ML20151X705

Partially Withheld Ltr Forwarding Final Rept of Facility Insp/Investigation

ML20151X705
Person / Time
Site:	Quad Cities
Issue date:	07/08/1977
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	FEDERAL BUREAU OF INVESTIGATION
Shared Package
ML20151X676	List: IA-87-698, Partially Withheld Ltr Forwarding Final Rept of Facility Insp/Investigation ML20151X673 ML20151X705
References
FOIA-87-698 NUDOCS 8808260080
Download: ML20151X705 (45)

Text

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f otsN ELLYN, ILLINOIS 601 M July d, 1977 Special Agent in Charge of Federal Burehu of Inverti ATTN: Supervisor P. O. Box 3646 Springfield, Illinois 60708 q Centlemen: As discussed with you during the telephone conversation on, July 7, 1977 with Jack Hind of my staff, enclosed is a copy of our final report of the Qusd-Cities inspection / investigation. Please note that the first 26 pages of the report pertains to the inspection conducted and is considered proprietary (10 CTR 2.790(d)) information while the remainder of the report pertains to the investigation activities and is not considered proprietary information. If you have any questions, please call. l Sincerely, E &hS //JamesG.Keppfer s Director Information in this record was deleted Enclosures in accordance with the fre dom of Informall05 Inspection / Investigation Act, exem tions 3 O d g% Rpt Nos 50-254/77-14, F 50-265/77-14 g g. Mg '. v 8808260080 880802 PDR FOIA McKAYO7-698 PDR 5[ ARCH!D !?GX13 JUL 111977 ru. m:.scnn3 i, VY 6q - _ _ _gi

i INVF.STICATION ADDENDRI REASON FOR INVESTICATION t On April 26, 1977, a news articic appeared in the Daily Dispatch, Moline, Illinois reporting three former guards lud made allegations of lax security and safety procedures at the Ouad-Citics Muclear Power Station. An investigation was therefore initiated to determine the substance of these allegations. SU10!ARY OF FACTS On April 27, 1977, the three individuals formerly employed by Pinkerton, Inc. as guards at the Quad-Cities Nuclear Power Stat

• ion, who were nacied in the April 26, 1977 news article as having made allegations, wereJnterviewed. On April 28, 1977, another former Pinkerton employee, who was mentioned in a subsequent news articlo, was interviewed.

8 4 i On April 26, 1977, an unannounced security inspection was initated l at the Quad-Cities site. The inspection continued concurrently with the investigation of the allegations. On }tay 6,1977, Region III (RIII) received a copy of a letter dated April 27, 1977, written by another former Pinkerton guard to Senator Charles H. Percy and referred to the NRC. On !!ay 12,197 7,

• aL that individual was interviewed, h.13 The allegations set forth in the Details of this repor't were derived from the information obtained during these five interviews and the con-tents of the letter to Senator Percy.

i For the purpose of review, these allegations are grouped according to subject matter. They are included, herein, under the headings: Physical l,.,,. Security; Plant Operations; Radiation Protection; Internal, Company l W i' Matters; and Items that arc outside the jurisdication of the NRC. Some of these items were resolved with the allegers during interviews. A I description of the allegations and findings are included in the Details l I section of this report. As a result of this inspection / investigation certain of the licensec's IM activitics appeared to be conducted in noncompliance with rc<pirements. l h, None of those items represent a direct threat to the health, safety or / "I l

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4 i or interest of the public or common defense and security. Eleven items were categorized as infractions which indicate a possible potential for causing a threat and six represent no threat to the public and were categorized as deficiencies. f I W ca.q j iJ l 0 l .Y

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...i_ i.. s' i DETAll.S Introductton On March 2, 1977, the licensee's Nucicar Security Administrator visited Region III to advise that a Pinkerton guard employed at the Quad-Cities Nuc1 car Power Station had made complaints regarding security matters at that facility by letter dated February 24, 1977, to a corporate official. The Nuclear Security Administrator further advised that he had interviewed the individual on February 25, 1977, regarding his complaints. During the interview the guard was assured that the licensee would investigate. the complaints. The Muclear Security Adr.iinistrator stated although he advised the guard ha could communicate his complaints directly

• .o the NRC, the guard said he preferred not to involve the NRC at that time.

Because the guard had made known his complaints to the licensee and reportedly prefer-red not to communicate directly with the NRC, the lit,ensee was, advised by Region III to investigate the complaints and to report their findings to Region III. By letter Cated March 10, 1977, t.he licensee provided ' Region III a report oftheirfindingsandindicatedthatbyMarch28,ly?7,aninterimreport of the status of a relsted investigation being conducted by Pinkerton, Inc., would be provided. Although the licensee's report addresses 28 items, only fourteen of them ~ were considered as having some bearing on security or radiation protection matte.s under the jurisdication of the NRC. Region III considered the licensee's fini.ings satisfactory, awaited the Pinkerton report and planned h to pursue several items further during the next security inspection. Oh! By letter dated liarch 25, 1977, the licensee advised Region III that the Pinkerton investigation was continuing and that no substantial information regarding the allegations had been received freu Pinkerton who was provid-1 ing then daily reports. The licenses further advised that the final report Q would be provided to Region III by April 29,1977.! While awaiting this .g,. final report, Region III decided to begin a security inspectioa of the Quad-Cities facility, originally scheduled for July 1977, on April 26, 1977, .L%i and to include a review of the licensee's findings regarding these allege-tions during that inspection. By letter dated April 28, 1977, the licensee reported the results of the Pinkerton investigation. s 4 - 4

~ The reports rcccived f rom the licensec indicated no significant accurity problems were identified by the lictnace or Pinkerton during their investi-gation of the guard's allegations with one exception. It was indicated in the March 10, 1977 report that although the finding of unsecured vital arca doors was not a f requent occurrence, the primary probica area in this regard hao been identified, and consideration was being given to the ~I installation of local audibic alarms on those vital arca doors. In their letter dated April 28, 1977, the licensee advised that these alarms had been installed and "are providing adequate assurance that the doors are properly closed." On April 19, 1977, a newspaper reporter from the Daily Dispatch, Moline, Illinois visited the RIII offices. During this visit the reporter advised that he had received allegations from t'ormer guards at the Quad-Cities Nuclear Power Station regarding the security and radiation protection programs at chat facility. RIII requested the identity of the allegers so that t. hey could be interviewed to c':.ain core specific information regarding their concerns. The reporter, at that time, declined to identify the allegers to RIII. On April 26, 1977, the reporter contacted RIII by telephcne and advised that a news article concerning the allegations would appear in the Daily Dispatei that day. Since the nous articles would identify three fomer guards as the sources of the information in the news article, the reporter provided to RIII their names during this telephone conversation. At the time this call was received, two MRC security inspectors were already enroute to the Quad-Citics facility to initiate an unannounced inspection which was begun that day. Upon receiving the identitics of the three fomer guards, an investigator proceeded to the Quad-Cities y; area to interview them and to conduct an investigation concurrent with the ongoing inspection. + Following interviews with the three former guards on April 27, 1977, another fomer member of the guard force was interviewed on April 28, 1977, since that individual was identified in a subsequent neus article as the source of additional infomation. g., On May 6,1977, RIII received, through NRC Headquarters, a copy of a letter dated April 27, 1977, sent to Senator Charles H. Percy containind alle-( gations by another former guard. That individual was interviewed on May 12, 1977. 1y During, this investigation, l'., of the 14 Pinkerton personnel currently assigned to the Quad Citics aito were interviewed. (One individual was on vacation.) In additirn to an examination of records and pnocedures and observations and interviews of station personnel, the Pinkerton - 3 a.~'"'

office in Rock Island, Illinois was visited on May 4'and 6, 1977. The Of ficer-in-Chargo of this of fice was interviewed and portinent records were examined. The Nucicar Security Administrator was interviewed at the licensec's corporate of fices in Chicago,1111 nets on May 25, 1977, and a former Of ficer-in Charge of the guar ' force at the Quad-Cities site was interviewed on May 26, 1977. Following are the a11cCations made by former guards and a discussion of the results of the investigation which was conducted: Physical Security. Listed below are the allegations concerning the security program at the Quad-Citics Nuc1 car Power Station which were derived from interviews with five fomer guards and the letter to Senator Percy. 1. ALLEGATION: In January 1976 guards were instructed to discontinue recording vital area doors (VAD) that are found open on. guard patrol sheets and to place this information on a slip of paper and attach it to the guard patrol s'aeet. These slips of paper were subsequently discarded. s' +. FINDING: During theit' interviews, the allegers indicated that it was their belief that the purpose of this instruction was to prevent NRC security inspectors from finding this information during their inspec-tions. It was indicated that they did not know what was done with the slipt of paper but one alleger stated that he had seen the Station Security Of ficer, on at least one occas. ion, remove a slip of paper !ro: a patrol sheet and throw it suay. One alleger provided a copy of a patrK sheet dated April 15, 1977, with a slip of paper identifying two unsect.ni g, VADS shown attached to it and a copy of the same report with the slip of .se paper folded out of the way. These copies are attached to this report as Exhibits A and B respectively. 2 One of the allegers advised during his interview that a former Officer-in-Charge of Pinkerton guards at the site had, introduced the practice of w maintaining a log of pertinent information on a forn he ievised and called it a Shift Officer's Report. This repo-t was prepared each shift by the shif t officer for the information of the shif t of ficer relieving him. The alleger indicated that it was his understanding that these y reports were not furnished to either the Pinkerton Rock Island office or l the licensee. He said the reports are kept in a loose leaf notebook in a desk in the guardhouse at the site. He indicated that these Shift l yq Officer's Reports would contain infornation concerning the status of g"4 alarm zones, cameras, security gates and other security related equip-l ment as well as unsecured VADS. The NRC had previously bcon unaware of gj the existence of these reports. M l t 7, ,a ,J*N \\'s e e,e L

Through interviews with guards on itay 4 and 5,1977, it was ascertained that this instruction had been issued about.the end of January 1976 or, in those cases where the guard had beconc subsequently enployed at the site, they received this instruction upon assuming their dutics. Each guard's estinate of the f requency with which they had found VADS unsecured difforcd. The consensus, however, was that unsecured VADS were not an infrequent occurrence. Several of the guards shared the opinion of the allegers that the purpose of recording unsecured VADS on slips of paper rather than on their patrol sheets was to make the records look good for NRC inspectors. A review of the patrol sheets retained by the Station Security Officer covering the period since the last security inspection-in November 1976 to the present revealed one instance in which an unsecured VAD was recorded on a patrol sheet dated April 26, 1977. This was subsequent to the appearance of the first newspaper article concerning the security allegations which apocated in the Moline, Illinois Daily D.ispatch on April 26, 1977 and was the door found tied open by NRC security inspec-tors on April 26, 1977. TheShiftOffkccr'sReportsfortheperiodNovember1976tothepresent were reviewed. Entries relating to unsecured'] ads were made on the following dates: February 9 and 12; March 7, 8 and 28; and April 9,13,14 and 15,1977 On May 26, 1977, the individual, who had been in charge of the Pinker- ']"l@! ton guards at the site at the time the practice of reporting unsecured VAD's on slips of paper began, was interviewed. He stated that this ~ ~* 3Ob@ practice was begun at the instruction of the Security Officer. Althou;h he could not recall the specific conversation or the expressions used, -{ he stated that the message was clear that the licensee did not want this infornation in records reviewed by URC security inspectors. The licensee did not want the inspectors to see in the records that VAD's were still being fcund unsecured frequently. This individus1 said that the Station Superintendent was quite upset about the civil penalty the licensee had received in 1975 and that soon af ter a January 1976 NRC security

• kfi inspection the licensee changed the method of reporting unsecured VAD's.

flbft (NOTE: The inspection conducted January 21-23, 1976 examined the l l $. licensce's corrective action regarding ti.c items of nonconpliance upon ib( which the civil penalty was based, one of which involved unsecured VA3's.) l i 'u# Nbh Pinkerton Forn 286B contains' a series of items.rhich are checked "yes" d*8 or "no". Item 4 relates to doors or windows found open or broken. The , Nkh! l individual interviewed on }by 26, 1977, stated that some time after - -- 1 I l _ t I

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the reporting method was chtiged, the Security 02ficer told him to check that item as "no" so that it would bo'concistent sith the con-tents of th! patrol sheets. During an interview with the present Of ficer-in-Charge of Pinkerton guards at the site on May 5, 1977, he stated that the use of slips of paper for recording insecured ? ads was in effec *. when he began work R at the site in August 1976. It was his understanding that this method was employed at the request of the client, the licensee. He indicated that within the last week or ten days the procedure was modified and-that such itchs were now being reported on the patrol sheets as well as on a slip of paper attached'to it. kiuring an interview with the Station Security Officer on May 5,1977, he stated that he did not recall when the practice was bagun but that it was mere than a year ago. He indicated that unsecured VADS wort a matter of continuing concer'n to station management and that the Station Superint.endent took a personal irterest in attempting to keep these doors secured. The Security officer stated that the patrol sheets ware submitte'd to him by Pinkerton n evidence that the required patrols were p er f o rmed. He indicated that he instructed PJnkerton to record unsecured VADS on slips of paper and to attach then to these patrol saects so that he could pull the slips of paper and turr them over to the Station Superintendent. It was his understanding that the Station Superinte. dent used these slips of paper as a basis for discussions with his staff and to attenpt to determine whose personnel were leaving these doors un-secured. The Station Security Officer said there was no ree.uirement that records E be nr.intained on VALs found unsecured. He had regarded the reporting cf M these matters ty the guards as informational and for use in discussin; p the problem with station persennel. In those instances wherein a VAD ' y} was reported by the guard? as unsecured because of damage, he initiates a work reqvest. He pointed out that in some instances a damaged door is reported to the Shift Engineer by the guard and the Shift Engineer initiates the work request. I puring discessions with the Station Superintendent on May 6,1977, he l @_ indicated th,1t the mc.thod of reporting unsecured VADS was his decision. l He indicated that unsecured doors had been a continuing problem becarce of the facility's design. The facility was constructed and in I operation several years before security requirements were established. lie :, aid that he had been personally involved in ef forts to minimize l the occurrence of unnecured doors. This matter had been a topic of-discussions wi*h his department heads and they, in turn, had discussed I it with their personnel. He said ti.at evidence of this could be found l .in the minutes of his meetings with the department heads, the notes I - g, i .. -1a. 7 5..

o kept by department heads of their meetings and entrics in the Daily Order Book. The Station Superintendent produced the department head meeting notes for meetings held on Novenber 8 and 22, 1976, and March 7, 1977, which indicated that this matter was discussed. He indicated that this topic had also been discussed at carlier meetings but the practice of recording the contents of the mee'.ings had begun in September 1976. Notes used by one department head for meetings with his personnel were reviewed and they indicated that the securing of doors was a topic on at least 14 occasions from January 23, 1974 to March 21, 1977. The Daily Order Book, which'is a means of comunication from statior. panagement, specifically the superintendent, assistant superintendent, administrative assistant and the chief operating ensineer, to the shift engineers, was reviewed for the period Februttry 16, 1976 to February 17, 1977. Six entrics were found which related to the topic o,f keeping VADS secured. The Stath .. inten.J en t stated that station personnel, in addition to the g'uat.. checked VADS to asst.. e they are secured. These indivi- + duals are expected to secure any doors found open but they have not been requi-eil to record these occurrences. Yan 'Ine Station Superintendent stated that NRC security inspectors were l aware that the licensee had a continuing proble:- keeping VADS clored. He indicated he had discussed it with the inspectors during their visits to the site. Regarding the 5 plication that the method of reporting unsecured doors l 1 by guards was intended to mislead NRC security inspectors, the Statica ouperintendert prepared a written statement, a copy of which is attached M to this report as Exhibit C. 2. AI. LEGATION: Viritors requiring an escorc in ihe Trotected area have lg returned to the gu.ardhouse unescorted and personnel who are required I lM to oc escorted in vital areas have been lef t unescorted in those areas. lN FINDING: Through an f aterview with a station employee on May 3,1977, l Ay it was ascertained thac although he was required to be escorted while in u l vital areas, he routinely enters v3.tal arens unescorted to perform his dutics. Pinkerton Forms 286B. Security Service Report, for the period h August 28, 1974 through March 14, 1976 were reviewed. On seven occasionc '75 unescorted visitors were recorded. All of these occurred during the period September 17, 1975 to Deceuber 39, 1375. On these occasions the matter was reported to the Station Superintendent. c;.,. < L.'. 9_ j

\\ Shift Officer's Reports, which ara an internal Pinkerton report retained by Pinkerton personnel in the site. guardhouse and not furn-ished to the licensec. were also reviewed. The Shift Officer's Reports for the 8:00 a.m. to 4:00 p.m. tour on January 14, 1976, coniairs an entry on its reverse side that a visitor had returned t to the guardhouse unescorted after making a delivery and that the yh Station Superintendent had Lcen notified. A further notation on by this form stet?s that any calls to the Station Superintendent "c regarding unescorted visitors do not need to be reported on Forn 286; that the Station Security Officer had approved this and that the Station Superintendent "says he does not want certain people to see it on the 286." The individual who made this entry was inter-viewed on Iby 13, 19'/7 regarding the circumstances surrounding this bntry. It was that individual's recollection that this instruction had been received from the Officer-in-Charge of the Pinkerton guards at the site at that time and that the Of ficer-in-Charge had received t'wt instruction from the Station Security Officer. The ind$vidual who ctde the entry stated thar "certain people" meani NRC security inspectors. The indi.vidual who was che Officer-in-Charge at that time is no longer employed by Pinkerton. He was subsequently interviewed on Iby 2d, 1977 regarding this matter. He stated he did.got receive this instruc-tion from the Security Officer and pointed out that he was not on duty that shift. This is supported by the Shift Officer's Report for that shift. He expressed the opinion that the individual who made the entry received the instruction directly from the Station Security Officer. During ar int 2rview with the Station Security Officer on iby 5,1977 g;r he stated that he had no recollection of ever issuing an instruction to Pinkerton guards to discontinue recording instances of unescorted visitors or. the Form 286s. i During an intarview with the Station Superintendent on May 11, 1977, he stated that he did not rc:all issuing any instructiens in this regard to either the Station Security Officer or any member of the Pinkerton guard 'u force. He recalled that at one point in tiec the Station Security Officer had expressed concern about instances wherein visitors had - Ti? returned to the guardhouse unescorted. The Station Superintendent had instructed the Security Of ficer to have the guards notify him personally when that occurred so that he could take action himscif to prevent recurrence by discussing the matter with the responsible employee. y The Station Superintendent stated that it was not his intention to prevent NRC security inspectors during their inspections from finding information in the records regarding unescorted visitors. He indicated that he had no control over entries made by other individuals in the Shift Officer' Reports. e - ' '. s I. . y;;;n '\\ e s

This subject is also addressed on page 4 of a statement furnished by the Station Superintendent dated May 13, 1977, a copy of which is attached l to this report as Exhibit C. 3. ALLEGATION: On-the-job training s inadequate. O FINDING : It was alleged that upon assignment as a guard at the site, other gua'ds rather then a sergeant or a licutenant provide on-the-job r training on manning the alarm and TV console, performing par.rols and controlling access to the protected area. One alleger stated that he was assigned to man the alarm console without being instructed in its operation. During interviews with current guard personnel, it was indicated that their on-the-job training experience was varied. In most instances, the guard has been shown the location of the watchelock keys and how to conduct patrols by a guard supervisor. Other guards indicated that they haa received instruction on the oneration of the console before being assigned to man 10. The instruction was provided in some instances by a supervisor; in others, by guards while they were performing that assign-ment. The consensus was that on-the-job training was.not given in an organized fashion end the quality of the train}ng varied from one indi-vidual's experience to anothers. None of the guards stated that the on-the-job training was insufficient for them to adequately perform l their duties. 4. ALLEGATION: k' hen guards are given a written test at the end of t Pinkerton training, some have been given the answer sheet, others have ]f been given someone else's completed test paper and some have been

.ggg allowed to use their notes and course texts.

E', FINDINGS: This allegation could not ba verified fully. In the case of one former guard, whose written test is on file, th< test was not dated, no grade was assigned, no marks were made to indi-cate wherher the answcrs were right or wrorg and one co.plete gjag section on First Aid was not taken by the guard. In spite nf this, JbWd a written certification was.made to CECO by the guard-contractor g:::q that the guard received a grade of 75% on the written test and 211 on marksmanship. This particular guard who subsequently resigned, was rehired but was not required to retaxe the written test or undergo any f t-ther training by the guard.-contractor. He has since resigned the second time. Interviews with present site guards indicated ano did noe receive any Pinkerton training prior to site assignment, but received on-the-job trair,ing and some classroom work and took the written test on the sito rather than at the 'inkerton Training Office. During the written examination, the 3 said no uutside help was given. After the test, no score was mentioned but the instructor reviewcd missed questions to assure adequate understanding. A passing score was certified to CECO by Pinkerton. '~ r' .. /* '

Other guards denied using an answer si.act, opca book, course notes or discussions of correct ans"crs while taking the examination. Two guards said thcies was.n "open book" examination and that no one supervised the test. One guard who said he had no assistance, thought he did "very peor in the writ ten examination but no one reviewed the test results with him. Since he did not have to retake the exam, be assumed he passed. In many casri, che guards were not told of their cxsminatica scores but severs 1 indicated the instructor reviewed missed geestions to assure their understanding of what they should know as a guard. The Officer-in-Charge (OIC) of the Pinkerton Rock Island Office was interviewed and produced requested reccrds to the investigators. lie displayed a Pinkerton In,tructor manual which incorporates the 80-hour training course for guards including Chapter 38 of the Illinois Code. This manual did not contain any specifics on weapons training er qualific_ tion scores. The OIC etated that vritten tests are administered at the conclusion of the study, discussion ~ and instruction course and covers "everything" given in the train-ing sessions. The OIC said that the written test is "not a cake or break" thing. If a guard has wrong answers on the test, the instruc-tor counsels the guard to attempt to solicit A, correct understar'ing of why the answer was wrong. The OIC said that a passing grade is noc established "in the true sense." If a score is not above 75%, the practice is to discuss the wrong answers to correct any miscon-ceptions. There have been no "re-takes" of examinations since he l has been OIC (July,1975). The OIC was asked for a copy of the cone.ract with Ceco and a copy ---l of the specifications established by CECO f'r classroon vork, } o ,gyg written exaninations and firearms qualification. He said the contract or purchase order was kept at Chicago and that he under-stands that guard specifications were made by CECO but he couldn't recall ever having seen them. While the OIC presented a course outline, a training maaual and a training outline for class work, l he could not produce nor recall ever having s,een specifications on the firearms qualification, e.g., number of practice rounds, number to be fired for qualification, length of range, types of targets to be used, course to Se fired (Short Course or ::ational Police Course), ~ score to be attained or the pace of firing - slow, timed, rapid. He l understands that Regulatory Guide 5.20 should ha followed for fireanns qualification but it has not been used nor has he seen it .j; since he assumed charge of the Rock Island Office. i g, The CIC denied ever giving an answer sheet to the written examina-l tion to any of the guards or letting any guards use another guard's test to assure a passing grado, lie admitted that some tests may ,;3 12 - p [. .. 3. :b e

\\ not be monitored "100% of the time" but if tilcre was any cheating, t he was not aware of it. A visit as made by an investigator to CECO Corporate offices in i Chicago to revicu a copy of the original purchase order and the specifications made to Pinkorton concerning the training require-c ents for guards prior to assignment to the Quad-Citics site. Purchase Order 1/176697 dated November 5. 1974, based upon Pinkerton Quotes of July 25 and October 11, 1974 specifics, "Provide union guard service for Quad-Cities Station from 9-1-74 to 9-1-75 in ac-cordance with U.S. AEC Regulatory Guide 1.17, ASNI N18.17,10 CFR m 4 73.50 and 10 CFR 73.60." A, hand-printed addition stated, "and CECO specification dated 7-3-74." An exhaustive scarch for. Ceco speci- ,fication dated 7-3-74 was made at CECO Corporate offices but could not be located. As previously indicated, these specifications could not be found at the Pinkertor Rock Island Office. Neither could they be located in 'ae files of Quad-Cities Station. Later, on. June 1, 1977, a document dated "7-3-74" titled "Specifications for Guard Ser-vice at Quad-Cities Station" was provided to RIII by the CECO Nuclear Security Administrator who indicated it was found in the CECO Pur-chasing ' Department. This document contairs aglist of 11 general requirements. Although it alludes to the fact that training in fire-arms and other related duties is necessary, it does not specify exactly what methods are to be used. In summary, it apocars that the assignment of a passing grade for the written exanination on the certification prcvided to Quad-Cities Station is not based upon actual test results. It also appears that assignment of a score for firearms qualification is Q-~ not based upon actual weapons firing results. There is no indica-N tion that guards have had to retake any tests or to refire on the !M fd irms range upon completion of their initial training courses. L. .xamination and fircares scores provided by the Guard Contractor .;5 are meaningless in the absence of acequate specifications and the lack of uniformity by which these scoring detgrminations are made. 1 i This is r.n item of concern which will be discussed with the licensee. l 5. ALLEGATION: Some guards did not qualify in the use of firearms ,;,A

$7 before being assigned to work at the Quad-Cities Nucicar Power i

Station. 1 da.& l AI FINDINGS: Through a review of records and interviews with an alleger and a guard, it was confirmed that at least two security force members did not qualify on fircarms before being assigned to - ~, work at the site. In both cases, however, they indicated did .~ : - e -4 l l l 1

~ s o not carry a weapon on duty until af ter tl ey received their fircarms training. One, who was hired on January 21, 1975, did not raccive firearms training and "quald fication" unt.11 late thrch 1975; another hc cd on January 12, 1975 received fircarms trainit; and "qualification" also late Fbrch 1975. In this resp 2ct, since the individuals referred to in this allo-gation were utilized as uniformed, but unarmed, members of the security.' force, both are cate' orized as "Watchmen" vbich is defined g as, "a uniformed, unarmed member of the plant security force whose sole duty is the execution of security procedures for t..e protec-tion of special nuclear materials against thef t and/or the protection of the plant against indt strial sabotage." Utilization of untchmen within the securi.y organization at Quad-Cities is provided for in the security plan with the proviso that there are at least cwo armed guards on duty on (ach shift. Other aspects of the total training program commitsents 'for these 4g particular guards, however, were not met by tha licensee and there-fore an item of noncompliance, not specifica11,y related to the context of the above allegation, was disclosed by the. inspection effort. 4 It is the understanding of the Site Security Officer that the guard contractor uas to provide all required traini g, including firearms training and qualification, before a guard-contractor employee was assigned to the site. Copies of such training are sgggg provided, sometimes af ter the fact by the guard-contractor. The TEPa whole matter of firearms qua3 ification proceduras was reviewed through interviews with the present guards and through interviews with the Guard ContYactor Officer-in-charge and r,eview of his m records. It was determined that no, detailed written specifications an to the j type, quality or content of a qualification firing course has been established between the licensee and the guard contractor. Some guards said they fired only.at c bulls-eye at slow fire, some ficed only at a silhouette, some fired at bulls-eye and ailhouette, some fired courses at slow, rapid and timed rates. Most guards, af ter fir-ing, were not told their scores or if they "qualified." Some did not fully inspect their targets. Targets wer,c turned over to the "range officer" who told them they would be notified if they quali-fled. Most guards only fired 20 practice rounds before attempting to fire a qualifying course with 30 rounds. Some guards who had I never before fired a weapon, particularly a.38 caliber revolver, C '- 2 "qualified" en their first attempt. A passing score was esta-blished at 175 out of 300. Many scored in the 200 + range on their

et t. r to had rds n io, a gu at t hat fic ed "o a ge n f i r r fo. taliy. al lo r qu tai he at qu fo t r en of of a indic to ed be io State what n s r no rde us ate ve et r ntr firing aining r r ha cr in rgets to dis t cto was o he a tr courses ta re ars the he o of afetyrd The appe eit rd c or l shed at t ta earms gu rity I mity n a s ha he gu rgets a te pt. io course t n at ni ofr m i t he m jo he at fic nufiring stab a t ut h of fir to t to ed o s of rd The ted delay st ali be pointished wit .r no e or type qu he ot n Caduty. bmit ate n io n ny of n t io rds l what let io s rdin ha su at a stab m at on ccuse fic al gu uld op fic r lic course to en o or an ensee n be in ali e c r i whe had du sho ha rde s be es rt Be indivi qu ich It uld equir Ce o es l afte The firingrds rn e." Ceco sho r ha in wh n im io ainingall t t at nor ha stateTr at rt r un ois. of gu score fic ti once a toffic i lni oising The of a rd ce llin type cto of c by r rds 3, e po s, 3".,7 of I he ntr te a r suance er Il iy he ourse ca f n t al heirState la,by m be. a n co at v qu uld t i c 'Y ry who eiv he rity leted is ca r m t a a is ry nd,ivi-p is sho e r re ca Islaind ,7 befo st fo rec r t op Th to ck suance secu u by m m rds ot e. ed Ro hat c who e of gu didn its l io. ois r n to, in sful y a at ens riz 8 t days prio .[' r rto,In.,equir l c es fic lic ho in is n Ill ut Stateheirted be t sucesi al 'the s ub-en r he ion s qu wit ot h be t e ois8 of Fiv be at P nke 'in mit st heir ed n i ln 3 i fic he to st com u t he Il i s mu t cuss ve t m rt of al r m. ish of hat ha at ois. rge State Chapte rm ar ce l ds rds du l fo i eipt ivi nd ng t stab he of s ulat aining, a i al n be a ind sta in io rec on m will Gu e r in Cha O:f Illin hat aining r rd tr the he nde N t Matricof wingrizing he e t u ca EGATI us t o e tr he e t fic his blu hat He / stated ALL State in io Fol o ho wa t urs t Of a n l t s he nt ted. to irty aining aining tet ho he The ut it, ve ficieubmit ted n rd a 6 t e ted. tr com N: Offic h stated ha uf G to r-ubmit is n ca t tr n, upo ubmit I to s s l du nt yhat FIND ois eiv a e nd th e was was a rge d al d s blu s of r in Chaindivi u en ce Illin rec aining be Codeningstate als It t be reated of a s o il sue had nt ic als al in e n tr e po.of rials c'ards ind Offic but is duCrimin beg he m he st a u o all tw e State t u w Offic t r a ate ate he to He State fo Tho r se fo ef ef ct he The t ry ficed m blu ity. he rds r e to ted ay r i ca mit hat ate, t ess rt cil t legal y ca ity. equir ed l ce visited a nec n we po.ot e cil t su fa fic he r blu fa ed is s to i t n nd he rt a ot ie s eiv ry was to a icked up e,thad nad cit had .i ce ie n rec al n rm r s it sio fo ad C e po. ot annu I ca it he s / tL~ t sses n ca Qu 7 Statehe / hat t 197,had p Qu w a n io all ve an is po ulat in t a ha n he 7 nd t he at ry s (Q ) e r / dpy Hatric hat but rds i h rds SP l 2,n a to ca a gu Apri at sign io ed ot fied gu t a / aid State he ofRegistr n re 9' o nt yi ated, d ~ s edu as i t he of ek ied nt Proc t l we nd st he a ind c io curre al y rity mo l t n ,[I ing at rdsals, he spe ie cu fic Se a ci Eudc s gu

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tw ivi fwu ad Cit o du ind TION: in Qu GAaining 15 - ALLE s. etr 7 r sis. ba . '. L a. 1 g , h i_.-

FINDINGS: Review of training records, which had the individuals signatures affixed, revealed that one individual was initially trained on May 30, 1975 and that retraining occurred on April 14, 1976 and April 7, 1977. The second individual's rc ords showed that initial training'was conducted on February 5,1976, and that retraining occurred on April 8, 1976, and April 7, 1977. 8. ' ALLEGATI0N: Guard personnel have been promoted to supervisory posi-tions, Sctgeant and Lieutenant, without adequate training. FINDING: The personnel in supervisory positions indicated that they had received no specific training for their position. The Guard Lieutenant stated that he had previous police experience before being employed by Pinkerton and had worked for Pinkerton for about one conth before being assigned as a guard at Quad-Cities Nuclear Power Station. He indicated that when he was assigned to the site as a guard it was with the understanding that after a short period of famili'arization of that operation he would be placed in charge. The Guard Lieutenant indicated that he selecto, guards for promotion to sergeant. This selection is based upon his observations.of their performance and their interest in the work. He indicated that he quizzes them orally to detereine whether they possess the knoQ1 edge necessary to perform as a sergeant. He makes his recommendations to the Of ficer-in-Charge of the Rock Island office who makes the final decision regarding promotions. The Lieutenant advised that the licensee was not involved in the selection of guard supervisory personnel. g 9. ALLEGATION: The physical examination for guards is inadequate and one guard is not phys,1cally fit to perform the, du, ties of a guard. ,4 a l FINDING: A certification signed by the examining physician is furn-ished to the licensee by Pinkerton for each guard assigned to the site. This certification states the individual examined "... is et capable of exerting moderate physical activity under emergency situ-1 F4 ations and is capable of conducting all required surveillance '~ activities within the range of environmental conditions likely to be encountered at a nuclear site." Attached as Exhibit D is a copy of the certificacion form. ~ Through a review of the licensee's files,'it was ascertained that fjy such' certification was received from Pinkerton regarding the guard I ~' ' whom it was alleged was not physically fit to perform the dutics of 2r a guard. Through interview with the guard in question it was ascertained that this guard performs patrols as well as the other assignmente which require some physical excreion. l }.a 1 s l

10. ALLEGATION: Two individuals who have worked as cuards at the Quad-Cities Nuclear Power Station have been patients in a mental iuscitution and one has an arrest record. FINDING: One of the allegers, who had been a guard at the site, stated that he had been treated for depression as a patient at a mental institution during two periods of time, once in 1962 and again in 1963. A review of this individual's employment applicatica at the Pinkerton Rock Island office revealed that he had entered a r.cgative response to that question on his employment application. The Officer-in-Charge at the Pinkerton Rock Island office stated that the pre-employ-ment checks made on applicants for guard positions covers only the ~ previous ten year period. The other guard identified by the alleger as having been a patient in a mental institution and as having an arrest record was intervieved. He stated that on one occasion, while hospitalized, he was seen by a psychiatrist who informed him he did not require psychotherapy. He stated that he was not a patient in the psychiatric section at the time he was hospitalized and had never been treated for mental illness. Regarding an arrest record, the guard stated 'that he was once arrested as a juvenil.e for assault. He stated that at 'the time he filed his application for employment with Pinkerten these matters were discussed orally with the Of ficer-in-Charge and he was informed that they would not disqualify him. e 11. ALLEGATION: Guards sometimes sleep while on duty. ) FINDINGS: Through interviews with thirteen of the fourteen site j$d[ guarde ubo were available at the time of this investigation, eight indicated they observed that occasionally, on back shifts in parti-li cular, some guards were seen to be "dozing" or "resting their ~ eyes." Only one of these eight guards stated that he found one guard fast asleep on a manned post but, in mi,tigation, of f ered that this guard had worked an 80 hour plus work week. Five of the guards said they had not observed any other guards dozing or asleep either in the main gate house or on a manned post. The consensus ,,A'l was that there was always one or more of the guards in the main 15bl gate house fully awake at all times since the alarm and CCTV )[fl console operation is an integral part of the security protection i system. Some guards mentioned that a few guards who were prone to "doze" or consistently "rest their eyes" had 'ucen discharged. Pinkerton guard manual polic'y' states that guards found asleep on duty are subject to discharge. CECO has not pronulgated a policy on this matter and has lef t it to the discretion of the Guard Contractor to take appropriate disciplinary action. This matter, q ' s gv.v y '..

while not an item of noncompliance, is bewever, a serious item of concern to the NRC which will be discussed further with CECO manage-ment.

12. ALLEGATION: During the Memorial Day weekend in 1976 the guards walked out and only one armed guard remained to protect the site.

FINDINGS: The licensee is conc itted to having two armed guards onsite at all times. To augment the guard force during the Memorial Day weekend, May 29-31, 1976, a trained and qualified guard was sent to the Quad-Citics site on May 28 from CECO's Dresden Station, Morris, Illinois.

• Because'of a dispute between the guard centractor and its employees, all but one of the regularly assigned guards failed to report for work on the morning of Saturday, May 29th, for the 8 a.m. shift.

The Dresden guard reported for the 8 a.m. shift and worked with the regular site guard (the Pinkerton Captain) until 8 p.m'. on the evening of lby 29. To supplement the two guards during this weekend, records. show. that CECO employces, including the office manager, the site security officer and members of the technical staff, assis:ed in the monitoring of security devices and conduc' ting patrols throughout Saturday and part of Sunday at various overlapping times. In

addition, crangements were made to have the off-duty armed Rock Island County Deputy Sheriff near or in the main gate house for l

periods of 1 p.m to 9 p.m. Saturday, 9 p.m. Saturday to 6 a.m. I Sunday and 1 p.m. to 9 p.m. on Sunday. l While efforts were being made to encourage site guards to return to 'gMq% wor.k, the site was manned by the Pinkerten Captain on Saturday froc

VM 8 a.m until Sunday at 4 a.m., and the Dresden-assigned guard on Saturday f rom 8 a.m. until 8 p.m. when she lef t the site.

At that point in time. (8 p.m. Saturday until 2 a.m.'on Sunday), - a six-j hour period - armed guard protection was afforded by the Pinkerton l Captain an.i a Deputy Sheriff. After a late Saturday night meeting l vas held with the reguisr site guards and a settlement reached, two l of the regularly-assigned guards reported for duty at 2 a.m. on 9 j Sunday, iby 30. The Guard Captain, according to the records, did j not leave the site until 4 a.m. on Sunday. The Shift tog records ,y_ yh?2 indicate that two or more regularly-assigned site guards were on M duty for the balance of the Memorial Day veckend. Normal guard shift complements were supplemented by threc additional guards from Wh. Dresden Station for part of the following week until the licensee 3.[ was assured that the regular guard force was going to remain on ,.g duty. The licensee, in a Ictter dated Junq 2,1976, advised RIII of the Juhd ' walkout of guards and provided information regarding the contin-gency measures taken. The licencee considered that with.the 1 - y i

presence of the Guard Captain and an armed Deputy Sherif f, sup-plemented by CECO staff employees, security at the pl.7nt was not severcly downgraded. The allegation that only one armed guard was present to protect the sito during the Memorial Day weekend is not substantiated by the investigation findings. For an approximately six-hour period from 8 p.m. Saturday, May 29, until 2 a.n. Sunday, May 30 when two of the regular site guards teturned to duty, the presence of the Captain of the guard force supplemented by an armed Deputy Sheriff satisfied the requirement for two armed personnel to protect the site. 13 ALLEGATION: Guard personnel frequently work sixty or more bours per week. FINDINGS: Through interviews with guard personnel it was ascertained that guards do work 12 hour shifts 5-7 days per week during reactor shutlown periods. Guards indicated that while they were not forced to work more than 40 hours per week, it was understood that this was expected of them. 14. ALLEGATION: Weapons at the site have never been fired and the cupply of ammunition is inadequate. ', 4 FINDING: Through interview < with guards and guard supervisory person-nel, it was determined that-the five pistols on hand at the site have not been fired. They have not been used on the firing range. While the weapons appear to be operable there has been no use of them to protide assurance of their operability and effectiveness. The weapons are cleaned and maintained on a weekly basis. Each weapon is leaded with five rounds of ammunition ar.d one box of about 50 rounds is stored in the guardhouse. The ammunition has not been regularly rotated but was replaced once during the past year. No other weapons are available at the site. 15. ALLEGATION: Quad-Cities Station Security Pro,'cedures (QSP) need updating. FINDINGS: An interview with the Station Security Officer and a review of his records was conducted on April 27, 1977, to deter-mine if a security plan commitment which requires periodic review of procedures, was being met. The requirement of an annual review of the QSP was met in that a review and updating of the procedures was conducted during April 1976. l In addition to that formal review, the presently utilized proce-dures were revised and updated more recently. All procedures now 1 l e Le 3 e

l i l i being used were approved on one of the following dates: October 5, 1976; January 6, 1977 cr !! arch 15, 1977. I During the cource of the security inspection conducted during April 26-28 and !!ay 2-6, 1977, cach of the procedures was reviewed to determine their currentness and completeness. This review showed that, in some instances, outdated information was contained in some procedures. Conversely, it was noted that certain recently instituted "procedures," which the guard foa 3 was actually adher-ing to, were not included in the formal QSP but rather were included in a "Temporary Procedure and Orders" book. The licensee had initiated an extensive program for procedure review and updating as a result of the pending icplementacion of new Federal Regulations for security at nuclear power plants. This regulation was published in the Federal Register on February 24, 1977 to become ef fective :'.ay 25, 1977. ?! cabers of both the Stat.on and Corporate of fice are completing these revisions.

16. ALLEGATION: An identified former Guard, while employed at the site.

l took floor plan drawings and five pages of the Quad-Citics Security Procedures (QSP) from the site. I 4 FINDINGS: The alleger was unable to specify exactly which "floor plan drawings" were taken from the site. However, interviews with l Station employees indicated that "drawings" (floor plan and techni-cal) are essential for many members of the staf f to properly perfor: their duties. There are many such drawings that exist which do not specifically relate to security equ hment or programs. The t - Quad-Cities Final Saf ety Analysis Report (FSAR) contains many such l "floor plan drawings." The Quad-Cities FSAR is a matter of public 'J __ record and can be viewed in local public document rooms. In this I case, the FSAR has been availabic to the public for appro:<imately l 3 five years. The Quad-Cities Security Procedures (QSP) have a limited distribu-I tion. One copy is maintained in tha site ga'ehouse for use by the t Security Force. Interviews with guards, who have been assigned i IN at the site for sometime, indicated that they have never noticed iN pages from the QSP "missing." llowever, some did indicate that'on ,f certain occasions, maps, which are included in the QSP, have been .,t reproduced. The inspector was directed to the Pinkerton "Shif t [ *'*g Officer's Reports" where an entry on the report dated Deceuber 16, j 1976, (0001-1600 shift) which showed: "Special Serv - Copics Run Off: Operating,I!aintenance, Ir.ncr Patrol Sheets, Peterson, Haps, j S.O. Reports." ,,M m t I.p e hO e= 6 *

J 's e

l f

.i o The Pinkerton Lieutenant indicated that it was not uncommon for a Shift Sergeant to reproduce copics of necded forms. (In the above entry, all listed items are blank forms used by the security force except for "> bps."). The Lieutenant produced copies of the maps which had been xeroxed. They were reproduced it crder to provide newly assigned guards diagrams needed in order to more completely understand their duties and patrol routes. The Lieutenant had numbered each of the four maps and was intending gg to issue them to new guards, by number, under signature. + Apparently, one of the Shif t Sergeants had made copies of the "Lieutenants numbered maps" and given them to the, then, two newly assigned guards (the alleger and a presently euployed guard). 'At the time of this investigation, the Lieutenant indicated that he had apparently acccunted for all map copies (those he had made i and those the Shif t Sergeant had made) except one, that being the l copy which the Shif t Sergeant had given the alleger. The prac-l tice of reproducing maps for guards has now been discontinued. l It should be noted that the maps in question show the following: (a) A diagram of the Restricted Area and Prot'ected Area with some l t building names; (b) a diagram of the Protected Area ;erimeter with gates lettered; (c) a general diagram of the entire cite; and (d) a diagram identifying exterior plant doors. This Lnformation could be obtained by direct visual observation from cutside the protected area. 93E] 17. ALLEGATION: An identified guard took the keys to vital area doors Jg; home and retained them for two days. l 1 1 i FINDINGS: A review of the guard force "Shift Officer's Reports" "" I showed that on February 17, 1977, during the midnight shift (0001-0800), a notation was made which indicated that a set of guard 9$8E' keys was discovered missing. These keys are issued to the guard force to enable them to properly perform their duties. This i notation was made by a Sergeant who was intetviewed. He iadicated -asa that when the keys were discovered missi.1g an immediate search of }{24 the guardhouse and extra guard coats was conducted. He also initiated l Jg?Q a search of the possible locations, on the site, where the keys might l have been lost (along guard's patrol route). A series of telephone l calls was also made to determine if any of the guards who had just cese l off duty had the keys. He indicated that they were all contacted / except one. The "Shif t Of ficers Reporte" for subsequent guard shif ts also con-tain notations that the keys were missing. Repeated attempts to j contact the one guard who had not been previously contacted failed.' l

l j l The Station Security officer stated that the key set which was found missing did not include a key to vital area doors, but did include a key that would open locks on protected area perimeter gates. Ile had those locks changed on February 17-18, 1977. ~~ The icgs indicate that the keys were returned during the day shift (0800-1600) on February 18, 1977, by the guard who had taken them off site when he discover 2d t. hat he had the keys. He was the guard who could not be contacted earlier bec:use he was out of town. 18. A11ECATION: A guard demonstrated that a vital area door could be opened with a pocket knife. The matter was reported but nothing was done. FINDINGS: A review of applicable records was conducted for the general period specified by the alleger. A check of the "Weekly Security System Electronic Surveillance Test Checklist" showed that on March 6, 1976, an additional handwritten report,' addressed to the Station Security Officer, was completed by the Pinkerton Shift Sergeant. This report indicates the Shif t Sergeant had 'been informed.by a l guard that it was possible to get through the fo11owing doors with a pocket knife: (1) "the blowdown building, the new building, west of the boiler building" and (2) "Trackway 2 West doors." The reper: also mentions that the guard "would be happy to. . show you the thing with the doors." HOTE: (1) above, is not a vital area door; (2) is a sital area door. During an interview with the Station Security Of ficer on May 4, 1977, he indicated that he did not recall the specif'ic report or the specific action taken regarding those, door locks, but did say that on occasion work is done without being documented by a "Work Request." A further review of the Station Security Officer's records showed that the first indication of a "Work Request" being issued regard-g ing the "Trackway 2" door was on Hay 10. 1976. Work Request No. 1822-76 states: "uitch Mechanism Faulty and Heeds Work On Door Closure Mechanism." This "Work Request" indicates that this work was complete by May 12, 1976. J '(. During u Physical Protection Inspection conducted by RIII cn ~ Noveober 10-12, 1976, an NRC inspector was able to gain entry to the Unit 2 Trackway by retracting the bolt from the strike using

• g a'picco of wire.

The licensee responded to that finding and Indicated that Work Requests had been issued to modify the locks - M O h

~ and that this work would be accomplished before February, 1977. During the most recent Physical Protection Inspection, this door and locking mechanism were inspceted and found to be adequate. 19. ALLEGATION: A door leading from the roof to a corridor at the vest end of the control room is not locked. FINDINGS: As stated, this door is not caintained in a locked con-dition. This particular door is part of the Service Building barrier which is not considered a vital area as defined in the Security ?lan. Also, there was an indication on the part of one alleger that there may be an unsecure door within the radwaste area that leads to vital equipment. The radwaste area was inspected by an NRC inspector and vital area doors were found to be secured as required by the Security Plan. The door described by th,e alleger was located and it was determined that this door dces not provide a means of access into a vital area. 20. ALLEGATION: A penetration test of the ; erimeter alarm system den-onstrated that Zones 1 through 6 were i 4'fedtive. This was reported but there were no corrective actions #taken. l FINDINGS: A review of the "t?eekly Security System Electronic Surveillance Test Checklist" dated March 6,1976, was conducted. The checklist, as verified by a guard Sergeant's signature, t indicated that infrared and nicrowave :enes 1 threugh 19 were 1pE1 operable and that overall security system perfor.cnce was accept-y79 abic. Handwritten notes dated !!:rch 6, 1976 by the Sergeant, 7- ~" however, appear not to support the findings indicated on the checklist. The Sergeant's notes indicate tha,t successful pene-( trations o! the surveillance system were made thrcugh zones 2, .t 3, 4, 6, 10 and 11. As indicated in the Security Of f.f eer's "'.'ork,' Request Is.ued" log, corrective action was taken on !! arch 8,1976, by initiating !!ork 'sw. Request No. 913-76. The work request generally required that .[p'a$[ irregularitics in the protected area infrared' zones be corrected. l Specific zones or work performed could not be decorsined since attached sheets of the work request could not be located. The above work request was completed on April 8, 1976. During this period two patrols per 8-hour shift were perforced as required when this condition exists. g l If$h Accord.ng to the Security Of ficer, the following policy (not written) has been in effect for a year or more. On Monday mornings, the l . s. y,., ici' " l l l

results of the weekend Security System Electronic Surveillance Test are reviewed by the Security Officer. If any anomalics or defici-encies are noted, he then reproduces a copy.of the test results and forwards them to the Company's Instrument Mechanic Supervisor for corrective action. 21. ALLEGATION: A damaged vital area door was left unguarded for 3's days I until it was repaired. FINDINGS: This allegation was first brought to the attention of the licensee's Corpor.2te Of fice on approximately February 21 and 24, 1977. The alleger was again interviewed by the licensee on February 25, 1977. The licensee conducted an investigation of this item, among others, during the perisd !! arch 2-8, 1977. This report indicates ' t he. t this particular door was first reported damaged at about 4:00 p.m. on "January 27, 1977," however, the door, at that time, was still able to be locked. (A review of licensee records show that the first contion of this door being broken was "January 28, 1977, 1600-2400 hrs"). The licensee's report indicates that on January 29, 1977, the door had now.he:.e.c "practically inoperable." Apparently the guard force was then instructed to check the door during,their patrols (each tro hours) to insure that it was secure. Subsequently, on January 31, 1977, a guard was posted (other records shov that a guard was posted beginning ati nidnight on January 31/ February 1). An independent review of licensee records showed that the door was reported damaged during the 3rd shift (1600-2400) on January 28, 1977. There was no cention of crrrective action at that time. The "Shift Officer's Report" for January 31, 1977 (0300-1600) indicated that a guard was sent to the door at 0830 hours. It could not be deter =ined 3 if this guard re.,ained there. The "Security Service Report" (Pinkcr:en Form 286B) for the 3rd shift on January 31 shcus "Guard on. . dccr due to repairs being made on it." These records show that the doer was 'f probably repaired by 1430 hours on February 1,1977 and that guards had been posted until then. Representatives of the licensee could add no other substantial information, i It appears that the door was guarded for a portion of the time it was };3 "damaged," however, no actual information could be found that would .Cy;. indicate that the door was "unsecure" and unguarded. 22. ALLEGATION: Gate.No. 28 was in need of repair for an extended peried } of time. FINDING: A review of records' revealed that Cate 28 remained in o damaged condition from at 1 cast January 1, 1977 to March 9, 1977 . I 3 .3

{N

\\ possibly a longer period of time. It was determinud, however, that Cate No. 28 is not located in the protected area fence line and is not of security significance. 23. ALLEGATION: Zones 7 and 10 of the perimeter alarm system were not functioning for two or three months and Zone I was not operational ~! for a longer period. FINDINGS: Between the weeks of May 31, 1976 and April 23, 1977 (a period of 47 weeks) Zone 1 (1) of the system was inoperative; between the weeks of December 25, 1976 and April 23, 1977 (a period of 19 weeks) alarm Zone seven (7) was inoperative for 17 weeks. The licensee was not cited with an item of noncompliance because of the following compensatory measure in the approved security plan: "If either the intrusion alarm system or the television system is out of service, patrols are made at irregular intervals no less frequently than twice per eight hour shift." Interviews with guard force personnel and reviews of patrol records disclosed that the above patrol frequency is adhered to. ~ .'y - 24. ALLEGATION: The metal detector in the Guardhouse does not function . ~... properly in that it did not detect the presence of a weapon on a guard's person when he tested its sensitivity'y FINDINGS: Interviews with security force and scaintenance person-nel indicated that during some tests performed on the metal detector, discrepancies have been found in the detector's sensitivity and ability to detect metal objects. These individuals indicated that whenever an anamoly is discovered, corrective action is taken "3Lgp to readjust the detector sensitivity. .E The metal detector was tested on approximately five dif ferent occasions during this inspection. On each occasion the detector n functioned properly. h

25. ALLEGATION: Portable radios carried by guards on patrol do not y

provide an adequate means of communications, In that, there is interference from off-site transmissions and the equipment is unreliabic. 3 FINDINGS: Shift Officers' Reports reviewed identified many occasionE when portable radios did not function properly and, in some instances. l it appeared that inadequate maintenance may have been the cause for equipment unreliability. Interviews with currently employed guard.; (as of }!ay 6, 1977) also revealed that on occasion they have had dif ficulty receiving and transmitting with the presently-employe ! w radios. 9 y - [ l i2 l ( I

26. ALLEGATION: The public address system in Tr'ackway 2 cannot be heard. FINDING: Several guards stated that the noise icvel in the Trackway 2 area near the guard post made the PA system ineffective. It was stated, however, that there are two telephones in the area whose ring could be ~ heard. This provides an adequate means of communicating with guards stationed there. Also, any emergency evacuation alarms could be heard in that area. 27. ALLEGATION: An unauthorized individual, a Guard Sargeant, had authorized the entry of a private vehicle to the protected area for use in conducting guard patrols. 4 FINDINGS: An extensive review of "Quad-Citics Station Vehicle Access Logs" was conducted. These records showad that guard force personnel had entered the protected area with privately owned vehicles to conduct patrols on January 28-29, 1977. On these dates, logs indicate that on 5 occasions private vehicles were brpught into the protected area 'to "Make Round and Alana Respcnse" or "To Make Patrols" or "Rounds." Each of these entries includes a "Authorized By" and "Guard Signatdre." I N-The names which appear in the "Authorized By" section were compared j(j! with the names of persons who actually have the ability to author-ize vehicle access. In all instances, the names appearing on the records, were in fact thosa who are allowed to authorize vehicle access. ' ] The space on the form titled "Guard, Signature" is used to indicate gp which guard actually allows, but not authorizes, a vehicle to enter the protected area. Procedures call for an authorization to be obtained prior to allowing the vehicle entry. The records appear to indiccte that of tha five entries, two guard Sergeants had allowed .g entry. ggg Intervieus with these individuals indicated that they could not specifically remember these particular instances, however, both g;i. g mentioned that they do not have the ability to "authorize" access ggg3-and are careful to get permission for a vehicle to enter from someone who is authorized. They stated that they probably did got proper permission f rom an authorized person. SE 28. ALLEGATION: On March 22 or 23, 1977, a delivery truck, without license plates, and whose driver provided no identification, was l permitted to enter the protected area. ( - '. ;A l 3 WA ,...wi

FINDINGS: During the interview with the all'eger, he specified that although he could not remember the can's name, he did recall the name of the company which employed him. The "Quad-Citics Station Vehicic Access Logs" were reviewed and two entries appear for that company during the period March 19-24, 1977. The first entry, March 21, 1977 (0930-0940 hrs) was partially completed by the alleger (who was then a security guard). This entry shows (1) name; (2) company name; (3) type of vehicle; (4) license number; (5) purpose of entry; (6) authorized by; (7) time in and out; and (8) guard signatures. All of the information contained in this entry appears authentic. It shows that, in this case, the individual vehicle was authorized entry by the Station Security Officer and it does show the vehicle's state license number. The second entry, !! arch 23, 1977 (0927-0940) was completed by guards other than the alleger. This entry also' includes the above l'sted information including a vehicle license number and signa-tures. In this case the vehicle was authorized entry by a member 3 .of station canagement. 4 The "Quad-Cities Station Visitor Admittance R'ecords" were also reviewed to determine if the individuals who were driving the above listed vehicles were properly iden:ified and authorized l admittance. The entries in the "Visitors Logs" substantiate and catch the infornation included on the ""ehicle Log." In l addition, in each case, a social security number appears for l each individual. These numbers were verified by catching them with nu:.ibers found in entries which pre-dated and post-dated the W above mentioned cntries. 1?" l' "3

29. ALLEGATION: Delivery vehicles whose drivers have not been issued photo l

badges are not alueys escorted while within the protected area and l authorization for their entry is not always obtained fr,m storeroom personnel. I 4 FINDING: Information obtained through interviews with guard person-W nel indicated that guards normally escort such vehicios to the. store-1 room or at least keep them under visual surveillance until an employee .M;1 of the storeroom acknowledges that he has assumed that responsibility. i ' W Nona of the guards said that they were aware of any occasions when a delivery truck was permitted entry without approval being obtained frora the storcroom or when a truck was not kept under at least visual j y j Q surveillance. t ., t} u ,.. ) s q s a 1 1 1 l

s 30. ALLEGATION: Visitors arc permitted to enter the protected area without being required to show any identification. FINDING: All of the guards interviewed stated they usually request a visitor to show his driver's license. Some guards indicated that they have accepted a business card f rom a visitor as a means of identifica-tion. In all cases the person to be visited is contacted to approve the visitor's admittance. 31. ALLEGATION: Searches of all personnel and vehicles entering and leaving the protected area are performed only once a month. During these periods the searches are ineffectiv.e in that all vehicles and handcarried packages are not searched and some personnel are permitted to proceed

• without further checking when the.y trigger the metal detector.

FINDING: The licensee's security plan contains a comnitnent that these searches will be conducted monthly. At the time of this, inspection / investigation the licensee was not required to perforn'these searches more frequently. Informa' tion obtained during interviews with guar'd personnel indicated that during heavy traffic periods, such as dur,ing shift changes, it is practically impossible to thoroughly search every person, parcel cnd vehicle. The physical layout of the guardhouse does not lend itself to effective control of tne personnel and bandcarried items at such times. The guards indicated that they do the best they can but stated that soma l packages and vehicles escape being searched. They also advised that some personnel who have triggered the metal detector vere not subse-9l@l( quently searched with a hand held metal detector before they proceeded ));; into or out of the protected area.,They also stated that enployees have on occasion triggered the metal detector because of the metal in the safety shoes they were wearing, but this.was.not aleays confirmed by subsequent checking with a hand held metal detector. 3?. ALLEGATION: Picture budges have remained in the badge rack long o - af ter their expiration date and employees hav,e taken badges hone and 4s - lost them, f FINDING: During the period of May 2-6, 1977, inspectors examined approximately 60% of the badges present in the racks. None of the badges had expired dates on them. Badge issuance records showed '^ all badges which expiro during a given conth, are marked in order to c notify the employee that a new badge must be issued. The badges are removed from the rack when they have expired. Interviews with security organization personnel indicated that on some isolated occasiens, employees have departed the site without turning .in their badges. However, the badge, in most cases, is returned when e p-kb

f s the employce reali::cs that the badge is in his (her) possession. To prevent badges from being removed and used in an unauthorized manner, certain procedures are used to determine if all badges have been returned. The guards _ who are responsibic for impicmenting these pro-cedures indicated that they have successf ully identificd the f act that badges had been inadvertently removed and they were successful in obtaining the return of the badges. The licensee has initiated addi-tional procedures to determine the frequency of this occurrc.nce. Badges have, on occasion, been lost by employees on site. The employee 4; is required to report the loss to his.(her) supervisor or security guard.- Interviews with station personnel and guards indicate that they are cognizant of these procedures and, when badges have been lost, the procedures have been followed. 33. ALLEGATION: On two specific occasions, contractor personnel entered the site intoxicated and on another occasion, contractor personnel who had apparently been drinking, engaged in a fight. FINDING: The Sergeat.t, who was identified as having permitted the contractor personnel entry on the first two o,ccasions stated he had no recollection of either incident and tha,t he had never seen any intoxicated personnel enter the premises. He indicated that on the date of the first alleged occurrence, one of the contractors had sent some men home soon after they had reported for work. He also stated at the time of the second alleged occurrence all personnel were required to pass through the metal detector and any beer cans on thtir person, as t allegad, would have been detected. He stated he had no knowledge of g anyone being found attempting to enter with cans of beer in their -r j possescion. .p i l' Regarding the third occurrence, it was ascertained during interview that the alleger did not see anyone drinking but he said he had smelled alcohol on the workmen's breath. It was determined guard personnel had prepared reports on the matter of the fight.. Based on these reports, the guard lieutenant had prepared a report ubich was submitted to the Quad-Citics Security Officer. The contractor terminated the employmer.t of eight men who were involved the same day. v R Licensee management stated that the drinking of intoxicants on the ! C site is not permitted. If it appears that a contractor employee is intoxicated, the matter is brought to the attention of the contrac-tor foreman for handling. In the case of a licensee employce, administrative measures arc.cmployed to assure that the employce is-l not permitted to perform any'dutics which would result in his being a hazard to himscif or others. ~ l.. ' .. y i g s' \\M

34. ALLEGATION: Camera monitoring of the protected area is inerfcctive ) as demonstrated by an instance in which two employees clic. bed the fence and were not scen by the guard at the monitor. FINDINGS: Interviews were conducted with the two employees on May 5, 1977. They both admitted that they had climbed the fence. ~! According to bath individuals they, as maintenance men, were sont out to repair zone 10 of the perimeter surveillance system. They described zone 10 as an isolated area in which access can only be gained by way of a gate in the fence adjacent to the zone or from the river side. They stated that after a guard had let them out through the gate, he locked it and departed from the immediate area. According to the two maintenance men, an arrangement had been made with the guard in the gatchouse, who was monitoring the surveillance system, that a maintenance man would use a hand signal directed at the camera when they were through repairing the system, The guard monitoring the surveillance system would then dispatch ano-i ther guard who would let the maintenance men back into the protected area. i Apparently, at some point in time, the camera was directed to another g section of the perimeter and never returned to survey the area where the maintenance men were working. After repair of the zone was effec-l ted, the maintenance men noticed that the camera was not surveying the area in which they were located.. They then decided to climb the fence and ucra able to enter the area undetected. i It should be noted that the camera surveillance system is utilized l f to immediately observe an area where an aldrm has been triggered by the perimeter detection system. l l J2W4 fo

35. ALLEGATION: Uniforacd and non-uniformed police who have entered the

'5" protected area have not been required to check their weapons at the ]ggg guardhouse. U $50 FINDINGS: The licensee advised the lau enforcement personnel have [kbb on occasion visited the site and have kept their weapons in their jgg possession. Neither the licensee's Security Plan nor their security I procedures contained any commitment in this regard. NRC security requirements do not prohibit the entry of armed law enforcement per-i sonnel.

36. ALLEGATION:

Extra patrols are sometimes made and some of the guard patrol sheets are discarded. .e. ,3.. A s l

FINDING: A review was made of Inner Patrol. Sheets for a one month period and were cross-checked with clock tapes to determine if all patrol sheets were on file. It was determined that extra inner patrol sheets were on occasion made over and above the committed-to two patrols per eight hour shift. Of approximately 188 patrols recorded by watch clock tapes during the month of March 1977, only two patrol sheet 4 could not be located. 37. ALLEGATION: On February 21, 1977, an identified licensee employee called an identified Guard Sergeant, tipping him off that a ~ penetra-tion test of an alarm zone would be made between 6:30 a.m. and 7:30 a.m. that day. FINDING: An examination of records showed that a penetration test was conducted by the Guard Lieutenant on that date. During tele-phone interviews with the two identified individuals on June 15, 1977, both denied the allegation. 38. ALLEGATION: An article appeared in one of the Quad-Cities news-papers which contained detailed information regardi+ the security prott :: tion program at the site. FINDINGS: A ' newspaper article appeared in thN Quad-Cities Times on March 18, 1977. The article generally described the visual features of the perimeter detection system by outlining the meaning of red and green indicators which illuminate on a display board within the control room under varying security situations.

Also, the article contained a statement apparently made by the licensee's l

Security Officer which inferred that when there is steam and fug I '-~ vapor from the spray canals, an individual would not.be detected by l ,.a the detection system. Other security program information identified l c in the article indicated that periodic unannounced searches of plant l employees were being conducted. A copy of the article was obtained a=i and is attached to this report as Exhibit E.

39. ALLEGATION: The licensee knows in advance kh'en inspections will be made by the NRC.

m-l FINDING: None of the personnel interviewed, including the allegers, j d provided specific instances or information that would support this y allegation. Several guards stated that personnel at the site would l ~f" anticipate that an inspection would take. place soon after learning that one of the other licensec's plants had been inspected by the NRC. l A review of the dates when security inspections were conducted at the l 'licensec's Dresden, Zion and Quad-Cities facilities revealed that no ! h-pattern was followed in performing these inspections. Licensco nunage-l ment denied thtt they had received any advance information regarding lp a ~ 31 - l 1 v r l Q') l

NRC inspections with the exception of some inpcetions, other than security inspections, which have been made cc an announced basis. 40. The following additional security related al:cgations were also investigated. All resulted in items of nonc:mpliance.ehich are outlined in the Details section of the inspection Report. (a) Keys to locks used for other purposes can also open security locks. (b) While Gate A, located adjacent to the gnardhouse, was inopera-ble for two or three days, a guard was not posted there to control access and control of access from inside.the guardhouse is inadequate. (c) Personnel not authorized unescorted access to vital areas have had keys to those areas in their possession. (d) Identification badges were not worn or are hidden from view by.mployees and/or contractor empi yees. (e) Guards do not always res, and to alams TV surveillance of the alarming zone fad's to determine the cause of the alare. l l (f) Vital area doors are frequently lef t open and are sometimes found tied or propped open. (g) Some guards did not receive required training before being assigned to work at the Quad-Citics Nuclear Power Station. ( D . One guard never received training in Quad-Cities Security (h) ~' Procedures (QSP). i ? Plant Operations: The following allegations were made concerning various aspects of the ftations Operations and vert. deriyed from interviews with i five fomer guards and the letter to Senator Percy: g One alleger expressed the following concerns: MS$ q 1. There were Icaks in valves and water present on the floor in the 5th crib house, boiler room and lift station. This is not an unusual condition and is considered to be of no ,y. safety significance with respect to reactor operations. y 1 2. The dif fuser gates at the sampic house were frozen and could not bc j opened. a_ -.. A I* ed ,4

RIII was aware of this conditiun. This gate is involved in the discharge of water to the river. While this.vas an operatin; dif ficulty, alternate methods were available and were utilized to make discharges to the river. 3. Green and black hoses were strung across the flume bridge over to the sample building. RIII was aware that this condition existed and it was due to the unusually severe winter. The radwaste discharge line to the south diffuser was frozen. A temporary line was run from the valve pit to the south dif fuser until frozen lines were returned to service. 4. At the hydrogen farm the door of a control box was left open exposing the gauges to bad weather. While it was confirmed that the door has been left open at times, this does not affect the operation of the plant,and is.not con-sidered a safety related catter. 5. Housekeeping should be better. i During inspections conducted by RIII between C'ctober and Decenber 1976, housekeeping problems were identified when Unit 1 and 2 were in refueling outages. Improvements in housekeeping vere observed during inspections conducted in January 1977. 6. Recirculation pumps seals were blown on February 12, 1977, a.d operations maintenance performance was poor. g It was determined that on February 12, 1977, Unit I was shutdown to ef. d. .epair a failed inboard seal on reactor circulation pump 1A. Tbc repairs were completed on February 34, 1977. ' This equipment f ailure is not a reportable matter. 7. On February 22, 1977, there was acid on the floor incide the Trackway #1 door and it was about two hours bcfore maintenance personnel put baking soda on it. The Shif t Engineers' l.og entries shoved the 1/2A acid pump was t.aken @UN out of service at 11:15 p.n. on February 21, 1977 for maintenance and was returned to service at 4:00 a.m. on February 22, 1977. This was the apparent cause of the acid on the floor. This matter is not considered to be of safety significance with respect to reactor, g .j < operations. .-T ' ~ A .ee .'A

g a 8. On February 28, 1977, the floor drain and waste collector were not functioning properly. During the period indicated, some difficulties were being experienced with floor drain and waste collector filters that resulted in reduc:d life for the radwaste domineralizers. The station had a higher than usual water inventory at this time and this, coupled with the reduced release rate of treated wastes via the canal blowdown created an operating inconvenience. Licensee personnel indicated that such probicas occur from time to time. This matter is not reportable. 9. In late March 1977, there was a crack in the water feedline to Unit 1 and there were other cracks in the reactor. 4 On March 24, 1977, during an inservice inspection while Unit 1 was down for a refueling outage, a small crack was identified on a 4" bypass line stub in the primary coolant recirculation system. No other crack indications have been found. The identified crack was reported by telephone to RIII on March 24, 1977, and was sub-sequently the subject of Reportable Occurrence No. 50-254/77-13 submitted to RIII by the licensee. ( 4 10. In March 1977, a compressor door was blown. On March 12, 1977, after maintenance was perforced, the torus and drywell were pressurized to 48 lbs..The licensee proceeded to blow down containment through a 2" vent line exhaust fan and filter uhich l contains a door. An 18" valve was opened to vent more quickly and the door was blown open because of the higher pressure. This is not I Ejbf considered a reportable occurrence.. lf

r-

11. Many fish are killed.

4 am The impingement of fish is monitored and an inventory of fish entrap-9fE* ped on the intake structure is inventoried twice each week. A semi-annual report submitted as required to the NRC by Salco Environ-7 ( mental Sciences, a licensee contractor, includes data on the number eea of fish killed. N.

12. Another alleger stated that on occasion he had observed everyone in the reactor control room asleep when he entered it during a patrol.

e" All guard personnel interviewed were questioned as to whether they had ever observed personnel in the control room asleep or apparently l asicep. One guard stated he had seen an equipment operator, not a l reactor operator, with his head down on a desk, apparently asicep. One other guard stated he had seen 'a. reactor operator sitting with 1 5 . '... W ' ' m.

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~ i his eyes closed but he could not say whether.hc was sleeping. In neither case were the guards abic to identify the individual nor did they recall whether the reactor was operating at the cine. No other instances of personnel possibly sleeping in the control room were noted by guard personnel. ~ Radiation Protection: Durir.g the interviews additional allegations also were,made relating to matters other than security. Those allegations relating to radiation protection were referred to RIII pei sonnel who con-ducted an inspection of the radiation protection program during the period April 18-22 and 27-29, 1977. These allegations generally relate to contam-ination control. The results of that inspection are contained in IE Inspection Report No. 50-254/77-11; 50-265/77-11. No items of noncompliance were identified relating to these matters. Internal Company Matters: An alleger also expressed concern about several other matters which are considered to be internal company matters. These included the following: 1. Enployees are not always logged into and out of the facility. 2. Discarded business pappers have been blowing, loose within and oucside the fenced area. 4 3. Sc. rap and other materials of value have been removed from the site by employees without proper authorization. l 4. Important documents relating to plant operations were lef t unatter ied l in a conference room. I f This alleger also raised questions which were resolved during the inter-view with him. They are: i 1. Pre-employcment checks made on guard applicants are not completed before the individual is hired and discrepancies are found but l the individual is hired. The alleger stated.that he was not l aware of any instances where these conditions applied to personnel who were employed at the Quad-Citics Nucicar Power Station. W.2- 'C'$ 2. He stated that a portion of the protected area fence was not of sufficient height. 16 was informed that this matter had been identified during an NRC inspection and was the basis for an item of noncompliance at that time. lie agreed that this condition l had been corrected. During this in.pcetion/ investigation, however, !e a different portion of the fence was found not to be of sufficient-l. height and is regarded to be an item of noncompliance. l l 3. He stated that a visitor to the site had a camera onsite for about six days without the knowledge of the guards. lic stated, however, that the visitor did have proper authorization for the camera. l 1 ">+#. si l 1

~ o Matters Considered Outside mtC's Jurisdiction In addition to the al. legations, a letter dated April 27, 1977, to Senato-Percy contained the following statements which were considered as being outside the jurisdiction of the NRC and were not pursued during this inspection / investigation: 1. "Scrop ly' ing all over CECO area - good scrap." E 2. Lieutenant drinks too much at a bar with a Sergeant and some CECO employees "Have very close relationship - too buddy, buddy for security purposes." 3. "At 10:10 p.m. Sgt. ( ) met a small short man with g, lasses - he appeared to be a CECO employee - at Trackway #2 door. Man was smoking a cigar. They headed in direction of trailers outside. Sgt. ( ) made rounds that night - something was up.", 4. "Former union shop steward again almost ran ever me at So. West corn (r of Boiler Rm 2-21-77. This will be the 3rd time he has almost hit me while driving recklessly in and around plant area." 4 G 5. "Many times (former shop steward) spendn 2 to 3 hrs. at a time in guard house talking with Sgt. ( )." 6. "Cuards recked (sic) little "electrical car" - reckless (sic), rod-ding, etc. - Repairman told me guards ruin car." 7. "NRC men and Co. President coming. This info is known for in advance - N joke among guards was to bomb Presidents helicopter on 2-22-77 " 8. "Smelled strong odor of gas leaking 2/21/77 at outside corner of So. West side of Boiler Rm corner. This was reported - they say Maint. no smell of gas. - This happens off and on." 9. Hard hats not being worn in hard hat area. l ,s3 Ett 10. "(Pinkerton guard personnel) and some CECO employees kid about shoot-dW ing people. Their behavior and attitudes is (sic) scary." r..s qMj 11. The Pinkerton Rock Island OIC, a lieutenant and a Sergeant are devious and deceptive.

12. The Pinkerton Rock Island OIC "Told me he had over $4000 worth of Pinkerton uniforms that had not been returned to main office - when guards oupposedly quit their jobs."

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l 13. "niny guards complained about their pay checEs ' coni:g 2 to 4 days late - also short changed in hrs and money on their pay cks." i 14. "On some occaf ens - al.1 lights out in Boiler Rm." I i l 15. "Doors left unlocked - open at of fgas Filter House." 16. "Bld; "C" lett open." on 3-30-7 7. 9 e p e F l t I ~ .j 6 e e Ist m i n

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~ j g.\\ y3, gg77 g. i Cr '" - r e r ','s ! :: ' w Q, - llilM1ui/L4t'CU31lY DAI A T0: Mr. G. A. Phillip I have decided to accept the opportunity to describe in our words the facts as we remember them related to the personal allegations made by the former ~Pinkerton guards. la order for you to have a better understanding of our position at the time of the occurrence of the events alleged to '1 ave been an Ottempt at concealment of informat'on, it is first necessary to put the 3 development, implementation, and growth of our security program into per-cpective. It is pointed out here, in the beginning that we are responding to the ollegations based upon what we understand them to be as surmised from the NRC isrvestigations, rather than based upon factual knowledge of exactly, phat discussions the former guards had with the NRC. Asastartingpoint,wewantlopointout that our implementatica of a security program was based on the Security Plan that was subm!tted to, and j dpproved by the NRC in the spring of 1974. An Irnmediate caytion we want to 4 pojat out is that it is difficult to properly judge yesterday's decisions M having the benefit of today's knowledge. Therefore, we are atterpting here to provide adequate related information to sho.i that our decision at the time of the alleged concealment was not at all a concealtrent, but rather, was an Ottempt to solve a frustration that cur Security Officer had with what we - Jud ed to be a quick, adequate solution te a re' tively rainor situation. S W When we lock in retrospect upon our decis!cn at.aat tire, it is not difficult to see that when Judged against today's regulations fer nuclear plant se:.:rity measures, the occision :,hould have been modo dif ferently. To illustrate our position, ar historical chronology of the security program Implerentaticn is l helpful. (f:2 Quad-Cities Station was designed and constructed in the late 1960's. The plaat began operating in 1972. At that time plant securiti eensisted merely i A. Cf an unmanned gatchouse with doors remotely controlled by the rain plant l control rooa operators. Plant personnel were issued plastic cards to provide their own routine access. No plant doors were maintained locked, other than , y$ smanner for several years. those providing passage to high radiation areas. The plant operated in this t With the advent of increased concern for possible C-diversion of special nuclear material, new security reasures becar.c necessary to ccumly wi th the latest regulations. As one would expect. cxtensive back-k fittiang was necessary. Initial moosures consisted of armed guard persone.cl, g with provisions for electronic intrusion detection and t.om controls to cccac A la ter. These initial measures becama effective in the spring of 1976. Since o new tratchouse had to be const ructed, installat. ion of the electronic systems was mzt possible until gatchouse con.pletion in early 1975. m ra'ac 1 ue c EXilIBIT l L i.

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Mtf77TITT.L LtdMtt1Y-Dith l At the same t ime, ef for't s were unders'ay to en.'c t ly ish nt i f y t h.it plant equipraent which was considered as vi tal to en*.ure safe shutdown of the plant with no adverse ef fects on the health and safety of the public in tne event of an act of industrial sabotage. Identification of this equipment was rela-tlycly easy because it involved most of the Engineered Safeguard Systems for the plant. However, because of the plant's design vintage, there was very littic provision for controlling access to many of the plant areas containing this vital equipment, in spite of that, initial efforts consisted of locking those vital arcas that had doors, and instructing the approximato 300 plant personnel te keep them locked. Howcver, because old habi ts. rc hard to brcok, it was becoming a major task to keep tne dcors locked and still provide efficient traf fic flow for the plant personnel to perform their jobs.

Also, during plant outages construction personnel numbering at times as many as the norrnal plant staf f are brought to the site by the various contractors.

These people are given an orientation ciass pointing out the security require-ments. However, because many of them had worked at the station at various times since early construction times, they too had habits to break. , Efforts to better define and control the vital areas continued through the sp:Ing of 1975. In June 1975, it was decided that in order to provide more eff!clent Internal traffic. flow, and achieve more effective vital door control, the building perimeter doors would be locked. Thus, 27 building doors were designated vital aree doors and access was to be possible o'nly by those properly authorized people. In order to implement this plan, It was necessary to designate a new lock cylinder code, and procure new lock cylinders. Allowing for the lead time to procure and install the locks, and to issue the new keys in a controlled manner, this system beccne effective in late summer of 1975. Once again, all station and contractor personnel had a new system to learn and old habits to brcok. Y Halntaining these doors locked, except for authorized pa'ssage continued to '"17 be a big task. Part of the door control problem was related to the fact that because the doors were not originally procured and installed as security d doors, their latch and lock mechanisms were not of such quality that they ^ would always operate properly. Efforts to achieve full co-operation with the program continued :onsisting of: Instructions curir.g, departmental g meetings, mer s to station persunnel, education during tra.ining classes, and i-Inspection cnd patrol by all levels of station personnel. The station pro-M cedures stated that personnel were to secure any doors they discovered to M{"' be open and report the event to their supervisor. The security guards were cdvised to also secure any vit.il doors they might find open while makin their routine patrols of the various plant areas. This progrca eventuoi cvolved to where the guards were given a route with time clock stations ' so that the station administrators were satisfied that patrols vicre actually carried out and that any open doors would, thus become secured. g The reporting requiresnent of the station procedure had been in-orporated so that tbc plant administrators could analy:c the occurrences of open doors and determino if there was a pattern of certain times or occasions when the doors were lef t open. The objective was to identify any chronic offenders and to properly instruct them about the vital door requirements and procedurcs. W'*- ~2 PYltih1T (- ~ s

~ ^ ~] %.3.'G (*mw,,-,rr,;;r '.*h IMican' 5 btCMTi'i Al' UI.CUllIlY MI'Y ~ ~ ~ ~ ' l + It was felt that verbal reports or br'ici notes and memos sati:.Iled our need for the information about thu unsecured doors, it was becoming evident that the occurrence of unsecured doors varied directly with increased numbers o r l contractor peoplc at the site. It was thus apparent to the station ad:inis-trators that the problem would probably not disappear completely, but rather would have peaks and valleys as the work load at the station varied.

Thus, our control ef forts were concentrated on education of ecw pcopic, and routinc patrols to ensure the doors remained secured.

i As these ef forts to achievo door control continued through the fall of 1975, the security guards began providing their reports of unsccured doors in the patrol sheets they provided to the Station Security Officer. As expected, their information had peaks and valleys, 'The information these sheets contained wa's considered by the Security Of flecr to be a problen that c re-flected poorly on the offectiveness of the Security Program. His concern was natural and complimentary of his efforts to maintain compliance with the security program, considering the increasing sensitivity about nuclear plant security. j In early January of 19.76, the station began a refueling outage on one of Its units. Because of work scheduled for this outage, a maxinum number of FJ construction people again began working at the site. And,'as had been the f previous cases, the number of unsecured vital doors began li.reasing. Curing one of the occasions when the. Security Of ficer was discussing his concern over the increasing numbers of unsecured doors appearing on his patrol sheets, concurrence by a small group of station administrators decided that sine.e there was no requirement to log the inforration about the doors, the gua-ds - -A should be instructed to discontinue legning the information, but to conti:nie N cupplying the information to the Secerity Of ficer in the form of notes or l Of nemos. This decision was * 'ckly r.ade by the smal.1 group during a tirac u'an they were tr. ore deeply engi. sed in discussing other business. Unfortunately, l this change of information flow from the guards to the Security Officer. c l when Judged by the guards out of the context of total station administrative ._g requirements, was apparently thought by some of them to be an attempt to conceal .. a the informat ion. Concealment was not the objective. In fact, quite the M opposi tc is true ss ev8 lenced by the repeated occurrences o'f memos and instruc-N tions in the station orders book and other station log books, and other measures I CM taken to inform and educate the personnel and to police the problem. it was M felt by the station administrators that our efforts to control the vital door i

1. 9 problem were achieving the best results we could expect with an unfortunate

problem.

. ".' The answer then, to the question of "why did wo instruct the guards to dis- ). continue writing the vital door information on their patrol sheets?", simply Ctated, is that it was done on very short notice without the benefi t of in-depth thought, to handle in a routino way what was one of many everydm decisions that are involved in the binistratiori and management of a- "usinessororejanization. There was in fact, no thought of concealment. Tlee objective was to calia the concerns of the Security Of ficer wi thout dis-l rupting thc.infors.iation flow regarding the effectiveness of door control. E: ^ - l 3 ..; wh a l ed Ullu L Pa e 3 of 4

f y,) CNeamr.vrr.lui rc"r..in 3;'<<!7lliDU311(l Al. GLCUHi lY DMA Ww- ~ ~ - - The set.ond allegat ion we are rer.punding to involve?..i,tatencot that.illrged that the Station Superintendent did not wint Inf onct ion logged l egarding the occurrence of unescorted visitors returning to t he ga tchotn.c. Onr direct respont.c to that statement is that no one on the station staff has any re-collection of ever n1 king such a statement to the guards. The probicm of the uncscorted visitors returning to the gatchouse only Cxisted for a relatively short time when corpared to the door problem. This was so because on each occurrence it was casy to determine who the responsible person was by checking the visi tors log to see who was visi ted. The Station Superintendent in fact talked to the responsib'.e partics on several of the occasions, it was thus eny to solve thlI probicm The fact that the Superinte icnt was directly accessibic by 'the Security Gaards, since usually .: upper rnanagemen,t peopic were having most of the visitors, and that he took personal responsibility for speaking to the resp'onsible parties further Illustrates that there was uppermost coricern to ensure compliance with the securl ty program. In sunrnary, we feel that the above Information puts the facts of the allega-I., tions in perspective as we saw them at the time of their occurrences. We also feel that the information adequately demonstrates that there was no attempt c. concealment. Ve agree that when Jedged with today's standards and knowladge in retrospect, the decision regarding the door information 'r,cflects a lack of in-depth thought. The criticism then should be just that, one of lack of in-depth thought, rather than one of concealment. Ve have no recollections regarding the second allegation discussed. E in conclusion, we are grateful for this opportunity to describe our position W,3 'regarding these allegations. We hope the infort ction presented provides A the perspective to vicu and understand the surrounding facts as we vie.eed them, and demonstrates that there were no attempts' made at concealment of Information. r o i Sincerely, c-HWds L J. Kallvianaki h h Station Superintendent u 8 N m t ~;'.1 e ~' ',- D EX111BTT C -f-Page 4 of 4 i

u h$ aa'oSp,r3m n ov.o o, nic, f 0UN ot 0 O Y A L L A'd rit.a t R I Of 8 14 *,0 Lat CullVC Of fICLS. tif W YORE P. C. WOL LilR las (if Pt DC. 10M 354D Avt *.n't 684 44 CI A nOC K # 51 A N D. e t t. f f t' s 1( t. 300 7'.64.'11 '. TO WHOM IT MAY CONCERH: This is to cortify that I have examined and found' hin to be in physical compllance with the following: 1. He is capable of exerting noderate physical activity under em,ergency situations and is capable of conducting all re- _ quired surveillance activities within the range of enviromental conditions likely to be encountered at a nuclear site. No cur-rent alcohol ar drug abuse is indicated. 2.*Hepossesseseyesightnecessarytoef[icientlyperform all required duties. Specifically, this includes distance vision correctable to at least 20/20 (Snellen) in each eye s close vision correctable to JaeSar ::o. 4 type test for both eyes: nort..al field of vision; good depth perception and ability to d3 oting.:ish basic colors. 3 He posses hearing necessary to efficiently perform all M required duties. Specifically, this includes a hearing loss not to exceed 30 decibels. i Audiogram and Physical Examination Form are attached. D. l I Certified By: T=4 Af5 Certified By: i w. BM g Address: City: State Tates ,19 l M ~ EXIIIBIT D d Page 1 of I l a-

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M *. led as the Nuclear Regulatory W, oMau ssy.a r. One reason for the concern . Offletals at lows.Utinois Gas .couh: have teen that submerged h N'Commissaon and Ntr compa. nles throur):out the nation con. & Electric Co., who own the fa- ,in two T4 foot deep pools en tho-U 1 db t!nue to tacef up twenty in the, cifity with Commor. wealth 1.dF. s!xth f:cor of the m:uive power y ".;.". _. ] N.,.! .. p ;. son Co!, are not certain what the'bected up xcunty.will cost J.t. djotMc pellets th1t p*)wer the wake of terTorist threats. p!ar.t are the tut >cs cf uramum G t '( ESOME 'OF 711F. new secur ty-the Cordova plant because r.ew turb;ncs that crank out the elec. Cgd. dperat.'otts are what off reials say safeguards and re;;ulations con." "thei:y. .g., I : t t,Q,,:

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U.S. !;t1CLEAlt lif.GUI.\\T0liY C0:' liSSIO 1 0FFICC Or INSPEC110N AND ESF0HCr.!-:CNT RECION III Report No. 50-254/77-14; 50-265/77-14 Docket No. 50-254, 50-265 Licenso No. DPR-29, DPR-30 Licensee: Cor=oovealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Nara: Qued-Cities Nuclear Power Station, Units 1 aad 2 Inspection At: Quad-Cities Station, Cordova, IL ..Y Inspection /Inve,tigation Ccnducted: Ap. il 26-28. flay 2-6,12, 13, and 26, 1977 t A .) f / .p, - \\ _ d /7 7 /') 7 Inspectors: J. L. Be.langer a date/ sign'ed IN f.% k,, l D. M. Carlsop.,* 6 f 7 't ~) g (, /) (i l} dhte n'igned . R. Creed ,_L,f fls/ 7/ c;f U . h ' k W' Q' .* / g dite signed 6 .l,Otd'u l . F. Donah e i 2.*/h1 da:e stEneI~ ~ ) 6t/ y, t . A. Phillip j, ~/ 77_ f date signed Approved By: N,.hief b / 77 I. safeguards Bratich date s'gned .i 1 At tnehenent: S-F3-77-91A a Findings (Part 2.790(d) Infurraation) Copy / and / copies. _7d, Pages Tills 110Cl*;!P'{T TS NOT TD i.E REPI:0Dt'Cl 1) 1.'l *lli Si'EC!i !!. Al>Pr. OVA!. CI' kIII y.,W

e Inspection Summary Inspection on April 26-28. May 2-6, 12, 13, and 26, 1977 (Report No. 50-254/77-14; 50-265/77-14) Areas Inspected: Implementation of approved security plan relative to security organization; physical barriers; access controls; conmunicatien I control; detection aids; testing and maintenance of security equipment; response controls. 1.icensee action on previously identified noncompli-ance items related to physical security. An investigation of allegations maae by former guards was conducted concurrently with the inspection. r-The inspection / investigation involved 280.5 man-hours onsite by five NRC inspectors and investigators. Results: Of the eight areas inspected, no apparent items of noncompliance or deviations were identified in two areas: Seventeen apparent items of noncompliance were identified in six areas. (Inf rac tions - Paragraph 4.a. guards not properly trained; Paragraph 4.b, deviation r' ports not e made; Paragraph 5, physical barrier inadequate; Paragraph 6.a. vital area door not secure; Paragraph 6.b access to vital equipment not limited; Paragraph 6.c. gate not properly controlled; Paragraph 6.d, improper escort in vital area; Paragraph 6.e, improper escort in,the protected area; Paragraph 6.f, imprnper authorizatipn of nonessential vehicles in the protected area; Paragraph 8.a. surveillance equipment not 7 effective; Paragraph 10.a. renponse to alarms not made. Deficiencies - Paragraph 4.c, guard's performance not evaluated; Paragraph 6.g. photo-identification badges not properly displayed; Paragraph 6.h visitors not required to walk through metal detector; Paragraph 7, all communi-cation tests not completed, Paragraph 8.b, all alarms not recorded; N Paragraph 10.b, all alarms not properly reported. .= i g e % e4 Ev 4 4 a m.%e -e y:31:n gg--.. p.- - 7: 3 .f r L. s..

c. Mc. _ Pa r t 2. 7'o (.1) I n f o rn ti o n , =

DETAILS, 1.

Persons Contacted (Principal Licensee Employees) ~ Commonvcalth Edison Corporate J. J. O'Connor, Executive Vice President 2/1/ B. Lee, Jr., Vice President 3/ R. L. Bolger, Assistant Vice President 2_/l/ F. A. Pal'-er. Division > tanager Nuclear Stations 1/ L. Bean Nue. lear Security Administrator 2/2/ 'M. I. Miller, Attorney, Isham, Lincoln and Beale 2/ D. M. Murphy, Attorney, Isham, Lincoln and Beale J/ Quad-Cities Station N. Kalivianakis, Station Superintendent 1/ J. Cudac, Assistant Station Superintendent 1/ K. L. CraesseN Administrative Assistant 1/ W. Meehan) station Security Officer 8 L. Cerner, rechnical Staf f Supervisor 1/ 4 J. B. Heilmag, Quality Assurance Engineer 1/ R. Roby; Master Electrician P. Lau. Training Supervisor (Refer to Paragraph 11. Exit Interview for footnote designations.) y% In addition to the above, many other, licensee employees, such as 2 Shift Operating Engineers, Nuclear Systems Operators, Quality i Assurance Techniciars, Instrument and liaintenance Technicians, fuel handle.es, and janitors were interviewed. The onsite contract gua'rd force, which is provided by Pinkerton, Incorporated, was also interviewed and/or pro'vided assistance. During the investigation of allegations, former Pinkerton guards as well as representatives of Pickerton Management were interviewed. 2. Licensee Action on Previous Inupection Findings ~. (closed) Noncompliance (50-254/76-26; 50-265/76-25): Failure o maintain the rotected area barrier ce) along alarm zones ,{ to a height of or provido an equivalent degree of penetration resistance. e inspector inspected these particular sections of fence and found that these specific sections now meet the required height.

=

1% = ... 1. ; ' *; e, y 5- .v J.ecdng OMd U k.g- "f'in ~ I

t Bart 3.7?3M) Trfor tilon (Closed) Deviatinn (50-254/76-26; 50-265/76-25): Vital area doot locking mechanisms were not adequate to prevent unauthorized entry. These lockinD mechanisms were changed or otherwise upgraded so that they now provide adequate penetration resistence. Each lock was inspected by NRC personnel. 1 3. Physical Security Plan A review of the licensee's presently approved physical security plan and impicmenting procedures was conducted during the inspection by comparing the documents used by the licensee and the documents which have been approved by.the NRC. No noncompliance with requirements was noted. One significant anomally was discovered, .however, relative to the licensee's audit program as described in Quad-Cities Security Procedure (QSP) 23. On March 16, 1977, a revision to the Quad-Cities Technical Specif-icatioes was approved and implemented. This revision,'in essence, places all audit functions under the responsibility of the Quality Assurance Department. The Technical Specifications for Licenses No. LPR-29 (Unit 1) and No. DPR-30 (Unit 2) a,t Section 6.1.G.1.b. state, in part: 4 "The Audit Tunction shall be the responsibility of the )bnager of Quality Assurance independent of the Production Department. Such responsibility is delegated to the Director of Quality Assurance for Operating and to the Staf f Assistant to the Manager of Quality Assurance for maintenance quality assurance activities." ".... Audits shall be perforhed to aasure that safety related functions are covered within a period of two years or a. less as designed below," . pn " 6) Audit of the Facility Security P]ag and implementirig procedures." i l QSP-23 at Section C. I.b states: "The security program is audited ..y] ennually by the onsite audit function."

• =*-1 l ME49 This situation was pointed out to representatives of the Quality l

yl] Assurance Department who are responsible for the audits of the Quad-Cities Station and who are not responsibile to onsite station i management. They explained that the "new Technical Specifications" have eliminated the "Onsite Audit" function as described in Section l ~ C of QSP-23. They also explained that, all audit responsibilities l J ..it cyt.. - - u.. l NNr t 1.'. 7.10 (4) I n f or:2ti c.n

~ i Port 2.7. H i) Infor-a ti on now f all under the QA department. They explained that, to their understanding, their basic responsibility was delineated by the Technical Specifications and that the QSP would have to be revised. This vould represent a reduction in the t'requency of security plan audits. 4. Security Organization a. Sections IV.F and IV.E.2 of the security plan requires l l In addition, recurds indicate that one guard (during.his - tenure of employment at the site) never received a portion of l the training, required by the Security Plan. A review of guard force training records;showed that a former guard began employment at the site on Jan,uary 12, 1975. nese @ records also showed that this forcer guard did not receive the ~ g block of instruction, which is given by the guard contractor, until approxiestely three months after site assign-ment. The Pinkerton certification for this training was dated April 4, 1975. This former guard confirmed this during an interview. M A guard, who is presently working at the site, began site assignment on uary 21, 1975. The Pinkerton certification for the of instruction shows that the training, for t s guard, was completed on April 3, 1975, a period of approximately two and one half months af ter assignment. These records also show that this guard did not receive certifi-F cation of having received training in the Quad-Cities security procedures until May 30, 1975, a period of approximately four isonths. The guard confirmed this it. formation during an inter-j g Yi'"' .h'$ A second former guard stated that he had never, during the entire tenure of his employment as a guard at the site, received training in the Quad-Cities security procedures. This individual was employed at the site from December 9, 1976 until April 1,1977. A review of training records m Q a r -,m 1 l v. m :_ Z...... .....i. l 5-T%rt 2.7';(1) Infer ttien

~' Pait 2.790(d) Infer:stien showed there was no record or certification that this guard had received the training, and confirmed the former guard's statement. 1 (See Notice of Violation Item 5) During the physical protection inspection conducted on August 28-30, 1974, the licensee had been cited for noncompliance for a similar situation. Ihe report (50-254/ 74-12 and 50-265/74-

07) dated October 1,1974, showed that the licensee had failed to properly train certain other guards, b.

Sections III.C.4.d and IV.B of the security plan require that observed noncoeformances with the security plan or security procedures be processed as deviations in accordance with Quality Procedure 15-52, which includes corrective action to preclude -ecurrence. Quality Procedure 15-52 (Commonwealth Edison Company, Quality Assurance Manual) states, in part: 4 "Sc ope: This procedure applies to procedures, admin-1i istrative controls and materials, equipment, components, or parts installed for use which have become operational." "Definitions - Deviation: J. departure from accepted equipeent performance or a failure to comply with adminis-9 trative controls which results in, or could, if uncorrected, result in a failure of an item to perform as required by Technical Specifications F or approved procedures." f'T Contrary tc the above, on several occasions, items of nonconforn-ance with the security plan and procedures were observed and T-were not processed as deviations in accordance with Comonwealth Edison quality procedures which include corrective action to . ;g preclude recurrence. For example, on April 13,197? a guard l f-- found a vital area door unsecure at 1341 hours and it was not proecssed as a deviation. During the conduct of this inspecticn and investigattun, records were found of a number of items which represent non-conformance with security ptogram commitments. Examination of certain of these nonconformances showed that the licensee's management had been previously informed of these items by staf f members f rom various Station Departments. Interviews r-C' a -

Par t 2. 7 '3 H) y,.To rm tl er.. with Station personnel and Station management showed that, when reported, these items were not evaluated as deviations in accordance with the provisions of the cited Quality Procedure, and that cither no corrective action to preclude recurrence. or inef fective corrective action M preclude recurrence was taken. A review of the licensee's "Deviation Report" records showed that between January 1,1976 and May 5,1977, only three security-related deviation reports were completed: (1) De' #iation No. D-4-1-76-21 was written as a result of items of noncompliance identified during an NRC inspection on January 21-23, 1976; (25 Deviation No. D-41-1-76-37 was written as a result of "Pir k Ton Security Cuard Shortage" which occurre.1 on May 29, 1. l3) Deviation No. D-4-1-76-68 us written as a result of an item of noncompliance and a deviation.identi-fied during an NRC security inspection on November 10-12, 1976. Each of these reports indicated that action had been completed. There were, apparently, no other "Deviation P.eports" made during this period. 4 During this period, however. other licensee records and inter-views with Station Management. Station Employees and Security ( Force personnel showed that many nonconformances with security program procedureo and the phys.4, cal security plan had occurre.l. Some exaiples, of these nonconformances are: M (1) Open or unsecure Vital Area doors: Ny (a) Records and interviews with security personnel l showed t. hat many vital area doors have been found open and informally reported to station management. No record of a "Deviation" report was prepared. t. (b) A Quality Assurance Surveillan'ce Report. (QAO-4 6-

77) dated April 13, 1977, reported that the south o f.

door of the was found ajar. This report recosamended t ta exterior doors be equipped with ~ a local "alarm" system that would give a positive l indication that che door was completely closed. No Deviation" repor t was prepared. (2) Improper display of, proto identification badges. l l An audit was conduct'ed by Ceco employees, not assigned l to the Quad-Cities '4tation*, on December 6-10, 1976. A i C- " ~......_ ....,e

Pad 2.??0(3) Information l finding of this audit was "Seversi personnel were observed not voaring their photo ID badges clearly displayed. No deviation report was prepared regarding this item. ) (3) Failure of the protected area perimeter intrusion alarm system to dutect attempted penetrations. (a) During the course of a routine alarm test a security guard was able to penetrate under the beams at certain seccions en March 6, 1976. his information was reported to the Station Security Officer, in ) 4 writing, by a memorandum on that date. No deviation report vis prepared regarding this item. (b) An inspection conducted by representatives of the licensee's corporate security organization'vas cuaducted on ptember 23, 1976. nis inspection showed that larm zones could be circucvented by rrective action, in this case, vns ta en, however, it did not preclude recurrence. Although an "audit" report was' examined, no devi-ation report was prepared. (See Notice of Vio'lation, Item 7) c. Section IV.E.5 of the security plan requires each member of the plant security force to be evaluated annually. 9" Contrary to the above, a member of the plant security force h was not evaluated during the period of February 9, 1976 to May 3,1977, a period of approximately fif teen months. A review of guard force personnel records and interviews with the station security officer disclosed that four cf fourteen guards have more than one year of service, thus qualifying them for at least an annual evaluation 14 accordance with the security plan cons itment. Cuard evaluation forms had been completed for three of the abave guards. n e fourth guard, who began site assigreent on February 9,1976, was not evalu-ated as of this inspection. his van confir ed during inter-views with both the guard and the Station Security Of ficer. (See Notice of Violatiu, Item 14) ........\\ SAF E l.:.L '...

X

( ( DFS EM(d) Infer:stho (

= , Port 2.7]O(d) Inferrition 5. Physical Barriers Sections II.B.5 and II.D of the security plan requires that the protected area fence be a minimum of, M fect high. Contrary to the above, the physical barrier (fence) along alarm sone 15 it the southwest corner of the protected areat adjacent to ~ the spray canal lift station was not effectively @ feet and did not provide an equivalent degree of resistance to penetration. A concrete "curb" along that area provides a base that reduces the effective height to approximate 1y'geet. During an exterior inspection of the protected area physical barrier (fence) on May 2, 1977, the NRC inspector, accompanied by a member of the security fo e, observed a section of the b6erier that was not effectively feet high, h is area was in alarm zoneg near the southwest corner of the protected area 'nsnediately i sdjacent a concrete vall vest of the lif t station. D e fence, at this point was installed behind a concrete curb (approximate 1;.vo f eet high and four f eet vide) whid runs up a. hill. Because of the slope of the bill, the height of the curb and relativa location of the fence, the NRC inspector (approximately 55" tall) estimated the height of the fence to be effectively 5'6". This would effect-ively reduce the penetration resistance of the barrier and would l facilitate penetration. I (See Notice of Violation, Item 3) i M 4 During a previous physical protection inspection conducted November 10-W 12, 1976, the licensee was cited for noncoop11ance with the above noted sections of the security plan, h is item of noncompliance occurred because foar particular portions of the fence did not meet requirements. Those sections did not include the above specific location. Adequate corrective action was taken for those other sections. (See Section 2 of this report) l 33 6. Access Con.tols ad h a. Section III.D.2 of the security plan requires that access to vital areas be controlled. Contra to the above control of access to the as not provided in that on April 2o, l 1977, at 2309 hours, the B4 inapector accompanies by a guard, obat.ed door Fo. tied open. r 1 r. b.... Pact P.'/YllO T=Carm Qion '

Fort 2.7.'3(3) Inter:ation Inspection of "Shift Officers Logs" showed that this door r had also been found unsecured on rc , 2, Apri 6, 22, 23, and earlier in the day on April 26, 1977. An initial check of Vital Area doors was conducted on April 26, 1977, by NRC inspectors icnediately af ter their arrival onsite. %is ir.spection, which began at approximately 2000 hours showed all vital area doors controlled or secured. During a subsequent inspection of the protected aret (at approximately 2309 hours) one inspector acconpanied b, a Pinkerton gua observed a vital door that was no locked or f secured. The was found tied open with a nylon rope. The rope was astened to the inside "crash bar," aol passed over the bolt housing mechanism and tied to the c,atside knob. This rope prevented the door from fully closing and-woul ot all the bolt to engage the strike. Access to the a vital area, could be 5 ) gained without the use o a key. So guard h&d been posted to control access. 8 i A subsequent inspection of the "Inner Perimeter Partol" r cords disclosed that' door (No.17) had been found unsecure<1 at 1300 hours, on the same day by a Pinkerton guard. To determine how many vital area doors had been found open in the past proved difficult because guards had been instructed E by supervisors not to record such occurrences on the "Inner M Perimeter Patrol" sheets. (This practice was discontinued ) April 22, 1977.) However, Lecause of Phif t Of ficers Logs kept in the guard office, which were not provided to the licensee nor to the guard contract agency'e office, it was determined that the guard shif t officer had recorded many of the vital area doo that had been found un cured. Thus, it was noted i that the was f'ound open on March 23,

28. April 2 and 23, 197.

Aiditionally, a review of the Shift Officers Logo for the - period following the last inspection (November 1976) disclosed j that other vital area doors have been found unsecured: February 9, 1977 _ - - 4 _in w ' Q,!.'p~ ' ' - ' ~ - - ....,,a . \\ inrt 2.700(d) Inf.r:stlo. 1

Fort 2.700(d) Inf6yc:-

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February 12, 1977 0700 hours. propped open March 7, 1977 h. March 8, 1977 door, 2015 ho.:: March 28, 1977 door ajar. April 9, 1977 North door of 1341 hours. { April 13, 1977 { April 14, 1977 t 0.ours April 15, 1977 During the August 28-30, 1974, physical protection inspection. M a vital area door was f ound unsecure by.* inspectors and an ite: f of noncompliance was cited. 1 As a result of the July 21-23, 1976 inspection, an item of E noncompliance was also cited as NRC inspectors found a vital area door 'msecure. As a result of the inspection a civil e penalty of $4,000 was assessed for that iten. The licensee was again in noncomplian:e with requirements, for ~~ - the door found unsecure during,the present inspection. (See Notice of Violation, Item 1. For additional information. = F refer to Paragraph 4.b., of this report and the Investigation ~, ' Addendum, Allegation Nos. 1 and 40.f) b. Sections III.D,1, III.D.2 and IV.C the security plan and P Section C.1.b of Q'P-9 re uire that Y L Contrary to the above, key issuance records and interviews w h-onnel aboved that :4

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3 A review of key control reca a we woducted on May 5, 1977. ~ Key inventories shc,wed that - keys (to locks on plant t,., b p 11 Part 2,3'0(1) Inferntion r_

i I 1 ? l Pirt 2.7'J0(J) Infor:stic )(cy issuance sir, nature cards were examined and the N C ins.cetor noted that J %.;s - s% U d (O[,g.a; f. e p ;f y . 40' '/. g ' - ?y L..,., ..! h. m :f tj Examp cs j <e of this are: 7.4

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i s/ 4g... .s . +, .y + The inspector then attempted to verify whether the above listed irdividuals were, in fact, authorized ce e v i areas. Access authorization is designated b I A selective exanination of the badges issued to t e above isted individuals showed that the anitors i 's (5) and the "Stores" employee (6) presently are issued' Further, it was noted l t at one n v ua no onger ia any photo-identification [ b badge and therefore was not authorized unescorted access to N the protected area. The inspector further verified t the j "red badged" janitorn did, in fact, have the as they produced the:n when asked. It should be noted tharM,, are also used for locks vt'ch + j control access to areas.other than vital aress, such as locker i rooms, washrooms, and gates outside the protected area. .ad l SF5 C.U.:... .......s',,U ._......y t i t ~ i ! l I f I

- _ _ -. ~ _ _ _ _ - _.. i i i Part 2,730(d) Infor:stle:. (See Notice of Violation. Item 4) I As a result of a physical protection inspection conducted on August 28-30, 1974, the luensee was cited for an item of l l c. Section III.C of the security plan r ir l i \\ l Contrary to the above, on February 25, 1977, i 1 l 1he Shift Officers los for February 25, 1977 (2000-00 hours) j indicated that the scent l to the house, was I The los for t e prev s 00 hours) l notedthai The log indicates that I the gate was repaired at 2 5 hours on February 25, 1977. l Log sheets for November 27, 1976, December 4 and 5,1976, i l February 15 1977, and April 8, 1977, also noted the inoper-ability of but did not specifically indicate whether i ' %g.;, the gate was opeh or closed. f j Interviews with guards disclosed that because of guard force j duties within the gatehouse (i.e., visitor control, ronitoring the central alarm station, answering the telephone, badge distribution, searches, etc.) it is impossible for the:h to I adequately monitor protected area access through ti.is gate l from inside the gatehouse. They also indicated that due to j 3-h those duties and shortage of guards, no one was posted at the t gate to control access. i I (See Notice of Violation. Item.6) i .j[' During a physical protection inspection conducted July 21-25, 1975 the licensee was in nonconpliance for failure to control-i access through a gate, in that so NRC inspector passed through the gate unchallenged, entered the protected area and proceeded J to the station control room. This citation resulted in 2 civil penalty of $5,000 bein.t.usessed. I ... mll r t-u.... 1 } i l Part 2.733(d) Inf * *~~'llA" I

fort 2.700(d) Infer:ation d. Sections 111.C.o.a.3 and IV.C of the sedurity plan and Section 6 Contrary to the above, on May 3, 1977, during an interview On May 4 and 5, 1977, a review of the licensee's photo-1'dentification badge system was conducted. A portion of this review was to verify that those individuals who were not authorized unescorted access to vital areas did not, in fact, enter vital areas unescorted. n e licensee utilizes a , Individuals authorized unescorted access to all area n t 'e Pr cted Area, including vital areas, have a on their badge. Individuals (usually contractors who are authorized pnly to vital areas in which they are working are coded ec . Individuals who are authorized unescorted acc rotected Area only, but not vital areas are coded w A ne NRC ins tor n.ade a selective check of individuals who were issued background badges to insure that they were in fact not ga g' unescorted access to vital area. During an interview with a Station janitor on Ma 3, 1977, the NRC q inspector found that he did enter the (a vital area) unescorted from the Service og during e routine cour,se of his duties. This janitor was, et, the time, displaying.gbackground pho o.identi'fication badge and. he indicated that when he entered the to work, he was displaying that ga ge. er, the ja itor Produced a heries key which will open these, and other, vital area r's. (See Notice of Violation, Item 9) e. Sections 111.C.2.b.2 and IV.C of the securit lan mod Section, C.3.6 of QSP-2 requires that all

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3tiou py g g,7)o(j) Infor: Contrary to the above, interviews with' personnel showed that on one occasion April 9, 1977, an thorized Comonwealth Edison cmployee allowed for a short period, in the protected ares (Service Building). This itere resulted f rom the NRC investigation of an allegation by a former Pinkerton guard. On May 5,1977, an NRC security inspector interviewed a Quad-Cities plant emp1 ew d that on Saturday April 7, 1977, he allowed outs e t e mac ine shop in the Service 11 ding (a non-l vital area) for a period of approximately two to five minutes while the plant employee utilized the sashroom facilities. (See Notice of Violation, Item 11) f. Section IV.C of the security plan and Sections C.3, C.4.5 and Contrary to the above, 1 entere e protec area. A review o icle Access logs on May 4, 1977, showed that on January 8, 11, 15, 16, and 17, 1977 Ceco employees brought th9ir

se tr A review of "Vehicle Access Logs" was ce ted on May 4 1S77.

Entries on these logs showed that le ollowing: Date Times Vehicle Purpose of Entrv 1/8/77 1520-2230 73 Vega ! Cold Weather 1/8/77 1520-2230 60 Chevy Cold Weather M 1/11/77 0030-0610 Maverick Cold Z* 1/11/77 0800-0000 Fly Duster Repair Car for Ji: h:h 1/15/77 1826-0224 Ford Maverick To plug car heater 1::o outlet due to cold. 1/15/77 2215-Blank Finto Check lights 1/16/77 0140-0705 Maverick Bring car into repair 1/16/77 1515-2225 VW Warm car up 1/16/77 1517-0601 Pontiac 72 Warm car up 1/16/77 1720-2243 Maverick To plus car in due to ec. .. 1/17/77 - 1703-2352 Rally Nova Trozen Tuel Line 1/17/77 1950-0005 Chevy Trk Mechanical Proble:s q. u... I ( b' 6 9 9Ml4) Tef4P"14t107. A

.Part 2.7?0(d) Inr:r :tton Additienally, the NRC inspectors observed nonessential vehicles parked adjacent the main entrance to the Servico Building (inside the protected area) not acccmpanied by a properly badged individual, unattended on May 4 and 5,1977. I Each of the above listed log entries indicated that, in each case a member of the Station Staff, who is authorized to allow access, did allow these vehicles to enter. (See Notice of Violation, It'em 10) 3 Section IV.C of the securit lan and Sections C.1 and C.1.a of QSP-2 requires that ) Contrary to the above, on May 3,1977 che NBC in

tor, Maccompaniedbya 1

On May 3, 1977 an NRC inspectu. decompanied by a member of the licensee's security force was nducting a tour of the station protected area. While approaching the southeast corner of the Turbine Sa11 ding at approximately 1025 hours, %g (within the protected area) the NRC inspector noticed in employee valking next to a fork-lift who did not appear to have a photo-identification badge. When pointed out to the guard, the individual was questioned about the location of his badge. He producted the badge f ro= a shirt pocket which was covered by two outer coats. The guard instructed the individual to properly display the badge. j ) Additionally, on April 27, 1977, the NRC inspector observed y employees entering theNkth badges improperly displayed. This portal was monitored by a guard. When l questioned about the situation the guard indicated that he k ) personnally recognized the individuals and did not want to i bother these by asking to see their badges. (See Notice of Violation,.Tteu 12) (. ,,r

c. ii l '

....it 1 1 16 - \\ l Part 2.7'30 HI I"IO#

J l Part 2.700(d) Infomation l During an "offsite" audit conducted during December 6-10, 1976, representatives of the licensee had id qtified a similar prob 1cm. R uir corrective action did not provint recurrence. 5 h. Section IV.C of the security plan and Section C.2.c.(3)(f) of f ( Contrary to the above, on May 3, 1977 [ Two NRC security inspectors, initially arrived at the Quad-Cities gatehouse on May 3,1977, at approximately 1200 hours. n ey received authorization from the Station Security Officer to enter the protected area t.nd completed the required infor-mation on the "Visitor Admittance Record." n ey 'vete issued numbered visitor buttons and then escorted to the Service

Building, ney were not required to walk through i

M prior to entering the protected area as r y the above procedure. 8 d It should be noted that QSP-5 at Sections C.2.c. (1)(e) and C.2.c.(2E e) specifies tha At irregular intervals. " H ere is, however, no mention of "irregular intervals" in connection with "Visitore" access i authorization procedurts. E3 7. Communications Controls Sections IV.I.2.b. knd IV.C of the see rity an and Section i C.1.a.(1) of QSP-21 require that the' nWQ g Contrary to the above interviews with ard force ersonnel showed i that the .M I l a I .j On may 4,1977, the NRC inspector conducted a review of "Quad-l Cities Station, Security Material Transfer" reports. Rese forms j have headings entitled "Radio Check" and "Tel Check." We security l L l Q '. *.}. I u l ed ... Part 2.710lell T nenmEt t an

~ l hd 2.773(i) Ir.for:3 tic forco supervisor explained these headings to mean: (1) "Padio Check": tests of guard force portable radios and test of the "intercom r.2dio" to the control room; (2) "Tel Check": a test of the inter-plant telephone system at the alam console accomplished by lifting the rocciver and hearing a dial tone. This does not meet I,.. the test requirements for the telephone as outlined in QSP-21. Further, interviews with other guard force personnel, responsible for ccepleting the "Quad-Cities tion Securit Material Transfer Reports" indicated that tests of I8. i (See Notice of Violation, Item 16) s Detection Aids a. Section III.C requires that the Contrary to the above, th I test of the. licensee's protected area perimeter intrusion j alarm system !was conducted on May 2, 1977. The ta ons ste a e ack'for operability of each sensor and a check of the ability of each alarm zone to I ( detect possible intruders', One 4.i: HRC inspector nonitored alarm annunc tions at the console in ) l the gatehouse and the other tes d each set of sensors in each i ? sone (except a portion of "phich was in the access mode) along the protected area barrier. Connunication was maint.ained l between inspectors by means of portable, radios provided by the licensee. I .AP m.1 2.:6 The test for operability of each sensor showed that all i %~5 tested sensors were operating properly. 'However, penetrat. ion I 9* tests, specifically crawling, showed that the system was not 1 si:.I,I entirely capable of detecting attempted penetrations. The.XRC inspector was able to penetrate the alarm systes' at the following locations: 's s L,

• 1

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,. ' g..n. ' ::.. s -.. '.. - >... w y i ? ,rf, ~ a NOTE: Each penetration was observed and verified by a member of the licensee's security force. (See Notice of Violation, Iters '2) i p During a physical protection inspection conducted by RIII on ,F.c January 21-23, 1976, one alarm zone was successfully circum-vented and the liceasee was cited for noncompliance. h t ,g Records and interviews indicated that during a routine weekly '= test of the alarm system on March 6,1976, security guards j (-J successfully penetrated the alarm system in a number of loca-l Ed tions and reported this in writing to'the Station Security 4

• • d Officer.

D !s ' Records also showed that during a test by representatives.of Ei the licensee's Corporate Security Organization on September 4 ES 23, 1976, the system did not detect attempted penetrations in eight alarm zones.

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q u. \\ PoN 2.700(d) Infer ation b. Section IV.C of the security plan and Sections C.2.g. (2) and C.3.a.(3) of QSP-13 requires that all alarm annunications be recorded in the Security Alarm Log. Contrary to the above, a selective review of alarm 10g records, 1 in comparison with the alarm console print-outs, showed that certain alarms, occurring on January 2, 3, 7, and 8 April 1, 5, 15, 20, and 30, 1977, were not recorded on the Security 1 Alarm 143 The fo11 cuing alarms were printed on the computer print-out tape but were not recorded in accordance with procedures, by l guards on the "Security Alarm leg," on the dates indicated: Date Time Alarminz Zone 1/2/77 0625 i 1/2/77 0828 1/3/77 0444 1/3/77 1636 i ( 1/3/77 1638 J I 1/7/77 1315 L 1/7/77 1316 1/8/77 1816 1/8/77 2124 4/1/77 0505 i

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4/5/77 0703 ! ;w 4/5/77 0357 l 4/20/77 0823 l 4/20/77 1313 i (See Notice of Violation. Item 13) f 9. Testing and Maintenance j ) We barriers losing the tected area were not continsosuly monitored by n that: between the weeks of May 31, 1976 and a period of 47 wecks). Zone one (1) of ) ...~n 1. i 9

s [' Part 2.7*0(d) Icrore: tier D the system was inoperative; between the weeks of Decenber 25, 1976 and April 23,1977 (a period of 19 weeks) alarm Zone seven (7) was inoperative for 17 of those weeks. Additionally, the isolation zone was not continuuusly surveyed and displayed on sufficient television monitors to simultaneously view the entire zone in that I CCTV Camera No. 4 was inoperable from Januaty 1,1977 to April 27, 1977, the time of this inspection. The above inoperability of security systems was disclosed through intetviews with guard force personnel, in addition to reviews of the "Shif t Officer's Log" and the "Weekly Security System Electronic s Surveillance Test Checklist." The above were used as' examples because of the extended periods of inoperability; however, it was also noted that duri the.. months of December, January, February, and March, more than percent of the alarm zones malfunctioned, on most days due t Commonwealth Edison Surveillance Audit QA0 April 2,1977, noted that during the period of the QA gudit (November 13, 1977 through March 5, 1977) were inoperable due to lack of parta. The au t a so noted, At no time wety all five ational." The audit concluded: "Th e esent o response to the audit was na y p ant management. Also, regarding the above specific instances, r3 cords showed that the Station Security Of ficer had initiated a number of work requests )!ll directed at repsiring these deficiencies.

• The work requests appear to have been "closed out" before the total job was completed.

It appears that although the "work requests" were issued, the work was not finally ccepleted until approximately April 3?, 1977. During a phyLical protection inspection conducted by Rill during November 10-12, 1976, this situation was diskovered and brought to the attention of plant management. Discussed during that inspection was the inordinate delay encountered regarding repr.ir of certain alarm system equipment. Station management had indicated that the delay was due

• A review clmaintenance records, during that inspection, showed that the ere going to be acquired from a new source.

S tation managenen said that the system would be repaired "within three weeks." It was found that it had remained not operational until April 23, 1977. (See IE In'spection Reports No. 50-254/76-25 and 50-265/76-25, dated December 2, 1976) t.. l 1 l Tart 2.7?3(d) Inforention i

s Part 2.770(d) Infor:stion The security plan at Sec tion III.C. 3.d. 3 requires and allows that compensatory measures be taken in event that CCTV or intrusion alarm equipment is out of service: It should be noted that a selective review o records showed that the patrols were conducted when the CCTV or intrusion i i alarm equipment was out of service, as required. 10. Response Procedures c a. Section IV.C of the securit lan and Section C.1.a.(2) of QSP-13 requires that 9 L Contrary to the above a selective examination of records (Security Alarm Logs) and interviews with guard force personnel showed that on January 6, 11, 12, 1977 and. April 1 5, and 20

1977, g

p I

A selective review of the "Security Alarm Log" was conducted for the months of January and April 1977 tat approxic:a tely five-day intervals. The log indicated several instances of no e logs information: ...m:..,... ;c e v s.W- ? 3.gm g m... ~

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g >a,.<r.. -:? ~. :,. ;c ; u...,;;' + { Interviews with guards who monitor the alarm console, showed that the records were accurate in that, on occasions, a survey of the alarming sector would reveal no apparent c se-but that because of the frequency of some alarms, responses .would not be made. l j (See Notice of Violat' ion, Item 8) b. Section IV.C of the securi an and Section C.3.a of QSP-13 requires that l l 1 ) Contrary to the above, the NRC inspecto N observed d ' day of the inspection, that' i Furthers 3uar orce an control reed that the, m E. -.=qg. hg!gk; I.>4 roon er e con o NkI/hiM.' p J Interviews with guard force personnel monitoring the gatehouse alara panel (central ala stat nd observation of their i activities, showed tha e 1 I ring the night { . inspection o April 1977, the NMC in tors observed that 1he shif t engineer on duty stated that l t e panel was normally reset about once per shift. He also confirmed that it is the normal practica for control room (See Notice of Violatio'n, Item 15) j 't l .D' l a

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11. Exit Interview

~ nrce of the inspectors / investigators cet with members of the Station's mangement (denoted in Paragraph 1 as Footnote 1) at the site on May 13, 1977. These individuals were briefed on the scope ( and findings of the physical protection inspection only, as the ~,. [ investgaticn of allegations had not, at that time, been completed. The licensee representatives made no substantial comment or rebuttal regarding the items of noncompliance except for the followingt Paragraph 6.b - The Station Superintendent mentioned that this ites had been discussed during the course of the ins ection. He indicated that the described situation (janitors having-keys) has existed { for a long time. Paragraph 6.f Re Station Superintendent indicated that he does not censider that this should be item of non liance'an in his inion, he considered it acceptable to ) s 1 f Paragraph 8.a - The representatives mentioned that work orders had been initiated and that the corrective action was either completed or near completion. Paranraph 9 - The Station Superintendent mentioned that problems vere still being encountered regarding obtaining proper replacement parts for the alarm systems, but that the parts would be obtained on a priority basis, as soon as possible. ) g A meeting was also held with representatives'of'the licenses's p Corporate management (denoted in Paragraph 1 as Tootnote 2) on May 13, 1977, to discus the licensee on cer,s insnediate corrective measures to be taken by tain of the more significant identified items. Discussed during this meeting vere the follo'ving items which were ) included in an Immediate Action Letter dated May 19, 1977. 1 Take immediate action to assure that access to vital areas is a. positively controlled and action is taken to prevent recurrence of open vital area doors. t .,.i u.. ~ ' Par.t 2.7% H) i+-"1 nt

i 4,. t... p Part 2.790(d) Inforer.rtieri b. Take appropriate action to assure that the are reliab c an e ect ve. i _ In this regard, steps are needed to assure system defects are corrected on a prin i*y basis and that the corrective action ?- is sufficiently broad to maintain high system reliability, In the event tions of the system are in rative j t Action: Contractor who installed the' I 'the Zios Nac ear nerating 1 Testion 'vTT1"FWITreii siniHTTyTeen at quad-cities for i improvement in reliability and effectiveness. System defects i vill be corrected on a priority basis. As stated in Item 1, the guard on special patrol is checkin?, the protected area i i fence. Take immediate action to restore the protected area. fence to i c. a minimum height of feet. Action: All sections o rotected area fence are now a minimum + 4 height of eight feet. ( i .{ d. Take immediate action to assurc that all alarus, the cause of which cannot be determined, are responded to incediately and a l record maintained to reflect this response. J Action: I If th'e canse cannot be deter-min ,a rom t res onse vil be made. { l e. Take immediate action to assure that, in the event of an j inoperable open gate in the protected area fence, positive l access control is exercised at the opening, j Action: In the event of an ?noperable open gate in the j protected area fence, a guard will be posted to control l access. I the licensee representatives indicated ti.at the above listed j corrective actions would be accomplished in the most expeditious manner. Representatives of. the RIII Safeguards Branch visited the j site after issuance of the Immediate Action latter to assure that i appropriate corrective actions were being taken. I p v.... i 4 l w.

!,, s ' i Part P.7?0(d) Infor.atlpn.. A third meeting was held on June 9, 1977 at the RIII office. Attending this mocting were representatives of the licensec's corporate offico (denoted in Paragraph 1 as Footnote 3) and the l Director, RIII and me.mbers of the staff. Discussed during the e,. meeting were: (1) the allegations made by former guards and the results of the investigation, (2) apparent items of~ noncompliance. and (3) items of concern. '4 f i e l 8 l \\ l e 3 I i 26 - j I .}}