ML20205M675
| ML20205M675 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/18/1986 |
| From: | Schaefer D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20205M477 | List:
|
| References | |
| FOIA-86-329, FOIA-86-363, FOIA-86-A-175 NUDOCS 8704020457 | |
| Download: ML20205M675 (12) | |
Text
-
- po'N 9 e
i j
o' ), e. '
.[ \\
1 ummin sTAtas NUCLEAR REGULATORY COMMISSION
{
. REG 80N V
.a
\\*eee*
tese MARIA LANs, suffs 210 WALNUT CResK. CALIFORNIA tests APR 181986 HEMORANDUM FOR:
Palo Verde File i
FR0H:
D. Schaefer, Physical Security Inspector
SUBJECT:
PALO VERDE INSPECTION HISTORY - AUGUST 1983 70 MARCH 1986 The attached 8 pages list the Security History for Palo Verde Nuclear Generating Station (PVNGS) from the initial Unit-1 " Fuel Storage" Security Inspection in August,1983 to the most recent routine security inspection of Units 1 and 2 fron,Tebruary 11 - March 13,1986. During this 2\\ year period, five pre-operational security inspections and five routtaa security inspections have been conducted.
During these security inspections numerous deficiencies / violations and follow-up items have been identified.
(Note: Prior to issuance of OL,
" deficiencies" were identified; upon issuance of OL, " Violations" were identified). The following licensee " common denominators" are present amongst these deficiencies and violations.
T,e 1.
The'*1icensee security management does not always properly evaluate problems and events that arise in the day-to-day operation, as follows:
A.
Failure to correct or compensate for previously identified problems.
U..(1) In May 1985, the inspector noted that the licensee had failed to close and secure an " extra" vehicle gate at Unit-1 which was
'not approved in the Security Plan. This violation had been g
previously identified by.the licensee's QA Department id an audit report.
~'
(2) In September 1985, the licensee determined that some of their perimeter alarm zones could be
, Even aster toentitytag tats problem, the licensee failed to take compensatory measures -
until prompted to do so by the inspector. Later, in October 1985, during the Unit-2 pre-operational security inspection, Region V again identified this same exact Violation. Overall these alarm zones have costed the licenses two separate Violations.
B.
Failure to properly Report Security Events to NRC. The initial example in 1.A.(2) above was not reported to NRC. Additionally, the most recent security inspection report identified 8 examples of events (documented by licensee's Security Incident Reports) that were not reported to the NRC.
r
?
APR 181986
. s
~
2.
Shortase of Security Officers. The licensep Security Department was supporting a 2-Unit reactor with l
3 3.as a result, security officers were often working between 6-/ days per week.
(Note: Security Officord work at other reactors. This shortage of Security Officers' has been identified during the following inspections:
a.
August 1984 initial pre-operational security inspection.
b.
October 1984 during the 2nd Unit-1 pre-operational security inspection.
e.
October 1985 during the let Unit-2 pre-operational security inspection.
d.
November 1985 durink the 2nd Unit-2 pre-operational security inspection.
In preparation for the April 10, 1986 Enforcement Conference at PVNGS, the inspectors determined through interviews with selected Security Officers that the utilisation of overtime for security officers had been reduced. The number of compensatory security posts had been reduced, thereby providing some relief to the shortage of security officers. For this reason, the subject of " Shortage of Security Officers" ves not A
addressed with licensee management. personnel on April 10, 1986.
Since the last SALP rating (which did not include the results of the s
Unit-2 pre-operational security inspection), the licensee has definitely slipped from a level-2 to a current rating of level-3.
87) i
/
ri j
w mR//v j
anis W. Schaefer Physical Security' Inspector
{.
Attachment:
As Stated
}
ll i
5 i
APR 13 Iggi Unite Involved:
Docket Nos.
Page I cf-l Type of Dates of Total Description of Violations Follow-Up Items and Observations Inspection Inspection Inspection and Severity Level
& Names of Nours
- Inspectors Routine August 22-24, 38 No viola ~tions identified (OL act (1) Concern over the lack of isolation zone l
Inspection 1983 issued) ~'
PA barrier -
1 (Fuel D. Schaefer (2) Concern over the expandefistlet-resist l
Storage)
L. Norderhaug barrier in 8
Unit-1 (BR barrieFis~for'CAS)-
(3) Encouraged licensee to turn over all 1
completed security systems as soca-as systems are installed and tested.
(4) Observed that fence barrier was affixed (5) Observed inadequate illumination at sev, areas of PA.
(6) Observed that nighttime was inadequate. ~
l (7). Supported finding of recent audit:
~
4 som.
electrical wiring enclosures - not equipped with tamper switches.
Pre-August 20-24 32 No violations identified (OL act (1) Exit meeting identified critical shortag Operational 1984 issued)
Inspection D. Schaefer (Initial)
(2) Identified tha't IN 83-36 discourages the
~
Unit-1 use of key pads on vital area doors.
(3) Identified design deficiency in at vital area doors (4) Observed that' only 62% of ~'
were operational.
(5) -
EJJiNING: SAyIm3LW INIVEEL7. 05 a
SECTIC3147 Armc mY ACI 1954.
~
71CLLIIC *.5 C7 ICIENC3 (6)~ fes tified that licensee do'es not have
',.gy;g;Y:ctI3 0710 C72 73.21 susJICT 10 CI(II.C'.IM nY-SANCT15.
ENF(5tCEMEhT HISTORF~
Unito Involved:
P;ge 2 cf Docket Nos.
Type of Dates of Total Description of Violations Follow-Up Items and Observations l
Inspection laspection Inspection and Severity Level
& Names of Hours j
' Inspectors Pre-October 1-10, 364 Exit meeting identified that (1) Excessive work hours for security offic l
Operational 1934 licensee was not able to demonstrate caused partially by shortage of securit
(
Inspection D. Schaefer their ability to protect the public's officers 2nd Inspection L. Norderhaug health and safety - Recommended to (2) Extremely high* alarm rate.
cf 3 total A. McQueen licensee that OL not be issued (3) Incomplete records being maintained for 1: nit-1 R. Bradley until appropriate corrective action response to security alarms.
(L15L) is taken (on open follow-up items).(4) Maintenance procedures supporting secur (Note: No violations were department, not available.
identified as OL was not issued).
(5) Elements of testing and maintenance pro, not available for inspection due to
}
equipment just having been released.
(6) Security Plan Change needed:
(7) ~ Several unsecured in protected area.
~
=
(8) VA Barrier adjacent to substandard material.
~
(9) VA Openings allows undetected access to VA.
(10) VA Barrier -
l
~
(11) VA Barrier -
(12) Several VA doors' (13) VA Vent Openings
_(14) VA Openings -
,].
~
(15) VA Barrier -
l (16] 5 vital areas - utilize chain link as barrier. This material is sub standard and not authorized for use as VA barries (17) Locking assembly on missile doors -
s (18) Security HQ Buildine ~
e f
~ ENFOsa.m.m.NT CISTORY
~
~
~ ~ ~ ~
~
I:!aito Involved:
Page 3 cf.
Docket Nos.
Type of Dates of Total Descriptica of Violations Follow-Up Items and Observations laspection Inspection Inspection and Severity I.evel
& Eames of Moers
' Inspectors October 1-10
^
(19) Security EQ Building -
1984 (coat.)
(20) Search Equipeedt la
' mot inspected.
~. -
(21) Numerous areas illuminated at less than footcandles.
(22) Several experienced white-a in afternoonTua~(glire).
(23) 4 perimeter zones cculd not be viewed b)
(24).
l
- _.7 -
__ act protected by tamper circuitry.
(25:
- are partly maskea.
l (26) Search equipment not stable enough to warrant only being tested on a l
l (27)' Search'Trala modifications to prevent unsearched persons from entering protect area.
(28, installed on l
i as required in' Security Plan.
~
(29) e
-receivers are~act eqdipped with adequate (30) _ _._.,_
~_
~.
l (31) Ability E _
at vital area doors, and
.2 (32) Excessivesse of
~
throughout Unit-1.
(33) Traising needed for alare station operat
- use pf _.
m
-ENFORCDENT'NISTORY-
~
l Units Involved:
'~
P ge 4 cf Docket Nos.
Type of Dates of Total Description of Violations Follow-Up Items and Observations Icspection Inspection Inspection and Severity Level
& Names of Nours Inspectors October 1-10 (34 at alare station 1984 (coat.)
(35) All alares at alare stations._
~ ~
(36) Physical examinations for Security Offic
- no glaucosa test.
l (37) Two security officers had expired medic: ;
examinations.
(38)Traininaforsecurity" Captains"-lacki!
CAS/SAS Training.
(39) Trainima for security officers - lacking CAS/SAS Training.
Pre-l December 10-14 74 Exit meeting identified 8 Alare Rate: la December 14, 1984 letter, Operational 1984 deficiencies which could not be licensee committed to further reduce their al ;
Icepectica D. Schaefer corrected prior to completion of rate.
i 3rd Inspection L. Norderhaug the preoperational inspection. Im Glaucoma Tests:
cf 3 total December 14, 1984 letter, licensee licensee coenitted to complete glaucces tests coenitted to complete correction for all security personnel by 4/30/85.
i of each deficiency.
Lishtima: In December 14, 1984 letter, licen No violations were identified as committed to correcting two areas that had l
OL was not issued.
deficient lighting.
l l
Additional Coeniteemts in December 14, 1984 Letter:
(1) Install a security lock on the (2) Revis '
' security lock procedure; (3) Reduce security i
alare rate; (4) Revise a security test procedure; (5) Correct 2lightingdeficiencief l
i acted above; (6) Complete glaucoma tests for L
security officers; (7)
~
(4)
}
?
l r_
--g
-o
-r,
.--,n,,--
c-
.e w
-nw
~.
-v-r
ENFORCE!ENT MISTORY- ~
Unito Involved:
Pese 5 ci:
Docket Nos.
k Type of Dates of Total Description of Violations Follow-Up Items and Observations l
Inspection Inspection Inspection and Severity Level
& Names of Nours
' Inspectors t
Routine May 6-10, 40 Level IV Violation against Unit-1. (1). Noted that approximately 8' section of Safeguards 1985 (Licensee ~was operating a separate protected area fence was missing - nevtl (Security)
D. Schaefer vehicle craft gate which was not la installed. This area was under coastar -
Inspection the approved Security Plan.
surveillance by posted security offices Note: This deficiency was previously however, the missing fence was not observed and documented by a QA identified by the licensee.
inspection and the licensee failed (2) Noted that licensee had recently submit to take corrective actions.
a design change request for correcting area with deficient lishtias.
~
(3) Noted that licensee was taking actions zaprove _
(4) Inspector noted that single entry into
'l alarm zone caused multiple alarms. The multiple alarms-(cascading alarms) slob, l
m the operation of the alarm station.
~
Licensee indicated they were in process l
l of carreciing this problem.
(5). Licensee continued to:TJceive 7 ~
~
_of fire alarms in security :
m -
- alcre stations.
_ ~
~
~
(6) ' Inspector noted that : licensee did not h i
_ ~
- g
-e--
--.--~%
...-m.._
s.
s
'[_
(7) Inspector observeU that several securit doors were equipped with_.
ti, be used during situation is which th {
x
~
lockiailed...
_ were
[
~ ;
ramoved during this inspection.
~
- }_
~_
~
,s p
s k
'A *
~m 4
,~
i j
~
e Ow e
--.=__- - --
~-
ENFORCEMENT HISTORY'
~ ~ ~ ~
Unito Involved:
Pcg2 6 ef Dock 2t Nos.
Type of Dates of Total Description of Violations Follow-Up Items and Observations Iespection Inspection Inspection and Severity Level
& Names of Hours
- Inspectors Routine July 22-26, 39 No violations identified during (1) Observed that the written contract with Safeguards 1985 the course of this inspection within Guard Service Company did not include t (Security)
D. Schaefer the areas examined.
4 part provisions of 10 CFR 73.55(b)(1)
Inspection (2) In 1983, in rdsponse to IN 83-15, the Unit-1 only licensee committed to implementing a Verification System where ~
(for security-
- background ~ investigation) would be recontacted to verify that the investigative agency had previously contacted them. Licensee was unable to provide documentation to support the implementation of this Verification Sys (3) Inspector observed that procedures allo the Security Badge, for terminated a
employees, to reamin in badge rack unti days following termination. Situation corrected.
(4) Corporate Security conducted an investigation regarding the unauthorize,
operation / manipulation of equipment at r
Unit-2.
No subjects were identified.
Rautine September 41 Level IV Violation against This inspection did not identify any new fol Safeguards 23-27, 1985 Unit-1 in that after the licensee up items.
(Security)
D. Schaefer determined through testing that a IEspection 3
portion of the perimeter Unit-1 plus was inadequate, no Storage of measure to compensate for this Feel deficiency was taken.(until noted Inspection by the inspector).
5 ct Unit-2 Level V Violation against Unit-1 in that upon identifying the deficiency in the perimeter alarm system,.,the licensee failed to telephonically
~
nqt{fy NRC within 2$ hoyrs.
~~
~
~ ENFORCEMENT HISTORY'~~
~
l Units Invalvsd:
Pag 2 7 ci Dsckat Nos.
Type of Dates of Total Description of Violations Follow-Up Items and Observations Inspection Inspection Inspection and Severity Level
& Names of Hours
" Inspectors Pre-October 3-10, 225 This Unit-2 preoperational (1) One Security Procedure was being rewritt Operational 1985 security' inspection identified four and needed to be reviewed upon being Security October 11-25, violations against Unit-1.
published.
Inspection 1985 (1) Screening records for (2)
Observed by in,pectors that increased s
for Unit-2 contract employee did not reflect security requirements because of Unit-2 that he had been evaluated in requirements, caused numerous security accordance with the licensee's officers to work on two or three of the Personnel Reliability Program.
(Note:
three scheduled days off. Continued Screening records documented 2 felony convictions for theft, plus serving time in prison for 3rd felony theft
~
conviction.)
of the uniformed security officers 3
(2) Security screening records (3) ~ Noted an excessive alarm rate which seve for 4 contract employees did not ly challenged the security organization:
have documentation to response capability. Measures to reduce the alarm rate will be reviewed in the future.
..... _ _. _ Inspectors observed licensee (4) Some portals were open and unable to be (3) designated vehicle parked outside closed. They were identified for the protected area in lieu of being inspection in the future.
parked inside the protected area.
(5) Noted in two areas that a (4) As a result of inspectors
- testing,
_ _ _ _ _ _. =. _
e (5) Lighting survey identified two areas wit insufficient lighting.
(6) Observed that the overtime for Contract Based upon'the results of this pre-Security Officers exceeded the licensee' operational security inspection the limitations.
licensee was advised that a (7) Observed
____ that were determination as to their compliance ineffective.
with NRC Security requirements and (8) Noted that the numbering for:
their ability to protect publi,c's was confusing, and of ten caused health and safety could not be made misinformation between security and at this time.,
maintenance organization.
e e
.a,,,,
. = _.
~ ~ ~~ ~~
ENFORCEMENT *HISTORi-- - - -
Units Involvsd:
Peg 2 8 cf Dscket Nss.
Type of Dates of Total Description of Violations Follow-Up Items and Observations Inspection Inspection Inspection and Severity Level
& Names of Hours
- Inspectors (9) Unit-2 Secondary Access Point
'~
~
was not operating - insgie~ct at
~
later date.
(10) for 15 doors was workin~g.~ Thiiisi-~ doors' were posted with security officers. Equipment was inspe, at a later date.
(11) 2 __
were inoperativ and inspected later.
(12) 4 vital areas will be inspected at a la date.
(13) High activity and noise level inside Central Alarm Station.
(14) Numerous were identifi Pre-November 11-79 No violations were identified at (1) Inspectors identified that as a result Operational 14, 1985 Unit-2 as OL had not been issued.
increased security commitments at Unit-Security D. Schaefer that numerous uniformed security person Inspection L. Norderhaug had. _ _. _
for Unit-2 with very little time
_p~~_..
9 O
g
'ENFORCEtiENT* HISTORT' Units Involved:
Pcg2 9 of Docket Nes.
Type of Dates of Total Description of Violations Follow-Up Items and Observations Inspection Inspection Inspection and Severity Level
& Names of Ilours Inspectors November 11-15, (2) Observed that:
1985 (cont.)
between vital islands were not adequatt
- s protected.
8 (3) Observed that the--
_ _ _ - - -were nc properly secured.
a (4) Noted three that did not provide an adequate-]
(5) As a result of this pre-operational ser ity inspection, the major deficiency wa in the area of communications.
~
As a result the licensee provided a 11/14/85 letter which stated specific actions they would be taking to correct this a
deficiency. Commitments in this letter were made part of the license.
conditions for the operating license. (
written report with a final plan of act is due to Region V prior to initial criticality of Unit-2, due o/a April 10 1986.
1 a
h
.)
e d
e e
~~ "~~~
~~ ~
' ENFORCEMENT HISTORY ~ ~ ~ ~
~
Units Involvad:
Docket Nos.
Pag 2 10 c.
Type of Dates of Total Description of Violations Follow-Up Items and Observations Inspection Inspection Inspection and Severity Level
& Names of Hours Inspectors Routine February 11-Level.III Violation against Unit-1 (1) Identified an inconsistency in the Secu i
Safeguards March 13, 1986 and Unit-2. Three instances in Plan concerning locked and alarmed oper.
(Security)
D. Schaefer which vital area doors were assigned in vital areas.
j Inspection L. Norderhaug a protected-area M. Schuster (2) Identified a portion of a security proc (exit only)
Level IV Violation against Unit 1 which was inconsistent with the securit j
and Unit 2.
Inadequate VA Barriers plan. The procedure incorrectly allowe' l
Note: During (required barrier coverine any i
exit meeting, M. Schuster expressed his
~
concern that 2
Level III Violation against Unit-2 the demonstrated contract employee entered a vital overall area for which he had no authorization.
~~~
~~~
~
performance of Security failed to respond to 5 alarms l
the licensee's caused by this emloyee..The sixth security alarm was responded to by security i
organization personnel.
was " marginal" i
at best.
Level IV Violation against Unit-1 and Unit-2.
Inadequate vital area barriers in that barriers i
were not welded in place.
i Level IV Violation. Failure to report security events to NRC. These 8 3
events were all properly compensated for, however, not reported to NRC Operations Center.-
s I
4 e
'o s
e