ML20216H350

Insp Repts 50-445/98-11 & 50-446/98-11 on 980323-27.No Violations Noted.Major Areas Inspected:Physical Security Program

ML20216H350
Person / Time
Site:	Comanche Peak
Issue date:	04/16/1998
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19044A108	List: ML20216H350
References
50-445-98-11, 50-446-98-11, NUDOCS 9804210117
Download: ML20216H350 (11)

See also: IR 05000445/1998011

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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.': 50-445/98-11; 50-446/98-11

Licensee: TU Electric

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

Location: FM-56

Glen Rose, Texas

Dates: March 23-27,1998

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Inspector: A. Bruce Earnest, Physical Security Specialist

Plant Support Branch

Approved By: Blaine Murray, Chief, Plant Support Branch

Division of Reactor Safety

ATTACHMENTS: SupplementalInformation

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9804210117 900416

PDR ADOCK 05000445

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EXECUTIVE SUMMARY

Comanche Peak Steam Electric Station, Units 1 and 2

NRC inspection Report 50-445/98-11; 50-446/98-11

This routine, announced inspection focused on the licensee's physical security program. The

areas inspected included review of alarm stations, communications, personnel and vehicle

access control, protected area detection aids, security event logs, assessment aids, and the

security organization.

Plant Sunood

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Excellent performance was noted in the areas of alarm stations, communications,

protecjed area detection aids, security event logs, assessment aids, vehicle access

control, and the security organization (Section S1.1).

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A noncited violation was identified for failing to adequately search personnel for

explosives and incendiary devices (Section S1,1).

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Report Details

IV. Plant Suonort

S1 Conduct of Security and Safeguards Activities q

S1.1 Access Control - Personnel

a. Insoection Scone

The personne; access control program was inspected to determine compliance with the

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

plan. ,

b. Observations and Findinos

The inspector determined through observation that personnel access to the protected

area was adequately 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 that the security officers clearly understood their responsibilities

as related to allowing access to visitors.

Section 6.2.4.1 of the Physical Security Plan, Revision 27, required that personnel be

searched utilizing detection equipment described in paragraph 7.2. Paragraph 7.2

described explosive detection equipment capable of detecting nitrogen-based

explosives.

Paragraph 3.2.1.1C of Security Instruction Procedure 3.2, Revision 12, required that if a

search device fails during testing or operation, the device was not to be used until it was

repaired and tested. Further, paragraph 3.2.1.2A required that all personnel and

packages be searched for explosives and incendiary devices.

The licensee discovered, reported, and corrected a violadun of the above requirements

on February 12,1998. On that date, the only operable explosive detector in the primary

access point failed prior to rush hour. The test utilized by the licensee to determine

operability was ineffective in determining that the detector had failed. Prior to discovering

the failed detector, 312 personnel were inadequately searched for explosives and

incendiary devices. The root cause of the failure was the testing methodology used

every 8-hour shift as an operability test. The licensee was not using a nitrate based

source as a part of the operability testing. The licensee did not realize that testing

without the source only tested the delay mechanism in the detector and not the detection

capability. The type of failure experienced caused the equipment to appear to function

correctly, therefore, there was no predictability to the failure. As far as the personnel

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processed were concerned, the equipment performed as required. As corrective action,

the licensee changed the testing methodology prior to the inspection. The corrective

action should be sufficient to prevent recurrence. The inspector determined that the

licensee failed to meet physical security plan requirements to adequately search  ;

personnel, constituting a violation of the physical security plan. This nonrepetitive,

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;-446/9811-01).

c. Conclusion

A noncited violation was identified for failing to adequately search personnel for

explosives and incendiary devices.

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S1.2 Acces,s Control- Vehicles  !

a. Insoection Scopa

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 Findinas

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

searched prior to entering the protected area. The security officers conducted the search

in compliance with their procedural requirements.

A resident inspector identified that on March 16,1998, a portion of a vehicle's cargo was

not completely searched at the south vehicle access point.10 CFR 73.55(d)(3) permits

the cargo of a vehicle to be exempted from search prior to entering the protected area if

that cargo presented a safety hazard to the security force. The rule also states that the

cargo will be searched inside the protected or vital area when unloaded. The cargo

consisted, in part, of radiologically contaminated equipment. Review during this

inspection determined that radiological procedures did not contain requirements for

radiation protection personnel to search contaminated equipment / cargo. The inspector

interviewed a radiation protection manager and determined that the cargo in question

was searched and that radiation protection personnel were aware of their search

responsibilities. The licensee security manager made a commitment at the exit meeting

to review plant procedures and to change, as appropriate, those procedures that do not

contain procedural requirements to search hazardous cargo. The commitment to review

the plant procedures as they apply to search requirements inside the protected and vital

areas is an inspection followup item (50-445;-446/9811-02).

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c. Conclusion

The licensee had an efficient vehicle access control program. An inspection followup

item was identified regarding the procedural search requirements for cargo unsearched

at the entrance to the protected area.

' S1.3 Communications

a. Insoection Scone

The communications capabilities were inspected to determine compliance with the

requirements of 10 CFR 73.55 (f)(1) through (4), (g)(3), and the requirements of the

physical security plan. The areas inspected included the operability of both radio and

teleptpne systems and the capability to effectively communicate both telephonically and

by radio with the local law enforcement agencies.

b. Observations and Findinos

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The inspector confirmed that the licensee had telephone and radio systems capable of

meeting all communications requirements of the security organization. The inspector

observed a test of the radio system. The alarm station operator demonstrated the ability

to communicate with local law enforcement authorities. In addition, the inspector

observed an onsite communications check with all security officers. The radio equipment

was effective and very well maintained.

c. Conclusion l

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The licensee had an excellent communications capability that performed well during the

inspection.

S1.4 Alarm Stations

a. insoection Scope

The alarm stations were inspected to determine compliance with the requirements of

10 CFR 73.55(e)(1) and (2), (f)(1) and (2), and the physical security plan.

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b. . Observations and Findinas

The inspector confirmed the redundancy and diversity of the alarm stations. Action by

one operator cannot reduce the effectiveness of the security systems without the

knowledge of the other alarm station operators. The central alarm station and secondary

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alarm station were bullet resistant. The inspector observed the work conditions and the

capabilities of the station operators in both alarm stations. The inspector asked

questions of the station operators and determined that they were very effectively trained

and knowledgeable of their duties. Forther, the operators did an excellent job of handling

alarms and radio traffic promptly and efficiently.

On March 20,1998, the HALON fire suppression system in the central alarm station

activated and forced the evacuation of the alarm station for approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

During that time, the secondary alarm station successfully handled all alarm station

requirements.10 CFR 73.55(e)(1) requires that all detection alarms annunciate in a

continuously-manned central alarm station.

Review during this inspection determined that when the fire suppression system was

designed and installed, the system audio alarm was installed outside the area being

protected. As a result, when the HALON activation alarm activated, the alarm station

operator was unsure which area was about to activate. If the system had been correctly

designed, the operator could have manually shut off the HALON prior to activation in the

absence of a fire. Further, the licensee had not determined the cause of the activation at

the end of the inspection. In addition, the inspector determined that the alarm station

operators were not trained in the manual activation or deactivation of the system. Prior

to the end of the inspection, the training issue had been resolved. The licensee was also

studying means to install the alarm in the area to be protected as well as continuing to

investigate the cause of the activation. The matter will be reviewed as an inspection

followup item (50-445;-446/9811-03).

c. Conclusion

The alarm stations were redundant, well protected, and the operators were alert, well

trained, and efficient. An inspection followup item was identified to review corrective

actions for a fire suppression activation that caused the evacuation of the central alarm

station.

S2 Status of Security Facilities and Equipment

S2.1 D_etection Aids - Protected Area

a. Insoection Scoce

The detection aids program for the protected area was inspected to determine

compliance with the requirements of 10 CFR 73.55(c)(4), (e)(2) and (3) and the

requirements of the physical security plan. The areas inspected included the detection

systems' capabilities, detection system security, and maintenance of the detection aids

system.

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b. Observations and Findings

The inspector observed nine licensee tests of the perimeter microwave and E-field

detection system. All tests were effectively detected. The detection system was well

designed and maintained. The microwave heads were double and triple stacked and

provided an effective detection capability to detect any intruder attempting to enter the

plant undetected.

c. Conclusion

An excellent perimeter detection system was installed and maintained.

S2.2 61sessment Aids

a. [0.Uwction Scoce

The assessment aids program was inspected to determine compliance with

10 CFR 73.55 (h)(4) and (6) and the physical security plan. The areas inspected

included the application of closed-circuit television to provide observation of the

perimeter isolation zones and the adequacy of the monitoring system in the alarm

stations,

b. Observations and Findings

The inspector observed the operation of the closed-circuit television system and

determined that it was an excellent system. The closed-circuit television cameras were

properly placed to ensure 100 percent coverage of the alarmed zones. The alarm station

monitors were positioned to facilitate assessment by operators. Further enhancement

was evident in the resolution of the cameras. The old tube cameras had been replaced

with new solid state cameras during a recent camera system upgrade,

c. Conclusion

The assessment aids system provided excellent assessment of the perimeter detection

zones. The addition of the new solid state cameras was a significant enhancement to

the assessment aids system.

S3 Security and Safeguards Procedures and Implementation

S3.1 Security Event Logs

a. Insoection Scoce

The security program safeguards 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

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security plan. The inspector reviewed the safeguards event logs for the third and fourth

quarters of 1997 and the first quarter of 1998.

b. Observations and Findinas

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The inspector determined that the licensee conformed to the regulatory and license i

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

identifying security events required by regulations. In addition, the licensee used the

information contained in their records and reports to track and trend problem areas.

After identification of problem areas, effective corrective action appeared to have j

resulted in a reduction of reportable safeguards events. During the first week of the l

previous outage, eight reportable events occurred involving vital area door infractions. A I

recent, innovation involving new card readers and audible and visual alarm systems that I

indicated when the person utilizing the door had not adequately followed the

requirements had been installed on high traffic vital area doors since the last outage.

The first week of the current outage had resulted in only one reportable door event.

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c. Conclusion

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l An excellent records and reporting system was in place for reporting safeguards events.  ;

S6 Security Organization and Administration l

S6.1 Security Oraanization

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a. Insoection Scope

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The security organization was inspected to determine compliance with the requirements

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plan.

b. Observations and Findinas

The security force consisted of adequate numbers of armed uniformed officers to meet

the plan requirements. The licensee had sufficient security force personnel to meet

contingencies. Morale appeared to be good. The officers appeared to be capable of

performing any assigned tasks. During the inspection, the licensee was in an outage.

c. Conclusion

The licensee has a good security organization capable of meeting security and

contingency plan requirements.

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V. Management Meetings

X1 Exit Meeting Summary

The inspector presented the inspection results to members of licensee management

at the conclusion of the inspection on March 27,1998. Mr. Don Alps, plant security

manager stated that TU Electric would review, and change as appropriate, plant

procedures to ensure that unsearched hazardous material will be searched within the

vital or protected areas. The licensee acknowledged the findings presented.

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ATTACHMENT

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l' PARTIAL LIST OF PERSONS CONTACTED

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! Licensee

C. L. Terry, Group Vice President

M. Blevins, Plant Manager -

D. R. Alps, Security Manager

J. Ardizzoni, Admin Security Supervisor

l J. M. Ayres, Plant Support Overview Manager

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B. Bird, Plant Support Manager

J. Braun, Security Coordinator

J. B. Britt, Corporate Security -

D. Davis, Nuclear Oversight Division Manager

l N. Harris, Licensing Engineer

T. Hope, Regulatory Compliance Manager

D. Kay, Radiation Protection Manager -

M. Marciniak, SMART Team 1 - Security

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

P. Passulugo, System Manager

R. Walker, Regulatory Affairs Manager

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Contractor

B. Bordeker, Security Test Group Supervisor

W. Cravey, Training Security Coordinator

K. Hayes, Burns Security Chief

M. Millsap, Training Supervisor

A. Wooldridge, Security Shift Supervisor

NRC

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INSPECTION PROCEDURES USED

IP 81700 Physical Security Program for Power Reactors

ITEMS OPENED AND CLOSED

Ooened

50-445;-446/9811-01 NCV inadequate Search For Explosives / Incendiary Devices

50-445;-446/9811-02 IFl Search of Hazardous Cargo

50-445;-446/9811-03 .IFl Review of Corrective Action For HALON Activation

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Closed

50-445;-446/9811-01 NCV inadequate Search For Explosives / Incendiary Devices

LIST OF DOCUMENTS REVIEWED

Station Procedure STA-308, Revision 7, Protection of Unclassified Safeguards information

Security Instruction / Procedure 4.0, Revision 4, Compensatory and Contingency Instructions

Security Procedure SEC-304, Revision 10, Vehicle and Material Control

Security lastruction/ Procedure 3.9, Revision 3, Material Inspection Building

Security Instruction / Procedure 3.2, Revision 12, Access Control

Security Procedure SEC-302, Revision 11, Personnel identification, Key Card, Badge issuance,

and Access Qontrol

Safeguards Event Logs, Third and Fourth Quarters of 1997 and First Quarter of 1998

Security Field Reports 0301-98,0262-98, and 0134-98