ML073550590
| ML073550590 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/21/2007 |
| From: | Darrell Roberts Division of Reactor Safety I |
| To: | Pardee C Exelon Generation Co |
| References | |
| EA-07-296 IR-07-405 | |
| Download: ML073550590 (21) | |
See also: IR 05000277/2007405
Text
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
December 21, 2007
Mr. Charles G. Pardee
Chief Nuclear Officer and Senior Vice President
Exelon Generation Company, LLC
4300 Winfield Rd
Warrenville, IL 60555
SUBJECT: NRC AUGMENTED INSPECTION TEAM (AIT) FOLLOW-UP REPORT
05000277/2007405 AND 05000278/2007405; PRELIMINARY GREATER THAN
GREEN FINDING - PEACH BOTTOM ATOMIC POWER STATION
Dear Mr. Pardee:
On November 9, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed an AIT
follow-up inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. This
inspection was conducted to provide additional assessment and determine the significance of
issues identified by an Augmented Inspection Team (AIT) in September 2007 regarding security
officer inattentiveness. The enclosed inspection report documents the AIT follow-up inspection
results, which were discussed at the public exit meeting on December 3, 2007, with Mr. Joseph
Grimes and other members of your staff. Following the inspection exit, the NRC responded to
questions from those stakeholders in attendance. It should be noted that the findings
documented in this report do not represent new or different issues or incidents of
inattentiveness other than those identified during the September 2007 AIT inspection.
EXEMPT FROM PUBLIC DISCLOSURE Attachment C Contains Sensitive
May be exempt from public release under the Freedom of Unclassified Non-Safeguards Information.
Information Act (5 U.S.C. 552)
Upon separation, the cover letter,
Exemption number: ___5____ enclosure, and Attachments A and B are
Nuclear Regulatory Commission review required before decontrolled.
public release.
James Trapp, RI/DRS/PSB1/RA by D. Roberts for/_____
Name and organization of person making determination.
Date of determination: _____12/20/2007___
OFFICIAL USE ONLY - SECURITY RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
C. Pardee 2
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The team reviewed selected procedures and records, observed activities, and interviewed
personnel.
As initially described in the NRC Augmented Inspection Team report dated November 5, 2007,
the enclosed report documents one finding regarding inattentive security officers and an
ineffective behavior observation program that was preliminarily determined to be greater than
Green, as determined by the Physical Protection Significance Determination Process (i.e., a
finding of at least low to moderate security significance). The Significance Determination
Process analysis contains security sensitive information and will not be made publicly available
(Attachment C). When notified of this issue by the NRC, compensatory measures were put in
place by Exelon that addressed this finding while longer term corrective actions were being
implemented. In accordance with Inspection Manual Chapter 0305, Operating Reactor
Assessment Program this finding has cross-cutting aspects in the areas of Human
Performance and Safety Conscious Work Environment.
As mentioned previously, this inspection was conducted as a follow-up to an earlier AIT
inspection that took place from September 21-28, 2007. Following the earlier inspection, the
NRC took several actions to ensure that the overall effectiveness of the security program at
Peach Bottom was not compromised as a result of the incidents of inattentiveness. These
actions included issuing a Confirmatory Action Letter (CAL) to Exelon to ensure that immediate
and long term corrective actions were being implemented at the site. The NRC supplemented
its own routine inspection effort by increasing its monitoring while Exelon transitioned to a
proprietary security force at Peach Bottom in November 2007. On November 28, 2007, the
NRCs Executive Director for Operations approved a Reactor Oversight Process (ROP)
Deviation Memorandum allowing the NRC Region I staff to increase its inspection and oversight
of Peach Bottom beyond that which would normally be prescribed by the ROP. These actions
ensured that adequate NRC oversight was provided to address the performance deficiencies
described in this report while the NRCs significance determination and enforcement process
were being completed. The NRC has made the public aware of these actions by holding public
inspection exit meetings and making related documents publicly available in ADAMS.
Before we make a final significance decision regarding this preliminary greater than Green
finding, we are providing you an opportunity (1) to attend a Regulatory Conference where you
can present to the NRC your perspective on the facts and assumptions the NRC used to arrive
at the finding and assess its significance, or (2) submit your position on the finding to the NRC
in writing. If you request a Regulatory Conference, it should be held within 30 days of the
receipt of this letter and we encourage you to submit supporting documentation at least one
week prior to the conference in an effort to make the conference more efficient and effective. If
a Regulatory Conference is held, it will be closed for public observation because it involves
security sensitive information. If you decide to submit only a written response, such submittal
should be sent to the NRC within 30 days of the receipt of this letter. If you decline a
Regulatory Conference and choose not to submit a written response, the NRC will proceed with
its final significance determination.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
C. Pardee 3
Please contact Mr. James Trapp of my staff at (610) 337- 5186 within 10 business days of the
date of your receipt of this letter to notify the NRC of your intentions. If we have not heard from
you within 10 days, we will continue with our significance determination decision. You will be
advised by separate correspondence of the results of our deliberations on this matter and
matters involving future enforcement decisions. In addition, please be advised that the
characterization of the performance issue described in the enclosed inspection report may
change as a result of further NRC review.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and Attachments A (Supplemental Information) and B (Event Chronology) will be
available electronically for public inspection in the NRC Public Document Room or from the
Publicly Available Records (PARS) component of the NRC's document system (ADAMS).
ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the
Public Electronic Reading Room). However, because of the security-related information
contained in Attachment C, and in accordance with 10 CFR 2.390, a copy of Attachment C will
not be available for public inspection.
In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for
your response, if any. This will ensure that your response will not be made publicly available. If
Safeguards Information is necessary to provide an acceptable response, please provide the
level of protection described in 10 CFR 73.21.
Sincerely,
/RA/
Darrell J. Roberts, Deputy Director
Division of Reactor Safety
Docket Nos: 50-277, 50-278
Enclosure: Inspection Report 05000277/2007405 and 05000278/2007405
w/Attachments
Attachments:
(A) Supplemental Information
(B) Event Chronology
Non-Public Attachment:
(C) Physical Protection Significance Determination Process Review Results (Official Use
Only - Security Related Information)
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
C. Pardee 3
Please contact Mr. James Trapp of my staff at (610) 337- 5186 within 10 business days of the
date of your receipt of this letter to notify the NRC of your intentions. If we have not heard from
you within 10 days, we will continue with our significance determination decision. You will be
advised by separate correspondence of the results of our deliberations on this matter and
matters involving future enforcement decisions. In addition, please be advised that the
characterization of the performance issue described in the enclosed inspection report may
change as a result of further NRC review.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and Attachments A (Supplemental Information) and B (Event Chronology) will be
available electronically for public inspection in the NRC Public Document Room or from the
Publicly Available Records (PARS) component of the NRC's document system (ADAMS).
ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the
Public Electronic Reading Room). However, because of the security-related information
contained in Attachment C, and in accordance with 10 CFR 2.390, a copy of Attachment C will
not be available for public inspection.
In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for
your response, if any. This will ensure that your response will not be made publicly available. If
Safeguards Information is necessary to provide an acceptable response, please provide the
level of protection described in 10 CFR 73.21.
Sincerely,
/RA/
Darrell J. Roberts, Deputy Director
Division of Reactor Safety
Docket Nos: 50-277, 50-278
Enclosure: Inspection Report 05000277/2007405 and 05000278/2007405
w/Attachments
Attachments:
(A) Supplemental Information
(B) Event Chronology
Non-Public Attachment:
(C) Physical Protection Significance Determination Process Review Results (Official Use
Only - Security Related Information)
SUNSI Review Complete: dcc (Reviewers Initials)
DOCUMENT NAME:C:\FileNet\ML073550590.wpd ADAMS ACCESSION NO. ML073550590
After declaring this document An Official Agency Record it will/will not be released to the Public.
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy
OFFICE RI/DRP RI/DRS RIV/DRS RI/SRA RI/ORA
NAME BBickett/BAB* DCaron/DCC* JLarsen/Via e-mail* WCook/Via e-mail* RSummers/RJS*
DATE 12/19 /07 12/19 /07 12/13 /07 12/14/07 12/17/07
OFFICE RI/DRP RI/DRS HQ/NSIR RI/OI RI/DRS
NAME Dlew/Via telecon* JTrapp/JMT RCorreia/Via e-mail* EWilson/Via Telecon* DRoberts/DJR
DATE 12/20/07 12/20/07 12/17/07 12/20 /07 12/21/07
OFFICIAL RECORD COPY
- See Previous Concurrence Page
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
C. Pardee 4
cc w/encl; w/Att. C:
J. Kovalchick, Acting Site Security Manager
D. Allard, Director, Dept. Of Environmental Protection, Pennsylvania
S. Pattison, Maryland Department of Environment
J. Powers, Director, Office of Homeland Security, Pennsylvania
A. Lauland, Director, Homeland Security Advisor, Maryland
N. Lowey, U.S. House of Representatives
cc w/encl; w/o Att. C:
Chief Operating Officer, Exelon Generation Company, LLC
Site Vice President, Peach Bottom Atomic Power Station
Plant Manager, Peach Bottom Atomic Power Station
Regulatory Assurance Manager - Peach Bottom
Manager, Financial Control & Co-Owner Affairs
Vice President, Licensing and Regulatory Affairs
Senior Vice President, Mid-Atlantic
Senior Vice President - Operations Support
Director, Licensing and Regulatory Affairs
J. Bradley Fewell, Assistant General Counsel, Exelon Nuclear
Manager Licensing, PBAPS
Director, Training
Correspondence Control Desk
Public Service Commission of Maryland, Engineering Division
Board of Supervisors, Peach Bottom Township
B. Ruth, Council Administrator of Harford County Council
R. Ayers, Harford County Emergency
E. Crist, Harford County Emergency
L. Ploener, Harford County Emergency
R. Brooks, Cecil County
Mr. & Mrs. Dennis Hiebert, Peach Bottom Alliance
TMI - Alert (TMIA)
J. Johnsrud, National Energy Committee, Sierra Club
Mr. & Mrs. Kip Adams
E. Epstein, TMI Alert
R. Fletcher, Department of Environment, Radiological Health Program
R. French, Dir., PA Emergency Management Agency
K. McGinty, Secretary, PA Dept of Environmental Protection
R. Janati, Chief, Nuclear Safety Division (DEP)
B. Mertz, Deputy Director, PA Office of Homeland Security
Lieutenant T. Shannon, PA State Police
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
C. Pardee 5
Distribution w/encl; w/Att. C:
S. Collins, RA
M. Dapas, DRA
D. Lew, DRP
J. Clifford, DRP
G. West, OEDO
H. Chernoff, NRR
J. Lubinski, NRR
P. Bamford, Backup NRR
P. Krohn, DRP
R. Fuhrmeister, DRP
F. Bower, DRP - Sr Resident Inspector
M. Brown, DRP - Resident Inspector
S. Schmidtt - Resident OA
ROPreports@nrc.gov
Region I Docket Room (with concurrences)
R. Correia, NSIR
D. Riffle, NSIR
M. Gamberoni, DRS
D. Roberts, DRS
J. Trapp, DRS
D. Caron, DRS
B. Bickett, DRP
J. Larsen, RIV
J. Willis, NSIR
D. Holody, RI
K. Farrar, RI
R. Urban, RI
C. ODaniell, RI
S. Figueroa, OE
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos: 50-277, 50-278
Report No: 05000277/2007405 and 05000278/2007405
Licensee: Exelon Generation Company, LLC (Exelon)
Facility: Peach Bottom Atomic Power Station, Units 2 and 3
Location: Delta, Pennsylvania
Dates: November 5 - 9, 2007
Inspectors: D. Caron, Senior Physical Security Inspector (Team Leader)
J. Larsen, Senior Physical Security Inspector, Region IV
B. Bickett, Senior Project Engineer
J. Willis, Security Specialist, NSIR
Approved by: Darrell J. Roberts, Deputy Director
Division of Reactor Safety
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Enclosure
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
SUMMARY OF FINDINGS
IR 05000277/2007-405, 05000278/2007-405; 11/05/2007 - 11/09/2007; Peach Bottom Atomic
Power Station (PBAPS), Units 2 and 3; Access Authorization and Protective Strategy
The augmented inspection follow-up was conducted by a team consisting of inspectors from the
NRCs Region I office, Region IV office, and a security specialist from Nuclear Security and
Incident Response (NSIR). One finding with preliminary greater than Green security
significance was identified. The significance of most findings is indicated by their color (Green,
White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination
Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a
severity level after NRC management review. The NRCs program for overseeing the safe
operation of commercial nuclear power reactors is described in NUREG-1649, Reactor
Oversight Process, Revision 4, dated December 2006.
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Physical Protection
- TBD. A preliminary greater than Green finding was identified for failure to
maintain the minimum number of available responders and failure to maintain an
effective behavior observation program (BOP). The licensee implemented
immediate compensatory measures and conducted a root cause analysis that
resulted in additional corrective actions.
This finding is considered more than minor because it is associated with the
Response to Contingency Events and Access Authorization attributes and it
affected the cornerstone objective to provide assurance that the licensees
security system uses a defense-in-depth approach and can protect against (1)
the design basis threat of radiological sabotage from external and internal
threats, and (2) the theft or loss of radiological materials. Specifically, an
inadequate BOP led to inattentive responders. With multiple inattentive response
team members at one time, the licensee was below minimum numbers of
available responders, which increased the potential for degradation in the
protective strategy of the site. Using the Physical Protection Significance
Determination Process (PPSDP), the team determined that the finding was of
greater than very low security significance. The cause of the finding is related to
the cross cutting elements of safety conscious work environment (SCWE)(S.1.a)
and management/supervisory oversight element (H.4.c) of the human
performance cross-cutting area. (Section 3.3)
B. Licensee-Identified Findings
None
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Enclosure
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
REPORT DETAILS
1.0 Inspection Background Information
On September 10, 2007, the NRC was contacted by representatives of WCBS-TV (New
York City), stating that videotapes of inattentive security officers (SOs) at the Peach
Bottom Atomic Power Station (PBAPS) were in their possession. The NRC verbally
informed Exelon management of the information and initiated enhanced oversight of
security activities at Peach Bottom that same day. On September 19, 2007, after
viewing the videos, the NRC determined an augmented inspection team (AIT) was
warranted to gather facts related to these events. On September 21, 2007, an
augmented team inspection was initiated. On September 27, 2007, the NRC issued an
advisory (SA-07-06) to the nuclear industry regarding inattentive security officers and
related fitness for duty and behavior observation issues.
On October 9, 2007, the NRC held a public exit for the AIT inspection. The team
identified that immediate corrective actions were adequate, but also identified additional
areas for follow-up inspection. On October 19, 2007, the NRC issued a confirmatory
action letter (CAL) to ensure immediate compensatory measures were maintained and
to document a schedule for planned long term corrective actions. On October 24, 2007,
the NRC instituted a weekly status call with Exelon to discuss CAL actions and the
status of transitioning from a contract security force to an Exelon force. On November 5,
2007, the AIT inspection report was issued and an AIT follow-up inspection began to
review issues identified by the AIT in detail and assess the significance of any
performance deficiencies. On November 28, 2007, the NRCs Executive Director of
Operations approved a Deviation Memorandum which provided additional NRC
inspection and oversight of Peach Bottom security beyond what would normally be
prescribed by the reactor oversight process.
Attachment B contains the detailed chronology associated with this issue.
2.0 Augmented Inspection Follow-up Objectives (93800)
This inspection was conducted to provide additional NRC review and significance
determination of performance issues identified by the NRC Augmented Inspection Team.
The specifics reviewed by the follow-up inspection team and previously documented in
the AIT inspection report (IR 05000277/278-2007404) were:
- Root cause analysis and extent of condition (Section 3.1)
- Corrective actions for identified security officer concerns (Section 3.2)
- Security officer inattentiveness and extent of condition (Section 3.3)
- Effectiveness of security management and supervisory oversight (Section 3.3)
- Behavioral Observation Program effectiveness (Section 3.3)
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Enclosure
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2
3.0 AIT Follow-up Inspection Team Findings and Observations
3.1 Review of Exelon Root Cause Analysis and Extent of Condition
a. Inspection Scope
The team assessed the adequacy of the licensees initial evaluation of the issue, the
thoroughness of the licensees root cause analyses, and whether the corrective actions
specified were sufficient to prevent recurrence (see Section 3.2). This assessment
included a review of the licensees investigation reports (IR), root cause analyses,
completed and scheduled corrective actions, procedures, additional related documents,
and interviews with key plant personnel.
The team reviewed the methodology and results of Exelons root cause analysis as
documented in the root cause report (IR 673505), Security program degradation due to
inattentiveness. Additionally, the team reviewed the root cause analysis to determine if
Exelon had appropriately identified the extent of condition to ensure that the scope and
station-wide applicability of any performance issues were appropriately evaluated.
b. Findings and Observations
The team found the level of detail of the root cause analysis, including its extent of
condition review, to be thorough and acceptable with a self-critical review of the station
and its management of security. The team concluded that Exelon appropriately
identified the root and contributing causes.
The analyses used several formal systematic processes to identify root and contributing
causes. Per LS-AA-125-1001, Root Cause Analysis Manual, Exelon formed a root
cause team consisting of a Mid-Atlantic corporate manager as the lead, supported by an
Exelon fleet security manager, a PBAPS human performance manager, site regulatory
and licensing personnel, and three external consultants. Time line analysis, cause and
effect analysis, and barrier analysis methodologies were utilized. The root cause team
appropriately evaluated information including past history and industry experience along
with interviews of personnel conducted by Exelons incident investigation team.
3.2 Review of Corrective Actions
a. Inspection Scope
The inspection team reviewed security condition reports, employee concerns program
files, station cultural surveys and Exelons root cause analysis on inattentive security
officers to assess whether the PBAPS adequately identified security adverse conditions,
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Enclosure
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3
including missed opportunities to identify unacceptable SO behavior, prior to being
informed of the videotapes in September 2007.
The team conducted interviews and reviewed corrective actions associated with
previous adverse security conditions to determine whether the actions taken by the
station properly identified and evaluated causes of the problems. The team reviewed
security condition reports for repetitive problems to determine whether previous
corrective actions were effective. The team also reviewed the timeliness of the
implementation of corrective actions and the effectiveness of corrective actions to
preclude recurrence for significant conditions adverse to quality.
b. Findings and Observations
The team concluded that, following September 2007, Exelon has implemented or
developed appropriate corrective actions to prevent recurrence that address the
principle areas of: 1) Exelon management not providing adequate contractual oversight
and leadership; 2) Wackenhut failure to provide adequate management and supervisory
oversight; and, 3) security officer inattentiveness and non-compliance with the BOP
within the PBAPS security organization.
The team also concluded that Exelons Corrective Action Program (CAP), prior to
September 2007, had not been an effective tool in addressing the adverse conditions
and trends which led to SO inattentiveness. The team determined that there were
several missed opportunities in the area of security problem identification and resolution
prior to the inattentive security officer events being made public in September 2007.
The team determined that these opportunities, while not primary causal factors for the
inattentive security officer events, indicated an adverse performance trend in the PBAPS
security organization. The following were examples of these missed opportunities:
1) the results of two safety culture surveys were not properly evaluated for indications of
negative performance trends in the security organization; 2) longstanding environmental
issues in the ready room were not properly evaluated and resolved; and,
3) attentiveness aids for security officers were not properly evaluated in the CAP. The
team concluded that following September 2007, the corrective actions implemented or
planned by Exelon for these CAP shortcomings were appropriate.
Issues involving inadequate corrective actions can be treated as findings in their own
right, however, the above stated examples of ineffective corrective actions and CAP
shortcomings directly contributed to the inattentive security officers and ineffective BOP
performance deficiencies for which a preliminary greater than Green finding is discussed
in Section 3.3 of this report. As such, these contributing causes and related
performance deficiencies were not treated as separate findings.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Enclosure
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4
3.3 Review of Security Officer Inattentiveness and Behavior Observation Program
a. Inspection Scope
The team conducted interviews and observations of the security organization to
determine the overall security program effectiveness and implementation during the time
frame of the inattentive security officer events. The team reviewed the Security Plan and
evaluated PBAPs ability to implement Security Plan requirements. The team performed
walk downs of the sites protective strategy to evaluate the potential effect of degraded
security officer response due to inattentiveness. The team also evaluated critical SO
defensive position response times, for a variety of potential threats, to evaluate the
potential significance of SO inattentiveness on Security Plan effectiveness.
The team reviewed Exelons and Wackenhuts actions preceding September 2007, to
assess the effectiveness of management and supervisory oversight and their
engagement with the station security organization. The team evaluated management
and supervisory inadequacies that may have contributed to the inattentiveness and BOP
performance issues present in the security organization.
The team reviewed implementing procedures for the BOP, the FFD program, and related
training. Interviews were conducted to evaluate the level of understanding of these
programs by the security officers and supervisors. The team reviewed records related to
self reporting fatigue, work hours, deviations from normal work hours, testing for cause,
and Employee Assistance Program utilization.
b. Findings and Observations
Introduction: A self-revealing preliminary greater than Green finding was identified for
failure to maintain the minimum required number of available responders and the
associated failure to maintain an effective behavior observation program.
Description: On four separate occasions (March 12; June 9; June 20; and August 10,
2007), multiple security officers, who were all members of the security response team,
were videotaped while they were inattentive in the security ready room. On March 12,
2007, five officers were inattentive at the same time. The ready room is a location within
the protected area boundary where officers are staged for response functions, while not
conducting security patrols. The officers in the ready room are required to be readily
available to respond and effectively implement their role within the Security Plans
protective strategy.
In addition, the Behavior Observation Program (BOP) was determined to be ineffective.
Security officers are required to self-report to supervision when they feel fatigued and
when they observe others who are fatigued. Although the security officers in the ready
room were in close proximity to each other, only one stated that he reported other
security officers being inattentive. Supervisors who had information regarding
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Enclosure
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5
inattentive security officers failed to take appropriate action, as required by the BOP.
The ineffective implementation of the BOP was directly linked to the events of inattentive
officers. An effective BOP could have mitigated the inattentive officer events.
The teams interviews with a number of security force members identified that security
officers were discouraged from bringing forward safety concerns to supervision. The
security officers stated that they did not raise safety issues, such as these involving
inattentive officers, because they were afraid of an adverse consequence. Based upon
these interview results, the team concluded that an adverse safety conscious work
environment (SCWE) was a contributing cause to the finding.
As discussed in Section 3.2.b above, Exelon and Wackenhut management/supervision
failed to properly evaluate attentiveness aids for officers, failed to adequately address
environmental issues associated with the ready room, failed to conduct adequate and
effective post checks, and failed to ensure effective radio checks were conducted.
Some of these issues were raised during previously conducted security officer surveys,
but no effective action was taken to address these security-officer-identified concerns.
The follow-up team concluded that each of these issues was a contributor to the
inattentiveness events.
The team determined that the licensees failure to maintain the minimum number of
response team members and the associated failure to maintain an effective BOP
constituted a performance deficiency.
Analysis: This performance deficiency is greater than minor because it is associated
with the Physical Protection Cornerstone attributes of Response to Contingency Events
and Access Authorization, and affected the cornerstone objective to provide assurance
that the licensees security system and material control and accountability program use
a defense-in-depth approach and can protect against (1) the design basis threat of
radiological sabotage from external and internal threats, and (2) the theft or loss of
radiological materials. Specifically, an inadequate BOP was a direct contributor to the
inattentive responders. With multiple inattentive response team members at one time,
the minimum numbers of available responders was adversely impacted. This affected
the defense-in-depth strategy and increased the potential for degradation in the
protective strategy for the site.
The team reviewed IMC 0609, Appendix E, Baseline Physical Protection Significance
Determination Process (PPSDP) for Power Reactors, for security findings. Using the
PPSDP, the team determined that the finding was of more than very low security
significance (i.e., preliminary greater than Green). The PPSDP takes into consideration
the security cornerstone key attributes, various levels of defense-in-depth, and
prioritized elements of security programs to determine the significance of findings. The
details of the PPSDP analysis contain sensitive security information and will not be
made publicly available. The analysis is included as a security sensitive attachment to
this report (Attachment C).
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Enclosure
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6
This finding has a cross-cutting aspect in the area of SCWE (S.1.a) because Exelon and
Wackenhut supervision did not encourage the free flow of information related to raising
safety concerns. Security supervisors who had information regarding inattentive officers
did not respond to employee safety concerns in an open, honest, and non-defensive
manner. This finding also has a cross-cutting aspect in the area of human performance
(H.4.c) because Exelon did not ensure that supervisory and management oversight of
security activities supported nuclear safety. The team concluded that, following
notification of the inattentiveness issues by the NRC, Exelons root cause analysis
appropriately identified weaknesses in the stations security management and
supervisory oversight and SCWE.
Enforcement: The enforcement aspects of the security officer inattentiveness and
ineffective BOP issues are still under NRC review. Upon completion of this review,
enforcement action will be considered, consistent with the Enforcement Policy. The
safety significance of this finding is preliminarily greater than Green. (FIN
05000277/278, 2007405-01, Failure to Maintain Minimum Available Responders and an
Effective BOP.)
4.0 Meetings
Exit Meeting Summary
On December 3, 2007, the inspection team presented the inspection results at a public
exit meeting to Mr. Joseph Grimes and other members of the PBAPS staff. Exelon
acknowledged the teams findings.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Enclosure
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A-1
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
J. Grimes Site Vice President
P. Cowan Director, Licensing and Regulatory Affairs
D. Deboer Security Manager
S. Craig Security Operations Supervisor
J. Mallon Licensing Manager
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000277/278-2007405-01 FIN Failure to maintain minimum number
of responders and an effective BOP
(Section 3.3)
LIST OF DOCUMENTS REVIEWED
Procedures
LS-AA-125, Corrective Action Program Procedure, Revision 11
SY-AA-1016, Watchstanding Practices, Revision 0
SY-AA-1016, Watchstanding Practices, Revision 4
SY-AA-1020, Supervisor Post Checks and Post Orders, Revision 0
SY-AA-1020, Supervisor Post Checks and Post Orders, Revision 1
SY-AA-102, Exelons Nuclear Fitness-For-Duty Program, Revision 11
SY-AA-101-130, Security Responsibilities for Station Personnel, Revision 8
SY-AA-101-130, Security Responsibilities for Station Personnel, Revision 9
SY-PB-101-124-1001, Security Control Center Operations, Revision 3
SY-AA-101-126, Duties and Responsibilities of the Station Security Organization,
Revision 5
SY-AA-103-513, Behavioral Observation Program, Revision 6
SY-AA-150-1001, Security Training and Qualification Manual, Revision 3
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
A-2
Miscellaneous
NER NC-07-034, Inattentive Security Officer Investigation Fleet Actions, September 24, 2007
NER NC-06-010, Increased Field Observation and Coaching of the Site Security Force,
Revision 2
SA-07-06, NRC Security Advisory - Security officers inattentive to duty, September 27, 2007
Nuclear Oversight Quarterly Reports, 2005 - 2007
NOSA-PEA-06-02, Security Plan, FFD, and Personnel Access Data System, February 1, 2006
NOSA-PEA-07-03, Security Plan, FFD, and Personnel Access Data System, January 21, 2007
Exelon General Employee Training, FFD Module, Revision 4
Exelons Security Transition Plan, September 24, 2007
Card Reader Transaction History 3/11-12/07 - 6/09/07 - 6/20-21/07 - 8/10/07
Vital Area Patrol Forms Fox 2/3/5/6/7
Drill/Exercise Reports 2006 (4th Qtr) - (2007 1st Qtr-3rd Qtr) (All Teams)
Weekly Work Hour Averages from March 4, 2007 through October 28, 2007
LIST OF ACRONYMS
ADAMS Agency-wide Documents Access and Management System
AIT Augmented Inspection Team
BOP Behavioral Observation Program
CAP Corrective Action Program
CFR Code of Federal Regulations
CR Condition Report
IMC Inspection Manual Chapter
IP Inspection Procedure
NER Nuclear Event Report
NRC Nuclear Regulatory Commission
NSIR Nuclear Security and Incident Response
PARS Publicly Available Records
PBAPS Peach Bottom Atomic Power Station
PPSDP Physical Protection Significance Determination Process
SCWE Safety Conscious Work Environment
SDP Significance Determination Process
SO Security Officer
WNS Wackenhut Nuclear Services
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
B-1
EVENT CHRONOLOGY
- 2004 - PBAPS security power block ready room established to support Security Plan
implementation and provide increased defense-in-depth for NRC Force on Force
exercises.
- April 16, 2006 - NRC Force-on-Force exercise conducted (No findings).
- January 2007 - Wackenhut Corporation issues improvement plan for Safety Conscious
Work Environment (SCWE) improvement actions for its security forces at all sites.
- February 2007 - Security Officer (SO) responsible for video recordings has first
observation of inattentive SOs in the power block ready room but did not record the
observations.
- March 2, 2007 - SY-AA-1016, Revision 4, implemented to add attentiveness tools
based on attentiveness issue experienced at an Exelon plant.
- March 12, 2007 - Five SOs inattentive to duty in the ready room captured by a SOs
personal cell phone. All five SOs are on Security Team No. 1.
- March 27, 2007 - NRC receives concerns involving Peach Bottom SOs that are
inattentive to duty at PBAPS.
- April 2007 - SO shows videotapes of inattentive SOs to a maintenance technician at a
little league ball game. Maintenance technician tells the SO to inform his security
supervisor. The following day the maintenance technician informs his supervisor who
responds that the SOs concern should be brought up to the security supervisor.
- April 2007 - Wackenhut Corporate investigation reveals two separate SO unacceptable
behavior issues received through Wackenhut Safe-2-Say program. In the course of this
investigation, it was determined by Wackenhut that multiple SOs on Team No. 2 were
initially untruthful to investigators and tried to hide and cover-up the events. Several
officers were disciplined for their lack of candor and not reporting a safety concern.
- April 18, 2007 - Plant review committee rejects $150K expense of further renovations to
ready room. PBAPS senior management notified of decision to not fund
improvements.
- April 30, 2007 - NRC provided Exelon management with written referral for concerns
associated with Peach Bottom SOs that were inattentive to duty.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
B-2
- May 30, 2007 - NRC received Exelons response stating the three referred concerns
associated with inattentive SO behavior were not substantiated. Exelon conducted
interviews that did not substantiate the issue. Exelon referenced enhancements in their
response that included radio check improvements and procedure changes to implement
fixed post checks twice a shift. Exelon also referenced 15 minute stand-ups on back
shifts and randomly on day shift.
- June 9, 2007 - Three SOs inattentive on-duty in the ready room captured by a SOs
personal video device (ARCOS camera).
- Mid June 2007 - SO informs a field supervisor of inattentive guards on duty that were
videotaped. Field supervisor told lead supervisor of this information including names of
guards who were inattentive to duty on video.
to stop bringing video devices into the plants protected area.
- July 19, 2007 - Security force transitions to new ready room that is considered larger
and a more moderate temperature.
- June 20, 2007 - One SO inattentive on duty in the ready room captured by a SOs
personal cell phone.
- August 10, 2007 - Three SOs inattentive on duty in the ready room captured by a
personal cell phone.
- August 22, 2007 - NRC reviews Exelon response that did not substantiate inattentive
SOs. NRC considers Exelon response acceptable after follow-up questions.
- August 28, 2007 - Exelon Corporate nuclear safety review board identified Wackenhut
performance as an area for improvement fleet-wide.
- September 10, 2007 - NRC received and verbally referred concerns to Exelon based on
WCBS-TV (New York) telephone call with information about videos that shows
inattentive SOs on shift at Peach Bottom. NRC resident inspectors begin enhanced
security inspections by performing increased number of observations at various security
posts during both normal and backshift hours.
- September 10, 2007 - Exelon forms an Issues Management Team based on NRC
information passed verbally. Exelon briefed PBAPS security force regarding heightened
awareness, fatigue, and responsibilities to report inattentiveness.
- September 11, 2007 - Exelon briefed their fleet security regarding heightened
awareness, fatigue, and responsibilities to report inattentiveness.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
B-3
- September 15 - 20, 2007 - Exelon corporate security interviews approximately 95
percent on-site members of Wackenhut organization at Peach Bottom.
- September 17, 2007 - SO responsible for videotaping inattentiveness has unescorted
access suspended because of trustworthiness concerns and procedure violations.
- September 17, 2007 - Maintenance technician acknowledged after a site communication
on inattentiveness that he had knowledge of a SO who taped inattentive SOs on duty
and showed him the videos.
- September 17, 2007 - Exelon is contacted by WCBS-TV.
- September 18, 2007 - NRC received and verbally referred inattentive SO concerns that
were received based upon telephone conversation that specified ready room as area
of concern for inattentive SOs.
- September 18, 2007 - Letter from President - Wackenhut Nuclear Services (WNS), to
WNS security force emphasizing fitness for duty and fatigue standards.
- September 18, 2007 - Exelon makes decision for outside legal counsel to take over
investigation in response to allegations. Exelon issues first press release at 11:00 am.
- September 19, 2007 - NRC views WCBS-TV videotapes and initiates AIT charter. NRC
verbally refers to Exelon additional information to be considered in their investigation.
- September 19, 2007 - Exelon management and Wackenhut establish enhanced security
oversight at PBAPS. Additional Wackenhut supervision brought in providing 24-hour
oversight and observation.
- September 20, 2007 - Exelon implements 24-hour on-site security supervision in the
ready room. Additionally, on-site Wackenhut supervision providing enhanced oversight
and observation.
- September 20, 2007 - NRC informs Exelon that an AIT will be dispatched to Peach
Bottom the following morning to begin inspection on the security events surrounding
inattentive SOs. NRC issues press release announcing the augmented inspection at
PBAPS for inattentive SO concerns.
- September 21, 2007 - WCBS-TV supplies Exelon with videos for viewing. Exelon
confirms that videos contain Peach Bottom SOs in the ready room.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
B-4
- September 21, 2007 - NRC commences AIT and arrives on site for inattentive SO
events.
- September 21, 2007 - Letter from Exelon to NRC Regional Administrator highlighting
Exelons efforts to immediately address SO inattentiveness concerns and current fact-
finding investigative efforts.
- September 21, 2007 - Nine SOs inattentive to duty placed on administrative hold
pending outcome of investigation.
- September 22, 2007 - NRC Region I security inspectors supplement resident staff in
conducting backshift inspection and observation of the security posts and compensatory
measures throughout the weekend until full AIT arrives on-site.
- September 24, 2007 - Exelon initiates termination of Wackenhut security contract at
Peach Bottom.
- September 24, 2007 - Exelon issues NER NC-07-034 to fleet for mandatory fleet actions
in light of inattentive SO issues at Peach Bottom.
- September 25, 2007 - Exelon places remainder of Security Team No. 1 on
administrative hold pending outcome of investigation.
- September 25, 2007 - Exelon issues an Operations Experience item regarding Security
Officers Inattentive to Duty on the NEI security web site
- September 26, 2007 - Exelon announces transition of security force from Wackenhut to
a proprietary guard force (Exelon).
- September 27, 2007 - Exelon enhances compensatory measures for BREs.
- September 27, 2007 - NRC issues advisory SA-07-06 regarding Security Officers
Inattentive to Duty.
- September 28, 2007 - AIT completes on-site portion of inspection.
- October 4, 2007 - NRC issues letter to Exelon requesting the actions taken or planned to
assure the following: (1) security officers remain attentive at all times while on duty in all
required locations at the facility; (2) security officers are both willing and able to
recognize instances of inattentiveness and promptly take all appropriate actions; (3)
supervisors and personnel take the necessary actions to encourage officers and all plant
staff to bring forward any concerns, including indications of inattentiveness, and
promptly address such concerns when raised; and (4) inattentiveness does not extend
to other departments or contractors at Peach Bottom. The NRC also requested that
Exelon address why this issue was apparently not self-identified.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
B-5
- October 4, 2007 - Letter from Exelon to NRC Regional Administrator describing
preliminary results of investigation, additional interim actions taken, and actions planned
for the near term.
- October 9, 2007 - NRC conducted a public exit for the AIT inspection. A public question
and answer session was held following the exit meeting.
- October 19, 2007 - NRC issued Confirmatory Action Letter (CAL - ML072920283) to
ensure continued security plan effectiveness.
- October 24, 2007 - NRC instituted a weekly status call with Exelon concerning CAL
actions and the status of transitioning from a contract security force to an Exelon force.
- November 1, 2007 - Peach Bottom transitioned to an Exelon security force. NRC
enhanced monitoring included observation of the transition, attendance at shift turnover
meetings, and interviews with selected officers.
- November 2, 2007 - Exelon responded to NRC October 4, 2007, inattentiveness letter
on the docket (ML073180128).
- November 5, 2007 - AIT inspection report issued (ML073090061).
- November 5 - 9, 2007 - NRC AIT follow-up inspection conducted to assess Exelons root
cause analysis, corrective actions, and significance of performance deficiencies.
- November 28, 2007 - NRCs Executive Director of Operations approved a Deviation
Memo which provided additional inspection and oversight of security activities at Peach
Bottom (ML 073320344).
- December 3, 2007 - NRC conducted a public exit for the AIT follow-up inspection with
one potentially greater than green finding and two cross-cutting aspects. A public
question and answer session was held following the exit meeting.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION