ML20210L426
| ML20210L426 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/08/1997 |
| From: | Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Richard Anderson FLORIDA POWER CORP. |
| References | |
| NUDOCS 9708210145 | |
| Download: ML20210L426 (24) | |
Text
{{#Wiki_filter:s AUGUST 8, 1997 Florida ~ Power Corporation Crystal River Energy Complex Mr. Roy A.--Anderson =(SA2A) Sr. VP. Nuclear Operations ATTN:- Mgr.. Nuclear Licensing .15760 West Power-Line Street _ Crystal River,-FL _ 34428-6708
SUBJECT:
-MEETING-
SUMMARY
CRYSTAL RIVER 3 SECURITY ItiPROVEMENT PLAN CRYSTAL RIVER 3 - DOCKET N0. 50-302 L This refers to the meeting on July 30, 1997, at the Region II office in-Atlanta. Georgia. The purpose of-the meeting was to discuss your intention to implement a Security Improvement Plan. It is our opinion, that this meeting _ as beneficial, [ w Enclosed is a-List of Attendees and a Florida Power Corporation Handout. The discussions included the.following-topics: Restructuring of the Nuclear Security Department. Security Equipment Improvement, and Security Process / Procedure Adherence -In accordance with Section 2.790 of NRC's " Rules of Practice. "Part 2. Title 10 Code of Federal Regulations, a co)y of.this letter and its enclosures will be placed in the NRC Public Document Room. Should you have any questions:concerning this letter, please contact us. Sincerely. ORIGINAL SIGNED BY JOHNS P. JAUDoN Johns P-. Jaudon, Director Division of Reactor Safety
Enclosures:
1. List of Attendees-2. FPC Handout Docket No. 50-302 License No. DPR-72 cc w/encls: John P. Cowan. Vice President- . Nuclear Production (SA2C) -FPC, Crystal River Energy Complex 15760 West Power Line Street Crystal River FL 34428-6708 cc w/encls: See page 2-9708210145 970008 PDR ADOCK 05000302 F PDR $G h i
5 FPC-2 ~~cc w/encls: Continued C. G. Pardee. Director. Nuclear Plant Operations (NA2C) FPC. Crystal oiver Energy Complex 15760 West P:we* Line Street Crystal River. F.' 34428-6708 David F. Kunsam'.ller. Director (SA2A) Nuclear Operations Site Support Florida Power Corporation Crystal River Energy Complex 15760 West Power Line Street Crystal River. FL 34428-6708 R. Alexander Glenn Corporate Counsel Florida Power Corporation MAC - ASA j-P. O. Box 14042 St. Petersburg FL 33733-4042 Attorney General Department of Legal Affairs The Capitol Tallahassee FL 32304 Bill Passetti Office of Radiation Control -De)artment of Health and lehabilitative Services -1317 Winewood Boulevard Tallahassee FL 32399-0700 Joe Myers. Director ) Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee FL 32399-2100 Chairman Board of County Commissioners Citrus County 110 N. Apopka Avenue Inverness. FL 34450-4245 Robert B. Borsum Framatome Technologies 1700 Rockville Pike. Suite'525 Rockville. MD 20852-1631
FPC 3 Distribution w/encls: K. Landis, Rll L. Raghavan, NRR B. Crowley, Ril G. Hopper, RII PUBLIC NRC Resident Inspector U.S. Nuclear Regulatory Commission 6745 N. Tallahassee Road Crystal River, FL 34428 l nre!ce py y o7,.ne g or, non, f) SIGNATURE, NAQ,-' la ratton_ CJulian Kl.a ,Mk / 97 08/h/97 082_k/97 DAll c8 / / 97 08 / / 97 08 / / 97 coav7/ vts > =0 vos (wo, g ts / so vos so vts ,o vos so ur r itws con w u u w + m u m.5us l
s LIST OF ATTENDEES Florida Power Corooration F. Marcussen. Manager. Security M. Marano. Director. Site and Business Support Nuclear Reaulatory Commission A. Belisle. Chief. Reactor Projects J. Jaudon. Director. Division of Reactor Safety Inspector C. Julian Acting Chief. S)ecial Inspection-Branch K. Landis, Chief. Reactor.)rojects L. Stratton, Safeguards Inspector l ~ i
M Fl>ORIDA POWER ~ CORPORATION 1T CitVKiwl It1Vicit US'IT 3 ^ ~ Security Improvemen : ~ . Plan JULY 25,1997 4 s .a i
FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 SECURITYIMPROVEMENT PLAN JULY 25,1997 I '\\\\\\ F.E\\ Marcussen Manager Nuclear Security Department dwM a - M.W. Marano Director Nuclear Site and Business Support
FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 SECURITY IMPROVEMENT PLAN Foreword: Crystal River Unit 3's recent history of regulatory issues and the results of analyses by both our own and outside resources clearly indicate the need for an aggressive and broad-based action program for the overall_ strengthening of our nuclear security program. Ouring the past several months, CR-3 has taken a number of actions to begin improvement of its program: replacement of the incumbent Director of Nuclear Site and Business Support and Manager Nuclear Security with individuals having extensive experience in. nuclaar security program management; inclusion of Nuclear Security in the Plant's - Correc.tive Action Process; and two peer assessments. Assessments by the new management team and the peer assessment groups identified a number of weaknesses in the effectiveness and implementation of the physical security-program and provided recommendations for improvement. Additionally, data obtained by_ inclusion of Security in CR-3's Corrective Action Process and the results of Quality Assurance audits supported management and peer assessment recommendations and identified additional areas of the physical security program that required corrective action. At the Pre-Decisional Enforcement Conference held with NRC Region II on May 22, 1997, CR-3 management committed to develop a comprehensive Security Improvement Plan (SIP) that would serve as a vehicle to achieve and maintain superior compliance with regulatory requirements. The pl an, detailed in the following pages, meets that commitment and reflects the determination of CR-3's management to again have an exemplary nuclear security program. The development of the SIP was based upon lessons learned as a result of regulatory findings; experience of the new management team; recommendations made by peer assessment groups; and program weaknesses identified by the Corrective Action and Quality Assurance programs. The SIP win be implemented by CR-3's Nuclear Secur.ity Department with the support and oversight of FPC management. The status and results_ of Plan activities will be available for review by the Nuclear Regulatory Commission. l Page 1 l
a. I Purpose & Scope: The- - Securi ty - Improvement Plan delineates a program for_ the overall strengthening of physical security at CR-3, with the_ goal of achieving-and maintaining-verbatim compliance with the applicable security requirements of 10 CFR, Part 50. Three major attributes contributing-to the total security program improvement are addressed in the - plan: people, the individuals who implement the program; equipment, the tools needed to' do the job; - and, processes, which structure and direct security program activities. Objectives, to be achieved in strengthening each. attribute, are identified. Some objectives may be -accomplished quickly while others will require a long-term or ongoing effort. For each objective, a number of " tasks" representing action items leading to the objective, are identified and a projected date for completion - given. A brief descriptive comment is provided for each _ task. The SIP-identifies initial improvement actions o_nly, and is not intended to be definitive. Other objectives will have to be achieved and additional ' tasks completed before excellence can be reached in each security program attribute. The plan does,
- however, delineate an
' initial action program that represents CR-3 management's thrust. and strategy for-overall -nuclear security program improvement. l Method of Approach: The implementation of the Security Improvement Plan will have a decided impact on nuclear security force activities and the accustomed ways _ of- , implementing the security program. Attitudes, operational methods, equipment and,. ossibly, personnel assignments will require change. p Except where immediate action must be taken to-preclude non-compliance, changes will be systematically phased-in over a period of time. This approach is necessary to maintain continuity and effectiveness in day-to-day security operations and to ensure regulatory compliance. While addressing program weaknesses, care will be taken to preserve and build upon existing strengths. In addition to the efforts of CR-3's management and supervisory staff, assistance in the improvement effort will be provided by CR-3's Corrective Action Review Board (governing body of the Corrective Action Process), Quality Assurance, and Nuclear Training departments. Outside resources will also be used to evaluate progress and provide assistance. These resources will include help from the Cooperative Management Audit Program, a follow-up peer assessment planned during December, and an NRC Regional Assist visit, scheduled for early August of this year. l Page 2 l.
-l A1 TRIBUTE: PEOPLE OBJECTIVES: 1. -Restructure-the Nuclear Security Department to Include the Replacement and/or Reassignment of Management,- Supervisory, and Support Personnel. l Tasks: 1-1 Assion New Director: In May 1997, overall responsibility for i the Nuclear Security Program was assigned to Mr. Mark Marano, newly appointed Director Nuclear Site and Business Support. Mr. Marano recently worked in management with PSE&G in support of the Salem Plant recovery effort and was previously with Carolina Power & Light where he had several management responsibilities including oversight of the nuclear security program. .As Director, Mr. Marano reports to the_'Vice President Nuclear Production, and is empowered to establish policies in the area of security and to ensure that the Nuclear Security Department has the resources and training needed to fulfill its mission. To-Start By: N/A Complete By: Completed 2 Accoint A New Nuclear Security Department Manaaer: Mr. Fred E. Marcussen was appointed as Manager Nuclear Security and joined the CR-3 staff in June 1997. Mr. Marcussen was previously Manager of Security at Turkey Point Nuclear Power Pl ant. He brings to CR-3 over sixteen years of experience covering all aspects of nuclear security. Mr. Marcussen has a demonstrated record of success in security program development, implementation, and management. As indicated by the July 1997 Nuclear Quality Assessments audit, the recent management changes in the Security area have had a positive impact and increased management focus on improving the effectiveness of the security organization. To Start By: N/A Complete By: Completed l Page 3 l l l _d
1-3 Establish and Fill a - New FPC - Nuclear Security Deoartment Position To Assume Resoonsibility'for the Security System and Sub-systems and to' Suoervise Alarm Station Ooerations: A position-of _ Nuclear Security Systems -Coordinator has been established and was-filled _ by Mr. Ron Hess in July._ For sixteen years Mr.- Hess was responsible for the installation, daily operation _ and testing of the security -. system and subsystems-'at ' the Turkey - Point Nuclear Plant where-he also supervised alarm istation operations. Ron has a thorough, hands-on knowledge of securi ty electronics-and; their application in the security operational program. To Start By: N/A-p Complete By: Completed 1-4 Establish - and Fill a New - FPC Nuclear Security Deoartment-Position To Suoervise the Access Control and Reoulatory Comoliance Proorams: The new - position will consolidate,.- wi thin the Nuclear _ Security Department, the Access Authorization Program, formerly under _ Nuclear Operations, and-the Security-Department's site badging operations. The supervisor will: also oversee and coordinate all aspect's of the _ nuclear security. program to ensure compliance with CR-3's security commitments and regulatory compliance. Mr. David Watson, who has had previous experience in Access Control, 7 has been appointed to the position. To Start By: N/A Complete By: Completed 1-5: -Develoo A New Oroanizational ' Structure - For the -Nuclear Security Deoartment -and Assion-Personnel to Identified Suoervisory and Administrative Positions:' 'A new organizational structure has been established and personnel assigned to identified positions. The intent of. the new structure is -to strengthen departmental management control by identifying _.tas ks, - assigning responsibilities, and establishing channels for command and reporting. A chart depicting the new departmental organization is presented as Attachment One. As positions and personnel assignments may change during the Security Improvement
- Program, the organizational chart should be considered as " temporary."
To Start By: N/A Complete By: Completed (Temporary) l Page 4 l
2. Improve Security Force Performance. Tasks:- 2-1 Establish and Fill a FPC Staff Security Ooerations Suoervisor Ensition: The primary duties of the supervisor will-include: ensuring regulatory compliance in day-to-day security force operations; coordinating security operations with -plant
- g. -operational activities; supervising operational activities of g-the Security Shift Supervisors and ensuring continuity 'in shift-to-shift operations.
To Start By: N/A Complete By: Completed l l-2-Reouire All-Members of the Security Force to Wear Uniforms: This has been done as a part of an overall effort to improve 4 esprit de corps. Shift Supervisors and Alarm Station Operators are now in uniform. To Start By: N/A Complete By: Completed 2-3 Chance Security Officer Work Schedule: The current schedule requires weekly rotation between day and night shifts, limits time available for training and includes extended time-off periods _wherein. officers can not be kept abreast of current-activities. A new -schedule is being implemented which will correct these problems and improve work performanc.e, To Start By: Preliminary-action underway Complete By: Target - Sept. 30, 1997 2-4 Evaluate Security Of fice'r Staffino. Duties. -And Post Assionments: Although evaluated on a near daily basis, a formal study will be,made following the current plant outage to ensure an appropriate level of staffing to meet normal operational and contingency needs. To Start By: In progress Complete By: Jan. 31, 1998 -l Page S l
2-5 Imolement Imoroved Continoency Resoonse Drills: Improved drills will focus on plant protection strategies and are . designed to improve security force skills and teamwork. l To Start By: In progress Complete By: On going 2 As Necessarv. Retrain and Reoualifv Security Force Personnel l Followino - Security Plan and Procedurc Chanoes_: The FPC Training Department is responsible for _ Security Officer training, qualification, _ and requalification. Although its support has been excellent in the past, additional resources will be required to meet increased training and requalification needs resulting' from security program changes. To Start By: Preliminary action underway-i Complete By: On coing -3. Strengthen Alarm Station Operations Tasks: 3-1 Increase Suoervision of Alarm Station Ooerations: The supervision will be provided by the newly established Nuclear Security Systems Coordinator position and will stress proper use of alarm station resources and consistency in operator performance. To Start By: Initial action underway Complete By: -On going 3-2 Imorove Alarm Station Ooerator Skills: This will involve increasing operator understanding of the security system, retraining, and implementing software enhancements to improve I equipment / operator interaction. The changes are essential to -improving command and control of security shift activities. To Start By: Initial action underway Complete By: On ooing l l Page 6 l
ATTRIBUTE: EQUIPMENT I OBJECTIVES: 1. Evaluate the Security System and System Operations. Identify and Correct Deficiencies Found. Tasks: 1-1 Conduct Test To Evaluate the Perimeter Surveillance (CCTV) System: The evaluation will verify day and night visual coverage of the perimeter, quality of alarm station-monitor display and proper camera display in response to Perimeter Intrusion ' Detection System Alarms. This test will be structured to detect vulnerabilities and will be more rigorous than routine, "Seven-day" tests. Action will be taken to correct any deficiencies found. To Start By: July 28. 1997 Complete By: July 31, 1997 1-2 Conduct-Tests to Evaluate the Perimeter Intrusion Detection System: Each perimeter alarm zone will be subjected to stringent penetration testing and a -detection _ probability of at least 90% with a 95% level of confidence confirmed. This . test will be structured to detect vulnerabilitir, and will be n more rigorous than routine, "Seven-day" tests. Action will be taken to correct any deficiencies found. To Start By: N/A Complete By: Completed-7/17/97 l Page 7 l
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3-3 Iest and Evaluate Security System Back-uo Power Sucolies: Tests will be conducted to evaluate the ability of back-up power supplies (UPS and Diesel) to
- support, without interruption, security systems in the event of normal power loss. -Testing will be done in conjunction with normal Plant
-restart activities. Action will be taken to correct any deficiencies found. l To Start By: Per Restart Schedule Complete By: During Restart Actions i 1-4 Test and Evaluate Protected Area Liahtino: A test, to be i conducted once every thirty days, will be developed and implemented to evaluate security lighting levels within the protected area and isolation zones. To Start By: N/A Complete By: Task completeJ 2. Conclude the Security System Upgrade Project Tasks: 2.1 Resolve Security Svstem Concerns With Vendor: Durito Factory and Site Acct.ptance testing, a number of software concerns unrelated to alarm annunciation, were identified as "open items." CR-3 is working with the Vendor to "close" the items. To Start By: In progress Complete By: August 31, 1997 2-2 Comolete Ucarade in the Area of the Nuclear Security Ooerations Center: The equipment is installed. Initial testing identified the need for.an additional power supply. To Start By: In progress Complete By: July 31, 1997 (Based on successful testing)' l-Page 8 l J
2-3 Perform A Site Evaluation Test of Security Uoorade Proiect -Eauioment Performance: The test will provide a technical evaluation of the. new equipment's conformance to design criteria and the_ equipment's operational reliability. Action will -be taken to correct any problems identified during testing. l To Start By: September 1, 1997 i Complete By: 30 to 60 days from start 3. Install a Video-Capture System in CAS and SA5 Tasks: 3-1 Comolete Preliminarv Work Reauired for Eauioment Installation: The work will include the design, engineering and, if needed, modification of equipment required to support the video-capture devices. UPS and video-switcher capacities may require change. To Start By: In progress Complete By: Jan. 31, 1998 3-2 Install. Test. and Place Video-Cacture Eauioment Into Service: In addition to start-up. testing, Security will conduct extensive functional tests before use. Operators will be trained on _ equipment use and procedures changed to-include the use of video-capture as a means of alarm ' assessment. To Start By: Jan. 31, 1998 Complete By: Feb. 14, 1998 .l Page 9 l
ATTRIBUTE: PROCESSES ' OBJECTIVES: 1. Revise the Physical Security Plan and Security Procedures Tasks: 1-1 Revise the Physical Securi ty Plan: The Physical Security Plan has been revised sixteen times during the past five years. Each revision has been partial, affecting one or more Plan segments. As-a result, the Plan has become disjointed, overly descriptive and, in some areas, vague. The following criteria are to be met in the revision: o Restate commitments in a clear and concise manner ', [I g ' o Eliminate redundancies Eliminate unnecessary descriptive detail o l kg@ Revalidate information describing equipment performance o and emergency power supply ,Ao Pattern to NUREG 0908 y- ,m To Start By: August 4, 1997 / Complete By: Jan.- 31, 1998 C 1-2 Make Immediate Chanaes to Existina Procedures as Needed to Imorove Security Force Performance: This is an interim measure that is in progress and will be continued until a new set of procedures or instructions can be developed. The revisions will include proceduralizing security force instructions now contained in Security Information Reports. To Start By: In proaress Complete By: Dec. 31, 1997 I -l Page 10 l
1-3 Enable the Use of Security Departmental Procedures or Instructions: At present security procedures
- are, by references in the FSAR and Tech. _ Specs. to Regulatory Guide 1.33, Quality Control documents.
The revision, review, and approval process for procedural change is labor intensive and slow. A quicker way is needed to impan and change instructions to the security force. To Start By: In progress Complete By: Dec. 31.-1997 l 1-4 Develon a New Set of Departmental Procedures or Instructions to Direct the Activities of the Security Oraanization: The I condition of the Security Plan is, to a lesser degree, reflected in the security procedures. Both require significant change to provide a stronger basis for implementation of the security program. As the new procedures / instructions will require frequent modification to address program changes, the task will be considered to be complete when a majority of the new Departmental Procedures / Instructions have been developed and implemented. To Start By: August 4, 1997 ( Complete By: Jan. 31, 1998 2. Transfer Security Related Activities Now Performed by Other Departments to the Manager, Nuclear Security Department Tasks: 2-1 Transfer -Resoonsibility for the Access Control (Authorization) Proaram from the Trainina to the Nuclear Security Deoartmen.t: The transfer-is designed to make better use of resources and establish stronger control: by placing all access responsibilities under Nuclear Security Department leadership. To Start By: N/A Complete - By: Completed I Page 11 l
.2-2 Transfer Security Activities Now Included in the Procedures of Other Disciolines to the Nuclear Security Department: Some security tasks (example; performance testing of the perimeter intrusion detection system) are now proceduralized and. performed by other departments. The change is needed to strengthen performance by placing all security operational activities under Nuclear Security Department leadership. To Start By: July 8, 1997 Complete By: Dec. 31, 1997 l 3. . Develop and Implement a Security Department Self-Evaluation Program-Tasks: 3-1 Initiate a Security Deoartment Trackino and Trendina Proaram:- The program will supplement CR-3's Corrective Action Program and consist of a number of " Indicators" that will enable Security to closely monitor program problem' areas,. including the following: o Loggable Events Attributable to Security Force Error o Total Loggable Events l o unsecured Doors o Compensatory Hours Worked Due To Equipment Failure o Badges Lost On-site o Security Force Overtime o Security Force Staffing Level Compared To Authorized. To Start By: In progress Complete By: On-going 3-2 Imolement Security Office r Assessments of the Security Proaram: The assessments will be performed with support by Quality Programs Department and security supervisory personnel and will be based on NRC. inspection modules. In addition to program evaluation, the assessments are intended to increase - Security Officer awareness of-regulatory = requi rements. To Start By: In progress Complete By: On going 1 l Page 12 l .h_.M
4. Complete and Evaluate Actions for the Protection of Safeguards Information Tasks: 4-1 Complete the Destruction and/or Reclassification of Documents No Loncer Determined to be Safeauards Information: Action to meet the planned completion date stated in the May 22, 1997 Pre-Decisional Enforcement Conference is in progress. l Aperture cards and microfilm remain a concern for on-time l completion. To Start B': In progress Complete By: Sept., 30, 1997 4-2 Evaluate Corrective Actions Taken for the Protection of Safeauards Information: All Safeguards Information is now within repositories cont olled-by the Nuclear-Security Department and procedural controls have been strengthened. The effectiveness of the measures taken will be evaluated by the Corrective Action Review Board. To Start By: In progress Complete By: On going 5. Implement Hand Geometry System for Routine Identification of Persons Authorized Unescorted Access to the Protected Aa'ea. Task: 5.1 Receive NRC Acoroval of Physical Security Plan Changest Comolete Procedures. Inform CR-3 Pooulation. and Imolement Identification Process. To Start By: N/A Complete By: July 24, 1997 l-Page 13 l
Summary: Consistent with -FPC's mission to achieve excellence in all CR-3 activities, management is committed to the _ implementation of the Security Improvement Plan. Some tasks have already been completed, and actions are in progress on a number of others. As more tasks are completed and objectives achieved. within each Plan Attribt te, we -anticipate a quantifiable improvement in our overall nuclear security program._ The skills, regulatory awareness, and the quality of security officer task performance will. be improved. Our security systems _will be enhanced, giving us better and more reliable equipment to work with.
- Also, we will-have __in _ place the management team, - organizational
-structure, and-the Physical Security Plan / procedural foundation necessary to achieve and maintain excellence. In-addition to the activities _ identified in the Security-Improvement _ Plan,- other actions for the enhancement-of the nuclear security program are now being considered by CR-3's Management. Under consideration are an upgrade of the security system's host computers, an expansion of the -{ CCTV system, and the addition of_ a : fence-mounted perimeter-detection system to supplement our existing microwave detectors. I ..CR-3 will devote the resources and continued effort needed to achieve the verbatim compliance goal of the Security Improvement Plan. The Nuclear -Security Department' has _ been tasked with the implementation of the plan and the timely completion of the plan's tasks and objectives.- Progress will be closely monitored by FPC management. -l Page 14 l
1 ATTACHMENT ONE NUCLEAR SECLRITY F.E. Marcussen Manager Nuciar Security A.D. Blanchard Department Support Specialist i I I I D.L Watson J.S. Campbell R.E Hess Dale Crabtree Admin / Compliance Security Operations Security Systems Project Manager Supervisor Supervisor Supervisor (Contractor) l I I G.H. Foster Security Shift JA Capra A.A. Korlaewski Access Control Supervisor Systems / Locks Projects Supervisor (Contractor) (Contractor) (Contractor) l I I Y.P. Dorminy Access Control Access Control Assistant Coordinator Meg c
ATTACHMENT WO CLOSURE DOCUMENTATION REQUESTS / TRACKING i o Each action item will be tracked to closure and statused, o Documentation supporting closure will be required, o Tracking of closure will be the responsibility of Compliance Supervisor (D. Watson). o Concurrence on closure will be given by Manager of Security (F. Marcussen). o Effective reviews will be conducted by Compliance Supervisor and followed up by Quality Assurance and our outside peer assessments, o All files will be maintained by Security. 1 .}}