ML20235B870
| ML20235B870 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/08/1989 |
| From: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8902150267 | |
| Download: ML20235B870 (1) | |
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.g ATTACHMENT A-CCN389-14020 PHILADELPHIA ELECTRIC COMPANY h
PEACil 130TTUNI ATONIIC POWER STATION R. D.1, Ilox 208 NSTn T8 Delta, Pennsylvania 17314
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REACH BontW THE POWER OMXCELLENcz (717) 456-7014 D. M, Smith Vice President 10CFR50.54(p)
February _8, 1989 Docket Nos.: '50-277 50-278 U. S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Mail. Station P1-137 Washington, DC 20555
Subject:
PBAPS Response to USNRC Security Team Assessment Nos. 50-277/89-80; 50-278/89-80
Dear Sir:
As a result of Peach Bottom Atomic Power Station (P8APS) Self Assessments of Security and the United States Nuclear Regulatory Commission (USNRC)
Security Team Assessment conducted from January 23, 1989 through January 27, 1989, Mr. R. R. Keimig, Chief, Safeguards Section, requested that PBAPS supply completion due dates for the items listed on the Attachment, so that it can be made part of USNRC Report Nos. 50-277/89-80; 50-278/89-80. Mr.
R. R. Keimig also requested that this correspondence become an attachment to the PBAPS Physical Security Plan.
The attachment to this letter provides our response to the specific items requested and is being submitted as a 10CFR 50.54(p) change to_the PBAPS
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Physical Security Plan. These changes do not decrease the effecthcness of the PBAPS Physical Security Plan.
If you have any questions or require additional information, please do not hesitate to contact us.
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Sincerely, DMS/DRM/ GAB:aus Attachment
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cc:
W. T. Russell, Administrator, Region I, USNRC (2 copies)
R. E. Martin, Project. Manager, USNRC R.'R.iKeimig,' Chief,; Safeguards Section, Region-~I,~USNRC:
R. F. Skelton, Office of Nuclear Reactor Regulation, USNRC T. P. Johnson, Senior Resident Inspector, USHRC T. E. Magette, State of Maryland (w/o Attachment)
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Urban, Delmarva Power (w/o Attachment)
J. T. Boettger, Public Service Electric and Gas (w/o Attachment)
H. C w mm Ariantic ~
ric (w/o Attachment)
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ATTACHMENT 1
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1.)
Identify the projected installation date of the weapons /
security equipment safe in the power block.
The weapons / security equipment safe was shipped by the manufacturer on February 3, 1989 and will be installed in the power block by March 6, 1989.
2.)
Identify the projected repair and/or replacement date for failed / defective detection equipment.
PBAPS repairs, replaces or modifies defective security
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equipment on an as needed basis. As of this date, all required security systems identified in the Physical Security Plan are functioning properly. PBAPS also plans to upgrade its detection capabilities as part of the PBAPS Site Master Plan, starting in 1990.
3.)
Identify the projected implementation date for the newly developed Preventive Maintenance (PM) Program for Security systems and equipment.
The computerized PM Program for security systems and equipment will be fully implemented by March 1, 1989.
At this time there are six (6) Plant Operations Review Committee (PORC) approved security related PM Procedures in place. The remainder of the procedures will be developed and PORC approved by December 31, 1989.
In the interim, PBAPS will implement Vendor Manual Recommendations for PM of security equipment if a procedure has not been developed.
This PM Program will also enhance PBAPS capabilities for tracking and trending equipment failures.
PBAPS requires the contractor security force to maintain a PM program for their security equipment.
4.)
Identify the projected completion date of Modification No. 2395 HVAC Security Barriers.
Subsequent to a detailed study of air flow of the identified HVAC ducts, Gilbert / Commonwealth, Inc. was contracted to prepare the conceptional design of the physical barriers to be installed in the air ducts. The security barrier design should allow access to the fire dampers for inspection / testing and must allow the ducts to maintain their Seismic Class I design basis.
Gilbert / Commonwealth, Inc.'s conceptional design is scheduled for completion by June, 1989.
Installation of the barriers '
scheduled for the cycle 8 refueling outage.
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Attachment Page 2 5.)
Identify the projected completion date.for installation of.the Protected Area and-Protected Barrier Lighting (short-term) and identify PBAPS-long term lighting enhancements.
Installation of additional 300W'and 500W Halogen lighting will be completed by March 30, 1989. These permanent lighting
. fixtures were requested to delete-numerous temporary lighting fixtures which'are a safety concern. They also will be an enhancement.for security lighting. PBAPS will install additional lighting as part of the PBAPS Site Master Plan' starting in 1990.
6.)
Identify the projected revision date of the PBAPS Physical ~
Security. Plan (PSP), Training and Qualification Plan.(T&QP), and-the Safeguards Contingency Plan-(SCP) to reflect PBAPS improved practices.
As a result of PBAPS Self Assessment of the PSP T&QP and the SCP it was determined that these documents require revision.
PBAPS will revise the PSP by June 30 -1989, to reflect improved security practices, clarify roles and responsibilities,and remove ambiguities. The T&QP will be revised to model the Limerick Generating Station (LGS) T&QP.. The PSP and the T&QP will be revised with input from LGS and the Nuclear Plant Security Section.
To ensure that PBAPS improved security practices are incorporated into these revisions, the Support Manager, PBAPS, will have final approval of the plans prior to submittal to the USNRC. The SCP will be revised within one hundred eighty (180) days upon receipt of the USNRC approved PSP and T&QP.
7.)
Identify the projected completion date for additional detection equipment in the Receiving Area.
The detection equipment discussed during the USNRC Security Assessment will be installed by June 30, 1989. This modification will be made in addition to the fortified barriers that were installed during the USNRC Assessment.
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' Attachment Page 3 8.)
Identify the projected completion date for revision of all Security Surveillance Tests (ST) and identify responsible individual (s) for performance of the STs.
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All Sec Ts were previously reviewed for compliance prior December 31,
, and those determined to be inadequate were revised and implemented. Subsequent to this review, all Security STs were reviewed and revised to assure enhanced detection capabilities, and were in typing at the time of the USNRC Security Assessment. These drafts were made available for USNRC Assessment.
All STs that required revision will be submitted for PORC approval by March 30, 1989. PBAPS currently has a team of: ten (10) trained and qualified ST personnel. These ST personnel perform STs on all three (3) shifts.
It is PBAPS' intention to increase the number of trained and qualified ST personnel to sixteen (16).
These ST personnel are identified in an Administrative Instruction procedure and perform the STs under the cognizance of the Security Technical Assistant.
9.)
Identify the projected completion date to correct radio communications difficulties in the Central Alarm Station (CAS) and the Secondary Alarm Station (SAS).
Modification No. 2523 was initiated in 1988 to upgrade the PBAPS Radio System. The CAS and SAS communication console upgrade includes:
o Mini Command Control Center - SAS o Desk Console - CAS Desk o Incorporation of State Police and Emergency Planning channel This portion of Modification No. 2523 is expected to be completed by May 31, 1989.
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10.)
Identify the projected completion date for additional Shift Security Assistants' (SSA) _ training. This training should include emphasis on l
the performance objectives of the Physical Security Program.
Additional SSA enhancement training has been developed and includes the following topics:
o 10CFR 73.55 - Performance Objectives 1
o 10CFR 73, Appendix B - Requirements Basis o 10CFR 73, Appendix C - Purpose and Objectives o Discussion of training program requirements and process o USNRC Authority and Enforcement Policies o USNRC Missions and Inspection Principles o USNRC Violations / Severity Categories / Fines o - Contingency Event Recognition and Response o Conduct of Drills / Security Communications /
Response Team Deployment and Coordination PBAPS SSAs will have completed this training by February 18, 1989.
11).
Identify the projected completion date for the development of additional tactical training for Response Team Members and reassess current Power Block defensive positions.
Additional tactical training for Response Team Members will be developed by June 30, 1989.
Current Power Block defensive positions j
will also be reassessed and revised, if appropriate, by June 30, 1989.
12.)
Identify the projected completion date for removal of two (2) sections of fencing that may assist an intruder in by-passing certain q
detection equipment.
1 The identified sections of fencing, which were recommended by the USHRC Regulatory Effectiveness Review (RER) Team, were removed as j
of February 6, 1989.
13.)
Identify the projected completion date for the development of a formalized Validation and Verification (V&V) Procedure for Security Computer Software Changes.
A Plant Protection (PP) Procedure for Validation and Verification of Security Computer Software Changes will be developed and PORC approved by March 31, 1989 and the PSP will be revised to require V&V of Security Computer Software Changes.
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14.) Revise the PSP to clearly identify that guards respond to all unanticipated intrusion alarms.
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The PSP will be revised by June 30, 1989, to clearly state that guards respond to all unanticipated intrusion alarms.
PBAPS currently requires this practice in the PSP, PPs and in Security Force Member (SFM) training lesson plans.
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15.) Revise the PSP to require that Response Team Members wear Bullet Resistant Vests whenever contingency equipment is issued.
The PSP will be revised by June 30, 1989 to mandate that whenever a Response Team Member obtains contingency equipment-from any of the weapons / equipment issue areas, in the event of a contingency or drill, they shall wear a Bullet Resistant Vest.
In the interim, all armed responders have been instructed and retrained to implement this requirement.
16.). Delete Type I and Type II Vital Area Designations in the next revision of the PSP.
The PSP will be revised by June 30, 1989 to delete Type I and II Vital Area Designations. These areas will be referred to as Vital Areas, l
17.) P8APS should consider the use of portable video equipment to further enhance the SFM training program.
PBAPS will procure a portable video camera to be used for enhancing the SFM training program. Video Cassette Recorders (VCRs), slides and overheads are currently used as training aids for SFMs.
l 18.) PBAPS should include these items as an attachment to the current USNRC approved PSP.
PBAPS will include this attachment as Appendix D to the PBAPS Physical Security Plan.
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