4.0 Summary of Major DCISC Review Topics, 17th Annual Report - July 1, 2006 thru June 30, 2007
4.18 Plant Security
Note: because of the sensitive nature of nuclear plant security, only limited information can be presented in this public report.
4.18.1 Overview and Previous Activities
The DCISC has previously reviewed plant security in Fact-finding meetings by reviewing security performance measures and by reviewing plant audits and NRC inspections of the Security Program. Additionally, there have been overviews of the Security Program in DCISC public meetings.
The DCISC reviews and NRC inspects these measures. The DCISC monitors and assesses current security measures and expected modifications to determine whether there may be negative effects on plant safety during normal operation and maintenance and emergency response during off-normal conditions.
The DCISC reviewed the following security topics during the previous reporting period:
- Security Updates at Three DCISC Fact-finding Meetings
- Security Updates at Three DCISC Public Meetings
- NRC Inspections of DCPP Security Program
- NRC Information Notice 2005-20, Electrical Distribution System Failures Affecting Security Equipment
- Security Force-on-Force Drill
In the last reporting period the DCISC concluded that PG&E appears to have met or exceeded the NRC requirements for physical security protection. The DCISC is concerned about the effects of security barriers on the continuing effectiveness of station functions (i.e., operations, maintenance & emergency response). DCPP has taken this into account in implementing new security measures; however, continuing diligence is warranted.
4.18.2 Current Period Activities
Because of the September 11, 2001 terrorist attacks, nuclear plant security has been looked at more closely and has been augmented by special NRC orders. The DCISC has increased its review of security and performed the following reviews of the DCPP Security Program during the current reporting period. The DCISC has received a security update as one of its three public meetings and at three Fact-finding meetings during the current reporting period as shown below.
Security Updates at DCISC Fact-finding Meetings
The DCISC Team met with the Security Services Manager on the following Fact-finding meetings to receive updates on the augmented DCPP Security Program:
- October 25-26, 2006 (Volume II, Exhibit D.3, Section 3.4)
- December 14-15, 2006 (Volume II, Exhibit D.4, Section 3.5)
- May 30-31, 2007 (Volume II, Exhibit D.9, Sections 3.2 and 3.3)
Member Peterson and Consultant Wardell, holding valid security clearances at DCPP, met with the Security organization at these Fact-finding meeting to review security matters.
Plant Security Update – October 25-26, 2006 Fact-finding Meeting
The DCISC Fact-finding Team met with Bob Zimkowski, Security Manager; Sean Dienhart, Security System Projects and Compliance; and Jeff Hartley, Security Operations Manager, at the October 25-26, 2006 Fact-finding Meeting (Volume II, Exhibit D.3, Section 3.4) for an update on DCPP Security.
Along with DCPP, Security is working at being “the best” in the industry and is working on identifying performance gaps to close to meet that goal. These gaps include personnel safety, human performance, equipment issues, facilities, work/life balance, and cost. Plans are being developed to improve performance in these areas and to move from “White” to “Green” performance in the Quality Performance Assessment Report (QPAR).
Major plans and activities include the following:
Project and Outage Support
- Preparing for Outage 1R14 in April 2007
- Security work for the Independent Spent Fuel Storage Installation (ISFSI) to be completed by mid-2007 (casks will not be loaded until after Outage 2R14 in 2008).
- Security support for installation of the new spent fuel pool racks
- Security support for the Steam Generator Replacement Project (SGRP)
- The Old Generator Storage Facility construction will occur from February to October 2007
- Preparing for Outage 2R14 in February 2008
Regulatory Performance and Security Procedures
- All Security procedures but one have been upgraded for latest round of periodic reviews
- ISFSI Appendix to the Security Plan scheduled for completion mid-2007
Security System/Locks & Keys
- Lock core changes being implemented
- Working on new badge packets/lanyards
- Two-man rule imposed for changes to security system
- Maintenance Improvements
- Maintenance backlog reduced by half since June 2006
- New Security Maintenance Supervisor
- Preventive Maintenance being prepared
- Planning on an Asset Management Program in 2007/2008
- New software installed in explosives detectors to reduce false alarms
- Owner Controlled Area (OCA) cameras strategy changes made to strengthen OCA System
Oversight and Planning
- Force-on-Force Preparation Project (hardening buildings, new cameras, additional fencing and razor wire, additional lighting, etc.)
- New Security Training Building to be completed in 2007
- Range Training Tower to be completed in early 2007
- Latest Design Basis Threat Order actions completed (mostly vehicle barriers)
The DCISC has reviewed Security equipment issues in previous Fact-finding meetings. Most of the equipment problems have been with search trains, cameras and detection equipment. Security is taking the following actions to assure equipment performance and reliability:
- More preventive maintenance
- Hiring a vendor to assist with equipment management and preventive maintenance scheduling
- Requesting Engineering support for equipment
Security has already seen the monthly Action Request backlog for equipment corrective action reduced from approximately 150 to 55-60.
Recent NRC inspections and Quality Verification assessments have found no significant issues. QPAR rates Security as having “White” performance and improving.
DCPP Security appeared satisfactory with a “White” Quality Performance Assessment Report rating. Security has goals and plans for achieving Quality Performance Assessment Report (QPAR) “Green” and of becoming the best in the industry.
Security Update – December 14-15, 2006 Fact-finding Meeting
The DCISC Fact-finding Team met with Bob Waltos, Manager of Emergency Services, at the December 14-15, 2006 Fact-finding Meeting (Volume II, Exhibit D.5, Section 3.5) to review DCPP’s response to NRC’s February 25, 2002 & June 20, 2006 Orders Section B.5.b which dealt with loss of large areas of the plant due to large fires or explosions which are generally beyond design basis events.
The NRC has issued the following security orders and requests since the September 11, 2001 terrorist attack:
- February 25, 2002 - Interim Safeguards and Security
- January 7, 2003 - Access Authorization
- April 29, 2003 - Design Basis Threat
- April 29, 2003 - Training Enhancements
- April 29, 2003 - Fitness-for-Duty (FFD)
- July 10, 2003 - FFD Order Relaxation, Enforcement Discretion, Extension of Time to Respond
- October 23, 2003 - FFD Order Relaxation
- December 2, 2005 – Demand for Information
- March 20, 2006 - Updated Adversary Characteristic
- June 20, 2006 -Order for Licenses for Operating Power Reactors
- June 21, 2006 – Site-Specific Request for Details of Phase 2 Spent Fuel Mitigation Strategies
- October 26, 2006 – Mitigation Strategy Assessment and Closure Process for Phases 1, 2, and 3
NRC has met with DCPP regarding Section B.5.b to review how DCPP would respond to (beyond design basis) losses of large areas of the plant due to fires or explosions and what features DCPP incorporates to help mitigate such losses and maintain control of the plant in a safe condition. Like other nuclear plants, DCPP had responded to NRC’s December 2, 2005 Demand for Information outlining its Section B.5.b strategy. Following industry responses, NRC issued its June 20, 2006 order requiring key radiological protection mitigation strategies and corresponding changes to DCPP’s Site Security Plan, Safeguards Contingency Plan, Guard Training and Qualification Plan, and Emergency Plan.
The Nuclear Energy Institute (NEI) has coordinated industry actions and responses and released its NEI 06-12, “B.5.b Phases 2 & 3 Submittal Guideline, Revision 2.” DCPP will respond to NRC in January 2007 referencing the NEI document, which NRC has approved and recommends, and committing to implement the strategies. NRC plans to issue a Safety Evaluation Report in April 2007 on the proposed changes. DCPP will have until the end of 2007 to implement the strategies. There are eleven strategies, including internal and external Spent Fuel Pool (SFP) strategies and Reactor and Containment strategies. The changes include development of a new set of procedures, Extensive Damage Mitigation Guidelines (EDMGs) which will be similar to existing Severe Accident Management Guidelines (SAMGs). A project team will develop the EDMGs using the Design Change Process to ensure that all affected plant organizations/functions have a chance to review them to assure plant access, control and safety. DCPP has developed a plan to complete all actions and is preparing a presentation to the Plant Health Committee for funding approval.
DCPP is developing a January 2007 submittal to respond to requirements in NRC’s June 20, 2006 Security Order Section B.5.b (loss of large areas of the plant due to fires or explosions) and a plan to implement the order’s requirements. Implementation is to be completed by the end of 2007. It appears that DCPP is taking the correct steps to satisfy the NRC requirements.
May 30-31, 2007 Fact-finding Meeting
DCPP Response & Implementation to NRC Security Order B.5.b
The DCISC Fact-finding Team met with Terry Grebel, Strategic Project Manager, and Mike Kennedy, Special Projects Shift Manager for B.5.b, at the May 30-31, 2007 Fact-finding Meeting (Volume II, Exhibit D.9, Section 3.2) to review DCPP’s progress in implementing NRC’s February 25, 2002 & June 20, 2006 Orders Section B.5.b which dealt with loss of large areas of the plant due to large fires or explosions beyond design basis events.
DCPP has answered NRC’s questions about its strategies and approach for mitigation of large fires and explosions, has met with NRC at DCPP, and submitted to NRC on January 11, 2007 its “Response Providing Information Regarding Implementation Details for the Phase 2 and Phase 3 Mitigation Strategies.” There are 15 specific strategies centered on providing additional sources of water to the Spent Fuel Pool and Steam Generator, fire control and mitigation, and establishing Reactor Coolant System cooling.
NRC had additional questions which DCPP answered in a May 8, 2007 submittal. NRC’s Safety Evaluation Report accepting DCPP’s actions is expected in June 2007. DCPP committed to having applicable procedures (Extensive Damage Mitigation Guidelines), equipment and training available for the above by December 31, 2007. All procedure and plant changes will be made using the normal DCPP Design/Procedure Change Process assuring cross-functional review by affected disciplines. This process will assure that the changes do not have any significant adverse impact on plant safety. The DCISC Fact-finding Team believes DCPP’s responses actions are appropriate.
DCPP has responded appropriately and acceptably to NRC’s June 20, 2006 Security Order Section B.5.b (loss of large areas of the plant due to fires or explosions). All equipment and procedure changes and related training will be completed by December 31, 2007. All procedure and design changes will be reviewed using standard plant change procedures to assure that the changes have no significant adverse impact on plant safety. The DCISC will follow up to review the implementation in early 2008.
Plant Security Update
The DCISC Fact-finding Team met with Bob Zimkowski, Security Manager; Sean Dienhart, Security System Projects and Compliance; and John Huddle, Security Shift Supervisor, at the May 30-31, 2007 Fact-finding Meeting (Volume II, Exhibit D.9, Section 3.3) for an update on DCPP Security.
DCPP Security had the following activities it was planning or working:
- NRC proposed restrictions on work hours (Security had implemented these hours)
- NRC proposed rulemaking on access controls
- Final Independent Spent Fuel Storage Installation (ISFSI) security equipment and controls (NRC will inspect this 30 days prior to actual implementation.)
- Force-on-Force (FoF) drills
- Upcoming Steam Generator Replacement Project (SGRP) outage security
- Security is finally getting a (contractor) System Engineer for its systems to develop an equipment inventory, prioritize preventive maintenance, etc.
Security achieved Green status in the Fourth Quarter 2006 DCPP Quality Performance Assessment Report (QPAR) and has maintained it, although QPAR standards are being raised. All NRC security performance indicators are Green. NRC had no violations or findings in its 2006 security inspection. In a recent inspection NRC had one unresolved item on vehicle control, one Green non-cited violation (NCV) for Safeguards document control, and one Green NCV for key/lock control. The NCVs appeared to be minor.
DCPP Security appears to be effectively meeting plant and NRC requirements. As in previous reviews, the DCISC concludes that the plant activities related to plant security are properly reviewed for potential safety impacts, and that current plant security measures do not have any significant adverse impact on plant safety.
Security Updates at DCISC Public Meetings
The DCISC received public updates on security at one of its three Public Meetings as described below; however, there is only a limited amount of security-related information which may be discussed in a public forum.
Update on Security at the June 14, 2007 DCISC Public Meeting.
DCPP continued to evaluate the manner in which it deploys its defensive strategy, both as to physical security issues and to optimizing training and operational experience. Additional detection and delay enhancements were being installed and equipment has been upgraded to provide improved tools for the plant security officers. DCPP is evaluating major revisions to 10 Code of Federal Regulations (CFR) 73.55, based on a multitude of compensatory measures directives from the NRC.
DCPP is revisiting the NRC’s proposed work hour restrictions relative to its security force. The work hour restrictions have, for example, affected DCPP’s opportunity to callback security personnel for overtime and he confirmed the work hour restrictions apply to other DCPP organizations as well as Security. The work hour restriction affects mainly overtime and should not affect the routine hours put in by the station’s operators; however, although rules during outage and non-outage periods differ, operation during refueling outages could be affected by the new work hour restrictions proposed by the NRC.
For long-standing issues in maintaining its physical assets, primarily electronic systems a contractor has been hired to review security equipment issues.
Quality Verification Security Audit
The DCPP Quality Verification Department performed the 2006 Security Program Audit to verify adequacy and implementation of the DCPP Security Plan. The Audit Team included two industry peers. The audit results showed that the DCPP Security Plan, including Training and Qualification and Contingency Plans, and the Protective Strategy, meet the NRC regulations and orders and are effectively implemented. The effective implementation of these Plans assures DCPP’s capabilities for responding to the Design Basis Threat (DBT) and preventing radiological sabotage or the theft of Special Nuclear Material.
The Audit Team identified five quality problems, one non-quality problem, and two recommendations but did not consider any of the identified problems to be significant; however, documentation weaknesses are a continuing problem and need management attention. The DCISC will follow up on the audit.
NRC Inspections of DCPP Security Program
The NRC inspects nuclear plant security on a regular basis and has stepped up its inspections since September 11, 2001. The NRC Revised Reactor Oversight Process (Section 3.4) included performance indicators for physical plant protection. These are now withheld from public view, so no report is possible.
Although NRC inspections occurred during the July 1, 2006 – June 30, 2007 reporting period, none of the inspections reports had been received. The DCISC will report on those inspections in its next report. The NRC published its Annual Security Assessment Letter for DCPP on March 2, 2007. The Letter reported the following:
With respect to physical protection and security, Diablo Canyon Power Plant, Units 1 and 2, were operated in a manner that preserved public health and safety, promoted the common defense and security, and fully met the cornerstone objective. Plant performance for the fourth quarter, as well as for the first three quarters of the assessment cycle, was within the Licensee Response column of the NRC’s security action matrix because all inspection findings had very low security significance (Green. Therefore, we will conduct security baseline and temporary instruction inspections at your facility though September 30, 2008.
4.18.3 Conclusions and Recommendations
- Conclusions:
- PG&E appears to have met or exceeded the NRC requirements for physical security protection. The DCISC continues to review the effects of security barriers on the continuing effectiveness of station functions (i.e., operations, maintenance & emergency response).
- Recommendations: None