IR 05000528/1986007

Forwards Partially Deleted Criteria Used in Evaluating Three of Six Violations Noted in Physical Security Insp Repts 50-528/86-07 & 50-529/86-06 on 860211-0313

ML20205M620
Person / Time
Site:	Palo Verde
Issue date:	04/17/1986
From:	Andrea Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Axelrad J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20205M477	List: IA-86-329, Forwards Security Insp History for Aug 1983 - Mar 1986. Numerous Deficiency/Violations & Followup Items Identified, Including Failure of Licensee Security Mgt to Properly Rept Security Events to NRC IA-86-363, Partially Deleted Notice of Violation & Proposed Imposition of Civil Penalties in Amount of $100,000 Due to Security Violations IR 05000528/1986007 IR 05000528/1986014 ML20205M474 ML20205M510 ML20205M566 ML20205M580 ML20205M675 ML20205M810
References
FOIA-86-329, FOIA-86-363, FOIA-86-A-175 NUDOCS 8704020442
Download: ML20205M620 (4)

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[ [' ....,,]o,, UNITED STATES

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,8 NUCLEAR REGULATORY COMMISSION ".

e a REGION V T"6 teso MARIA LANE.SulTE 21o e.... VtALNUT CnE E N. CALIFORNIA 94Ses

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.APR 171986 MEMORANDUM F04,

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Jane A. Axelrad. Director Enforcement Staff IE

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A. Johnson, Enforcement Coordinator, Region V *

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SUBJECT!

PALOPENALTT CIVIL VERDE NUCLEAR GENERATING STATION ~ PROPOSED The enclosed documentis l

• are submitted for your review and approval in accordance withiqtC Enforcement Polic .<.

From February 11 - March 13, 1986 Region V conducted a routine physical security and inspection at Palo Verde Nuclear Generating Station (PVNGS), Units 1 Efforts during this onsite inspection (followed by in-office review of Security Incident Reports) determined six violations described herewith as two severity level III and four level IV violation violations has multiple example Each of these level III These six., violations, collectively demonstrate the licensee's failure to correct"and properly report to the NRC previously identified problem Additionally, these violations represent a lack of effectiveness on the part of the licensee in fully implementing and maintaining the provisions of their NRC approved the overall Physical security programSecurity at PVNG Plan, and their lack of effective management of the Notice these problemof Violation area and Proposed Imposition of Civil Penalty, identifiesOur letter

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Enclosure these violations. 1 to'this memorandum outlines Region V's evaluation of three of

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Upon discovery of these problems, the licensee instituted timely measure compensatory adequate. All licensee actions regarding compensatory measures appeared Considering the multiple lixamples of each violation, together with the relatively short period of time the licensee has operated their security program, it is recommended that the base civil penalty of $50,000 per each level III violation not be increase During the enforcement conference on April 10, 1986, the licensee representatives indicated that, with the exception of the violation identified in paragraph report was accurate. !!B of the inspection report, the information contained in this'

Based upon licensee comments and supporting documentation, the violation identified in paragraph 11B of the inspection .,

report has not been included in the proposed Notice of Violatio vill be followed up during the next routine security inspection. The item

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0704020442 070327 bMP -175 PDR

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. -2 If you have any quest s, please do not hesitate to cal .'

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A. Johnson - *

Enforcement Coordinator .

Enclosures: '. Evaluation of three violation .

Letter to licensee with Notice of Violation and Proposed Imposition of Civil Penalty 3. Inspection Rep. ort 50-528/86-07 and 50-529/86-06

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ec w/encisoures J. Lieberman. ELD Regional Enforcement Coordinators RI, RII, RIII and RIV

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i . Enclosure 1

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l . Evaluation of Violations

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The following criteria was used.in, evaluating three of the six violations contained in'Pa.lo .. Verde Inspection Report 50-528/86-07 and 50-529/86-06.

1 _ Paragraph 11A (pages 11 and 12 of inspection report).

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This level III violation identified the fact that on three separate occasions (involving

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i the protected area, could have gained entrance to these vital areas. One i one occasion, an NRC inspector, authorized access only to the protected j area was admitted

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in one of these vital areas.

' Barrier were Element Inadequate. The doors at the vital areas barriers Monitoring El'ement Inadequate. The autNrized opening of the doors

at the vital area barriers would not ha'e caused an alar Response Element Adequate. Sufficient security response personnel were on duty Parndraoh 6B (pages 6 and 7 of inspection report). This level III violation respond toidentified the fact that the accurity organization failed to

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I l ... rva uatAon ut tis enroe e cmenta etermined tne to owing.

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_ Barrier Element Adequate. The vital area barrier perforced as designed.

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. Monitorine Element

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. '. Paragraph 8A (page 9 of inspection report). This paragraph identified a

level IV violation involving three inadequate vital area barriers. Each of thesir:three areas were

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sed on our o servations and pnysical ettorts we elleve it wou e a

,barring extremely inadequacies difficult and unlikely that an adversary would exploit these */

severity I .

For these reasons we have cited the problem as a

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