IR 05000528/1986007

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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  Arizona Public Service icon.png
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:
References
FOIA-86-329, FOIA-86-363, FOIA-86-A-175 NUDOCS 8704020442
Download: ML20205M620 (4)


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UNITED STATES

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b NUCLEAR REGULATORY COMMISSION a

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REGION V

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VtALNUT CnE E N. CALIFORNIA 94Ses

.APR 171986

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MEMORANDUM F04, Jane A. Axelrad. Director Enforcement Staff IE

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FRON:

A. Johnson, Enforcement Coordinator, Region V

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SUBJECT!

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PALO VERDE NUCLEAR GENERATING STATION ~ PROPOSED CIVIL PENALTT The enclosed documentis *are submitted for your review and approval in accordance withiqtC Enforcement Policy.

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From February 11 - March 13, 1986 Region V conducted a routine physical security inspection at Palo Verde Nuclear Generating Station (PVNGS), Units 1 and 2.

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 violations.

Each of these level III violations has multiple examples.

These six., violations, collectively demonstrate the licensee's failure to correct"and properly report to the NRC previously identified problems.

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 Physical Security Plan, and their lack of effective management of the overall security program at PVNGS.

the Notice of Violation and Proposed Imposition of Civil Penalty, identifiesOur lette these problem areas.

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

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these violations.

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Upon discovery of these problems, the licensee instituted timely compensatory measures.

All licensee actions regarding compensatory measures appeared adequate.

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 increased.

During the enforcement conference on April 10, 1986, the licensee representatives indicated that, with the exception of the violation identified in paragraph !!B of the inspection report, the information contained in this'

report was accurate.

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

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report has not been included in the proposed Notice of Violation.

vill be followed up during the next routine security inspection.

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0704020442 070327 bMP-175 PDR

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If you have any quest s, please do not hesitate to call.

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A. Johnson

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Enforcement Coordinator

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Enclosures:

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Evaluation of three violations.

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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

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contained in'Pa.lo Verde Inspection Report 50-528/86-07 and 50-529/86-06.

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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 one occasion, an NRC inspector, authorized access only to the protected i

area was admitted in one of these vital areas.

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Barrier Element Inadequate. The doors at the vital areas barriers were b.

Monitoring El'ement Inadequate. The autNrized opening of the doors

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at the vital area barriers would not ha'e caused an alarm.

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Response Element Adequate. Sufficient security response personnel were on duty Parndraoh 6B (pages 6 and 7 of inspection report).

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This level III

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violation identified the fact that the accurity organization failed to respond to

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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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3.

Paragraph 8A (page 9 of inspection report).

This paragraph identified a level IV violation involving three inadequate vital area barriers.

of thesir:three areas were Each sed on our o servations and pnysical ettorts we

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',barring inadequacies For these reasons we have cited the problem as a

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severity IV.

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