ML20137B078
| ML20137B078 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 11/25/1996 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| Shared Package | |
| ML20137A863 | List: |
| References | |
| FOIA-96-492 EA-96-344, NUDOCS 9703210153 | |
| Download: ML20137B078 (14) | |
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g NUCLEAR REGULATORY COMMISSION INTERNAL DISIRIBUTION REGloN I KSmith RCooper r,
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NsYLv A 19406-141s CGordon November 26, 1996 EA 96 344 11/25/96 MEMORANDUM TO:
James Lieberman, Director Office of Enforcement
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FROM:
Hubert J. Miller Regional Administrator
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Region i
SUBJECT:
PROPOSED ACTION TO PUBLIC SERVICE ELECTillC AND GAS COMPANY (PSE&G) FOR SECURITY VIOLATIONS AT SALEM / HOPE CREEK Attached for your review and concurrence is a proposed Notice of Violation aad Proposed imposition of Civil Penalties to the subject licensee based on six violations of the security program at Salem / Hope Creek. The violations are described in detailin the enclosed proposal.
Three of the violations relate to two specific events involving the failure to control access at the facility. One event involved the taping of the lock on the door to one of the photobadge keycard areas, thereby allowing any individual who had gone through the search process the opportunity obtain a photobadge keycard and use it to access the protected area. The second event involved a contractor individual accessing the protected area without a pat-down search, as required, after the individual had, on three occasions, alarmed two separate metaldetectors at the access control point. In addition, the licensee staff's initial followup after the second event was poor.
For the reasons described in the attached proposal, Region I proposes classifying the one violation related to the first event individually at Severity Level 111 and issuance of a $50,000 civil penalty; classifying the two violations related to the second event in the aggregate at Severity Level ill and issuance of a $50,000 civil penalty; and classifying the other three violations individually at Severity LevellV. Application of the civilpenalty assessment process for the Severity Level lil violation and the Severity Level lit problem is described in the attached proposal which was discussed with you and Mark Satorius of your staff at the caucus following the enforcement conference on November 14,1996.
This case is being forwarded to Headquarters for review and concurrence, as you requested at the caucus, given the current interest in the Salem facilities.
Docket Nos. 50-272;50 311;50-354 License Nos. DPR-70; DPR 75; NPF-57 MPR POSED ENFOBCEMENT ACTION NOT FOR PUlKIC RELEASE WITHE 0T APPik) VAL OF THEOIRECTOR, OE v
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Memorandum to James Lieberman 2
Attachments:
1.
Proposed Letter and Notice of Violation and Proposed imposition of Civil Penalties to Public Service Electric and Gas 2.
NRC inspection Report O.
Licensee Presentation during the Septernber 3,1996 exit meeting 4.
Licensee Presentation at the Enforcement' Conference 5.
Relevant Regulatory Requirements (contains Safeguards Information) 6.
Enforcement History cc w/ Attachments:
. F. Davis, OGC R. Zimmerman, NRR B. Summers, OE D. Screnci, PAO N. Sheehan, PAO l
No The Regional Counsel has no Legal Objection to this Proposal Yes 1
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ATTACHMENT 1 EA 96-344 Mr Leon R. Eliason Chief Nuclear Officer and President Nuclear Business Unit Public Service Electric and Gas Company Post Office Box 236 Hancocks Bridge, New Jersey 08038
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES
- $100,000 (NRC Inspection Reports No. 50-272/96-14, 50-311/96-14 and 50-354/96-08)
Dear Mr. Eliason:
This letter refers to the NRC inspections conducted at the Salem and Hope Creek Nuclear Generating Stations between August 15-September 3,1996. Four apparent violations were discussed with you at an exit meeting in the Region i office on September 3,1996. Two additional apparent violations were identified subsequent to the September 3,1996 exit meeting and were discussed in a telephone conversation with your staff on September 25,1996. The inspection report was sent to you on September 30,1996. On November 14,1996, a predecisional enforcement conference was conducted with you and members of your staff to discuss the apparent violations identified during the inspection, their causes, and your corrective actions.
Based on our review of the inspection findings, and information provided during the conference, six violations are being cited and are described in the enclosed Notice of Violation and Proposed imposition of Civil Penalties (Notice). Three of the violations relate to two specific events which occurred involving the failure to control access to the facility. One event involved a security force member taping a photobadge keycard area door lock, due to problems with the lock, thereby allowing any individual who had gone through the search process the opportunity to obtain a photobadge keycard and use it to access the protected area..ais failure to control photobadge key cards for entry into the protected area, which constitutes the first violation, could have allowed unauthorized access to the protected area.
This violation, which is set forth in Section i of the enclosed Notice, was identified when an NRC inspector observed that the locking mechanism on the door to that specific photobadge i
issue area had been taped over rendering the lock inoperative. At the time the lock was observed as inoperative by the inspector, the area was not occupied by security force personnel (SFP), and no compensatory measures were in place for this degradation. You subsequently took immediate action to remove the tape, restore the lock to an operable OFFICIAL RECORD COPY a: PROP-SHC.SEC
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j Public Service Electric and Gas 2
Company l'
condition, and verify that this degradation had not resulted in an unauthorized entry into the i
protected or vital areas of the facilities. Nonetheless, this condition created an opportunity for unauthorized individuals to gain access to the protected and vital areas, and, as such, represented a significant degradation of the security program at the facility. Therefore, the o
violation has been categorized at Severity Leveilllin accordance with the " General 20: ment l
of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), NUREG 1600.
1 The second event involved a contractor individual accessing the protected area without a pat-l~
metal detectors at the access control point. In addition, your staff's initial followup after the down search, as required, after the individual had, on three occasions, alarmed two separate
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second event was poor. In this case, although the contractor employee was allegedly told by i:
security force personnel to stand aside and await a hands-on search to determine the cause of the alarms, the contractor employee went to the badge issue area, was issued a photo badge / key card, and entered the protected area without being detained by security force personnel, contrary to NRC requirements. This violation is described in Section ll of the Notice. Subsequently, although a security supervisor initiated actions to identify the contractor individual once notified of the event, the security supervisor did not notify the Senior Nuclear Shift Supervisor onsite, which was required since the contractor individual should have been considered an intruder, and your NRC-approved Security Contingency Plan requires such notification whenever there is an intruder at the facility. This violation is also described in Section ll of the Notice. The contractor individual was not identified by the officers performing the search function until 50 minutes after his entry.
Although appropriate searches were conducted once the contractor was located, including searches of the individual, his locker, and his whereabouts while uncontrolled, the NRC is concerned that the control room was not notified, as required, of the potential security threat that existed, and the contractor's badge / key card was not deactivated during that time, which would have precluded him from entering any vital areas. In addition, the contractor was not paged on the plant paging system, once he was identified, to expedite locating him. These failures also constitute a significant regulatory concern regarding your regard for control of access to the facilities, and therefore, the two violations are categorized in the aggregate as a Severity Level lli problem in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), NUREG-1600.
These three violations of fundamental access control requirements at nuclear power plants represent a significant degradation in the security program at the facility, which during the prior SALP, had been recognized as a strength at the facility. At the enforcement conference, you noted problems in the work culture at the facility, and also noted that deficiencies in procedural adequacy, procedural adherence, job skil!s, and management oversight contributed to these violations. It is important that these causes are fully corrected to ensure that only authorized individuals are granted entry to protected and vital areas.
OFFICIAL RECORD COPY a: PROP-SHC.SEC
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Public Service Electric and Gas 3
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'In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is considered for a Severity Levellli problem or violation. Your facilities have been the subject
. of escalated enforcement actions within the lau 2 years. For example, cumulative' civil penalties in the amount of $600,000 were issued on October 16,1995 for, in part, several instances of the failure to identify and correct conditions adverse to quality at Salem l(
Reference:
EAs 95-62/95-65/95-117). In addition, a civil penalty in the amount of $100,000 I
was issued on December 12,1995, for violations of shutdown cooling requirements at Hope Creek (
Reference:
EA 95-216). Therefore, the NRC considered, for each Severity Levellli j
j violation and prob'em, whether credit was warranted for ident//7 cation and Corrective Action l
in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement 1
2-Policy.
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With respect to the violation in Section I, credit is not warranted for /dentification because the violation was identified by the NRC. Credit is warranted for Corrective Action because at the l
. time of the enforcement conference, your actions were considered both prompt and comprehensive. These actions, which were discussed during your presentation at the l
conference, include, but are not limited to the following: (1) replacement of security management; (2) reestablishing expectations and direction in the security department; (3)
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ensuring management involvement in the program; and (4) upgrading the training of security personnel.
With respect to the violations in Section 11, credit is not warranted for /denti// cation because the violation was self-revealing when security personnel could not locate the individual, and
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i then failed to notify the control room as required. Credit is warranted for Corrective Action j
because at the time of the enforcement conference, your actions, as already described, were considered both prompt and comprehensive.
k Therefore, to encourage prompt identification and correction of violations, I have been j-authorized, after consultation with the Director, Office of Enforcement, to propose a separate
. l civil penalty of $50,000 for each of the Severity Level lli violations and problems in Sections j
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1 and 11 of the enclosed Notice.
The three other violations identified during the inspection are described in Section lli of the enclosed Notice and are classified at Severity LevellV. Those violations involve (1) the failure to deactivate photo badge key cards for individuals who no longer required site access after e
being terminated; (2) the failure to complete training for security supervisors prior to assigning them to perform supervisory duties; and (3) the failure to test an intrusion detection system j
in accordance with procedures.
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You are required to respond to this letter and should follow the instructions specified in the 1
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enclosed Notice when preparing your response. In your response, you should document the j
specific actions taken and any additional actions you plan to prevent recurrence. After j
reviewing your response to this Notice, including your proposed corrective actions and the 1
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OFFICIAL RECORD COPY 1
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Company results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,its enclosure, and your response will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR. If redactions are required, a proprietary version containing brackets placed around the proprietary, privacy, and/or safeguards information should be submitted. In addition, a non-proprietary version with the information in the brackets redacted should be submitted to be placed in the PDR.
Sincerely, Hubert J. Miller Regional Administrator Docket Nos. 50-272, 50-311, 50-354 License Nos. DPR-70, DPR-75, NPF-57
Enclosure:
Notice of Violation and Proposed imposition of Civil Penalties OFFICIAL RECORD COPY a: PROP-SHC.SEC
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Public Service Electric and Gas 5
Company cc w/ encl:
L. Storz, Senior Vice President - Nuclear Operations E. Simpson, Senior Vice President - Nuclear Engineering E. Salowitz, Director - Nuclear Business Support C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.
D. Garchow, General Manager - Salem Operations M. Bezilla, General Manager - Hope Creek Operations J. Benjamin, Director - Quality Assurance & Nuclear Safety Review D. Powell, Manager, Licensing and Regulation
' R. Kankus, Joint Owner Affairs A. Tapert, Program Administrator i-R. Fryling, Jr., Esquire l
M. Wetterhahn, Esquire P. MacFarland Goelz, Manager, Joint Generation Atlantic Electric i
Consumer Advocate, Office of Consumer Advocate W. Conklin, Public Safety Consultant, Lower Alloways Creek Township Public Service Commission of Maryland
' State of New Jersey State of Delaware i
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OFFICIAL RECORD COPY a: PROP-SHC.SEC i
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Public Service Electric and Gas Company i
DISTRIBUTION:
PUBLIC SECY CA JTaylor, EDO JMilhoan, DEDR JLieberman, OE HMiller, RI FDavis, OGC
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FMiraglia, NRR RZimmerman, NRR Enforcement Coordinators Rl, Rll, Rlil, RIV BBeecher, GPA/PA GCaputo, 01 DBangart, OSP 4
HBell, OlG EJordan, AEOD OE:EA (2)
NUDOCS i
DScrenci, PAO-Ri i
NSheehan, PAO-Ri LTremper, OC Nuclear Safety Information Center (NSIC)
NRC Resident inspectors - Salem and Hope Creek 1
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DATE 11/i ((/96 11//1/ /b6 11/9 )/56 W/
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/96 OFFICIAL RECORD COPY a: PROP-SHC.SEC d
I
l ENCLOSURE NOTICE OF VIOLATION AND f
PROPOSED IMPOSITION OF civil PENALTIES d
Public Service Electric and Gas Company Docket Nos. 50-272, 50-311, 50 354 Salem Nuclear Generation Station License Nos. DPR-70, DPR-75, NPF-57 j.
Hope Creek Nuclear Generating Station EA 96-344 During an NRC inspection conducted between August 15-September 3,1996, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the Nuclear Regulatory Commission proposes to impose a civilpenalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:
1.
VIOLATION INVOLVING LACK OF CONTROL OF PHOTOBADGE KEY CARDS License Condition 2.E of License Number NPF for the Hope Creek facility,' and License Conditions 2.E of License Numbers DPR-70 and DPR-75 for Salem, require that PSE&G fully implement and maintain in effect all provisions of the physical security, guard training and qualification, and safeguards contingency plans approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).
The Public Service Electric and Gas Company (PSE&G) Salem - Hope Creek Security Plan, Revision 7, dated June 21,1996, states, in Section 5.6, " Access Control to Vital Areas" that " Vital area access is physically controlled by the photobadge-keycard system which permits access into specific areas to persons designated on the current access list contained in the system computers. Positive access controlls accomplished by [ Security Force Personnel] (SFP) prior to issuance of the photobadge-keycard.
Persons are positively identified by requiring them to request the badge by number, and visually, by comparing the picture to the person before issuing the keycard."
Contrary to the above, on August 14,1996, vital area access was not physically controlled in that positive access control over photobadge keycards was compromised, thereby creating the opportunity for unauthorized access to the vital areas.
Specifically, on that date, an NRC inspector identified that the lock mechanism on a door to one of the badge issue stations had been taped over, rendering the lock incapable of performing its locking function, and at the time, the badges were left unattended in the issue station, and no compensatory measures were in place for the inoperative lock to preclude an unauthorized individual from gaining access to the badges and the protected and vital areas.
OFFICIAL RECORD COPY a: PROP SHC.SEC
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Enclosure 2
This is a Severity Level lli Violation (Supplement 1).
Civil Penalty - $50,000.
ll.'
VIOLATIONS INVOLVING INADEQUATE SEARCH OF AN INDIVIDUAL PRIOR TO ENTRY TO THE PROTECTED AREA, AND INADEQUATE FOLLOWUP AFTER THE
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ENTRY OCCURRED License Condition 2.E of License Number NPF 57 for the Hope Creek facility, and
. License Conditions 2.E of License Numbers DPR 70 and DPR-75 for Salem, require that i
PSE&G fully implement and maintain in effect all provisions of the physical security, guard training and qualification, and safeguards contingency plans approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).
A.
The PSE&G Salem - Hope Creek Security Plan, Revision 7, dated June 21, 1996, states,in Section 4.2.1.4, " Personnel Search and Access Control," that
" Searches at the guardhouses are performed by locally alarming portal or hand-held metal and explosives detectors. When there is reasonable cause to suspect that a person is attempting to introduce firearms, explosives, incendiary devices or other unauthorized materialinto the protected area, the person is given a physical pat-down search. When the metal and/or explosives detectors are not in service and operating in accordance with equipment test standards,.
physical pat-down searches are performed."
Contrary to the above, on August 26,1996, a contractor employee entering the protected area caused two portal metal detectors to alarm on three different j
attempts to pass through them, and although these alarms provided reasonable l
cause to suspect that the contractor was attempting to introduce firearms, explosives, incendiary devices or other unauthorized materialinto the protected area, no physical pat-down search was performed, and the contractor was given his photobadge-keycard and entered the protected area.
B.
The PSE&G Salem - Hope Creek Security Contingency Plan, Revision 4, dated February 12,1996, states, in part, in Section 8.1.3.2, that it will be assumed that a security threat exists until it is known otherwise. Section 8,1.4 of the Contingency Plan defines an intruder as a person present in a protected or vital j
area without authorization. Section 8.3.2.6 of the Contingency Plan statesthat in the event of discovery of intruders or attack, notify the Senior Nuclear Shift Supervisor (SNSS) of implementation of Contingency Event 6 (Discovery of Intruders), provide a concise situation report, and request SNSS to classify the
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event per the Event Classification Guide in Section 16.
OFFICIAL RECORD COPY a: PROP-SHC.SEC
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Enclosure 3
Contrary to the above, on August 26,1996, a contractor who had alarmed the two portal metal detectors on three. occasions, entered the protected area without receiving a pat down search, was not authorized to enter the protacted area without having received a search, and, therefore, should have be,cn assumed to be an intruder and security threat until it was known otherwise; however, the SNSS was not notified of the threat, and the event was not classified per Event Classification Guide 16.
This is a Severity Level lli problem (Supplement lil).
Civil Penalr/ - $50,000.
Ill.-
OTHER VIOLATIONS OF NRC REQUIREMENTS License Condition 2.E of License Number NPF-57 for the Hope Creek facility, and License Conditions 2.E of License Numbers DPR-70 and DPR-75 for Salem, require that PSE&G fully implement and maintain in effect all provisions of the physical security, guard training and qualification, and safeguards contingency plans approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).
A.
The PSE&G Salem - Hope Creek Security Plan,. Revision 7, dated j
June 19,1996, ~ states, in part, in the introduction Section that the implementing documents of this plan are the Security Plan Procedures and Post Orders. Security Plan Procedure 4, Revision 3, dated November 1,1994, states, in Section 4.13, that when a person granted unescorted access terminates employment or no longer requires access to the site Protected Area, the cognizant department shall notify the Screening Supervisor within two working days, and the Screening Supervisor ensures that the administrative actions required to inactivate the security photobadge and personnel access clearance are accomplished.
Contrary to the above, the Screening Supervisor was not notified within two working days that 12 employees had been terminated in June and July 1996.
Specifically, notification of five employses that were terminated in June 1996.
was not made until the 31-day revalidation list was issued in July 1996, and notification of seven employees that were terminated in July 1996 was not made until the 31-day revalidation list was issued in August 1996.
This is a Severity Level IV Violation (Supplement lil).
OFFICIAL RECORD COPY a: PROP-SHC.SEC
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' Enclosure 4
I' B.
The PSE&G Salem - Hope Creek Security Training and Qualification Plan,
- Revision 3, dated February 12,1996, Section 3.3, states, in part that,.the qualification matrix identifies the cc ;rses of instruction by job classification, j
which each person shall pass in order to qualify for performance of related security duties.
Section 3.8, titled, Supervisory Training, s. ::: that supervisors are required to qualify in all security force tasks.
Critical Security Task No. 5, titled, " Conduct Patrols," states,in Element 05-A, that the examinee will demon:trate knowledge of the site by responding correctly to the location of several protected and vital area alarms.
Contrary to the above, on August 20,1996, the inspectors determined by a review of training records and shift activity logs, that two supervisory personnel were performing Field Operations Supervisor duties prior to qualifying on all of the required critical security tasks for the performance of their related security duties. Specifically, the supervisors were signed off as qualified supervisors by -
the security training department and given a 90-day period to complete Element 05-A. However, during the 90-day period, the supervisors were assigned independent Field Operations Supervisor duties, to include contingency response coordination, requiring extensive knowledge of the protected and vital area alarm locations.
This is a Severity Level IV Violation (Supplement lil).
C.
The PSE&G Salem - Hope Creek Security Plan, Revision 7, dated June 1996, states,in part, in the introduction Section, that the implementing documents of this plan are the Security Plan Procedures and Post Orders. Security Plan Procedure 8, Vehicle Access Control, Revision 8, dated February 28,1996, requires, in part, in Section 10, Use of Crane Gate, that the Security Shift Supervisor / designee direct that the zone be crawl tested after the vehicle passes and prior to securing the patrol. This procedure further states, that the security force member (SFM) No.1 shall remain posted at the gate ' ntil the
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u zone passes the crawl test.
Contrary to the above, on June 5,1996, a vehicle passed through the Crane Gate, and a crawltest was not conducted prior to SFM 1 being released from i
the post.
This is a Severity Level IV Violation (Supplement Ill).
Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed imposition of Civil Penalties (Notice). This reply should be OFFICIAL RECORD COPY a: PROP-SHC.SEC
Enclosure 5
clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an Order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalties by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the cumulative amount of the civil penalties, or may protest imposition of the civil penalties in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.
Should the Licensee fail to answer within the time specified, an order imposing the civil penalties will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the violation (s) listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalties should not be imposed. In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigetion of the penalties.
In requesting mitigation of the proposed penalties, the f actors addressed in Section VI.B.2 of the Enforcement Policy should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately frorn the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalties.
Upon failure to pay. any civil penalties due that subsequently have baen determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act,42 U.S.C. 2282c.
The response noted above (Reply to Notice of Violation, letter with payment of civil penalties, and Answer to a Notice of Violation) should be addressed to: James Lieberman, Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North,11555 Rockville Pike, Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S.
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Enclosure 6
Nuclear Regulatory Commission, Region I, and a copy to the NRC Senior Resident inspector at the facility that is the subject of this Notice.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR. If redactions are required, a proprietary version containing brackets placed around the proprietary, privacy, and/or safeguards information should be
- submitted. In addition, a non-proprietary version with the information in the brackets redacted should be submitted to be placed in the PDR.
Dated at King of Prussia, Pennsylvania this day of November 1996 I
I OFFICIAL RECORD COPY a: PROP-SHC.SEC
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