 5.b and 5.c.
Ctmpletion Security St' ff Mcaber will attend the P:F21 Work
'Ihrough e.
a Group acceptance meeting to ensure Security NSIP mainterance P:F21s are being worked. Senior Ccnpletion Fenni 2 Paragement will discuss ccnpensatory measures requirire minterance when apprcpriate pricrities need enphasis.
f.
Conduct a surveillance of this effort during the May rreiew cf Te::ing =d :2. inter 2_r.ce.
Xy Cct&er g.
Security Staff Mc er will attend FCO reetirg Throu;P to address Security conce=s ard work requiring
- SIP c=;ensatcrj ncasures.
Ccrpletic:
1
- NSIP - 1986 N y 1, 1986 Page 7 h.
Follow up as required to resolve surveillance Throuch findings.
NSIP ~
Ompletion 6.
Security Systcm nodifications (EDPs) for identified im-prcycrents for security doors, alarm stations, INAC systers, and outside grounding will be completed, a.
Security Staff Mrber will attend roetings
'Ihrough to ensure the Security EDPs are appropriately NSIP 4
addressed and progress to PN-21s and are worked Ccrpletion to ccupletien.
b.
CbnSuct a surveillance of this effort during the my review of Testing and thinterance.
July Octcber c.
Follcw up as required to resolve surveillance Through findings.
NSIP Ccrapletion 7.
Security-System preventive rainter2.nce will be i:Trcved as an elernt in the Plant Pre /entive hinterance Program, i
a.
All security systen equi 1 rent requiring April preventive rainterance will be ider.tified.
b.
Preventive minterance instructions will be my written on all security system equiIrent requiring preventive rainterance, c.
Preventive Ninterance scheduling intervals June will be established.
d.
Fbnitoring of preventive d.
Fbnitoring of pre /entive raintenance ccrpleted.
July e.
Conduct a surveillance of this effort during the my re/iew of 'Ibsting and hintenance.
July Octcher f.
Follcw up as required to resolve surveillance
'Ihrough fi:xiings.
NSIP Ccnpletion S.
Varehouse 3 w:l'. he cxcluded frc-the 'rc:ected Jrt:. t:
Ju_us:
reduce ccrpensntc-j reccets regired.
9.
gggtcygguqc;pgge:gg{es for micrcuave egiIrent e
tne nJ. cr c: cec =1:y perscnne hours to acccnr ;s...
IEIP " 1986 May 1, 1986 Page 8 a.
Ibclear Security Chief will rnonitor compliance Tbzough Inonthly.
NSIP Ccnpletion b.
Conduct a surveillance of this effort during the Fay review of Ccntensatory Measures.
August Noveber c.
Follcw up as required to resolve surveillance
'Ihrough findings.
NSIP Ccrpletion 10.
Coordiste senior Femi 2 Panagment and Ibclear Security efforts.
a.
Nuclear Prcxiuction SuperinteMent - Paintemnce and Ccrplete Modification issued nao ephasizing high priority for Security equirrnent trainterance.
b.
Director - thclear Security conducts Inonthly revies
'ihrcugh neetings with Plant Fanager, General Dircrter -
ISIP Ibclear Engineering, General Director - !bclear Ccupletien Operations Services, to establish Security Systen DP priorities and ronitor work cepletions.
c.
OcMuct a surveillance of this effort during the Fay review of tranagernent effectiveness.
Septerber Deceber d.
Follcw up as r_ quired to resolve surveillance
'Ihrough findings.
131P Ccnpletion j
11.
Re% rite General Employe Training (Fenni 2 Orientaticn A)
Security Inodule, for both init;.' and requalification training to ephasize Security responsibility and disci-plinary consequences to all personnel, a.
Ensure the upgraded training is inpleented.
April b.
Conduct rarxicra sarpling of perscnnel ccnpleting Through upgraded training to verify effectivcaess.
NSIP Ccrpletion
,~ _
NSIP - 1986 bby 1, 1986 Page 9 00AL C:
Clarify Security respcnsibilities.
OBJECTIVES:
i 1.
Incorporate IE Bulletin 85-79 on Security Notification when Barriers are Rarved, into thin-tenance procedures.
9 a.
Retise procedures and discuss changes with Caplete thinterance Personnel.
b.
Conduct a surveillance of this effort during the thy reviea of Testing and Fhinterance.
July Octcher c.
Follow up as required to resolve surveillance
'Ihrough findings.
NSIP Capletion 2.
Clarify Ibclear Security organizational responsibilities to parallel ANS 3.3.
a.
Sutctit Physical Security Plar., Rev 9, to the NEC Ccriplete Region III.
b.
Review all Nuclear Security Co:porate jcb June descriptions and re-write to appropriately reflect current responsibilities, c.
Corduct a surveillance of this effort during the thy reeiew of ranagement effectiveness.
Septe-ber Deccher d.
Follow up as required to resolve surveillance
'Ihrough findings.
NSIP Ctrpletion a
3.
Impleent lines of ccmmnication between the Director -
Nuclear Security, and Nuclear Security personnel to ensure concerns are brought to ra-2gment attention.
a.
'Ihe Director - Itclear Security nomally atterds
'I~rzotch weekly Unifored section supervisors' reetings.
USIP Capletion b.
Ccnduct business /dir.er cetings with all Security Cr;1ste Perscnnel to cnphasi::e ccr;11a.ce w!th regatc y requir ments.
c.
Ec1d cabined DSco/ security centractor shift Tccctch briefings.
USIP Ccrp1etien
NSIP
'1986 May 1,' 1986 Page 10 d.
Director - Nuclear Security at least monthly /per Through shift atte:ds Security Officer shift briefing to NSIP e:phasize meeting regulatory security require ents.
Ccrpletion 4.
ReOise IMclear Operations Programs covering Security responsibilities and functions and access authorization.
a.
Obtain senior Fermi 2 Panage ent approzal and April comunicate Security responsibilities and functions based on the Physical Security Plan c:vanizational 3
definitions and the FSAR Gapter 13.7 to all Fermi 2 personnel.
5.
Upgrade, sirplify, clarify, work instractions for the April Ibclear Security Gief and Shif t Lieuterant to raore precisely direct their efforts in the overall coverage of their responsibilities.
6.
Review IE Bulletin 85-97, Material False Statenents, with all recurity Persormel.
a.
Ensure Secu-ity personnel presently working Fa/e a Caplete clear understanding of IE 85-97.
b.
Include IE 85-97 in the Security Personnel annual June requalification program.
c.
Include IE 85-97 in the initial Security Personnel August training..
d.
Corduct a surveillance of this offort during the Pay reties of Personnel T&Q - General.
August Novc-ter c.
Folloe up as required to resolve surveillance Through findings.
NSIP Cmpletion i
7.
Conduct an internal capliance evaluation of Ibclear Security tranagement effectiveness covering the ele-ments of the NRC Inspection module IP 81020.
a.
An evaluation including all surervisory July ard staff personnel, (A-Grade and M-Grade) ard will be rade by the General Director - IMClear Operations Seriices.
3.
Ccrduct Saf(sinrds Ccntingency Flan drills and exercises.
a.
Fach Shift Lieuterant cerducts and d:ctrents resu' ts
':Srctph of arnthly drills and e<ercises on all shifts USIP fer varicus e/ent strarios.
Ccrpletion
e NSIP - 1986 thy 1,1986 Page 11 b.
Security Staff Merbers corriuct (quarterly)
Through and document results of monthly drills and IGIP exercises on all shifts for various event Ccrpletion scenarios.
c.
Cbnduct a surveillance of this effort during the bhy review of Safeguards Contingency Plan.
August-NCVErber d.
Follow up as required to resolve surveillance
'Ihrough findings.
NsIp Ccupletion 4
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1 GIP - 1986 May 1, 1986
'Page 12 CDAL D:
Inprove understarvhg of Sccurity plans and inpirmmHrry a u ulares.
OBJECTIVES:
1.
Revise and clarify Security Plan Inp1menting Procedures and Ibclear Security Plan Work Instructions and Post Instructions to clearly inp1 ment Physical Security Plan and Safeguanis Contingency Plan ccnmitrents.
a.
Assign each current revision of an existing Ccrplete prccedure to one of the five Shift Lieuterants for review, to ensure clarity and consistency with Plan ccrrc.itments.
b.
Determine required charges and inplement apprcued
'Ihrough procedures to assist in the cperation of Nuclear NSIP Security, at the rate of 5 per month.
Ccnpletion 2.
Ecplcy a consultant to revicw and u;gade the clarity of Decerher the Physical Security Plan, Safeguards Contingency Plan, and Security Personnel T & Q Plan.
3.
Enhance Uniform section understanding of cuerall organica-tional res;xxisibilities by jcb enrichrent assigrrents to the Staff section.
1 a.
Conduct interviews with assigned personnel to Through identify strengths and v.eaknesses of this personnel NSIP developmental prcgra.. Ihese interviews could Ccrpletion result in future changes in assip.t periods to more effectively develcp personnel.
4 Review of QA audit and NRC Inspection Reports with
'Ihrough Security supervision and staff by the Director -
NSIP Nuclear Security, as they are received. 'Ihis review Ccrpletion will contribute to lessons learned and minhnize the potential for repeating the findings and cbservations.
5.
Reduce the nirber of Security reportable events Deceder 10CFR 70.71(c) for Security perscnnel errors to at least 50% belcw that of 1965.
.ill ccr:leticn dates a e de las: day cf d a rcn d indin ted.
'5/1/S5
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