ML20211D203
| ML20211D203 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 08/19/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211D154 | List: |
| References | |
| 50-254-99-16, 50-265-99-16, NUDOCS 9908260194 | |
| Download: ML20211D203 (9) | |
See also: IR 05000254/1999016
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U. S. NUCLEAR REGULATORY COMMISSION
REGIONlil
Docket Nos:
50-254;50-265-
License Nos:
Report Nos:
50-254/99016(DRS); 50-265/99016(DRS)
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Licensee:
Commonwealth Edison Company (Comed)
Facility:
Quad Cities Nuclear Power Station, Units 1 and 2
Location:
22710 206* Avenue North
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Cordova,IL 61242
Dates:
July 19-22,1999
Inspectors:
Terry J. Madeda, Physical Secur;y inspector
Gare t.. Pirtle, Physical Security inspector
Approved by-
James R. Creed, Safeguards Program Manager
Division of Reacter Safety
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9908260194 990819
POR
ADOCK 05000254
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SUMMARY OF FINDINGS
Quad Cities Nuclear Power Station, Units 1 & 2
NRC Inspection Report 50-254/99016(DRS); 50-265/99016(DRS)
The report covers a four day, announced inspection by two regional security specialists. This
inspection focused on the Physical Protection Comerstone, within the Safeguards Strategic
Assessment area and included a review of the access authorization program, access control
program, performance indicator verification, changes to the security plan, and review of previous
inspection findings.
" Inspection findings were assessed according to potential risk significance, and were assigned
colors of GREEN, WHITE, YELLOW, or RED. GREEN findings are indicative of issues that,
while not necessarily desirable, represent little risk to safety. WHITE findings would indicate
issues with some increased risk to safety, and which may require additional NRC inspections.
YELLOW findings would be indicative of more serious issues with higher potential risk to safe
performance and would require the NRC to take additional actions. RED findings represent an
unacceptable loss of margin to safety and would result in the NRC taking significant actions that
could include ordering the plant shutdown. The findings, considered in total with other inspection
findings and performance indicators, will be used to determine overall plant performance."
Comerstone: Physical Protection - Performance Indicator Verification (4CC2)
URI. The licensee identified that the process used to determine and compute the index
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value number for the Protected Area Security Equipment Performance Index did not
capture all application information. The subsequent calculation of the correct data
changed the established response band and placed performance in the white response
band for the first two calender quarters of 1999 instead of the green response band which
the licensee had reported to the NRC. A response threshold was crossed. The licensee
has entered this issue in their corrective action system.
The revised Protected Area Security Equipment Performance index showed that for the
first two quarters of 1999, the equipment performed in the white response zone. The risk
significanoe of the equipment performance has not been evaluated. Regulatory
requirements were met because compensatory measures were property implemented.
The licensee has entered this issue in the corrective action system. (Section 4CC2.b) '
There were no findings identified and documented during this inspection relating to the
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submitted data for the Fitness-for-Duty Personnel Reliability Performance Indicator (PI) or
the Personnel Screening Program Pl. (Section 4CC2.b)
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Report Details ,
1.
REACTOR SAFETY
Cornerstone:: Physical Protection
1RO2 Chance to License Conditions (Physical Protection)
a.'
inspection Scope
The irispector reviewed Revision 45 of the Commonwealth Edison Quad Cities Nuclear
Power Station Security Plan, which was submitted by licensee letter, dated June 7,
1999. The security plan revision was submitted in accordance with 10 CFR 50.54 (p).
b.
Observations and Findinos
The inspector determined that the changes did not decrease the effectiveness of the
security plan.
3.
SAFEGUARDS
Cornerstone: Physical Protection
13PH1 Access Control (Identification. Authorization and Search of Personnel. Packsoes. and
Vehicles
a.
Inspection Scooe
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The inspectors reviewed testing and maintenance procedures, observed licensee testing
activities, and interviewed and monitored security personnel regarding the staffing and
operational requirements for the following protected area access control equipment:
Metal and Explosive Detectors .
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X-Ray Devices
Biometric Hand and Card Readers
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The inspectors also conducted random observations and interviewed selected security
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personnel responsible for access control measures for packages and vehicles that
entered the protected area.
b.
Observations and Findinos
There were no findings identified and documented during this inspection.
3PH2 mrooram (Behavior Observation oniv)
a.
Inspection Scope
The inspectors interviewed six supervisors and six non-supervisors ( both licensee and
contractor employees) to determine their knowledge of behavior observation
responsibilities. Procedures pertaining to the Behavior Observation Program and
fitness-for-duty semi-annual test result reports were also reviewed.
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b.
Observations and Findings
There were no findings identified and documented during this inspection.
4.
OTHER ACTMTIES
4CC1 Identification and Resolution of Problems
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a.
Inspection Scope
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The inspectors reviewed a sample of licensee self-assessments, audits, security .
loggable events, security drills, and maintenance work requests regarding the licensee's
access authorization and access control programs. In addition, the inspectors
interviewed security managers to evaluate their knowledge and use of the licensee's
corrective action system.
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b.
Observations and Findings
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There were no findings identified and documented during this inspection
4CC2 PerformanceIndicatorverification
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a.
Insoection Scope
The inspectors reviewed the licensee's program for the gathering and submittal of data
for the three Physical Protection Performance Indicators (PI). Specifically, a sample of
plant reports related to security events, maintenance logs and other applicable security
records were reviewed.
b.
Observations and Findings
There were no findings identified and documented during this inspection relating to the
submitted data for the Fitness-for-Duty Personnel Reliability PI or the Personnel
Screening Program Pl. One unresolved item was identified relating to the accuracy of
the Protected Area Security Equipment Performance Index, and the performance of the
equipment measure by that PI was in the white response band.
On May.14,1999, the licensee submitted historical data, based on their best efforts, for
the Protected Area Security Equipment Performance index for the last four quarters
which showed equipment performance in the white response band during each of the
last two quarters of 1998; and in the green response band for the first two quarters in
.1999. However, on July 22,1999, the licensee's Station Security Administrator (SSA)
notified the inspectors that they just discovered an error in gathering the data for the
most recent Pls.
The computer query that had been used to extract the information needed for the Pl,
contained in a large data base, did not capture all the applicable data. Entries in the
data base, used to calculate the index, were categorized with multiple definition codes.
The system operator and the categorization of the entries changed just prior to
gathering the Pl data for the first_ quarter of 1999. The new operator did not realize that
some of the needed information was not being captured by the query that was used.
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While independently reviewing the detailed information that was used to establish the
index values, the operator identified anomalies between the results of the various
quarters' queries. This problem was identified while this inspection was being
. conducted.
This performance indicator was calculated using several values and data 'nputs. The
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first was the IDS (intrusion detection system) Unavailability Index which uses
compensatory hours in the previous four quarters divided by the IDS Normalization
Factor multiplied by 8760 hours0.101 days <br />2.433 hours <br />0.0145 weeks <br />0.00333 months <br />.- The second step of the calculation was the Closed
Circuit Television (CCTV) Unavailability index, which used the same formula and the
CCTV Compensatory hours instead of the IDS Compensatory hours. The last part of
the Pl calculation added the IDS Index and the CCTV Index and divided the summary by
two. The resulting number was reported as Protected Area Security Equipment
Performance Index values.
The licensee's security staff determined that the Protected Area Security Equipment
Performance index values for the 1" and 2ad quarters of 1999, which were reported as
.04 and .05, respectively, and placed the licensee's performance in the green response
band, were actually .067 and .063, respectively. This placed the licensee's performance
in the white response band for those two reporting periods. The corrected data for the
last two quarters of 1998 also changed the index values. They changed from .07 and
.06 to .102 and .102 respectively, which represented a lower performance index, but still
within the white response band. This matter is categorized and will be processed as an
unresolved item.
The newly developed Pi information relating to the performance of the protected area
security equipment was reduced from that previously reported. The revised
performance index showed the equipment performing in the " Increased Regulatory
Response Band."
The inspectors verified that this finding was entered into the licensee's corrective action
program (Reference No. PlF Q1999-02416). The finding involved a problem with Pl
accuracy and completeness and resulted in a PI threshold being lowered. The
inspectors determined that regulatory requirements were met because compensatory
measures for the equipment outages were apparently implemented in accordance with
security plan requirements. To ensure consistency in NRC actions, the matter relating
to the Pi information error, would be categorized and processed as an Unresolved item.
(50-254/99016-01: 50-265/99016-01)
4CC4 Other
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(Closed) Violation. 50-254: 50-265/98018-04: Failure to maintain an adequate security
barrier. This issue was evaluated using the Significance Determination Process (SDP)
for the Physical Protection cornerstone and was green. The inspectors verified that the
finding was entered into the licensee's corrective action program (Reference
No. AR0013843). This item is closed.
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(Closed) Insoection Follow uo item. 50-254: 50-265/98024-01: Lack of documentation
for security equipment deficiencies. This issue would not have raised to the level of
SDP evaluation. This inspection Follow up item was a minor issue and is closed.
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14CCS Manaaement Meetinas
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Exit Meetina Summarv
The inspectors presented the inspection results to members of licensee management at
the conclusion of the on site inspection on July 22,1999. The meeting attendees were
- informed that our evaluation of the performance indicator issue would continue. The
licensee representatives acknowledged the findings presented and did not identify any
information discussed as proprietary or safeguards information.
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Suoolemental Phone Call
. On August 16,1999, a follow-up call was made to the Station Security Administrator,
and representatives of the site and corporate regulatory assurance and licensing
. organizations. They were informed that the evaluation of the performance indicator
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issue had continued and resulted in the assessment that supplemental inspection would
' be required, as indicated in the cover letter. Those inspection plans would be discussed
' with the security staff when the plans are established. They were also informed that, to
ensure consistency in NRC actions, the matter relating to the Pl information error, would
be categorized and processed as an unresolved item while the NRC evaluates this
issue.
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee
W. Beck, Regulatory Assurance
. B. Brady, Director of Corporate Licensing
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R. Chrzanowski, Nuclear Oversight Assessment Manager
B. Finley,' Corporate Security
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T. Fuhs, Regulatory Assurance
K. Gladrosich, Nuclear Oversight
R. Gideon, Work Control Manager
K. Hungerford, Bums Security Force Manager
J. Kudalis, Director, Support Services..
K. Leech, Station Security Administator
P. Loftus, Director of Regulatory Projects
- M. McDowell, Operations Manager
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'J. Ottens, in-Processing Supervisor
C. Peterson, Regulatory Assurance Manager
G. Powell, Radiation Protection
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T. Richmond, Training Group Leader
. B. Rittmer, Assistant Station Security Administrator
B. Saunders, Corporate Nuclear Generation Group Security Supervisor
J. Sirovy, Nuclear Oversight - .
. C. Tzomes, Acting Support Services Manager
D. Wozniak, Engineering Manager
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J. Belanger, Senior Security inspector
- J. Creed, Safeguards Team Leader, Region ill
C. Miller, Senior Resident inspector, Region lli
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ITEMS OPENED, CLOSED AND DISCUSSED
Opened
50-254/90n16-01
White Perimeter Alarm System Performance Index Change
. 50-265/99016-01-
White Perimeter Alarm System Performance Index Change
50-254/99016-02
Protected Area Security Equipment Performance Index Values
50-265/99016-02
Protected Area Security Equipment Performance Index Values
Closed
50-254/98018-08
Failure to Maintain an Adequate Security Barrier
50-265/98018-08
Failure to Maintain an Adequate Security Barrier
50-254/98024-01
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Documentation of Security Equipment Deficiencies
50-265/98024-01
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Documentation of Securityliquipment Deficiencies
Discussed
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LIST OF BASELINE INSPECTIONS PERFORMED
The following procedures were used to perform the inspection during the report period.
Documented findings are contained in the body of the report.
Access Authorization
Access Control
Performance Indicator Verification
Changes To License Conditions and Safety Analysis Reports
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LIST OF DOCUMENTS REVIEWED
Security System Testing and Maintenance (QCSP 800-14, Revision 13, dated July 1998)
Explosive Detector Test (QCSP 800-16, Revision 4, dated December 1998)
Firearms Detector Test (QCSP 800-17, Revision 4, dated July 1998)
- X-Ray System Test (QCSP 800-19. Revision 6, dated December 1998)
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Alarmed Security Door Test (QCSF "X) _18, Re_ vision 8, dated July 1998) :
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- Lock and Key Control (OCSP 810-0; Revision 12, dated April 1999)
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Security Maintenance Action Requests Between January and July 1999)
Security Badge Guidelines, Supervisor instruction No. 7, Revision 4, dated ' July 1999
' Out processing of Personnel (SY-A-A-103-518, Revision 0) .
. Self Assessment Report (January through June 1999) for Access Control
Self Assessment Report (January through June 1999) for Fitness-For-Duty and Access Control
Quad Cities Station Assessment Report NOA-04-99-030, April 30,1999
Security Event Logs for Period Between January through June 1999
Security Drill Logs for Period Between January through June 1999
Comed Nuclear General Employee Training Study Guide, Revision -21, dated March 1,1999
Procedure QCAP 0810-01, " Station. Access Control," Revision 8, dated April 6,1999
Comed Procedure SY-AA-102-220," Reporting of Significant Fitness For Duty Events," '
Revision 0
- Comed Procedure SY-AA-103-516, " Evaluation and Processing of Individuals Reporting
' Arrests," Revision 0
l Comed Procedure SY-AA-103-513, * Policy For Reporting An Arrest," Revision 0
Comed Procedure SY-AA-103-512, " Continual Behavior Observation Program," Revision 0
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Comed Procedure SY-AA-102-201, " Call-outs For Unscheduled Work," Revision 0
- Comed Procedure SY-AA-102-202, " Testing For Cause," Revision _ O '
Corporate Nuclear Security Guideline No.1, " Reporting and Recording of Security Events,"
Revision 13, dated October 1998
Problem Identification Form No. Q1998-03905, dated September 17,1998
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- Summary of Security Event Logs Between ~ July 1,1998 and June 30,1999
Nuclear _ Oversight Assessment No. NOA-04-99-001, dated February 8,1999
Nuclear Oversight Assessment No. NOA-04-99-030, dated April 30,1999
Nuclear Oversight Assessment No. NOA-04-99-029, dated May 7,1999
Field Observation Report No. 04-99-06, " Interviews with Supervisors about Behavior
Observations, dated June 25,1999 '
Field Observation Report No. 04-99-06, "For Cause Testing vs. Random Testing," dated
June 24,1999 =
Field Observation Form No.13106-03, Behavior Observation Interview with Operations
Supervisor," dated July 6,1999
Field Observation Form No.13106-02, " Security Self-Assessments and NRC Security
inspection," dated July 8,~ 1999
Field Observation Form No.13106-01, " Interviews with Personnel Regarding Escort Duties,"
- dated July 8,1999
Field Observation Form (not numbered), " Review of 2Q1999 Security Event arid IrJdent
. Reports'," dated July 12,1999
Field Observation Form (not numbered), " Corrective Actions Taken For Selected Security
PIF's," dated July 15,1999
Semi Annual Fitness For Duty Performance Data Reports Between July 1997 and
December 31,1998
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