ML20199E648

Insp Repts 50-445/97-21 & 50-446/97-21 on 971027-31.No Violations Noted.Major Areas Inspected:Licensee Physical Security Program Including Records & Repts,Test & Maint and Access control-vehicle

ML20199E648
Person / Time
Site:	Comanche Peak
Issue date:	11/13/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20199E540	List: ML20199E534 ML20199E648
References
50-445-97-21, 50-446-97-21, NUDOCS 9711210270
Download: ML20199E648 (10)

See also: IR 05000445/1997021

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ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50-445;50 446

License Nos.: NPF 87; NPF 89

Report No.: 50-445/97-21; 50-446/97 21

Licensee: 1U Electric

Facility: Comanche Peak Steam Electric Station, Units 1 and 2

Location: FM-50

Glen Rose, Texas

Dates: October 27 31,1997

Inspector: A. B. Earnest, Sec urity Specialist, Plant Support Branch

Approved By: Blaine Murray, Chief, Plant Support Branch .

Division of Reactor Safety

ATTACHMENT: Supplementallrfo nation

s

9711210270 971113

PDR ADOCK 05000445

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EXECUTIVE SUMNIARY _,

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Comanche Peak Steam Electric' Station, Units 1 and 2.

~ NRC Inspection Report 50 445/97 21: 50-446/97 21-

This was an announced inspection of the licensee's physical security program. The areas

inspected included records and reports, test and maintenance, access control 6 vehicles,

access control - personnel, access control . packages, training and qualifications, iighting,

and followup of previously identified findings.

Plant Sw;mn

• - An excellent records and reports systerri were in place. A noncited violation was

identified involving the failure to temporarily deactivate access' authorization of

personnel with only occasional access to the plant if they are not on site to be

immediately tested (Section S1.11.

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• - ' A good test and maintenance program was implemented that ensured security

systems were maintained at their maximum effectiveness. A noncited violation was

identified involving the failure to inspect all vital area doors every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

- (Section S2.1).

• - = An efficient vehicle access control program was in place (Section S2.2).

• Personnel access to the protected area was effectively controlled (Section S2.3). ,

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• An ef fective program was in place for searching hand carried packages and material

.(Section S2.4).

• ~ A noncited violation was identified involving the f ailure to properly requalify security

officers on the semiautomatic pistol (Section S2.6).

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i * The protec'ed area lighting system was excellent (Section S2.6).

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Rooort Details

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lV. Plan.t Sunoort .

S1' Conduct of Security and Safeguards Activities -

SL1 flecord and Heoorts -

a. Inspi: tion Scong

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The se( Jrity event logs Were inspected to determine compliance with the

requirements of 10 CFR 73.71(b) and (c),10 CFR 73.70(a)-(c), and the physical

security plan. The inspector reviewed the safeguard's event logs for the second,

third, and portions of the fourth quarter of 1997.

b. Observations and Findinas

The inspector determined that the licensee confw,ud to the regulatory and license

requirements to report security events. The licensee's security staff was correctly

identifying security events. In addition, the licensee used the information contained

in their records and reports to track and trend problem areas. During a review of the

safeguards event logs, the inspector noted that two examples of fitness for-duty

requirement f ailures wereidentified. Station Procedure STA 910, Revision 3,

' paragraph 6.10.6 requires, in part, tihut personnel, who only occasionally access the -

site and are selected for random drug and alcohol screening, will have their access

authorization temporarily deactivated in the security computer if they are not on site

to be immediately tested. The deactivation will remain until they next arrive on site

at which time they will be tested prior to having the unescorted access restored.

On June 20 and June 27,-1997, the licensee identified two examples where

. contractor personnel access authorization was not deactivated when they were

unavailable for testing upon being selected for random testing. Security Field Report

0530 97 indicated that the first individual was supposed to have had his unescorted

- access deactivated on May 17,1997. Computer records indicated that the

individual accessed the plant on May 23, June 5, and June 17,1997. Security Field

Repot 0557 97 indicated that a second individual was supposed to have had

unescorted access deactivated on June 25,1997. A review of the comnuter

records indicated that the second individual accessed the plant on June 27,1997.

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Both indiviouals accessed the plant without being tested.

The licensee determined that problems existed with the computer commands

necessary for deactivization of access authorization. Corrective actions included

computer program ch:mges and security instruction changes for the alarm station

' operators to require that a copy of the computer deactivation be attached to the

. memorandum requesting deactivation and returned to the fitness for-duty

supervisor. The inspector reviewed all reportable events in the safeguard's event

logs and determined that there were no recurrences of this nature from June 1997

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to the date of this inspection. The failure to correctly authorize entry into the

protected area is a violation of Station Procedure STA 910 (50-445; 446/9721-01), a

This nonrepetitive, licensee-identified and corrected violation is being treated as a

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noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy.

c. _ Conclusion

An excellent records and reports system were in place. A noncited violation was

identified involving the f ailure to temporarily deactivate access authorization of

personnel with only occasional access to the plant if they are not on site to be

immediately tested.

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S2 Physical Security Program for Power Reactors (81700)-

- S2.1 lestina and Maintenance

a. Insoection Scoce

The testing and maintenance programs were inspected to' determine compliance

with the requirements of 10 CFR 73.55(a), (g)(1) through (3), and the physical

security plan,

b. Observations and Findinos

The inspector reviewed testing and maintenance re' cords and confirmed that the

records committed in the physical security plan were on file, well documented, and

readily available for review. The licensee provided instrumentation and controls

technicians to repair or replace any security equipment that required corrective

maintenance. The inspector determined through a review of work records and-

, _ interviews with security officers and supervisors that repairs were compl6ted in a

timely manner. A quarterly preventive maintenance program.was in place for the

security systems.

The inspector ob' serve'd the testing of metal detectors during the inspection. ,The

tests observed by the inspector were completed in a professional and competent

manner.

Based on interviews of security personnel and a review of procedures, the inspector

determined that prior to July 1997, two vital area doors were not tested as required.

Paragraph 3.5.2.4 of Security Instruction Procedure 3.5, Revision 5, requires

security patrols to physically inspect vital area doors every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. A security self

assessment determined that for several years af ter both units at the plant.were

licensed, vital area doors 227 and 527 were not inspect ~ed every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> as required

! by the procedure ' The doors in question are outside doors on the roof of the power

building and provide emergency egress from containment. To get to the door.s, a -

person must enter and exit through two other vital areas within the power block.

l= There was no viable path way up the outside of the power block or containment

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buildings. The doors were locked and alarmed, but were not equipped with card

readers. Security testing and maintenance personnel tested the alarm system on the

doors every 7 days. Security officers have been trained and briefed te ensure that

all vital area doors are inspected at leest once each 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period, The failure to

inspect all vital area doors is a violation of Security Instruction Procedure 3.5. This

nonrepetetive, licensee-identified and corrected violation is being treated as a

noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy

(50-445;-446/9721-02).

c. Conclusion

A good test and maintenance program was implemented that ensured security

systems were maintained at their maximum ef** ctiveness. A noncited violation was -

identified involving the failure to inspect all vital area doors every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

S2.2 Access Control- Vehicles

a. insoection Scong

The vehicle access control program was inspected to determine compliance with the

requirements of 10 CFR 73.55 (d)(4) and the physical security plan,

b. Observations and Findinos

The inspector observed searches of two vehicles to ensure that they were properly

searched prior to enteritig the protected area. The security officers conducted the

search in compliance with their procedural requirements,

c. Conclusion

An efficient vehicle access control program was in place.

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l. S2.3 Access Control - Personnel

a. insoection Scoce

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The personnel access control program was inspected to determine compliance with

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the requirements of 10 CFR 73.55(d)(1), (2), (3), (5), (6), and '7), and the physical

security plan,

b. Observations and Findinas

The inspector determined through observation that personnel access to the

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protected area was properly controlled. The protected area access control

equipment was inspected and found to be functional and well maintained. The last

control area for access to the plant was contained within a bullet resistant

enclosure. The inspector confirmed by interview and observation that the security

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officers clearly understood their responsibilities as related to controlling personnel

access.

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c. Conclusion

Personnel access to the protected area was effectively controlled.

S2,4 Access Control- Packaaes

a. IDsoection Scone

The package access control program was inspected to determlae compliance with

the requirements of 10 CFR 73.55 (d)(3) and the physical security plan,

b. Observations and Findinos

The inspector observed the searching of packages and materials at the personnel

access control points. The package and material search process was very efficient.

Tests indicated that the X-ray equipment performed in an adequate manner. The

security officers operating the equipment were well trained and answered all of the

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inspector's questions.

c. CQncluhiDD

An effective program was in place for searching hand carried packages and material.

S2.5 Securitv Trainina and Qualificati?ns

a. Insoection ScDDR

The security training and qualification program was inspected to determine

compliance with the requirements of Appendix B of 10 CFR Part 73,73.55(b)(4),

th)(3), and the training and qualifications plan.

b. . Observations and Findinas

The inspector reviewed the current training and qualification records of 10 security

officers. The training and qualifications records of the officers were complete and

readily available for inspection.

The inspector determined through a review of the safeguards event logs and

security officer training records that 48 security officers were requalified on the

handguns in a manner contrary to that required in the training and qualification plan.

Patagraph 4.3.1 of the Training and Qualification Plan, Revision 9, requires all armed

officers to requalify anr ually, Paragraph 4.2.1 of the Training and Qualification Plan

requires security officers to requalify annually with the revolver or semiautomatic -

pistol by successfully completing the applicable course described in Appendix D to

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= the Training and Qualification Plan. Appendix DiStage 2, requires each officer to

fire three rounds from a kneeling, strong-hand _ supported position.

' On September 4, September 11, and September 18,1997,48 security. officers ,

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were requalified on the semiautomatic pistol without firing from the kneeling .

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strong hand _ supported position as required by the Training and Qualification Plan. -

The security officers were certified as having_successfully requalified.

A security officer informed a member of security management who informed the

training supervisor of the failure to qualify in accordance with the approved course

of. fire. Security Field Report 0791-97 was _c ompleted that documented the violation

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of the Training and Qualification Plan. The inspector reviewed licensee

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investigations of the issue and determined that the range sergeant thought that he

had the option to fire the three rounds from a standing position'. The licensee -

immediately determined that corrective action was necessary and started

requalifying the 48 security officers. At the time of the inspection,30_of.the 48

security officers had been properly requalified in accordance with the Training and

Qualification Plan. The other 18 officers will be requalified as scheduling permits,

! probably within 2 weeks. The failure to properly requalify the security efficers is a

violation of the Training and Qualifications Plan. This nonrepetitive,

licensee-identified and corrected violation is being treated as a noncited violation

consistent with Section Vil,B.1 of the NRC Enforcement Policy (50-445;

446/9721 03).

c. C.onclusion

I A noncited violation was identified involving the failure to properly requalify security

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officers on the semiautomatic pistol.

S2.6 Lichtina (71750)

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, a. insoection Scone

The lighting system was inspected to determine the licensee's compliance with the

requirements of 10 CFR 73.55(c)(5) and the physical security plan.

b. Qbservations and Findinas

The inspector observed the lighting along the perimeter barrier and associated

= isolation zones. The lighting effectively ensured cameras and security officers can

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visually inspect the areas. The entire protected area was inspected, and the lighting

was at least 0.2-foot candlepower throughout. Access control points, alarm

stations, and vital area portals were lighted in an adequate manner.

-c. Conclusion

The protected area lighting system was excellent,

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S3 - Followup (92904)

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S3.1 (Closed) Violation 50-445: 446/9523 01: Protection of Safeauards Information

The inspector reviewed licensee records and a root cause analyr's o' the event

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described _in the violation. The inspector reviewed the safeguard's i,<t'it logs and

determined that there were no recurrences. The inspector confirmed that corrective-

actions were complete and effective.

S3.2 LCJosed) Insoection Followuo item 50 445: 446/9703-01: Sianature Authority

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Licensee personnel were signing for supervisors, not by signing their own names but

by signing the supervisor's name. The inspector reviewed corrective action

including training for supervisors. No recurrences have been reported.

S3.3 -iClosed) Violation 50-445:-446/9717-04: ' Protected Area Liahtina

The inspector determined that two trailers were not properly lighted under the

- trailers. The inspector walked down the entire protected area and determined that

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the licensee had effective corrective actions in place. All vehicles had temporary

lighting under the vehicles.

V. Management Meetings

X1 Exit Summary

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-The inspector presented the inspection results to members of licensee management

at the conclusion of the inspection on Octrber 31,1997. The licensee

- acknowledged the findings presented. No proprietary information was identified.

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ATTACHMENT

- SUPPLEMENTAL INFORMATION - 'i

. PARTIAL LIST OF PERSONS CONTACTED

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Licensee ,

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D. Alps, Security Manager'-

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-J. Ardizzoni,' Administrative Security Supervisor-

J. Ayres, Plant Support Overview Manager

G. Bell, Regulatory Aff airs

J. Braun, Security Coordinator

J. Britt, Corporate Security

J. Brown, Fitness for Duty Supervisor

W. Cravey, Training Security Coordinator

B. Grace, Safety Services

N. Harris, Licensing Engineer

T. Hope, Regulatory Compliance Manager .

- M. Lucas, Maintenance

M.' Marcinak, SMART Team 1 - Security

P. Mills, Senior Quality Assurance Specialist, Operations Quality Assuranca

D. Moore, Plant Operations i

D. Walling, Plant Engineering

Contrattot

B. Bodeker, Burns Lieutenant

K. Hayes, Burns Security Chief

R. Jeffus, Burns Security Training Sergeant

G. Willis, Security Training Sergeant.

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R. Nease, Resident inspector

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INSPECTION PROCEDURES USED

IP 81700 Fhysical Security Program for Power Reactors

IP 92904 Followup - Plant Support

IP 71750 - Plant Support Activities

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ITEMS OPENED, CLOSED, OR DISCUSSED: ,

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50 445;-446/9721 01 NCV Fitness for Duty- " -

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50-445;1446/9721 02- NCVL Test and Maintenance

50 445;-446/9721-03 NCV- Training and Oualification ,

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- 50-445; 446/9721 01 .NCV Fitness for Duty-

50 445; 446/3'721-02 NCV Test and Maintenance

= 50-445;.446/9721 03- NCV- Training and Qualification -

50 445;-446/9523-01: VIO - Protection of Safeguards information. .

50-445; 446/9703-01 .lFI Signature Authority '

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50 445; 446/9717 04 VIO - Protected Area Lighting

LIST OF DOCUMENTS FIEVIEWED

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Security instruction / Procedure 4.0, "Cnmpensatory and Contingencp Instructions,"

Revision 4

Station Adminis;rathie Procedure STA 190, " Fitness-for Duty Program," Revision 4

Security Instruction Procedure 3.2, " Access Control," Revision 10  ;

Security Instruction Procedure 3.5, " Protected and Vital Area Patrols," Revision'5

Safeguards Event Lcgs, Second, Third and Fourth Quarters of 1997

Safeguards Field Repotts, 0557-97, 0530-97,0549 97, 0791 97, 0531 97, 0296-97

Physical Security Plan, Re~ vision 27 ,

Training and Qualification Plan, Revision 9

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