IR 05000454/1998007

Insp Repts 50-454/98-07 & 50-455/98-07 on 980217-25.No Violations Noted.Major Areas Inspected:Various Aspects of Physical Security Program

ML20216G996
Person / Time
Site:	Byron
Issue date:	03/13/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20216G953	List: IR 05000454/1998007 ML20216G948
References
50-454-98-07, 50-454-98-7, 50-455-98-07, 50-455-98-7, NUDOCS 9803200152
Download: ML20216G996 (11)

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! U. S. NUCLEAR REGULATORY COMMISSION t

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REGIONlli

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Docket Nos: 50-454;50-455 License Nos: NPF-37; NPF-66 l

l Report Nos: 50-454/98007(DRS); 50-455/98007(DRS)

i Licensee: Commonwealth Edison Company l

Facility: Byron Nuclear Generating Plant, Unit 1 and 2 q Location: 4448 North German Church Road Byron, IL 61010-9750 Dates: February 17-25,1998

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inspector: G. Pirtle, Physical Security Inspector I

Approved by: James R. Creed, Chief, Plant Support Branch 1

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9903200152 990313 PDR

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0 ADOCK 05000454 PDR i

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l EXECUTIVE SUMMARY Byron Nuclear Generation Plant NRC Inspection Reports 50-454/98007; 50-455/98007 This announced inspection included various aspects of the physical security program. The inspection was completed onsite by one region-based physical security inspection over a two week perio *

Security equipment observed durinig the inspection functioned as desgined, and compensatory measures for equipment were seldom required. Although the security equipment testing program was generally very strong, some security-related component capabilities were not being tested periodically. Some security equipment performance {

has been erratic. (S2)

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Security procedures were generally well-written. Records reviewed were accurate and !

complete. A procedure for controlling a certain category (details considered Safeguards information) of equipment entering the protected was lacking. (S3)

Security force members were knowledgeable of post requirements and performed their duties in an adequate manner. Security shift supervisors were very effective in monitoring security activities. A recent increase in security force personnel errors was identifed. (S4)

Self-assessment activities were multi-faceted and involved licensee and contractor personnel. (S7)

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Report Details IV. Plant Suonort 82 Status of Security Facilities and Equipmsnt Insoection Scone (81700)

The inspector reviewed the condition of security equipment and facilities required by the security plan. The equipment observed included, but was not limited to, search equipment, intrusion alarm equipment, alarm assessment equipment, and equipment within the secondary alarm station (SAS) and Main Access Facility (MAF). Observations and Findinas Search equipment at the MAF and equipment at the alarm stations functioned as designed. Observed security force personnel were appropriately equipped with operable, required communication equipment and weapon The security equipment testing program was generally very strong and at times exceeded security plan commitments, especially for the perimeter alarm system. An l observation was noted, however, that some security components were not tested on a l recurring basis. Specifically, some control box tamper alarms and cardreader tamper l alarms were not tested. These alarms are within areas that are manned continuously by security force personnel. Additionally, two locking mechanisms within the MAF were not routinely tested to determine their operability. The inspector requested a test be conducted to verify the locking mechanisms were functional. The locking mechanisms functioned as designe Maintenance support for security equipment appeared to be timely, especially when security compensatory measures were required. Security door maintenance was consistent also. However, when compared to other security doors, two specific doors were causing the vast majority of loggable security events for security door Additionally, several zones of the perimeter alarm system have recently had erratic performance, supposedly due to weather conditions (exact zones and nature of the performance is considered Safeguards Information and exempt from public disclosure).

During the inspector's initial check of the secondary alarm station,10 zones of a surveillance system were inactivated due to excessive alarms. A modification completed on the surveillance equipment during the visit seemed to stabilize performanc The inspector was briefed by the security staff and attended a meeting pertaining to plans and progress for significantly changing and upgrading the defensive strategy for the plant. The changes include barrier upgrades and different deployment of security response force personnel. The defense strategy modification is planned to be completed by mid-October 199 .

I Conclusi.Qas

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Security equipment observed during the inspection functioned as designed, and compensatory measures for equipment failure were seldom required. Although the security equipment testing program was generally very strong, an observation was noted pertaining to some security-related component capabilities not being tested on a periodic basis. Recently, some security system equipment performance has been j errati S3 Security and Safeguards Procedures and Documentation a. Insoection Scooe (81700)

The inspector reviewed selected procedures pertaining to the areas inspected and also reviewed appropriate logs, records, and other documents portaining to security operations observe b. Observations and Findinas Procedures reviewed were generally well-written. An Inspection Followup item was !

identified pertaining to controlling some types of equipment entering the protected area. l During this inspection it was noted that processing of some equipment entering the j protected area and referred to as " tools", rather than vehicles, was not addressed in security procedures or training. An example of such " tools" included riding lawnmower Such equipment observed during the inspection was being searched and logged into the protected area. Authorization for need of entry into the protected area was not verified or addressed. Procedural guidance for processing such equipment into the protected area was not addressed in existing security procedures or training material. The lack of l procedure guidance limits security officers' knowledge of management's expectations for processing and controlling such equipment. This issue will be monitored as an Inspection Followup Item (IFl 50-454/98007-01(DRS); 50-455/98007-01(DRS)).

Records reviewed were complete and accurate. Proper controls were observed for !

protecting records and procedures that were designated as Safeguards Information in accordance with 10 CFR 73.2 .

c. Conclusions Security procedures reviewed were generally well-written. Records reviewed were accurate and complete. A procedure for controlling a certain category of equipment entering the protected area was neede S4 Security and Safeguards Staff Knowledge and Performance l a. Insoection Scoce (81700)

The inspector toured various security posts, including the secondary alarm station and Main Access Facility. The inspector also observed performance of duties to determlne

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I whether the security officers were knowledgeable of post requirements. Security event

! logs and other records pertaining to security force performance were also reviewe ' Observations and Findinas

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Excellent vehicle search and control measures were observed. The searches were complete, thorough, and in accordance with the appropriate procedures, except as noted earlier for equipment referred to as" tools."

No deficiencies were noted in security force personnel's performance during post checks. Security Shift Supervisors were very knowledgeable of ongoing security activities and the status of security equipment, personnel, and activities requiring security support. The supervisors provided effective oversight of ongoing security activitie ~

An inspection followup item was noted in r'eference to the performance trends for the security force. Within the past six months (August 1997 through January 1998) 16 security plan deviations have occurred, and seven of the 16 have been errors by ,

security force personnel, in many of the cases by supervisors. The security plan deviations were not outage-related, and they were not identified as a result of an audit during that time period. Within the preceding six months (February 1997 through July l 1997) only three security plan deviations occurred. This potential adverse trend was l

identified by the inspector, using data that had been available to contractor and licensee 6 security managers. This area will be reviewed during future inspections to determine

whether the short term trend has been corrected, or if the recent performance trend is a

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percussor to an adverse trend in performance by the security forc (IFl 50-454/98007-02(DRS); 50-455/98007-02(DRS)).

Conclusions I Security force members were knowledgeable of post requirements and performed their duties in an adequate manner. Security shift supervisors were very effective in monitoring security activities. A recont increase in security force personnel errors was identifie S7 Quality Assurance in Security and Safeguards Activities insoection Scooe (81700)

The inspector reviewed self-initiated performance evaluations conducted by security staff and personnel (licensee and contractor) and the Quality Verification Departmen Observation and Findinas

The self-assessment efforts continued to be varied and effective. Since the previous i

inspection in July 1997, the security contractor had completed a four-day audit of security functions, and the security contractor has completed at least three security self

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l assessments. Additionally, a security corporate-led audit of the security program

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(referred to as an "A" team audit) is scheduled to begin March 2,1998. The Site Quality i Verification Department also completed and documented several observations of security activities during their field observations. All self-assessment findings were documented and were being addressed by the security staff.

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Nineteen security contractor personnel completed Human Error Reduction Training l

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conducted by the licensee in 1997. Additionally, all of the licensee's security staff completed similar training in 1996. One security staff member had also completed Root Cause Analysis training in 1996.-

Conclusions

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Self-assessment activities were multi-faceted and involved licensee and contractor personnel. Many licensee and security contractor security staff had recently received training in Human Error Reduction.

! S8 . Miscellaneous Security and Safeguards issues (92904)

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S . (Closed) Unresolved item (50-454/96006-07

50-455/96006-07): Ascertaining of l l activities was not being completed for personnel issued a security badge and away from

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a behavior observation program for extended periods of time (up to 60 days). This item will be closed as an inspection-related item and tracked through our system used to monitor resolution of unresolved items. Resolution of this issue will be addressed by l

separate correspondenc S8.2 - (Closed) Unresolved item (50-454/96010-01: 50-455/96010-01): Weak security badge issue and control procedures which may allow a single individual to fabricate and enter a security badge into the system without the knowledge and authorization of another person. NRC review concluded that the security badge control measures were a poor practice, ieuwever, the immediate actions taken by the licensee's security staff were adequate to remedy the badge issue and control proces S8.3 (Closed) Insoection Followuo item (50-454/96010-02: 50-455/96010-02): Need to revise the security plan to show the correct location of some segments of the vehicle barrier system (VBS). The Byron Security Plan was revised to show the correct location of all segments of the VBS.

L S8.4 (Ocen) Insoection Followuo item (50-454/97011-03: 50-455/97011-03): A procedure l

had not been prepared addressing exempting certain vehicles (C vans) from search upon entry into the protected area when certain security measures had been implemented. A Corporate Nuclear Security Guideline (No.107 " Maintaining Search Integrity Between Stations)" was prepared in February 1998. However, a security plan change has not been completed to address this issue. The adequacy of such measures will be reviewed when the security plan change is submitted in accordance with 10 CFR l

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50.54(p) or 50.90.

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S8.5 (Closed) Violation (50-454/97020-03: 50-455/97022-01): A contractor visitor was left unescorted within the protected area for up to 30 minutes. The licensee's corrective actions identified in Security Event Report Number 97-S01, dated September 15,1997, I

were adequate to prevent recurrence of similiar incidents during the Steam Generator l Replacement Project outag S8.6 (Closed) Security Event Reoort 95-SO2. dated October 3.1995: This Security Event Report (SER) pertained to no compensatory measures being implemented for a failed i

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security alarm for a turnstile within the Main Access Facility. The alarm was not fully i functional because a tamper alarm for the tumstile had not been cleared. The corrective j actions identified in the SER were implemente S8.7 (Closed) Security Event Reoort 96-S01. dated June 8.1996. and SER Revisioni. dated {

Qecember 06.1997: This SER and revision pertained to apparent falsification of background information during security background investigations for personnel being {

considered for unescorted access to the protected area. The licensee's corporate security staff have completed their inquiry into this matter and have advised the NRC of ,

their findings and conclusions. This issue is closed as a specific item for the Byron Station. The NRC is reviewing the licensee's investigation result X1 Exit Meeting Summary The inspector presented the onsite inspection results to members of the licensee management at the conclusion of the onsite inspection on February 25,1998. The licensee acknowledged the findings presented. The inspector asked the licensee whether any inspection findings discussed during the exit meeting should be considered as proprietary or safeguards information. No proprietary or safeguards information was identifie !

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l PARTIAL LIST OF PERSONS CONTACTED Licensee:

! J. Bowers, Assistant Station Security Administrator D. Brindle, Regulatory Assurance Supervisor R. Cassidy, Assistant Station Security Administrator R. Colglazier, NRC Coordinator

' J. Gee, Administration / Training Coordinator, BISSI K. Kofron, Station Manager M. Mareth, Force Manager, BISSI S. Meyers, Maintenance Administrator, BISSI S. Mills, Station Security Administrator D. Minor, Operations Supervisor, BISSI R. Morley, Nuclear Security Administrator NBC N. Hilton, Resident inspector, NRC Region lil INSPECTION PROCEDURES USED IP 81700 Physical Security Program For Power Reactors IP 92904 Followup - Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-454/98007-01 IFl Procedure Needs to be Developed For Certain Types of Equipment That Enters the Protected Area 50-455/98007-01 IFl Procedure Needs to be Developed For Certain Types cf Equipment That Enters the Protected Area i

50-454/98007-02 IFl Possible Adverse Trend Noted in Security Force Performance 50-455/98007-02 IFl Possible Adverse Trend Noted in Security Force Performance ClGLSftd 504 54/96006-07 URI Licensee Personnel Activities Not Ascertained After Extended Absence From a Behavior Observation Program 50-455/96006-07 URl Licensee Personnel Activities Not Ascertained After Extended Absence From a Behavior Observation Program

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50-454/96010-01 URI Security Badge issue Process Had Weak Controls to i- Prevent Circumventing the System.

l 50-455/96010-01 . URI Security Badge issue Process Had Weak Controls to Prevent Circumventing the System.

! 50-454/96010-02 IFl Security Plan Revision Required to Show Correct Location

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of the Vehicle Barrier Syste /96010-02 IFl Security Plan Revision Required to Show Correct Location of the Vehicle Barrier System 50-454/97020-03 VIO Visitor Within the Protected Area Without an Escort for '

Extended Period of Time 50-455/97020-03 VIO Visitor Within the Protected Area Without an Escort for Extended Period of Time -

50-454/95-S02 SER No Compensatory Measures Were implemented For a Defective Alarm Capability

.50-454/96-S O1 SER Apparent Falsification of Security Backround Investigation Information Discussed 50-454/97011-03 IFl Security Measures Used to Exempt Vehicles From Search at Licensee's Sites Are Not Addressed by Procedure or Security Plan 50-455/97011-03 IFl Security Measures Used to Exempt Vehciles From Search at Licensee's Sites Are Not Addressed by Procedure or Security Plan LIST OF ACRONYMS USED-BISSI Bums International Security Services, In IFl Inspection Followup item MAF Main Access Facility URI Unresolved item -

-SAS Secondary Alarm Station SER Security Event Report VIO Violation i

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l PARTIAL LISTING OF DOCUMENTS REVIEWED l

Byron Station Security Performance Trending Reports from August 1997 through January 1998 Corporate Nuclear Security Guideline No.1," Reporting and Recording of Security Events",

i Revision 12, dated February 1998 Corporate Nuclear Security Guideline No.107, " Maintaining Search Integrity Between

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Stations", Revision 0, dated February 1998 Security Event Report 95-S02, "No Compensatory Measures For Failed Security Alarm", dated October 3,1995 Security Event Report 96-S0101, " Apparent Falsification of Background information", dated December 6,1997 Security Event Report 97-S01, " Unescorted Visitor in Protected Area", dated September 15, 1997 Log of Security Maintenance Requests covering the period between September 30,1997, and February 23,1998 i

Borg-Wamer Protective Services Quality Assurance Audit Report No. RSBU 98-02 for period l covering January 12-16,1998 l

BISSI interoffice Memorandum, Subject " Ammo", dated February 25,1998 (Memorandum addressed characteristics of handgun ammunition used for training and ammunition used on duty)

Procedure BIS IS-2, " Annual Security Microwave Maintenance Inspection Surveillance",

l Revision 4, dated June 26,1987 BISSI Security Self Assessment No. 97-04, " Training and Qualification File Audit", dated l September 15,1997 BISSI Security Self Assessment No. 97-05, "GSEP PROCEDURES", dated April 16,1997 BISSI Security Self Assessment No. 97-06," Appendix B Range Requalification", dated December 15,1997 BISSI Security Self Assessment No. 98-01," Security Procedures", dated January 19-21,1998 Annual Perimeter Alarm Test Documentation for tests conducted in August 1997, and Quarterly Perimeter Alarm Test Documentation for tests conducted in October 1997 Procedure OBHS IS-3, "Perifield Zones Performance Check", Revision 1, Approved June 6, 1995, with printout of zone test dates for the perimeter alarm system for 1995 through 1997

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o h Temporary Designated Vehicle List, dated February 13,1998

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Designated Vehicle List, dated February 13,1998 Minutes of Security Defensive Upgrade Modification Team Meeting, dated Feb'ruary 10,1998 L Procedure BSP 200-1, " Access Control *, Revision 8, dated January 5,1996 i Procedure BAP 900-4, . Vehicle Access Control" , Revision 10, dated May 11,1994

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! : Post Order 11, " Vehicle Search Officer", Revision 15, April 16,1997 l l Post Order 40, ." Station to Station Shipments", Revision 0, dated February 3,1998 -

Loggable Security Events for period between December 1,1997, through February 15,1998

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