ST-HL-AE-5090, Provides Update of Status of security-related Commitments

Provides Update of Status of security-related Commitments

ML20085D579
Person / Time
Site:	South Texas
Issue date:	06/08/1995
From:	Groth J HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ST-HL-AE-5090, NUDOCS 9506160278
Download: ML20085D579 (30)

Text

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i The Light c o mp a nySouth Texas Project Electric Generating Station P. O. Box 289 Wadsworth, Texas 77483 gp June 8, 1995 ST-HL-AE-5090 File No.: S13 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 Status of Security Related Commitments Houston Lighting & Power Company has completed a self-assessment of security commitments made during meetings with the Nuclear Regulatory Commission, in written response to findings, and Notice of Violations. The purpose of this letter is to provide an update of the status of these commitments.

Houston Lighting & Power considers all commitments identified in Attachment A closed as they are no longer applicable to conditions at the South Texas Project. The activities identified in Attachment B were made to redress past concerns and continuc to be implemented in our Security Program. Although we may continue the activities, we no longer view their continued implementation as a commitment. Attachment C identifies commitments that are now included or will be included in the next revision of our Physical Security Plan, Safeguards Contingency Plan, or Security Personnel Training and Qualification Plan.

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The results of this self-assessment and the status of these commitments have been discussed with Region IV Security personnel.

9506160278 950608 PDR ADOCK 05000498 A

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MISC-95\\95135 001 Project Manager on Behalf of the Participants in the South Texas Project J

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- Houston Lighting & Power Company South Texas Project Electric Generating Station ST-HL-AE-5090 Page 2

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If there are any questions regarding this matter, please contact Mr, S. M. Head at (512) 972-7136, or me at (512) 972-8664.

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J. F.

ro Vice President, Nuclear Generation MKJ/lf Attachments: A.

Commitments Completed or No Longer Applicable U

B.

Activities.No Longer Considered to be Commitments C.

Ongoing Commitments l

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- MISC-95\\95-135 00I

i Houston Lighting & Power Company ST-HL-AE-5090 '

y South Texas Project Electric Generating Station File No.: S13 Page 3 c:

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• Leonard J. Callan Rufus S. Scott Regional Administrator, Region IV.

Associate General Counsel U. S. Nuclear Regulatory Commission Houston Lighting & Power Company

,611 Ryan Plaza Drive, Suite 400 P. O. Box 61067 Arlington, TX 76011-8064 Houston, TX 77208 j

i Thomas W. Alexion Institute of Nuclear Power Project Manager Operations - Records Center U. S. Nucle.ar Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 13H15 Atlanta, GA - 30339-5957

• David P. Loveless Dr. Joseph M. Hendrie

'Sr.' Resident Irispector >

50 Bellport Lane c/o U. S. Nuclear Regulatory Comm.

Bellport, NY l1713 i

P. O. Box 910 Bay City, TX 77404-0910 Richard A. Ratliff Bureau of Radiation Control J. R. Newman, Esquire Texas Department of Health Morgan, Lewis & Bockius 1100 West 49th Street 1800 M Street, N.W.

Austin, TX 78756-3189 Washington, DC 20036-5869

• U. S. Nuclear Regulatory Comm.

K. J. Fiedler/M. T. Hardt Attn: Document Control Desk.

City Public Service Washington, D. C. 20555-0001 P O. Box 1771 San Antonio, TX 78296 J. C. Lanier/M. B. Lee J. R. Egan, Esquire City of Austin Egan & Associates, P.C.

Electric Utility Department 2300 N Street, N.W.

l 721 Barton Springs Road Washington, D.C. 20037 Austin, TX 78704 i

G. E. Vaughn/C. A. Johnson Central Power and Light Company P. O. Box 2121 Corpus Christi, TX 78403 4

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Above copies distributed without Attachments except as noted by asterisk (*).

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ST-HI-AE-5090 ATTACHMENT A COMMITMENTS COMPLETED OR NO LONGER APPLICABLE l

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l MISC-95\\95-135.001 i

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ATTACHMENT "A" Commitments Completed or No Longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 1

ST-liL-AE-2305, 7/24/87, CCTV:

CCTV:

.. description of Security

a. Fences in at least camera zones 4,7, Note: He proposed conditions were somewhat related activities which are and 40 will be realigned to place the fence modified in Attachment "A" to ST-HL-AE-2317, proposed to be ongoing on the center of the camera's field of view.

7/30/87. Final conditions of licensing and dates for after initial fuel loading of Relocation will not reduce isolation zone.

their completion are contained in ST-ill AE-2407, Unit 1.

b. Cameras 3 and 16 will be relocated to 11/17/87.

line up on the PA boundary fence.

c. Remaining cameras, except for the CCTV:

interim barrier, will be relocated or

a. - d. Complied: The CCTV " wall effect" cantilevered off of existing tower locations, concerns were resolved by relocating some cameras as necessary, to reduce the fence and cantilevering others from their existing towers.

interference.

Also, the number of angle posts supporting

d. He additional roving patrols added to protected area fence barbed wire topping were mitigate CCTV " wall effect" concerns will reduced. At completion of this work, the number be continued until the detection system is of roving patrols (d) was reduced.

determined to be adequate.

E-Field:

E-Field:

e. An approxitnately 6 foot high 5 strand

e. Complica: Due to reconfiguration of protected barbed wire fence is being placed area the section of E-Field which required approximately 4 feet behind the E-Field installation of barbed wire to preclude defeat by (protected area side.) [to preclude defeat by running and/or jumping no longer exists.

running-jumping.]

f. Within 90 days of fuel load, lilAP will

f. - g. Complied: Pending resolution of submit a conceptual design for NRC methodology used to determine excessive approval which will provide an adequate FARINAR, the E-field was found to be acceptable detection system.

- NRC Letter of 92825 dated 8/27/91. The

g. The long term detection system will be methodology for determining FAR/NAR was in place prior to startup following the first mbsequently resolved and is now reflected in the refueling outage of Unit 1. IIL&P will Physical Security Plan, Rev 1 A, Chapter 8.

continue to work with the E-Field manufacturer to determine if circuit modifications can be made to improve detection capabilities.

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ATTACHMENT "A" Commitments Completed or No Longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 1

ST-IIL-AE-2305, 7/24/87, Training:

Training:

... description of Security

h. An evaluation will be undertaken by the

h. - j. Complied: An evaluation of the security related activities which are Nuclear Training Department to assess the training program was conducted, recommendations proposed to be ongoing status of the Nuclear Security Training and made, and an implementation schedule provided to after initial fuel loading of Qualification Program.

the NRC under HL&P cover letter ST-HL-AE-Unit 1.. (Con't.)

i. A Systematic Approach to Training 2327, dated 8/18/87. Security training was done (SAT) methodology will be utilized to by the Nuclear Training Department and is now restructure the existing program and done by the Nuclear Security Department.

implement the changes.

j. Program assessment will be completed and available for NRC approval by August 14, 1987.

2 ST-IIL-AE-2317, 7/30/87, Adds commitment:

Complied: Results of study were provided in ST-Revision to Attachment A design study will be performed within 90 IIL-AE-2407, dated 11/17/87.

"A", Proposed Ongoing days of fuel load to identify improvements in Activities Delineated in the intrusion detection system necessary to Item #1 bring the false alarm rate into a range normally accepted for similar systems. This study will be submitted to the NRC for approval with an implementation schedule.

3 ST-HL-AE 2333,9/4/87, A program was initiated whereby radio "Ihe radio checks were discontinued as they SER (Inattentive Security checks for compensatory posts are disrupted security communications and were Officer) perforraed approximately every fifteen (15) distracting to alarm station operators.

minutes.

4 ST-HL-AE 2346, 9/9/87, An intercom at the badging window is being Complied: An intercom system was tried in the SER (Wrong Badge Issued) tested to reduce the potential for East Gatehouse and was abandoned as ineffectual.

communication related errors when issuing badges.

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ATTACHMENT "A" Commitments Completed or No Longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 5

ST-lil AE-2407,

a. CCTV 1mprovements - 2/88.

a. Complied: A complete upgrade of the CCTV 11/17/87, system has recently been completed.

Resolution of Licensing

b. Relocation of E-field controller heads -

b. Complied: E-field controller heads were Condition F(l) &

2/88.

moved to locations outside of the isolation zones.

Completion of

c. Remove Start-up building / straighten PA

c. - h. Complied: nese items address initial Commitment to a Study of fence - 2/88.

problems with E-Field performance. Since Unit 1 PIDS by 90 Days

d. Rework drainage across PA boundary licensing, a number of modifications to the E-field after Licensing. (Ref: ST-1st Qtr. 88.

system have been made and studies of lil AE-2317,7/30/87.)

e. Rework E-field zones over E.

false / nuisance alarm rates provided to the NRC.

Gatehouse - 1st Qtr. 88.

Pending resolution of methodology used to.

f. Perform E-field study - 12/87.

determine excessive FAR/NAR, the E-field was

g. Implement improvements found in E-found to be acceptable - NRC Letter of 92825 field study 1st Qtr. 88.

dated 8/27/91. He methodology for determining

h. FARINAR Criteria - Comparison of FAR/NAR was subsequently resolved as reflected IDS performance - Mid 89.

in the Physical Security Plan, Rev 1 A, Chapter 8.

i. Evaluate ECWIS Intrusion detection

i. -j. Complied: An alarm system (E-field) was tnethods - 12/88.

extended around the protected / vital area barrier

j. Implement ECWIS Intrusion detection walls of the ECWIS to maintain integrity of the improvements - 1st Qtr. 88.

perimeter intrusion detection system.

k. Remove North Gatehouse - 2/88.

k. Complied: ne configuration of the protected area was changed so that the North Gatehouse is now located within the protected area and no longer serves as a protected area portal.

1. Remodel East Gatehouse - 2nd Qtr. 88.

1. Complied: He East gatehouse 1 is been remodeled to enhance control and flow of pedestrians entering / exiting the protected area.

m. New CAS/SAS panels - Unit 2

m. Complied: New CAS/SAS panels were lockdown.

installed. He CAS was removed from the security computer room and located in a separate vital area.

n. Improve CAS/SAS cornmunications -

n. Complied: New radio consoles were installed Unit 2 lockdown.

in both the CAS & SAS.

o. Improve CCTV monitor response - Unit

o. Complied: A complete upgrade of the CCTV 2 lockdown.

system has recently been completed. His item should be closed.

p Install, test, and accept Unit 2

p. Complied: Microwave units were installed, microwave IDS - Unit 2 lockdown.

tested and accepted.

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-I ATTACHMENT *A" Commitments Completed or No Longer Applicable 8

l ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION i

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ST-HL-AE-2407,

q. Construct and turnover the Unit 2 West

q. Complied: The West Gatehouse was 11/17/87, Resolution of Gatehouse - Unit 2 lockdown.

completed and placed into service prior to Unit 2 Licensing Condition F(l) &

startup.

Completion of

r. Construct additional Unit 2 security

r. Complied: The West Security Facility was Commitment to a Study of facilities - Unit 2 lockdown.

constructed and placed into. service prior to Unit 2 Unit 1 PIDS by 90 Days startup.

after Licensing.' (Ref: ST-

s. Provide Unit 2 vehicle barriers - Unit 2

s. Complied: Vehicle barriers were installed l

HL-AE-2317, 7/30/87.)

lockdown.

prior to Unit 2 startup.

(Con't.)

t. Make Unit I roof lighting permanent -

t. - u. Complied: Roof lighting is gist and Unit 2 lockdown.

meets or exceeds regulatory requirements.

u. Provide Unit 2 roof lighting - Unit 2 lockdown.

6 NRC IR 87-43,11/23/87, Assessment Aids:

Assessment Aids:

Pre-Op Inspection

a. In a July 24,1987, letter to the NRC

a. Complied: Fence effect problem wrs which became part of a license condition, corrected.

the licensee committed to study, redesign, and correct the problems of the CCTV fence effect.

b. Additionally, STP agreed to respond security officers to all alarms in zones that

b. Complied: The action was taken.

I have " fence effect" prcblem and to increase the protected area patrols from three officers to six officers.

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ATTACHMENT "A" Commitments Completed or No Longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 6

NRC IR 87-43,11/23/87, Detection Aids-E-Field:

Detection Aids-E-Field:

Pre-Op Inspection (Con't.)

c.

..the licensee is under a licensing

c. Complied: The results of various studies were condition to demonstrate that the [E-field]

provided to the NRC in ST-IIL-AE correspondence system will be proven operable to NRC 2407, 11/17/87; 3117, 6/11/89; 3344, 1/30/90; staff's satisfaction under the criteria and 3620,12/18/90; and 3712,2/14/91. NRC letter reliability standards as set forth in 92825 of 8/20/91 states in part that:...pending Regulatory Guide 5.44, Revision 2, prior to acceptable resolution of the FAR/NAR issue initial criticality.

[ method of computing rates] the E-Field was acceptable. Following guide.nce provided by the NRC, STP adopted the criteria and method for computing FAR/NAR The criteria and methods are reflected in the Physical Security Plan, Rev 1 A, Chapter 8 and in security procedures.

Detection Aids - BMS:

Detection Aids - BMS:

d. IllAP committed to evaluate available

d. Complied: All single-bias switches were

[BMS] switches on the market and perform replaced with triple-biased balanced magnetic a changeout with an acceptable device.

switches.

7 NRC IR 87-54,12/23/87 Item 7, Compensatory Measures:

Complied: Door IM2205 leading from the Unit i During total system outage compensatory Control Room to tne relay room was initially drill, Door 205 leading from the relay room secured with a locking bar and padlock and into the Control Room was not posted. The subsequently welded shut.

licensee agreed to add the necessary personnel to secure this door until the door could be permanently blocked.

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ATTACHMENT "A" Commitments Completed or No Longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 8

Statements - Enforcement

a. ESS Simulator [is] to [be] added.

a. Complied: An ESS simulator was installed Conference Package, and, in the past, used for CAS/SAS operator 1/19/88 training. He simulator is now used for security system engineering and diagnostic work.

b. ESS analyst training and testing required

b. - c. Devices controlled by RMTs are no longer all trainees to memorize all devices listed in procedures. Upgrades have expanded controlled by Remote Multiplexer Terminals system software features to include both static and (RMTs.)

active graphic displays which indicate the status of

c. Two procedures (GS101-GST-0001, RMT's and their associated alarm points.

GSI-ESS-001) list all devices controlled by each RMT. Rese procedures are available and used by CAS/SAS operators in the event of RMT failures.

9 NRC IR 884)3,2/12/88 Testing:

Testing:

a....the inaintenance program will be

a. Complied: He requirements for probability modified so that the quarterly requirement testing are stipulated in the Physical Security Plan, for probability testing will not be exceeded Rev 1 A, Chapter 9 and delineated in security and the testing program is being turned over procedures. The Nuclear Security Department is to the security department.

responsible for assuring that testing and probability tests are conducted under security direction.

10 ST-IIL-AE-2593, 3/31/88, Badge /Keycard Control:

Reply, NOV/ Proposed

a. A double check is made of all key cards

a. The double check is no longer necessary, as Enforcement Action 87-236 to badges prior to placing them in the badge the badge and the keycard are now a single unit.

racks.

b. [ System] log [is] revised / simplified

b. - c. Complied: Badge inventories are

c. Training given on loc performed during each shift.

d. Shift color coded card system.

d. The use of color coded cards to designate the issue of badges by shift was tried and abandoned as confusing and ineffectual due to split scheduling and differences in work group start /stop times.

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ATTACHMENT "A"

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Commitments Completed or No Longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 10 ST.IIL-AE-2593, 3/31/88,

c. He procedure on issuance and Control

e. Complied: He obligations of plant personnel Reply, NOV/ Proposed of Security Badges has been revised to more in the badge issue process are delineated in

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Enforcement Action 87-236 clearly delineate to plant personnel their procedures.

(Con't.)

obligations in reference to badge issues.

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f. Badges are not attached to the

f. He double check is no longer necessary, as the Transaction Form before submitting to the badge and the keycard are now a single unit.

ESS for action in order in ensure that the proper keycards are attached to the correct ID badge before issuance to the Gatehouse.

Badge /Keycards leaving PA:

Badges /Keycards:

g. A security officer (s) is posted at the exit g. - h. Physical changes have been made in the turnstiles of the East Gatehouse during exit corridors of the gatchouse. Card readers personnel exit to ensure badge sets are controlling the exit turnstiles are now within the returned prior to the employee exiting site.

badging cubicles. To exit the protected area

h. Barriers creating lanes have been through the turnstiles, keycards must first be established to assist security personnel in returned to a security officer within a badging maintaining positive control of each cubicle. Lane barriers are no longer needed to individual during the exit process. leitering assure that badges are returned to security prior to is prohibited in the area.

persons exiting the protected area.

i. The design of the North Gatehouse was

i. He North Gatehouse no longer serves as a changed such that badge set retrieval now protected area portal.

takes place inside the Protected Area.

Protection of Safeguards Information:

j. Security Event Reports are now treated

j. Security Event Reports are reviewed, evaluated, as Safeguards Information.

and classified as Safeguards Information, if appropriate.

Disarmed access control and IDS condition unrecognized by alarm station operators:

k. CAS/SAS operators are now required to

k. The Security Systems procedure requires alarm ensure that after any maintenance or failure station operators to verify that equipment has been of RMTs, all associated channels are "On-operability tested and returned to security service Line' prior to removing compensatory posts.

prior to relief of compensatory posts.

1. RMT/ channel cross reference checklists

1. Complied: Devices controlled by RMTs are no are provided in both alarm stations.

longer listed in procedures.

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ATTACHMENT "A" Commitments Completed or No Longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION

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11 ST-HL-AE-2727, 7/15/88, Violation D. Testing, Explosive Detector:

Violation D, Explosive Detector:

Amended Response to

a. The procedural requirements for this test

a. Complied: He exact position and handling of Enforcement Action 87-236 have been revised to detail, per the explosive detector test sample is stipulated in manufacturer's directions, the exact security procedures.

position / handling of the new test samples and to direct proper responses in cases of test failures.

Violation F, Determination of Safeguards Violation F, Determmarion of Safeguards information:

Information:

b. Security Event Reports are not

b. Security Event Reports are reviewed, transmitted / controlled as Safeguards evaluated, and classified as Safeguards Information, Information.

if appropriate.

12 NRC IR 88-71,12/8/88

a. Potter BMSs: De licensee has

a. Complied: Potter BMS Sv> itches. All Potter purchased new triple bias switches and has BMSs in Units 1 & 2 have been replaced with committed to installing the switches in Unit triple bias switches.

2 by D=mki 31,1988. The Unit I switches will be installed shortly after January 1,1989.

b. Leaky-coax antennas: ne licensee

b. Complied: Coax: leaky coax was corrected.

committed to correct the problem.

c. Storm drams & hydrant houses within

c. Complied: Drams / hydrant houses: Openmgs PA: De licensee committed to placing and hatches which provide access to man-sized barriers over the openings of the storm pipes and drams passing under the protected area drams to prevent entry and to place some bamer are secured ey grates, bcits or strapping manner of seal or break-away locks on the bars to preclude acass Hydrant houses within the hydrant houses protected area are secured with a breakable padlock.

j 13 ST-HI AE-2773, Response Violation A - Safeguards information: The Complied: The Nuclear Training Department is no to Enforcement Action Nuclear Training Department has written longer responsible for security trammg. Site-wide,88-165 and implemented a procedure on the all safeguards procedures are handled in accordance handling of Safeguards Information in a with the station's Protection of Safeguards classroom environment.

Information procedure.

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ATTACHMENT "A" Commitments Completed or No Longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 14 ST-HI AE-3143,6/18/89,

a. Plant procedure OSDP01-SE-0001,

a. Complied: Instructions for testing of the Response to NOV 8910-

" Electronic Security Sysum" was revised emergency unlock function are delineated in Inattentive Officer (Revision 6) to include instruction on security procedures.

compensatory posting for testing of emergency unlock ft.nction.

b. It is now security policy to perform a

b. Drug Screening Policy: Behavioral dmg screening test on any officer who is Observation Training provides supervisors with discovered to be inattentive to his/her duties.

instructions for requiring "For-Cause* testing when substance abuse is suspected.

c. General Employee Training will be

c. Complied: LDV drivers are required to read revised to include instructions on operating and sign the station vehicle access procedure.

vehicles inside the Protected Area.

(accomplished by 7/21/89) 15 ST-H L-AE-3111, 5/22/89, Refers to ST-HL-AE-3087,5/5/89:

Complied: Cardreaders are installed in assembly Schedule for Revision of Commits to installation of cardreader in areas to speed accountability.

Accountability Program assembly areas for accountability by end of first quarter,1990.

16 ST-HIeAE-3117, 6/1/89, Commits to extend the comparison study of Complied: Commitment for study completed and Perimeter Alarm Sys; m alarm system performance through the end performance data provided - ST-HI-AE-3344, of 1989 and to reach a conclusion on the 1/31/90.

adequacy of Unit 1 E-field system by January 31,1990.

17 ST-HI AE-3122,6/8/89,

a. Security personnel processing visitors

a. Complied: Instructions to security officers Response to NOV 8908-01 have been instructed to emphasize the relative to having visitors read and sign the Visitor (Visitor without badge) requirements printed on the reverse side of Acknowledgement on the Visitor Escort the Visitor Access Regoest Form to the Responsibilities Form are delineated in the access visitor prior to signature by the visitor, control procedures. Note: Superseded by ST-Hle AE-4585,11/9/93.

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ATTACHMENT "A" Commitments Completed or No longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 17 ST-lil AE-3122. 6/8/89,

b. Break-away chams to enable wearing

b. Complied: Badges for visitors are attached to Response to NOV 8908-01 badges around the neck have been placed at break away bands and the requirement for bands (Visitor Without Badge) each visitor registration point and will be reflected in procedures.

(Con't.)

issued to visitors entering the protected area.

18 ST-111eAE-3163, 7/13789,

a. Computer: A software problem relating

a. Complied: The installations have been Response to 018910-03 to reconfiguration was identified and completed.

(Computer Crashes, Video resolved. A new inter-computer software Camera Alarm Display) driver was installed. Software to resolve

" Slave On-Line* function to be installed by 8/3I/89.

b. CCTV: A software coding problem

b. Complied: No further action required.

was identified and corrected to resolve the "four-video processing" function.

Performance to be monitored to determme if additional corrective action is needed.

19 ST-Ill AE-3263,11/6/89, Procedural changes allow plant security to Complied: Specific guidance for protecting Response to Generic letter adequately isolate all plant vital areas to STPEGS from land vehicle bomb threats is given in 89-07, I.and Vehicle associated standoff zones within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> the Safeguards Contingency Events Procedure, Bombs after notification by the NRC.

Appendix W.

20 ST-HleAE-3356,1/26//90,

a. Badges: Article detectors have been

a. Complied: Physical changes were made in the Response to NOV 89-39 installed in gatehouses.

crit corrido;3 of the East and West gatehouses and article detectors were removed, reference HLAP letter of January 24,1995.

b. Access to Contamment: A d r ler

b. Complied: Readers are installed at approaches has been installed at Unit I airlock and will to airlocks.

be installcJ at the Unit 2 airlock before first refueling.

c. Unarmed Officer posted: Security

c. Complied: A

• General Purpose leg

• is issued officers at compensatory posts will have post for compensatory posts and indicates if the post is orders that will specify whether the post is armed or unarmed.

armed or unarmed 10

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A'ITACHMENT "A" Commitments Completed or No Longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 21 ST-HI AE-3722,3/20/91, FHB Truck Door Opening:

a. - b. Complied: A memo was issued requiring Tech. Spec. Violation

a. L.abels have been placed on the FHB that the Contml Room be notified before a FHB truck doors which require Security to notify truck door is opened the Control Room to request permission to open the doors.

b. Security issued a bulletin requiring the presence of Operations, in addition to Health Physics personnel prior to a security officer unlocking the door.

22 ST-HI AE-3727,3/22/91,

a. The outer air-tight door wheel will be

a. Complied: The hand wheel was removed and Response: RER removed and controlled to restrict procedural controls provided until the barrier (Item unauthorized entrance, thus increasing

• b* below) was installed.

penetration resistance time of the existing structure. Procedural guidance for controlling the door wheel is expected to be in place by June 30,1991.

. b. The target-set identified will have an

b. Complied: An additional barrier was installed interposing barrier which meets or exceeds so as to provide two (2).nterposing bamers requirement for a protected area barrier.

Scheduled completion - 1992.

c. The Special Response Training has been

c. - d. Complied: A tact # combat course of enhancea to include a course of fire that will fire has been incorporated into mth initial and re-physically challenge and place the officer qualification training of Respome Team members.

under a stressful situation.

The training utilizes the same equipment that the officers use while on duty.

d. The response force training will include the same equipment used by officers while on duty.

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ATTACHMENT "A" Commitments Completed or No longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 22 ST-H1 AE-3727,3/22/91,

c. Familiarity with w capons loading and

e. - g. CompNed: Weapons skills, including safe -

Response: RER (Con't.)

handling will be inclur ed (reviewed) during handling, loading, weapons malfunction, and armed weapons requalifications and armed response response training are covered in the Armed weapons training.

Security Officer Training program.

f. 'Ibe armed response training will also include n.E.r--- ts on safe operation and j

carrymg of weapons.

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g. The armed response training discussed above includes weapons malfunction, weapon failure, and transition drills.

h. The X-ray search equipment at the East

h. CompNed: X-ray machines are fitted with and West gatehouses have been fitted with Plexiglas guards to prevent the passage of materials.

clear Plexiglas guards to channel hand-through areas not scanned by the x-ray beams camed packages and other items into the x-ray beam. The modification prevents passage of items through the equipment without their being scanned by x-rays.

23 ST-HI AE-3775,5/3/91,

a. At the direction of the NSD Manager,

a. Random physical searches of hand camed SER 91-S02 Weapon in random physical searches of hand camed items are not routinely performed, but may be P. A.

packages commenced as of May 3,1991.

initiated at the direcuan of the Manager, Nuclear Security Department.

b. Signs have been posted at the explosive

b. ComepNed: Signs, identifying and prohibiting detectors machmes in each gatehouse to the carrying of contraband items are posted at the remmd personnel of the requirement not to explosive detectors in the East & West Gatehouses bring contraband into the protected area.

c. The Visitors Access Request Form has

c. CompNed: Visitors must read and sign a been modified to include a statement by the Visitor / Escort Responsibilities Form acknowledging visitor that he/she does not have any that they have read and understand access rules and contraband in his/her possession.

are not in possession of contraband items.

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ATTACHMENT "A" Commitments Completed or No Longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 23 ST-HI AE-3775,5/3/91,

d. On May 3,1991, an additional security

d. Complied: During peak periods, security SER 91-S02 Weapon in officer was assigned to the East and West officer staffing in the gatehouses is increased to P. A. (Con't.)

Gatehouses to assist search officers during effectively control entry and exit processing.

the Monday through Friday 0700 to 0800 hour0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> busy period.

c. During the Phase 11 of the Security

e. Complied: During the Security Force Training Force Requalification training, commencing Program, an audio-visual trainmg aid was used to July 15,1991, an audio / visual training aid show contraband items as they would appear ort a will be utilized that shows articles of x-ray monitor. He training aid is no longer used.

contraband as they would appear on a x-ray machine.

24 ST-lit-AE-3788, 6/14/91,

a. The form to request unescorted access

a. Complied: He request for Unescorted Access Response to NOV 91104)1 has been revised to ensure supervisory Form was modified to indicate that the applicant 10CFR26.22 Supervisor personnel complete the requiied training had supervisory status and, therefore, must be Training prior to being granted unescorted access.

trained in the STPEGS Continuous Behavioral Observation Program as a requirement for unescorted access.

b. He Fitness for Duty and Personnel

b. Complied: Procedures require that all Processing procedures will be revised to supervisory persons receive both initial and annual ensure supervisors and newly appointed refresher training as required by 10CFR26.22(c).

supervisors receive supervisory training as required by 10CFR26.22(c) and to provide more specific procedural steps for compliance with the rule requirements. His action will be completed by August 1,1991.

25 ST-HI AE-3943, The procedure was clarified to ensure Complied: Procedure was changed.

12/13/91, Response to following a loss of power to the security NOV 9121-02 Failure to system or any portion of the system, Test Before Returning functional testing will be performed on the Equipment to Service affected security devices.

13 l

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ATTACHMENT "A"

~

Commitments Completed or No Lc:iger Applicable I

ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 26 NRC letter - 3/16/92,

a. Issue: VA keys issued to Station

a. ConspNed: Keys issued to management Re: Technical Meeting of management & Access without Armed personnel were withdrawn and the pid-3/12/92 officer at door: HL&P defended position changed. At this time, there is no intention of and wished practice to remam unchanged.

initiating a plan change to reestablish the issue of keys to management personnel.

b. Review of Pdwl Nuclear Files:

b. Comply: Review of Nuclear Files: Files are Personnel information shall not be disclosed maintained as confidential records as required by to persons other that the subject or designee, plant procedures or those authorized during the course of the screening process.

27 ST-HieAE-4085, 5/1/92,

a. HL&P changed the requirement to clip

a. ComepNed: The requirement that bej es will g

Response to Allegations the badge (in addition to wearing it on a be worn on a lanyard, which is clipped to a ring Re: Visitor Escort band) to a recommendation.

attached to the badge is proceduralized.

b. Revised procedures provide the

b. Consplied: Superseded by ST-HI.-AE-4585, following:

11/9/93: Change of Corrective Acti'et Response.

- i. Specially qualified escorts ii. Visual contact with visitor at all times.

l iii. A card camed by the visitor with the escort's name.

iv. Provisions for changing escorts by

)

means of the new escott signing in on the visitor's card._ Notification of security for change of escott is no longer required.

28 ST-HI AE-4130,6/30/92,

a. Visitor escort limited to those on an

a. - c. Superseded by ST-HI AE-4585.

Response to NOV 9207-02 Approved Escort list.

& 03 - Visitor Escort

b. Special training and annual retraming required of those on Approved Escott List

c. Actions have been taken to minimize the number of individuals requiring visitor access to the plant.

14

ATTACHMENT "A" Commitments Completed or No longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 29 ST-illeAE-4141, 7/2/92, Issuance of vital area keys to senior Complied: Keys issued to management personnel Rev. Response to NOV management was suspended on December were withdrawn and the procedure changed. At 9121-01. NSRB Unlocking 11,1991.

this time, there is no intention of initiating a plan VA Doors Without change to reestablish the issue of keys to Security Officer Presence management personnel.

or Response to Alarm.

30 ST-IIL-AE-4164, 8/5/92,

a. The responsibility of the Safeguards

a. Comply: De responsibility for the Safeguards Response NOV 922041 Information Program is being transferred Information Program now rests with RMS&A.

Safeguards Information from Nuclear Security to Records Management Systems and Administration (RMS&A.)

b. He new procedure will be required

b. Comply: Persons authorized access to reading for selected individuals to be Safeguards Information are required to read the completed by 9/15/92.

Protection of Safeguards Information procedure.

c. Safeguards Information training within

c. Comply: Safeguards Information training is General Employee Training (GET) will be included in the GET program.

enhanced to be completed by 11/6/92.

d. Training will be developed for

d. Comply: Persons responsible for classifying individuals responsible for classification of Safeguards Information were at one time provided Safeguards Information to be completed by with special training.

Ii/6/92.

31 ST-ill AE-4213,

a. He Security Training and Access

a. Superseded by ST-IIL-AE-4585.

10/28/92, Response IR 92-Control procedures were revised to require 07 Visitor Escort /VA Door that security officers and individuals on the Closure approved escort list complete the formal escort training program on an annual basis.

b. A procedure has been revised to specify

b. Comply: He responsibility of escorts to close that escorts are responsible for closing and and secure VA doors is delineated in station securing the VA door.

procedures.

15 1

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ATTACHMENT *A" I

Commitments Completed or No Longer Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 32 ST-HI AE-4267, A rotating shift schedule is planned for Comply: A rotating schedule is now in place.

I1/25/92, Supplemental 1993.

Response, SALP 33 ST-HI AE-4295,1/14/93,

a. Nuclear Security is implementing a five

a. A five-team rotating schedule was implemented HIAP Performance team rotating shift schedule in 1993.

in 1993. Early in 1994, the number of teams was Initiatives reduced in order to make better use of manpower i

resources

b. An engineenng design review of

b. Complied: An engineering design review of security equipment will be performed in the security alarm, surveillance, and access control 1993 to select upgrades to the security systems was done in 1993 by PSC, Inc.

system for implementation in 1994.

Recommendations for upgrading the fixed CCTV system have been implemented and the work completed.

34 NRC-IR 93-02,2/24/93, The licensee committed then to evaluate the Comply: Test standards using geometric target CCTV problems and establish standards for identification have been developed for evalualmg assessing camera and system degradation.

CCI'V camera / monitor performance.

l 35 NRC-TAC NOs, M85176

...there was an indication that the recently Comply: Target identification is a part of the l

& M85177 OSRE Report initiated weapons training course should combat firing course, which is a part of both the l

emphasize target identification for response initial and annual Special Response Team Training l

officers to ensure that deadly force is not Programs.

used inappropriately.

36 ST-HL-AE-4585,11/9/93, Visitor / Escort requirements will be reviewed Response, NOV 9207-02 &

in General Employee Training (GET 1.)

Comply: Visitor escort responsibility training is 03 Visitor Escort: Change provided in the Security Module of GET 1.

i of Corrective Action i

16

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ATTACHMENT "A"

~

Commitments Completed or No IAnger Applicable ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 37 NRC-IR 94-03,1/25/94,

a.... to commence in March 1994, a

a. Complied: The work has been completed.

Licensee Initiatives complete systems upgrade to include camera New cameras, monitors, and cables are in place, and monitor replacement as well as replacement of the degraded coaxial video cables with fiber-optic cables.

b. Complied: New desk-top consoles compatible

b. New desk top consoles (radio) for with new hand-held radios have been installed in CAS/SAS.

the CAS and SAS.

c... 122 hand-held, light weight portable

c. Compiled: New, multiple channel hand-held radios with telepho m capability. Each radio radios, are issued and in service. The radios issued has the capability of six channels, two are to key personnel are picgi.um44 for telephone reserved for the control rooms, two are communications.

teserved for security, and two are reserved for telephone usage. The telephone capability is being restricted, intentionally, to supervisors.

l 17

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ST-HL-AE-5090 l

l ATTACIIMENT B ACTIVITIES NO LONGER CONSIDERED TO BE COMMITMENTS MISC-95\\95-1351X)1 ii

ATTACHMENT "B" Activities No Longer Considered to be Commitments ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 1

ST-IIL-AE-2333, 9/4/87, He frequency of supervisory patrols at Comply: Supervisors check compensatory posts as SER (Inattentive Security compensatory posts is being increased prescribed in security procedures.

Officer) 2 ST-lileAE-2346, 9/9/87, A revision to OPGP03-ZS-0004, " Issuance Comply: He obligations of plant personnel in the SER (Wrong Badge issued) and Control of Protected Area and Vital badge issue process are delineated in procedures.

Area Security Badges and Keycards" is in progress to more clearly delineate to plant personnel their obligation in reference to badge issue.

3 ST-IIL-AE-2347, 9/10/87, ESS programming was modified to require Complied: A

• flag" was included in the system

& 2593,3/31/88, SER &

verification from the complementary alarm program which requires a positive action by both Reply to NOV (ASO station to activate the Emergency Evacuation alarm stations in order to activate the door unlock Unlocked VA Doors)

Function.

function.

4 Statements - Enforcement lilltP has hired a full time security Comply: A software pmgrammer from the Conference Package, pmgrammer to address computer program Systems Engineering Department is dedicated on a 1/19/88 weaknesses and revise and update as full time basis to the security computer system.

appropriate.

5 ST-lil AE-2593,3/31/88,

a. He issuing security officer (SO) now

a. Comply: De obligations of plant personnel in Reply, NOViProposed requires each employee to make a positive the badge issue process are delineated in Enforcement Action 87-236 identification of their own badge (the SO procedures.

holds the badge up to the window with ID picture facing out) prior to issuance of the badge.

b. Badge pull lists run one day in advance,

b. Comply: Badge pull lists are generated shortly after 0001 hrs., in advance of the calendar day's entry / exit activities.

c. Badge pass-on logs at each Gatehouse.

c. Comply: A badge pass-on log is maintained in each gatehouse to record the new badges received each day and badges removed (deactivated) from the security access control system.

I

ATTACHMENT "B" Activities No Longer Considered to be Commitments ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 5

ST-HL-AE-2593, 3/31/88, Vital Area Barriers:

Reply, NOV/ Proposed

d. A change was made to the Construction

d. Security has a representative at regularly Enforcement Action 87-236 Work Request procedure to require scheduled plant work control meetings. Plant (Con't.2 additional security involvement.

Change Form Processing requires an evaluation of impact on the Physical Security Plan.

c. Work documentation procedures were

e. During work process, when the planner revised to incorporate a mandatory security identifies work on penetrations that could impact review if the possibility exists that a security security barriers, a review is conducted with the barrier will be breached. Security procedure Security Force Supervisor.

requires a review of the work package and/or walkdown of the area if the possibility exists that a security barrier will be breached 6

ST-HL-AE-2727, 7/15/88, Violation H, PIDS Testing:

Violation H, PIDS Testing:

Amended Response to

...a specific group of capable individuals has Comply: Probability testing of the PIDS is Enforcement Action 87-236 been identified to perform probability testing restricted to security personnel who have been of the intrusion detection system.

specifically trained to perform the test function.

7 ST-HL-AE-2773, 8/23/88, Violation B, Mis-issue of VA Key:

Comply: Vital Area Keys:

Response to NOV 88-165 New color coded, laminated key tags were For identification, a colored tag is affixed to vital Attachment B attached to vital area key rings to facilitate area keys.

identification by issuing / receiving personnel.

8 ST-HL-AE-3143, 6/18/89,

a. A placard has been affixed to the

a. Comply: Requirements for affixing the Response to NOV 8910-02 dashboard of the Designated Vehicles placard are delineated in security procedures.

Control of LDVs reminding drivers to remove keys.

b. Prior to adding a vehicle to the DV

b. Comply: Vehicle Inspection: The List, a representative from Nuclear Security requirement for vehicle inspection prior to granting will inspect the vehicle to ensure that there LDV status is delineated in security procedures.

are no mechanical defects which would prohibit compliance with procedural requirements.

2 w

ATTACHMENT "B" Activities No Longer Considered to be Commitments ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION '

8 ST-ill AE-3143,6/18/09,

c....the security Sergeant responsible for

c. Comply: Requirements for reviewing Vehicle Response to NOV 8910-02 Access Control was instructed to ensure that Access Request Forms is delineated in security Control of LDVs (Con't.)

a review of Vehicle Access Request Forms procedures.

is performed on a daily basis. De purpose of this review is to monitor expiration of authorization and initiate appropriate action prior to expiration. His process will be proceduralized by July 14, 1989.

9 ST-illeAE-4245, He two security staff positions designated Comply: Only a limited number of designated 10/27/92, SALP Response for testing of security systems were security personnel are used to perform probability Concern on Decline of reinstated in February of 1992.

testing.

System Performance Assessment 10 ST-ill AE-4267, He Nuclear Security Department has Complied, with change: A new self-assessment 11/25/92, Supplemental implemented a self-assessment process using program was developed and should be implemented Response, SALP manags tent / supervisory tours, including in cady summer of 1995.

back-sh ft tours, structured to address all major aspects of the physical security program.

I1 NRC-IR 94-03,1/25/94,

a....and include... a new video capture

a. Complied: He new CCTV syst.em includes Licensee Initiatives system that will enhance assessment of video capture to assist in alarm assessment.

intrusion alarms.

b.

...a weekly trend report of security

b. Comply: Weekly trend reports of security equipment in need of repair.

equipment in need of repair are maintairml.

12 NRC Ixtter - 3/16/92,

a. Issue: Reportability of Degraded

a. Reporting Degraded Lighting: Secunty Re: Technical Meeting of Lighting: (IIL&P to provide their personnel procedures provide instructions for assessing PA 3/12/92 with) more definitive criteria for judgement lighting and guidance for determining incidents on reporting.

which require logging or reportability.

3

ATTACHMENT "B" Activities No Longer Considered to be Commitments ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 12 NRC letter - 3/16/92,

b. Issue: Reporting Pre-Posted System or

b. Comply: Reporting Pre-Posted Equipment Re: Technical Meeting of Equipment Failure: Imgging is not required -

Failure: All events are logged in accordance with 3/12/92 (Con't.)

for preplanned situations that require NRC guidance.

compensatory posting - security actions are recorded on a Security Incident Report.

13 ST-Hi<AE-4585,11/9/93,

a. Escorts will be required to read and

a. Comply: Procedures require escorts to read -

Response, NOV 9207-02 &

acknowledge visitor / escort requirements and sign the Visitor / Escort Responsibility Form.

03 Visitor Escort: Change each time prior to entry of the Protected of Corrective Action Area, thereby establishing an ongoing training evolution.

b. A copy of visitor / escort requirements

b. Comply: 'Ibe requirement is contained in a will be maintamed with the badged visitor special note in the Access Control Procedure.

should escorts change while in the Protected Area.

4

ST-lil AE-5090 ATTACIIMENT C ONGOING COMMITMENTS MISC-95\\95-135 001 tii

ATTACHMENT "C" Ongoing Commitments ITEM ORIGIN / REFERENCE COMMITMENT COMMENTiDISPOSITION 1

ST-HL-AE-2593, 3/31/88,

a. Inventories are perfonned once cach

a. - b. Comply: Physical Security Plan shall Reply, NOV/ Proposed shift rather than once per day.

conunit to a daily inventory of NRC non-photo l

Enforcement Action 87-236 badges held by security.

b. Inventories are based on current Electronic Security System log.

PA & VA Escorts:

c. Currently all site personnel are now

c. Comply: The Personnel Access Authorization screened to levels to be qualified as escorts Program at the STPEGS implements all elements of in order to prevent recurrence Regulatory Guide 5.66 to satisfy the requirements of 10CFR73.56. He commitment is made in the Physical Security Plan, Rev 1 A, Chapter 4.

2 ST-liL-AE-3344,1/31/90, States that the FAR/NAR averages exceed Complied: The FAR/NAR criteria is stated as a Comparison, UI & U2 IDS the RG 5.44 criteria. The criteria will Physical Security Plan commitment, Rev 1 A, continue to remain a goal. Commits to Chapter 5.

continued monitoring of FAR/NAR alarm rates and comparison of Unit 1/ Unit 2 alarm systems.

3 NRC IR 90-13,6/1/90,

...the licensee's security staff made a Complied: He commitment to taking item B, FAR/NAR commitment to the inspector that each zone compensatory action for zones which exceed that exceeded an acceptable rate of FAR/NAR criteria is made in the Physical Security false / nuisance alarms would be determined Plan, Rev 1 A, Chapter 8.

as degraded and posted.

1

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ATTACHMENT "C" i

i Ongoing Commitments ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 4

ST-HL-AE-3722, 3/20/91, Here are provisions in the Physical Security Complied: he Physical Security Plan, Rev 1 A, Tech. Spec. Violation Plan which will permit security alarm testing Chapter 9 states that alarms on vital area portals of the FHB doors on a periodic basis that shall be operationally tested before being returned will not interfere with the operation of the to service following outage or maintenance work FilB exhaust air system.

and at least once each seven (7) days, except as precluded by safety or operational constraints.

BMSs which cannot be routinely tested due to safety or operational concems shall be tested at the time when the door or gate is opened during refueling or other operational work.

5 NRC-TAC Nos. M85176

... consideration might be given to issuing Comply: Keys have been issued to operators and

& M85177, OSRE Report hard keys to auxiliary operators to ensure the change reflected in the Physical Security Plan, the quickest possible access to vital areas.

Rev 1 A, Chapter 4.

6 ST-ilL-AE-4585,11/9/93, Escorts will maintain direct observation of Comply: ne requirement is reflected in Response, NOV 9207-02 &

their visitors, except within restrooms from procedures and the Physical Security Plan, Rev I A,

03. Visitor Escort: Change which there are limited means of egress Chapter 4.

of Corrective Action (NUREG 1304.) In such cases, the escort will remain nearby and maintain full view of the egress area.

7 NRC-IR 94-03,1/25/94, Licensee had dedicated an Instrumentation Comply: Dedicated I & C Technicians are Licensee Initiatives and Controls Supervisor and six personnel to members of the security organization reporting to the repair of security equipment.

the Security Systems Supervisor. The commitment is contained in the Physical Security Plan, Rev 1 A, Chapter 9.

8 NRC 1R 88-03,2/12/88 Records:

Records:

... licensee indicated that these suitability Complied: Security officer suitability records are records were being consolidated into one maintained in a single file folder for each person.

folder for each person.

He Security Personnel Training and Qualification Plan shall be expanded to include the commitment.

2 0

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ATTACHMENT "C" Ongoing Commitments ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 9

NRC Ixtter - 3/16/92,

a. Issue: VA keys issued to shift

a. In response to a suggestion by the NRC, keys Re: Technical Meeting of supervisors: lilAP proposed to modify have been issued to operators and the change is 3/12/92 procedure to allow reasonable use by reflected in the Physical Security Plan, Chapter 4.

operations personnel during emergency and abnormal conditions,

b. Issue: Operational testing following

b. Operational Testing: Security procedures power failure: Tests are to be made require operability testing following power failure following disconnection, failure of primary and before equipment is returned to service. The and bxkup and when one or more Physical Security Plan, Rev 1 A, Chapter 9 now components fail to perform when power is states that equipment will be operability tested restored.

before being returned to service following a period l

of disuse. The wording of the plan will be strengthened to clearly state that equipment shall be operability tested following a power failure before being returned to service.

c. Issue: CCTV Failure, Compensatory

c. CCTV Comp. Measure: The Physical Security Actions: If there is a blind spot in an Plan, Rev 1 A, Chapter 8 shall be expanded to approach to the outer fence, or a blind spot indicate that a posted security officer shall be able in the isolation zone between the fences, but to view and detect penetration of the PA fence.

penetration of the inner fence is visible, the (posted) officers ability to assess the l

presence of a threat is not hampered.

l 1

d. Issue: Illumination of Roofs:

d. Illumination of Roofs: He Physical Security Illumination of MEAB, FIIB, DGB, and Plan, Rev 1 A, Chapter 5 will be expanded to IVC is not checked because the buildings are identify the MEAB, FIIB, DGB and IVC as l

not easily accessible and considered in the buildings not requiring rooflighting.

" Exempt Structure" class.

e. Issue: Visibility of Adjacent

e. Visibility Adjacent Guard Posts: The Physical Compensatory Guard Posts: Visibility of Security Plan, Rev 1 A, Chapter 8 will be expanded perimeter guards to adjacent perimeter posts to indicate that it is not necessary for compensatory is not a NRC requirement.

officers at adjacent posts to be within view of each other.

3

ATTACHMENT "C" Ongoing Commitments ITEM ORIGIN / REFERENCE COMMITMENT COMMENT / DISPOSITION 9

NRC letter - 3/16/92,

f. Issue: Retum to Work Policy: For

f. Return to Work: The Security Personnel Re: Technical Meeting of serious illness or injury: 1) Place person's Training and Qualification Plan, Rev 1A states that 3/12/92 (Con't.)

badge on hold until MD provides release to security officer : returning to work after illness, etc.

perform assigned duties; 2)(Contractor) are required to provide medical evidence of evaluates need for testing before resumption recovery and demonstrate the ability to physically of duties; 3) Final determination of need for perform the requirenwnts of their duties.

testing is HL&P responsibility.

10 ST-HleAE-4141, 7/2/92, Procedure OPGP03-ZS-0005 will be revised Complied: In response to a suggestion by the Rev. Response to NOV by July 31,1992. HlAP will consider a NRC, keys have been issued to operators and the 9121-01. NSRB Unlocking plan change under 10CFR50.90...to resume change reflected in the Physical Security Plan, Rev VA Doors Without issuance of vital area keys to senior I A, Chapter 4.

Security Officer Presence management in the future. The text referred or Response to Alarm.

to in the Statement of Violation would be clarified to avoid future misunderstanding or different interpretations...

4

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