05000261/LER-2017-002

LER-2017-002, Plant Vital Area Security Vulnerability Discovered Without Compensatory Security Measures

H. B. Robinson Steam Electric Plant, Unit No. 2
Event date:	10-24-2017
Report date:	12-14-2017
2612017002R00 - NRC Website

LER 17-002-00 for H.B. Robinson, Unit 2, Regarding Plant Vital Area Security Vulnerability Discovered Without Compensatory Security Measures

ML17349A025
Person / Time
Site:	Robinson
Issue date:	12/14/2017
From:	Kapopoulos E J Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/17-0077 LER 17-002-00
Download: ML17349A025 (5)

comments regarding burden estimate to the Information Services Branch (T-2 F43), U.S. Nuclear Regulatory Commission, Washington, DC 20555.0001, or by e-mail to used to impose an information collection does not dispiay a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

2017 H. B. Robinson Steam Electric Plant, Unit No. 2 261

3. LER NUMBER

00 05000-

BACKGROUND

Pursuant to the provisions of 10 CFR 73.71(b)(1), licensees shall report the discovery of uncompensated vulnerability in a safeguard system that could allow unauthorized or undetected access to a vital area within one hour of discovery. This report is being submitted in accordance with the requirements of 10 CFR 73.71(d), which refers to Appendix G, "Reportable Safeguards Events," Section 1(c), requiring a written report to be submitted within 60 days. The event described below meets this reporting criteria.

EVENT DESCRIPTION

On October 24, 2017, with H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2) in Mode 1 at 100 percent power, a security officer conducting security rounds discovered a breach in the south wall of the 4kV switchgear room, a vital area (VA). This breach exceeded the threshold for requiring compensatory security measures to be implemented. No compensatory security measures were in place for the breach at the time of discovery. The officer immediately contacted security supervision and all work was stopped. Compensatory security measures were promptly implemented. At approximately 1350 EDT on October 24, 2017, it was determined that a breach in a VA boundary existed due to the size of the opening, which could have potentially allowed undetected access in the area. An immediate (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) notification to the NRC (EN No. 53034) was made on October 24, 2017.

On April 27, 2017 an Engineering Change (EC) related to the Transmission Upgrade Project was approved. This EC contains eight sub-ECs; particularly, a sub-EC to install structural supports [SPT] for the electrical bus duct [BDUC] and raceways [TY] from the 4kV disconnect [DISC] switches to the new switchgear building 469. Security performed a review of the main EC but not the sub-EC that called for the opening to be cut, which did not indicate a need for additional security measures. This sub-EC was not required by the EC process to be reviewed by other organizations; including Security.

On October 20, 2017, workers began cutting the opening in the south wall of the 4kV switchgear room with no compensatory security measures in place. The opening was then shielded with a metal cover plate and sealed to prevent water intrusion. On October 24, 2017, the shield was removed prior to installing the support through the opening. When the cover was removed, a security officer conducting security rounds discovered the breach in the south wall at the ceiling near the top of the erected scaffolding. The officer notified security supervision immediately. Work was stopped, a new shield was installed over the opening, and security supervision implemented required compensatory measures.

CAUSAL FACTORS

The cause of the event was determined to be the removal of the requirement for planners to include instruction for the craft to contact security when breaching the VA, including the threshold for breach size that requires additional security compensatory measures.

CORRECTIVE ACTIONS

Immediate Upon discovery of the breach by security, work was immediately stopped and compensatory measures were promptly implemented. A search of the area was conducted by security, which revealed no evidence of unauthorized materials or workers in the area.

comments regarding burden estimate to the Information Services Branch (T-2 F43), U.S. Nuclear Regulatory Commission, Washington. DC 20555.0001, or by e-mail to Infocollects.Resource©nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, used to mpose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

2017 H. B. Robinson Steam Electric Plant, Unit No. 2 261

3. LER NUMBER

002 00 05000- CORRECTIVE ACTIONS (continued) Completed 1. Current work order tasks were reviewed to ensure the work planning group requires craft workers to contact security for any required compensatory measures related to barrier work.

2. Guidance was added to the work-planning procedure to notify security prior to creating openings of any size in structures or barriers into the owner-controlled area, protected area, or VA.

SAFETY ANALYSIS

There were no safety consequences from this event in that unauthorized intrusion into the 4kV switchgear room VA did not occur. During the period without compensatory security measures in place, no evidence of contraband or sabotage was found within the 4kV switchgear room. This event has low safety significance because there was no undetected access to the VA nor was there any evidence of contraband, tampering or sabotage in the VA. In the event that the equipment in the 4kV switchgear room was compromised, the plant could still be safely shut down via power from Emergency Buses [BU] E-1 and E-2.

ADDITIONAL INFORMATION

Additional information required for security events. (Item number from Regulatory Guide 5.62, "Reporting of Safeguard Events," provided below):

5. Type of Security Force Onsite: Proprietary 6. Number and Type of Personnel Involved: One Security Officer 7. Method of Discovery: Security Officer Observation 8. Procedural Errors Involved: None 11. Local, State, or Federal law enforcement agencies contacted: None 12. Description of media interest and press release: None 13. Similar Events: None Energy Industry Identification System (EIIS) codes are identified in the Text within brackets [ ]