IR 05000155/1997006

Insp Rept 50-155/97-06 on 970428-0502.No Violations Noted. Major Areas Inspected:Review of Vehicles Barrier Sys,Audits & Self Assessment,Testing,Maint,Security Contingency Capability & Protected Area Detection

ML20141J825
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	05/23/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20141J812	List: IR 05000155/1997006 ML20141J808
References
50-155-97-06, 50-155-97-6, NUDOCS 9705280237
Download: ML20141J825 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION 111

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Docket No: '50-155  ;

License No: DPR-06 j

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l Report No: 50-155/97006(DRS)  !

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l Licensee: Consumers Power Company i

Facility: Big Rock Point Nuclear Power Plant Location: 10269 U.S. 31 North Charlevoix, MI 49720 Dates: April 28 - May 2,1997 Inspector: Gary L. Pirtle, Physical Security inspector l

Approved by: James R.- Creed, Ch!af, Plant Support Branch 1 1 Division of Reactor Safety  :

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I-l 9705280237 970523 PDR ADOCK 05000155 #

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EXECUT VE SUMMARY Big Rock Point Nuclear Power Plant j NRC Inspection Report 50-155/97006 l

This announced inspection included a review of the Vehicle Barrier System. Temporary I instruction 2515/132 " Malevolent Use of Vehicles at Nuclear Power Plants" was used for inspection guidance. The features and structures that form the Vehicle Barrier System (VBS) met the design characteristics established by the NRC. Additional areas reviewed  !

included: Audits and Self Assessment: Testing, Maintenance, and Compensatory 1 Measures: Protected Area Detection: Training and Qualification: Alarm Stations: Security Contingency Capability; and followup on previous inspection findings. The inspection findings were as noted below:

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• One example of a failure to maintain an adequate barrier between the protected area and a vital area was reviewed. (Section S2.1) l l

• Some weaknesses in procedures relating to the VBS were identified and the ,

continuing need to further evaluate and analyze the plant protection strategy 1

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were also identified. (Sections S8.1.b.(3)(a) and S1.1).

• Positive observations were noted pertaining to: maintenance support; force-on-force training; self-assessment efforts: security force performance since January 1997: and observed training classes for newly hired security personne l i

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Renort Details l

S1 Conduct of Security and Safeguards Activities i i

S1.1 Evaluation of Security Continaency Trainino '

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. Insoection Scoon (81700)

i The inspector reviewed the security force's contingency training, equipment, and )

facilities. Extensive interviews were held with the security supervisor responsible ,

for the tsaining pertaining to the outside hostile force threa I l i l Observations and Findinos  !

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Extensive effort has been expended by the security force to assure an adequate response to security related contingencies that the security force may be required ]

to counter. Contingency equipment required by the security plans was available l

and functional. Between M. arch 1996 and March 1997, approximately 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> of j

contractor evaluated contingency training was completed. Additionctly, in j September 1996, approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> of contingency related weapons training ;

was completed. Also during 1996, approximately 316 hours0.00366 days <br />0.0878 hours <br />5.224868e-4 weeks <br />1.20238e-4 months <br /> of force-on-force  !

l contingency drill and exercise training was completed for the security force .

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l The security protection strategy for the plant was recently evaluated and revised ;

l (number of target sets reduced). The new protection strategy requires review and ;

j- concurrence with the Operations Department and, if valid, the security staff need to ;

re-analyze deployment positions for response force personnel and revise the force- )

on-force information and deployment manual for training purposes.- Completion of i these actions will be monitored as an inspection Followup item (50-155/97006-01).

.. Conclusions Extensive training has been conducted within the past year for force-on-force contingencies. The revised security protection strategy for the plant requires

' followup actions to validate the accuracy of the strategy and revise training material as necessary. Procedural guidance and training was excellent for the appropriate L contingencie ;

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! S2 Status of Security Facilities and Equipment l

S Effectiveness of Security Eauioment j l insoection Scone (81700)

The inspector reviewed the condition of security equipment and facilities required

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by the' security plan. The equipment observed included, but was not limited to, l search equipment, intrusion alarm equipment, alarm assessment equipment, and i equipment within the security alarm stations. Facilities observed included the Main i Access Facility and Security Alarm Station i l

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.. _ Observations and Findinas i

Maintenance support for security equipment was generally very good and compensatory measures were seldom required for excessive periods of tim Equipment failures requiring compensatory measures were generally repaired within two days. The security staff effectively monitored the status of pending work orders and was aware of equipment performance trend The Big Rock Point security plan requires access to vital areas to be positively controlled. Contrary to this requirement, on April 16,1997, the licensee discovered an opening that could allow access from the protected area to a vital area which was not controlled. A security officer, monitoring work activities near the area, happened to notice a maintenance worker reach through the opening. His observation led to the identification of the barrier problem. Immediate compensatory measures were in place at the time the violation was detecte However, the opening had existed undetected by the licensee for several year This was a hard to reach passage that was not discovered during previous barrier upgrades. Corrective actions included a walkdown of the immediate area to discover any further degradations of the vital area barrier (none were discovered)

and the opening was adequately repaired. A Condition Report (No. BRP-97-0249)

was prepared and the incident was logged in the security events log. The root cause was determined to be less than adequate design of the existing vital area barrier. This licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-155/97006-02). Conclusions Security equipment observed during the inspection was operable and functioned as designed. Maintenance support for security equipment was generally very good and compensatory measures were seldom needed. A licensee identified non-cited violation was noted because an opening in the barrier between the protected area and vital area was not positively controlle S3 Security and Safeguards Procedures and Documentation Insoection Scone (81700)

The inspector reviewed selected procedures pertaining to the areas inspected and also reviewed appropriate logs, records, and other document Observations and Findinas Except as noted in Section S8.1.b(3)(a), procedures reviewed were well written and adequately described the tasks to be performed. The procedures were routinely reviewed and were changed when new work practices were implemented. Security related records, logs, and other documents reviewed were accurat ._ . . . _ . _ _ _ _ _ _ _ _ _ _ . _ _-

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. Conclusions 1

Security procedures and records reviewed were adequat ,

S4 Security and Safeguards Staff Knowledge and Performance l Insoection Scone (81700)

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The inspector toured various security posts and observed performance of duties by I security staff. Security event logs and other records pertaining to security force ;

performance were also reviewed.

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l Personnel observed on post and interviewed were very knowledgeable of the

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procedure requirements applicable to their duties. Security forms required by procedures were reviewed and found to be properly completed. Alarms stations l and on-duty security supervisors were wellinformed of ongoing security activities I

and provided effective oversight of those activitie '

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Review of security event logs showed very good performance by the security force i since the beginning of the year (1997). Only two security-related incidents since !

January 1997 rose to the level of being logged as security events.

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l Security officers and supervisors were very knowledgeable of duty responsibilities l and no deficiencies were noted during post visits and interviews. Security force '

performance was very good and consisten S5 Security and Safeguards Staff Training and Qualification Insoection Scone Approximately four hours of classroom training for newly hired security force personnel was observed. The background investigation screening files for the newly hired personnel were reviewed. Training records for approximately 10 personnel completing requalification training were also reviewed.

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Training classes observed were conducted in an effective manner. Lesson objectives were clearly identified and lesson plans were followed. Personnel

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receiving the training were encouraged to ask questions and participated actively in l the training effort. Interviews with personnel attending the training (4) showed that the personnel believed the training was effective, interesting, and adequately

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balanced between classroom and on-the-job training sessions. All of the personnel I had prior military experience and considered the training received equally as

! effective as the security training courses they had received in the military.

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t Reviewed background investigation files for the newly hired personnel showed that the personnel had fingerprint cards submitted to the NRC prior to receiving training on subjects containing safeguards information, as required by 10 CFR 73.5 Required consent forms were completed prior to initiation of the background investigation elements or initiation of psychological evaluation. The investigation files in some cases were pending completion, but documentation within the files was accurate, with one exception. The consent form for administration of psychological testing and evaluation had different dates for the date the test was I administered and the date the testing was proctored. The records showed that the I testing date was April 9,1997, but the proctor signed on April 7,1997, as the date the testing was completed. Followup on this issue disclosed that the  ;

psychological testing date was April 9,1997 and the date entered by the person *

proctoring the testing (April 7,1997) was a simple logging error. The security staff ,

agreed to prepara a memorandum for file for inclusion in each of the investigation j files to explain the reason for the difference in date No deficiencies were noted in training files reviewed for requalification training purpose Conclusions Observed training classes were well conducted. Background investigation screening files were accurate with one exception for certification of psychological f testing dates which was resolved before the close of the inspection. Reviewed I requalification training files were accurate and complet S7 Quality Assurance in Security and Safeguards Activiths Insoection Scone (81700)

The inspector reviewed the most recent audit report of the security program and other documents and programs used by the security department for problem identification and correctio !

b. Observations and Findinos The inspector reviewed the most recent Nuclear Performance Assessment Department (NPAD) audit of the security program (Report PA-96-15). The audit l was conducted between June 3 7,1996. The audit results concluded that the i security program was adequately and effectively implemented. No program deficiencies were noted and some strengths were identified. The scope of the audit ;

was adequate and the audit results were adequately documente !

The security staff developed other methods to assess performance and identify

, potential problems. Assessment categories included: security personnel errors; I contingency drills; random X-ray operation evaluations; individual performance ,

I evaluations and other categories. The methodologies used offered flexibility to I l quickly address problem areas that had been identified as requiring additional l

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. . Conclusions  !

Self-assessment efforts were effective and offered flexibilit f S8 Miscellaneous Security and Safeguard issues S8.1 Temoorarv instruction 2515/132. " Malevolent Use of Vehicles at Nuclear Power Plants". Insoection Scone rTH515/132)

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Areas examined included the licensee's provisions for land vehicle control measures to protect agai1st the malevolent use of a land vehicle and to determine compliance l with regulator'r and licenses commitment Observationn and Findinos (1) Vehicle Barrier System The inspector found that the features and structures that form the Vehicle i Barrier System (VBS) met the design characteristics established by the NR The vehicle barrier components and the location of the barrier were as described in the summary description of the VBS (required by 10 CFR 73.55(c)(9)(i)) submitted by the licensee to the NR A visual walkdown performed by the inspector confirmed that the type of vehicle barrier described in the VBS summary description had been installed and that the barrier was continuous. No significant signs of barrier damage were noted during the walkdown of the VBS. The inspector also confirmed that the active barrier (gate) had manufacturer's certification that the barrier would meet or exceed the maximum parameters of the design basis vehicle l threa {

(2) Bomb Blast Analysis inspector field observations of standoff distances were consistent with those i documented in the summary description. The basis for the blast analysis consisted of an onsite visit by two NRC Headquarters personnel and a representative of the Corps of Engineers from the Omaha, Nebraska Distric The onsite visit confirmed the safe standoff distances for equipment required l to maintain safe shutdown of the plant. The onsite evaluation results were

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documented in a trip report dated December 1,1995. The trip report was submitted to the NRC on February 23,1996, as an attachment to the summary description required by 10 CFR 73.55 (c)(9)(i). Three actual measurements were completed. They confirmad that the minimum standoff distances (as documented in the trip report), or greater distances, were l achieved by the VBS.

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I The licensee defined criteria for maintenance, surveillance, and compensating for the VBS in appropriate procedures.1The procedures were -

well written and detailed, except as noted in (a) below. A memorandum from the Operations Manager to the Property Protection Supervisor stated existing off normal proceduros, emergency operating procedures, the site

! emergency plan and security implomontino procedures adequately covered l 3 loss of equipment contingencies.

L l During review of security procedures, the following weaknesses were noted i

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and will be monitored as an Inspection Followup item (50-155/97006-03). )

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No criteria or guidance existed to identify what VBS degradations !

c were to be logged or reported to the NRC in accordance with 10 CFR j i 73.7 i

• The procedure for VBS compensatory measures stated that a vehicle !

may be used to compensate for an ineffective vehicle barrie l However, the procedure did not require the vehicle to be of sufficient l, size and mass to act as an effective barrier for the design basis threat

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vehicl i t l l * The procedure for compensatory measures incorrectly stated that a security officer with a contingency weapon could act as a compensatory measure for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for passive eruf active ineffective vehicle barriers. NEl Document 96-01,(which the licensee has committed to for compensatory measures) states that a security l officer with a contingency weapon can compensate for up to 72 l hours only for active barriers (e.g. gates). Conclusion The licensee's program for land vehicle control measures met regulatory requirements and licensee commitments. The VBS program was consistent with the summary description submitted to the NRC. Components were identified in NUREG/CR-6190 or the licensee's engineering analyses, and appropriate procedures had been developed and implemented. An Inspection followup item was noted for 3 sorne procedure weaknesses in reference to the VB S8.2 (Closed) Insoection Followuo item (50-155/96004-02): Several procedure weaknesses were noted. Procedure CAC No. 7, " Access Authorization Program for Company /Noncompany Employees," Section 3.1, Attachment 2 incorrectly defined the scope of the appeal process. The procedure only addressed challenges to i l personal history information which may result in denied unescorted access

, authorization. However, the appeal process was intended to apply when, for any l reason, unescorted access was denied "for-cause" or under unfavorable conditions.

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Procedure CAC No. 7, " Access Authorization Program for Company /Noncompany

[ Employees," Section 17.1.1 made " ascertaining" of activities, after absence from a

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l .O l behavior observation program for more than 30 days, a permissive action (access ,

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"may" be denied). Such ascertaining of activities is required regardless of whether '

the access authorization is denied or not, even if the unescorted access was t terminated under favorable conditions.-  :

Both the general employee training manual (page 3) and the fitness-for-duty (FFD)  !

policy incorrectly stated that, if an employee was required to participate in an employee assistance service (EAS), unescorted access authorization would be '

denied until the EAS treatment was completed. The actual practice (which  !

conforms with 10 CFR Part 26) was that treatment need only be initiated before  ;

l reinstatement of unescorted access authorization could be considere :

Arrest reporting requirements, identified in the access authorization procedure and -(

on the background investigation consent forms, were different from the arrest  !

i reporting requirements identified in the general employee training material. The  !

i licensee stated that the arrest reporting requirements (report all arrests) identified in '

the procedure and on the consent form were the correct reporting requirement !

During this inspection, the inspector confirmed by interviews and document review  ;

that the above procedure weaknesses were correcto i S8.3 (Closedl Insnection Followuo item (50-155/96004-03h An access denial case file l was incomplete.- One of three case files reviewed did not contain documentation to ,

j show that the individual was advised of the reason for their access authorization l denial and of their right to appeal that decisio l

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The Human Resources Director stated that the individual was verbally advised of the reason for the access denial and of the right to appeal. To maintain adequate documentation, that individual was advised of the right to appeal the access l

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authorization denial decision within 10 days of receipt of a letter dated May 9, 1996.

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During this inspection, the inspector confirmed that the access denial case file i

contained adequate documentation to show that the individual involved was advised of the reason for the unescorted access denial decision and the individual's l

right to appeal that decision. The individual did not request an appeal.

j S8.4 A discovery of a licensee operating its facility in a manner contrary to the Updated l

Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that compared plant practices, procedures, and/or parameters to the UFSAR descriptions. The inspector verified that the wording in Section 13.6 of the Final Hazard Summary Report was consistent with observed plant practices, procedures, and/or parameters within the areas inspecte X1 Exit Meeting Summary i

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

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the conclusion of the onsite inspection on May 2,1997. The licensee acknowledged the findings presented, i-

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The inspector asked the licensee whether any materials examined or inspection findings -l discussed during the exit meeting should be considered as proprietary or safeguards information. No safeguards information or proprietary information was identified.

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O PARTIAL LIST OF PERSONS CONTACTED Licensee: *

R. Addy, Plant Manager S. Beachum, Systems and Project Engineering Manager i G. Boss, Operations Manager G. Johnson, Senior Engineer S. Lajoice, Chief, Contract Security, Burns International Security Services, In )

B. Rabideau, Senior Property Protection Operations Supervisor  !

M. Van Alst, Property Protection Supervisor l

G. Withrow, Plant Safety and Licensing Director  :

E. Zienert, Human Services Director

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I R. Leemon, Senior Resident inspector, NRC Region fil INSPECTION PROCEDURES USED Tl 2515/132 " Malevolent Use of Vehicles at Nuclear Power Plants" issued January 18,1996 IP 81700 Physical Security Program For Power Reactors

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IP 92904 Followup - Plant Support l

ITEMS OPENED, CLOSED AND DISCUSSED Opened 50-155/97006-01 IFl Site Security Protection Strategy Required Evaluation And Revision l

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50-155/97006-02 NCV insecure Pathway From The Protected Area To The Vital Area l 50-155/97006-03 IFl Some Weaknesses Were Noted in Procedures Relating To The l Vehicle Barrier System Closed 50-155/96004-02 IFl Procedure Weaknesses For Access Authorization Program 50-155/96004-03 IFl Access Denial Case File Did Not Have Adequate Documentation

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50-155/97006-03 NCV Insecure Pathway From The Protected Area To The Vital Area

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I LIST OF ACRONYMS USED t

IFl Inspection Followup Item NCV Non-Cited Violation UFSAR Updated Facility Safety Analysis Report '

URI Unresolved item l VBS Vehicle Barrier System PARTIAL LISTING OF DOCUMENTS REVIEWED Submittal of Vehicle Barrier System Summary Description (Executive Summary) with j Attachments, dated February 23,1995 '

l Certificate of Conformance for the Model TT212 Series Cable Beam Barrier System, undated, from Delta Scientific Corporation i incident Report Checklists from January 1 through April 29,1997 Security Event Logs from July 1,1996 through April 20,1997 i

Security Systems Maintenance Log Weekly Testing Forms from January 1 through  !

April 28,1997 I

( Maintenance Request Forms from July 1,1996 through April 25,1997

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Work Requests / Work Orders from July 1,1996 through April 25,1997

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Engineering Analysis Work Sheet for movement of 3'X 3'X 20' Blocks During Impact, dated February 12,1996 Engineering Analysis Work Sheet For Jersey Barrier Installation (Project 974-06), dated l February 12,1996 i Soil Logs (log of hand auger boring) For Soil Foundations for the Vehicle Barrier System, dated September 22,1995 Self Assessr.ient Performance Evaluations, January 1 through April 1,1997 Self Assessment Trend Analysis for January through December 1996 and January 1 through March 31,1997 l

Internal Memorandum From Operations Manager to Property Protection Supervisor, dated January 6,1997 (Addressed review and adequacy of existing procedures to cope with equipment loss).

Letter from D. Nebuda (Corp of Engineers, Omaha District) to Francis Young (NRC);

l Subject: Trip Report to Big Rock Point, dated December 1,1994 i

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