IR 05000277/2007404: Difference between revisions
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{{Adams|number = ML073090061}} | {{Adams | ||
| number = ML073090061 | |||
| issue date = 11/05/2007 | |||
| title = IR 05000277-07-404, 05000278-07-404, on 09/21/2007 - 09/27/2007, Peach Bottom Atomic Power Station (Pbaps), Units 2 and 3; Augmented Inspection | |||
| author name = Collins S L | |||
| author affiliation = NRC/RGN-I/ORA | |||
| addressee name = Crane C M | |||
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear | |||
| docket = 05000277, 05000278 | |||
| license number = DPR-044, DPR-056 | |||
| contact person = | |||
| document report number = IR-07-404 | |||
| document type = Inspection Report, Letter | |||
| page count = 26 | |||
}} | |||
{{IR-Nav| site = 05000277 | year = 2007 | report number = 404 }} | {{IR-Nav| site = 05000277 | year = 2007 | report number = 404 }} | ||
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==Dear Mr. Crane:== | ==Dear Mr. Crane:== | ||
On September 28, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed anaugmented inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.This inspection was initiated in accordance with NRC Management Directive 8.3, "NRC IncidentInvestigation Program," and Inspection Manual Chapter 0309, "Reactive Inspection DecisionBasis for Reactors," and conducted in accordance with Inspection Procedure 93800,"Augmented Inspection Team." The enclosed inspection report documents the observationsand issues developed by the team and discussed on September 28, 2007, with Mr. JosephGrimes. A public exit meeting was conducted with Mr. Ron DeGregorio and other members ofyour staff on October 9, 2007. The events that led to this inspection began when a PBAPS security officer videotaped multipleinstances of several security officers inattentive to duty at the station's former and current powerblock "ready rooms." The NRC was made aware of the existence of these videos, by WCBS-TV(New York City), on September 10, 2007. While the validity and nature of inattentiveness wasnot yet known, the NRC began enhanced inspection oversight of security at PBAPS andverbally referred the information to Exelon management for investigation the same day. TheNRC had the opportunity to first view these videos on September 19, 2007, which depictedmultiple security officers inattentive to duty on four separate occasions in the station's readyroom between March and August 2007. In response to the viewing of these videos and NRCknowledge of Exelon's investigation details, it was determined on September 19, 2007, that anaugmented inspection team was warranted. A charter was developed on September 20, 2007,and the NRC commenced an Augmented Inspection Team at PBAPS on September 21, 2007. The Augmented Inspection Team concluded that your staff's prompt compensatory measuresand immediate actions, in response to the videotaped inattentive security officers, | On September 28, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed anaugmented inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.This inspection was initiated in accordance with NRC Management Directive 8.3, "NRC IncidentInvestigation Program," and Inspection Manual Chapter 0309, "Reactive Inspection DecisionBasis for Reactors," and conducted in accordance with Inspection Procedure 93800,"Augmented Inspection Team." The enclosed inspection report documents the observationsand issues developed by the team and discussed on September 28, 2007, with Mr. JosephGrimes. A public exit meeting was conducted with Mr. Ron DeGregorio and other members ofyour staff on October 9, 2007. The events that led to this inspection began when a PBAPS security officer videotaped multipleinstances of several security officers inattentive to duty at the station's former and current powerblock "ready rooms." The NRC was made aware of the existence of these videos, by WCBS-TV(New York City), on September 10, 2007. While the validity and nature of inattentiveness wasnot yet known, the NRC began enhanced inspection oversight of security at PBAPS andverbally referred the information to Exelon management for investigation the same day. TheNRC had the opportunity to first view these videos on September 19, 2007, which depictedmultiple security officers inattentive to duty on four separate occasions in the station's readyroom between March and August 2007. In response to the viewing of these videos and NRCknowledge of Exelon's investigation details, it was determined on September 19, 2007, that anaugmented inspection team was warranted. A charter was developed on September 20, 2007,and the NRC commenced an Augmented Inspection Team at PBAPS on September 21, 2007. The Augmented Inspection Team concluded that your staff's prompt compensatory measuresand immediate actions, in response to the videotaped inattentive security officers, were appropriate to ensur e the station's continued ability to properly implement the Security Plan. Additionally, the NRC issued confirmatory action letter 1-07-005, dated October 19, 2007, toensure those compensatory measures remain in place until the NRC has completed its reviewof your causal evaluation and corrective action plan. | ||
C. M. Crane2Notwithstanding the confirmatory action letter, the Augmented Inspection Team identifiedperformance issues associated with security officer attentiveness, security management andsupervisor effectiveness, implementation of the station's behavioral observation program, andthe corrective action program. The augmented inspection was a fact-finding effort and,therefore, these performance issues | C. M. Crane2Notwithstanding the confirmatory action letter, the Augmented Inspection Team identifiedperformance issues associated with security officer attentiveness, security management andsupervisor effectiveness, implementation of the station's behavioral observation program, andthe corrective action program. The augmented inspection was a fact-finding effort and,therefore, these performance issues w ill require additional NRC inspection follow-up and furtherreview prior to determining what enforcement action, if any, is appropriate. The NRC AIT follow-up inspection will be conducted during the week of November 5, 2007.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosures, and your response (if any) will be available electronically for public ins pection in theNRC Public Document Room or from the Publicly Available Records (PARS) component of theNRC's document system (ADAMS). ADAMS is accessible from the NRC Website athttp://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | ||
Sincerely,/RA/Samuel J. CollinsRegional AdministratorDocket Nos:50-277, 50-278License Nos:DPR-44, DPR-56 | Sincerely,/RA/Samuel J. CollinsRegional AdministratorDocket Nos:50-277, 50-278License Nos:DPR-44, DPR-56 | ||
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===Cornerstone: Physical Protection=== | ===Cornerstone: Physical Protection=== | ||
The team concluded that Exelon's prompt compensatory measures and corrective actions inresponse to the videotaped inattentive security officers at PBAPS were appropriate and ensuredthe station's ability to satisfy the Security Plan. Overall, Security Plan implementation providedassurance that the health and safety of the public was adequately protected at all times. Notwithstanding, the security officer inattentiveness adversely impacted elements of thedefense-in-depth security strategy. In addition, actions by security guard force supervision werenot effective in ensuring that unacceptable security officer behavior was promptly identified andproperly addressed.AIT Inspection Follow-Up IssuesIn accordance with guidance in IP 93800, the AIT was principally a fact-finding inspection andthe team did not make a determination whether NRC rules or requirements were violated. However, based on the team's observations, the following issues warrant additional NRC follow-up and review:1) Corrective actions for identified security officer concerns (Section 2.4)2) Security officer attentiveness and extent of condition (Section 2.5)3) Effectiveness of security management and supervisory oversight (Section 2.6)4) Behavioral Observation Program effectiveness (Section 2.7)5) Root cause analysis and extent of condition (Section 2.9) | The team concluded that Exelon's prompt compensatory measures and corrective actions inresponse to the videotaped inattentive security officers at PBAPS were appropriate and ensuredthe station's ability to satisfy the Security Plan. Overall, Security Plan implementation providedassurance that the health and safety of the public was adequately protected at all times. Notwithstanding, the security officer inattentiveness adversely impacted elements of thedefense-in-depth security strategy. In addition, actions by security guard force supervision werenot effective in ensuring that unacceptable security officer behavior was promptly identified andproperly addressed.AIT Inspection Follow-Up IssuesIn accordance with guidance in IP 93800, the AIT was principally a fact-finding inspection andthe team did not make a determination whether NRC rules or requirements were violated. However, based on the team's observations, the following issues warrant additional NRC follow-up and review:1) Corrective actions for identified security officer concerns (Section 2.4)2) Security officer attentiveness and extent of condition (Section 2.5)3) Effectiveness of security management and supervisory oversight (Section 2.6)4) Behavioral Observation Program effectiveness (Section 2.7)5) Root cause analysis and extent of condition (Section 2.9) | ||
iii Enclosure | |||
=REPORT DETAILS= | =REPORT DETAILS= | ||
1.0Inspection Background InformationOn September 10, 2007, the NRC was contacted by representatives of WCBS-TV (NewYork City), stating that videotapes of inattentive security officers (SOs) at the PeachBottom Atomic Power Station (PBAPS) were in their possession. Based upon thisinformation, the Region I Regional Administrator directed implementation of enhancedinspection oversight of security activities by the resident inspectors at PBAPS. Thatsame day, the NRC verbally informed Exelon management of the information received,whereupon Exelon commenced an internal investigation. During the subsequent daysbefore the NRC staff made arrangements to view the videotapes, Region I engagedExelon several times to discuss the status of their investigation, results achieved, andactions taken to address the alleged security officer inattentiveness issues. OnSeptember 19, 2007, the videos were made available by WCBS-TV and viewed by theNRC staff. Based on the viewing of these videos and NRC knowledge of Exelon'sinvestigation details, it was determined on September 19, 2007, that an augmentedinspection team was warranted. A charter was developed on September 20, 2007, andthe NRC commenced an Augmented Inspection Team at PBAPS on September 21,2007. The NRC staff learned that the videos were taken by a station SO on-shift using apersonal video device and a cell phone video camera on four different occasionsbetween March and August 2007. Video images depicted multiple SOs inattentive toduty in the station's "ready room" during security shifts on March 12, June 9, June 20,and August 10, 2007. The ready room is a location within the protected area boundarywhere officers are staged for response functions, while not conducting security patrols. The videos showed a total of ten SOs all working on Security Team No. 1 that appearedto be inattentive. The video clips were taken at various times during both day and nightshifts. Exelon formed an issues management team based upon NRC information passedverbally on September 10, 2007. One of Exelon's initial actions was to re-emphasize to the PBAPS security guard force and Exelon fleet security staffs the need for continuedfitness for duty (FFD), with emphasis in the area of | 1.0Inspection Background InformationOn September 10, 2007, the NRC was contacted by representatives of WCBS-TV (NewYork City), stating that videotapes of inattentive security officers (SOs) at the PeachBottom Atomic Power Station (PBAPS) were in their possession. Based upon thisinformation, the Region I Regional Administrator directed implementation of enhancedinspection oversight of security activities by the resident inspectors at PBAPS. Thatsame day, the NRC verbally informed Exelon management of the information received,whereupon Exelon commenced an internal investigation. During the subsequent daysbefore the NRC staff made arrangements to view the videotapes, Region I engagedExelon several times to discuss the status of their investigation, results achieved, andactions taken to address the alleged security officer inattentiveness issues. OnSeptember 19, 2007, the videos were made available by WCBS-TV and viewed by theNRC staff. Based on the viewing of these videos and NRC knowledge of Exelon'sinvestigation details, it was determined on September 19, 2007, that an augmentedinspection team was warranted. A charter was developed on September 20, 2007, andthe NRC commenced an Augmented Inspection Team at PBAPS on September 21,2007. The NRC staff learned that the videos were taken by a station SO on-shift using apersonal video device and a cell phone video camera on four different occasionsbetween March and August 2007. Video images depicted multiple SOs inattentive toduty in the station's "ready room" during security shifts on March 12, June 9, June 20,and August 10, 2007. The ready room is a location within the protected area boundarywhere officers are staged for response functions, while not conducting security patrols. The videos showed a total of ten SOs all working on Security Team No. 1 that appearedto be inattentive. The video clips were taken at various times during both day and nightshifts. Exelon formed an issues management team based upon NRC information passedverbally on September 10, 2007. One of Exelon's initial actions was to re-emphasize to the PBAPS security guard force and Exelon fleet security staffs the need for continuedfitness for duty (FFD), with emphasis in the area of fati gue, and their responsibilities toremain alert on duty and report any inattentiveness to supervision. On September 19,2007, Exelon management and Wackenhut established enhanced security staffoversight at PBAPS, including Wackenhut corporate management providing 24-houroversight and observation of the security officers. On September 20, 2007, Wackenhutimplemented 24-hour on-site security supervision in the "ready room." By letter to theRegional Administrator, dated September 21, 2007, Exelon highlighted their immediateefforts to address security officer attentiveness concerns and their investigation findings,to date. Exelon removed site access privileges and placed the security officers,identified as being inattentive in the videotapes, on administrative hold, pending theoutcome of Exelon's internal investigation.Attachment C contains the detailed chronology associated with this event. | ||
2Enclosure1.1Augmented Inspection Objectives (93800)Based on the deterministic criteria specified in Management Directive 8.3, "NRC IncidentInvestigation Program," and Inspection Manual Chapter 0309, "Reactive InspectionDecision Basis for Reactors," an Augmented Inspection Team was initiated using theinspection guidance of IP 93800, "Augmented Inspection Team." As outlined in the AIT charter (Attachment B), the inspection team's objectives were to:(1) review the facts surrounding the specific security events identified and Exelon'scorrective actions; (2) understand Exelon's short and long-term approach to address theobserved performance issues; (3) assess the Peach Bottom security program to assurethat the current security program is effective and meeting the security plan; and(4) identify any generic issues associated with the events. 2.1Independent Review of Events (AIT Charter Items No. 2 and 3) | 2Enclosure1.1Augmented Inspection Objectives (93800)Based on the deterministic criteria specified in Management Directive 8.3, "NRC IncidentInvestigation Program," and Inspection Manual Chapter 0309, "Reactive InspectionDecision Basis for Reactors," an Augmented Inspection Team was initiated using theinspection guidance of IP 93800, "Augmented Inspection Team." As outlined in the AIT charter (Attachment B), the inspection team's objectives were to:(1) review the facts surrounding the specific security events identified and Exelon'scorrective actions; | ||
: (2) understand Exelon's short and long-term approach to address theobserved performance issues; | |||
: (3) assess the Peach Bottom security program to assurethat the current security program is effective and meeting the security plan; and(4) identify any generic issues associated with the events. 2.1Independent Review of Events (AIT Charter Items No. 2 and 3) | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The team used formal and informal interviews, plant walkdowns, and unannouncedobservations during day and night shifts to independently assess the extent thatinattentive SOs may go undetected at the station. The team reviewed the station'semployee concern program files, Wackenhut's Safe-2-Say program, and correctiveaction documents to determine station effectiveness in addressing security program andpersonnel issues related to the behavior exhibited during these events. The teamreviewed security corrective action | The team used formal and informal interviews, plant walkdowns, and unannouncedobservations during day and night shifts to independently assess the extent thatinattentive SOs may go undetected at the station. The team reviewed the station'semployee concern program files, Wackenhut's Safe-2-Say program, and correctiveaction documents to determine station effectiveness in addressing security program andpersonnel issues related to the behavior exhibited during these events. The teamreviewed security corrective action doc uments, audits, surv eillances, and drilldocumentation to determine station opportunities to identify an adverse trend in securityperformance prior to the videotaping events. b.ObservationsThe team determined the following causal factors contributed to inattentive behavior inthe security organization: *Adverse behavior had developed among SOs on Security Team No. 1 thattreated inattentiveness in the "ready room" as an acceptable practice; *The "ready room" was not accessible for adequate supervisory oversight. Specifically, the room was locked and did not permit unannounced supervisorychecks, and the single room window was blocked from supervisory observationsby a file cabinet; *Management failed to effectively communicate and reinforce stationattentiveness expectations. Although generic briefings were given to securityteams on alertness and behavior observations, the communications were noteffectively received or specific to actual conditions at the plant;*Security supervisors failed to properly address concerns involving inattentiveSOs and were not receptive to these concerns being brought forward. At leasttwo security supervisors were informed that SOs were inattentive andappropriate actions were not taken;*The environmental conditions in the "ready room" were not conducive toattentiveness and station management failed to address these known adverseconditions. The "ready room" had high background noise, was dimly lit, and waspoorly ventilated; 5Enclosure*Management failed to identify human factor issues related to 12-hour shiftsspent, in part, at the "ready room" post with low physical activity. For some SOs,a significant portion of the shift could be spent sitting in the ready room when noton patrol or performing other duties; and*Management failed to provide adequate attentiveness stimuli to the SOs in the"ready room."2.4Corrective Actions and Compensatory Measures (AIT Charter Items No. 1, 8, and 9) | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The team performed reviews to verify that compensatory measures implemented atPBAPS were appropriate, maintained, and consistent with the site's Security Plan. Theteam conducted interviews with the SOs and supervisors performing compensatorymeasures and conducted walkdowns of those measures. The team reviewedsupervisory observation and coaching documentation. The team also reviewed Exeloninitiated nuclear event reports and Exelon's transition plan for the security guard force. | The team performed reviews to verify that compensatory measures implemented atPBAPS were appropriate, maintained, and consistent with the site's Security Plan. Theteam conducted interviews with the SOs and supervisors performing compensatorymeasures and conducted walkdowns of those measures. The team reviewedsupervisory observation and coaching documentation. The team also reviewed Exeloninitiated nuclear event reports and Exelon's transition plan for the security guard force. | ||
b.ObservationsThe station's prompt compensatory measures and corrective actions implemented | b.ObservationsThe station's prompt compensatory measures and corrective actions implemented to address SOs inattentiveness were appropriate and assured Exelon's ability to implementthe security strategy. The following is a list of prompt measures implemented at PBAPSby Exelon:*Briefed all SOs on fatigue and responsibilities for self-reporting;*Enhanced Wackenhut Corporate oversight at the site for 24-hour coverage and asecurity supervisor was placed in the "ready room" 24 hours a day;*Exelon senior site management and site security oversight observationsperformed daily;*Security Team No. 1 removed from the security shift rotation, denied site access,and placed on administrative hold, pending investigation results;*Exelon issued Nuclear Event Report (NER), NC-07-034, with fleet-wide actionsand issued a generic communication to the industry;*All SOs were interviewed;*Exelon plans to terminate the Wackenhut security contract for security services,effective November 1, 2007; and*Exelon implemented enhanced radio checks on September 27, 2007, basedupon NRC observations.The team identified one corrective action improvement associated with the predictabilityof radio communication checks for the various security posts. The team noted that arandom order radio check would enhance alertness. Exelon implemented this changeon September 27, 2007. In addition, Exelon communicated that any actions to changecompensatory measures established would be discussed with the NRC, in advance. | ||
6EnclosureThe team identified one example where the corrective actions, prior to September 2007,were not effectively implemented. The security organization did not enter instances ofinappropriate SO behavior from early 2007 into the station corrective action program(CAP). There was no indication that station corrective actions regarding unacceptableSO behavior were effectively received or acted upon by security supervisors ormanagers at PBAPS.2.5Extent of Inattentive Security Officers (AIT Charter item No. 5) | 6EnclosureThe team identified one example where the corrective actions, prior to September 2007,were not effectively implemented. The security organization did not enter instances ofinappropriate SO behavior from early 2007 into the station corrective action program(CAP). There was no indication that station corrective actions regarding unacceptableSO behavior were effectively received or acted upon by security supervisors ormanagers at PBAPS.2.5Extent of Inattentive Security Officers (AIT Charter item No. 5) | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The team reviewed Exelon's root cause team charter and interviewed the root causeteam to understand goals and milestones associated with the performance of their rootcause evaluation, including determination of causal factors and extent of condition. Theinspectors reviewed the scope and depth of the barrier analysis associated with thecausal evaluation. b.ObservationsExelon's root cause team and charter were established during the week ofSeptember 24, 2007. The Exelon team leader discussed their preliminary eventchronology and scope of efforts with the team on September 28, 2007. Exelon has acompletion milestone for the documented root cause evaluation by October 26, 2007. The NRC AIT follow-up inspection will review | The team reviewed Exelon's root cause team charter and interviewed the root causeteam to understand goals and milestones associated with the performance of their rootcause evaluation, including determination of causal factors and extent of condition. Theinspectors reviewed the scope and depth of the barrier analysis associated with thecausal evaluation. b.ObservationsExelon's root cause team and charter were established during the week ofSeptember 24, 2007. The Exelon team leader discussed their preliminary eventchronology and scope of efforts with the team on September 28, 2007. Exelon has acompletion milestone for the documented root cause evaluation by October 26, 2007. The NRC AIT follow-up inspection will review Ex elon's root cause and extent of conditionwhen this evaluation is completed. | ||
9Enclosure2.10Generic Issues and Implications (AIT Charter Item No. 11) | 9Enclosure2.10Generic Issues and Implications (AIT Charter Item No. 11) | ||
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: [[contact::J. GrimesSite Vice PresidentP. CowanDirector]], Licensing and Regulatory AffairsS. CraigSecurity ManagerJ. MallonLicensing Manager | : [[contact::J. GrimesSite Vice PresidentP. CowanDirector]], Licensing and Regulatory AffairsS. CraigSecurity ManagerJ. MallonLicensing Manager | ||
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED== | ==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED== | ||
None | None | ||
==LIST OF DOCUMENTS REVIEWED== | ==LIST OF DOCUMENTS REVIEWED== | ||
ProceduresLS-AA-125, "Corrective Action Program Procedure," Revision 11SY-AA-1016, "Watchstanding Practices," Revision 0SY-AA-1016, "Watchstanding Practices," Revision 4SY-AA-1020, "Supervisor Post Checks and Post Orders," Revision 0SY-AA-1020, "Supervisor Post Checks and Post Orders," Revision 1SY-AA-102, "Exelon's Nuclear Fitness-For-Duty Program," Revision 11SY-AA-101-130, "Security Responsibilities for Station Personnel," Revision 8SY-AA-101-130, "Security Responsibilities for Station Personnel," Revision 9SY-PB-101-124-1001, "Security Control Center Operations," Revision 3SY-AA-101-126, "Duties and Responsibilities of the | ProceduresLS-AA-125, "Corrective Action Program Procedure," Revision 11SY-AA-1016, "Watchstanding Practices," Revision 0SY-AA-1016, "Watchstanding Practices," Revision 4SY-AA-1020, "Supervisor Post Checks and Post Orders," Revision 0SY-AA-1020, "Supervisor Post Checks and Post Orders," Revision 1SY-AA-102, "Exelon's Nuclear Fitness-For-Duty Program," Revision 11SY-AA-101-130, "Security Responsibilities for Station Personnel," Revision 8SY-AA-101-130, "Security Responsibilities for Station Personnel," Revision 9SY-PB-101-124-1001, "Security Control Center Operations," Revision 3SY-AA-101-126, "Duties and Responsibilities of the St ation Security Organization," Revision 5SY-AA-103-513, "Behavioral Observation Program," Revision 6Condition Reports00673505003283480034463700354611003587030036947400425158004869030050911000525923005373330057041800613537006569460065727100670392006770890021008400504830 | ||
: A-2AttachmentMiscellaneousNER | : A-2AttachmentMiscellaneousNER | ||
: NC-07-034, "Inattentive Security Officer Investigation Fleet Actions," September 24, 2007NER | : NC-07-034, "Inattentive Security Officer Investigation Fleet Actions," September 24, 2007NER | ||
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ADAMSAgency-wide Documents Access and Management SystemAITAugmented Inspection TeamBOPBehavioral Observation ProgramCFRCode of Federal RegulationsFFDFitness For DutyIPInspection ProcedureNERNuclear Event ReportNRCNuclear Regulatory CommissionNSIRNuclear Security and Incident ResponsePARSPublicly Available RecordsPBAPSPeach Bottom Atomic Power StationSOSecurity OfficerWNSWackenhut Nuclear Services | ADAMSAgency-wide Documents Access and Management SystemAITAugmented Inspection TeamBOPBehavioral Observation ProgramCFRCode of Federal RegulationsFFDFitness For DutyIPInspection ProcedureNERNuclear Event ReportNRCNuclear Regulatory CommissionNSIRNuclear Security and Incident ResponsePARSPublicly Available RecordsPBAPSPeach Bottom Atomic Power StationSOSecurity OfficerWNSWackenhut Nuclear Services | ||
B-1AttachmentSeptember 20, | B-1AttachmentSeptember 20, | ||
: [[2007MEMORA]] [[ | : [[2007MEMORA]] [[NDUM TO: James]] | ||
: | : [[M.]] [[Trapp, Team Leader Augmented Inspection Team]] | ||
: [[ | |||
: [[FROM]] [[: Marsha]] | : [[FROM]] [[: Marsha]] | ||
: [[K.]] [[Gamberoni, Team Manager /]] | : [[K.]] [[Gamberoni, Team Manager /]] | ||
: [[RA]] [[/Augmented Inspection Team | : [[RA]] [[/Augmented Inspection Team SUBJECT: AUGMENTED INSPECTION]] | ||
: | |||
: [[TEAM]] [[]] | : [[TEAM]] [[]] | ||
CHARTER | CHARTER | ||
An Augmented Inspection Team (AIT) has been established for Peach Bottom to inspect andassess several security events and assess the licensee's security program. The teamcomposition is as follows: Team Manager:M. Gamberoni, | An Augmented Inspection Team (AIT) has been established for Peach Bottom to inspect andassess several security events and assess the licensee's security program. The teamcomposition is as follows: Team Manager:M. Gamberoni, | ||
: [[RI]] [[, | : [[RI]] [[, DRSTeam Leader:J. Trapp, RI,]] | ||
: [[DRS]] [[Assistant Team Leader:D. Caron,]] | : [[DRS]] [[Assistant Team Leader:D. Caron,]] | ||
: [[DRST]] [[eam Members: G. Smith,]] | : [[DRST]] [[eam Members:]] | ||
: [[G.]] [[Smith,]] | |||
: [[RI]] [[,]] | : [[RI]] [[,]] | ||
: [[DRS]] [[B. Bickett,]] | : [[DRS]] [[B. Bickett,]] | ||
: [[RI]] [[,]] | : [[RI]] [[,]] | ||
: [[DRPJ.]] [[Willis,]] | : [[DRPJ.]] [[Willis,]] | ||
NSIR OI Investigators: (2) Names to be DeterminedThe objectives of the inspection are to: (1) review the facts surrounding the specific securityissues identified and the licensee's corrective action; (2) understand the licensee's short termand long term approach to address the issues; (3) assess the Peach Bottom security programto assure that the current security program is effective and meeting the security plan; and(4) identify any generic issues associated with the events. For the period during which you are leading this inspection and documenting the results, youwill report directly to me. The guidance in | |||
Inspection Procedure 93800, "Augmented InspectionTeam," and Management Directive 8.3, "NRC Incident Investigation Procedures," apply to yourinspection.Enclosure:AIT Charter | |||
NRC Incident Investigation Procedures," apply to yourinspection.Enclosure:AIT Charter | |||
B-2AttachmentAUGMENTED | B-2AttachmentAUGMENTED | ||
: [[INSPEC]] | : [[INSPEC]] [[TION]] | ||
: [[TEAM]] [[(]] | : [[TEAM]] [[(]] | ||
: [[AIT]] [[) | : [[AIT]] [[) CHARTERPEACH]] | ||
: [[BOTTOM]] [[]] | : [[BOTTOM]] [[]] | ||
: [[UNITS]] [[]] | : [[UNITS]] [[]] | ||
: [[2 AND]] [[3]] | : [[2 AND]] [[3]] | ||
: [[SECURI]] [[TY | : [[SECURI]] [[TY EVENTSBasis for the Formation of the]] | ||
: [[AIT]] [[- Videotape provided by the alleger shows multiple instancesof multiple security officers sleeping in the former power block ready room. These events meetthe deterministic criteria for an]] | : [[AIT]] [[- Videotape provided by the alleger shows multiple instancesof multiple security officers sleeping in the former power block ready room. These events meetthe deterministic criteria for an]] | ||
AIT in Management Directive 8.3, in that they involved asignificant infraction or repeated instances of safeguards infractions that demonstrate theineffectiveness of facility security provisions.Objectives of the AIT - The objectives of the inspection are to: (1) review the facts surroundingthe specific security issues identified and the licensee's corrective action; (2) understand thelicensee's short term and long term approach to address the issues; (3) assess the PeachBottom security program to assure that the current security program is effective and meeting thesecurity plan; and (4) identify any generic issues associated with the events. To accomplish these objectives, the following will be performed: | |||
: [[1.V]] [[erify that compensatory measures implemented by the licensee for this problem areadequate and have been implemented and maintained. Review any licensee proposalsto modify the compensatory measures.2. Independently conduct interviews and inspections to fully understand the circumstancessurrounding the event and probable cause(s).]] | |||
: [[1.V]] [[erify that compensatory measures implemented by the licensee for this problem areadequate and have been implemented and maintained. Review any licensee proposalsto modify the compensatory measures.2. Independently conduct interviews and inspections to fully understand the circumstancessurrounding the event and probable cause(s). 3.]] | : [[3.AIT]] [[fact finding should include the conditions preceding the event, applicablechronology, any event precursors, human factor considerations, safeguardsconsiderations, and safety culture component considerations (as defined in]] | ||
IMC 0305,paragraphs 06.07c and d).4.Assess Exelon's root cause evaluation for adequacy with respect to the identification ofperformance deficiencies, extent of condition review, root cause(s), contributingcause(s), and corrective actions.5.Determine the extent of inattentive security officers. | |||
6.Determine inattentive security officer's impact on the Peach Bottom Security Plan. | 6.Determine inattentive security officer's impact on the Peach Bottom Security Plan. | ||
7.Evaluate Peach Bottom's supervision and management oversight of security. | 7.Evaluate Peach Bottom's supervision and management oversight of security. | ||
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B-3Attachment10.Document the inspection findings and conclusions in an AIT final report within 30calendar days of inspection completion (the day of the exit meeting).11.Consider providing appropriate information and feedback to the operating experienceprogram. | B-3Attachment10.Document the inspection findings and conclusions in an AIT final report within 30calendar days of inspection completion (the day of the exit meeting).11.Consider providing appropriate information and feedback to the operating experienceprogram. | ||
C-1AttachmentEVENT | C-1AttachmentEVENT | ||
: [[CHRONO]] | : [[CHRONO]] [[LOGY*2004 -]] | ||
: [[PBAPS]] [[security power block "ready room" established to support Security Planimplementation and provide increased defense-in-depth for]] | : [[PBAPS]] [[security power block "ready room" established to support Security Planimplementation and provide increased defense-in-depth for]] | ||
NRC Force on Forceexercises.*April 16, 2006 - NRC Force-on-Force exercise conducted (No findings). | NRC Force on Forceexercises.*April 16, 2006 - NRC Force-on-Force exercise conducted (No findings). | ||
*January 2007 - Wackenhut Corporation issues improvement plan for Safety ConsciousWork Environment (SCWE) improvement actions for its security forces at all sites.*February 2007 - Security Officer (SO) responsible for video recordings has firstobservation of inattentive | *January 2007 - Wackenhut Corporation issues improvement plan for Safety ConsciousWork Environment (SCWE) improvement actions for its security forces at all sites.*February 2007 - Security Officer (SO) responsible for video recordings has firstobservation of inattentive | ||
: [[SO]] [[ | : [[SO]] [[in the power block ready room but did not record theobservations.*March 2, 2007 -]] | ||
: [[SY]] [[-AA-1016, Revision 4, implemented to add 'attentiveness tools'based on attentiveness issue experienced at an Exelon plant.*March 12, 2007 - Five]] | : [[SY]] [[-AA-1016, Revision 4, implemented to add 'attentiveness tools'based on attentiveness issue experienced at an Exelon plant.*March 12, 2007 - Five]] | ||
: [[SO]] [[ | : [[SO]] [[inattentive to duty in the ready room captured by a]] | ||
: [[SO]] [['spersonal cell phone. All five]] | : [[SO]] [['spersonal cell phone. All five]] | ||
: [[SO]] [[ | : [[SO]] [[are on Security Team No. 1.*March 27, 2007 -]] | ||
: [[NRC]] [[receives concerns involving Peach Bottom]] | : [[NRC]] [[receives concerns involving Peach Bottom]] | ||
: [[SO]] [[ | : [[SO]] [[that areinattentive to duty at]] | ||
: [[PBAPS.]] [[*April 2007 -]] | : [[PBAPS.]] [[*April 2007 -]] | ||
: [[SO]] [[shows videotapes of inattentive]] | : [[SO]] [[shows videotapes of inattentive]] | ||
: [[SO]] [[ | : [[SO]] [[to a maintenance technician at alittle league ball game. Maintenance technician tells the]] | ||
: [[SO]] [[to inform his securitysupervisor. The following day the maintenance technician informs his supervisor whoresponds that the]] | : [[SO]] [[to inform his securitysupervisor. The following day the maintenance technician informs his supervisor whoresponds that the]] | ||
: [[SO]] [['s concern should be brought up to the security supervisor. *April 2007 - Wackenhut Corporate investigation reveals two separate]] | : [[SO]] [['s concern should be brought up to the security supervisor. *April 2007 - Wackenhut Corporate investigation reveals two separate]] | ||
: [[SO]] [[unacceptablebehavior issues received through Wackenhut Safe-2-Say program. In the course of thisinvestigation, it was determined by Wackenhut that multiple]] | : [[SO]] [[unacceptablebehavior issues received through Wackenhut Safe-2-Say program. In the course of thisinvestigation, it was determined by Wackenhut that multiple]] | ||
: [[SO]] [[ | : [[SO]] [[on Team No. 2 wereinitially untruthful to investigators and tried to hide and cover-up the events. Severalofficers were disciplined for their lack of candor and not reporting a safety concern. *April 18, 2007 - Plant review committee rejects $150K expense of further renovations to"ready room."]] | ||
: [[PBAPS]] [[senior management notified of decision to not fundimprovements.*April 30, 2007 -]] | : [[PBAPS]] [[senior management notified of decision to not fundimprovements.*April 30, 2007 -]] | ||
: [[NRC]] [[provided Exelon management with written referral for concernsassociated with Peach Bottom]] | : [[NRC]] [[provided Exelon management with written referral for concernsassociated with Peach Bottom]] | ||
: [[SO]] [[ | : [[SO]] [[that were inattentive to duty. *May 30, 2007 -]] | ||
NRC received Exelon's response stating the three referred concernsassociated with inattentive SO behavior were not substantiated. Exelon conductedinterviews that did not substantiate the issue. Exelon referenced enhancements in their | NRC received Exelon's response stating the three referred concernsassociated with inattentive SO behavior were not substantiated. Exelon conductedinterviews that did not substantiate the issue. Exelon referenced enhancements in their | ||
C-2Attachmentresponse that included radio check improvements and procedure changes to implementfixed post checks twice a shift. Exelon also referenced 15 minute stand-ups on backshifts and randomly on day shift.*June 9, 2007 - Three | C-2Attachmentresponse that included radio check improvements and procedure changes to implementfixed post checks twice a shift. Exelon also referenced 15 minute stand-ups on backshifts and randomly on day shift.*June 9, 2007 - Three | ||
: [[SO]] [[ | : [[SO]] [[inattentive on-duty in the "ready room" captured by a]] | ||
: [[SO]] [['spersonal video device (ARCOS camera).*Mid June 2007 -]] | : [[SO]] [['spersonal video device (ARCOS camera).*Mid June 2007 -]] | ||
: [[SO]] [[informs a field supervisor of inattentive guards on duty that werevideotaped. Field supervisor told lead supervisor of this information including names ofguards who were inattentive to duty on video.*Late June 2007 - Security shift supervisor and lead supervisor of Team No. 1 inform]] | : [[SO]] [[informs a field supervisor of inattentive guards on duty that werevideotaped. Field supervisor told lead supervisor of this information including names ofguards who were inattentive to duty on video.*Late June 2007 - Security shift supervisor and lead supervisor of Team No. 1 inform]] | ||
Line 177: | Line 183: | ||
: [[SO]] [[inattentive on duty in the "ready room" captured by a]] | : [[SO]] [[inattentive on duty in the "ready room" captured by a]] | ||
: [[SO]] [['spersonal cell phone.*August 10, 2007 - Three]] | : [[SO]] [['spersonal cell phone.*August 10, 2007 - Three]] | ||
: [[SO]] [[ | : [[SO]] [[inattentive on duty in the "ready room" captured by apersonal cell phone.*August 22, 2007 -]] | ||
: [[NRC]] [[reviews Exelon response that did not substantiate inattentiveSOs.]] | : [[NRC]] [[reviews Exelon response that did not substantiate inattentiveSOs.]] | ||
: [[NRC]] [[considers Exelon response acceptable after follow-up questions. *August 28, 2007 - Exelon Corporate nuclear safety review board identified Wackenhutperformance as an area for improvement fleet-wide.*September 10, 2007 -]] | : [[NRC]] [[considers Exelon response acceptable after follow-up questions. *August 28, 2007 - Exelon Corporate nuclear safety review board identified Wackenhutperformance as an area for improvement fleet-wide.*September 10, 2007 -]] | ||
: [[NRC]] [[received and verbally referred concerns to Exelon based onWCBS-TV (New York) telephone call with information about videos that showsinattentive]] | : [[NRC]] [[received and verbally referred concerns to Exelon based onWCBS-TV (New York) telephone call with information about videos that showsinattentive]] | ||
: [[SO]] [[ | : [[SO]] [[on shift at Peach Bottom.]] | ||
NRC resident inspectors begin enhancedsecurity inspections by performing increased number of observations at various securityposts during both normal and backshift hours. *September 10, 2007 - Exelon forms an Issues Management Team based on NRCinformation passed verbally. Exelon briefed PBAPS security force regarding heightenedawareness, fatigue, and responsibilit | |||
ies to report inattentiveness.*September 11, 2007 - Exelon briefed their fleet security regarding heightenedawareness, fatigue, and responsibilit | |||
PBAPS security force regarding heightenedawareness, fatigue, and | ies to report inattentiveness.*September 15 - 20, 2007 - Exelon corporate security interviews approximately 95percent on-site members of Wackenhut organization at Peach Bottom.*September 17, 2007 - SO responsible for videotaping inattentiveness has unescortedaccess suspended because of trustworthiness concerns and procedure violations. | ||
C-3Attachment*September 17, 2007 - Maintenance technician acknowledged after a site communicationon inattentiveness that he had knowledge of a | C-3Attachment*September 17, 2007 - Maintenance technician acknowledged after a site communicationon inattentiveness that he had knowledge of a | ||
: [[SO]] [[who taped inattentive]] | : [[SO]] [[who taped inattentive]] | ||
SOs on dutyand showed him the videos.*September 17, 2007 - Exelon is contacted by WCBS-TV. | |||
*September 18, 2007 - | |||
: [[NRC]] [[received and verbally referred inattentive]] | : [[NRC]] [[received and verbally referred inattentive]] | ||
: [[SO]] [[concerns thatwere received based upon telephone conversation that specified "ready room" as areaof concern for inattentive | : [[SO]] [[concerns thatwere received based upon telephone conversation that specified "ready room" as areaof concern for inattentive SOs.*September 18, 2007 - Letter from President - Wackenhut Nuclear Services (WNS), toWNS security force emphasizing fitness for duty and fatigue standards.*September 18, 2007 - Exelon makes decision for outside legal counsel to take overinvestigation in response to allegations. Exelon issues first press release at 11:00 am. *September 19, 2007 -]] | ||
: [[NRC]] [[views]] | : [[NRC]] [[views]] | ||
: [[WCBS]] [[-TV videotapes and initiates]] | : [[WCBS]] [[-TV videotapes and initiates]] | ||
Line 201: | Line 204: | ||
: [[NRC]] [[informs Exelon that an]] | : [[NRC]] [[informs Exelon that an]] | ||
: [[AIT]] [[will be dispatched to PeachBottom the following morning to begin inspection on the security events surroundinginattentive]] | : [[AIT]] [[will be dispatched to PeachBottom the following morning to begin inspection on the security events surroundinginattentive]] | ||
: [[SO]] [[ | : [[SO]] [[.]] | ||
: [[NRC]] [[issues press release announcing the augmented inspection at]] | : [[NRC]] [[issues press release announcing the augmented inspection at]] | ||
: [[PBAPS]] [[for inattentive]] | : [[PBAPS]] [[for inattentive]] | ||
: [[SO]] [[concerns.*September 21, 2007 -]] | : [[SO]] [[concerns.*September 21, 2007 -]] | ||
: [[WCBS]] [[-TV supplies Exelon with videos for viewing. Exelonconfirms that videos contain Peach Bottom]] | : [[WCBS]] [[-TV supplies Exelon with videos for viewing. Exelonconfirms that videos contain Peach Bottom]] | ||
: [[SO]] [[ | : [[SO]] [[in the "ready room."*September 21, 2007 -]] | ||
: [[NRC]] [[commences]] | : [[NRC]] [[commences]] | ||
: [[AIT]] [[and arrives on site for inattentive]] | : [[AIT]] [[and arrives on site for inattentive]] |
Revision as of 01:00, 22 October 2018
ML073090061 | |
Person / Time | |
---|---|
Site: | Peach Bottom ![]() |
Issue date: | 11/05/2007 |
From: | Collins S L Region 1 Administrator |
To: | Crane C M Exelon Generation Co, Exelon Nuclear |
References | |
IR-07-404 | |
Download: ML073090061 (26) | |
Text
November 5, 2007
Mr. Christopher M. CranePresident and CNOExelon NuclearExelon Generation Company, LLC200 Exelon WayKennett Square, PA 19348
SUBJECT: PEACH BOTTOM ATOMIC POWER STATION - NRC AUGMENTEDINSPECTION TEAM (AIT) REPORT 05000277/2007404 AND05000278/2007404
Dear Mr. Crane:
On September 28, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed anaugmented inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.This inspection was initiated in accordance with NRC Management Directive 8.3, "NRC IncidentInvestigation Program," and Inspection Manual Chapter 0309, "Reactive Inspection DecisionBasis for Reactors," and conducted in accordance with Inspection Procedure 93800,"Augmented Inspection Team." The enclosed inspection report documents the observationsand issues developed by the team and discussed on September 28, 2007, with Mr. JosephGrimes. A public exit meeting was conducted with Mr. Ron DeGregorio and other members ofyour staff on October 9, 2007. The events that led to this inspection began when a PBAPS security officer videotaped multipleinstances of several security officers inattentive to duty at the station's former and current powerblock "ready rooms." The NRC was made aware of the existence of these videos, by WCBS-TV(New York City), on September 10, 2007. While the validity and nature of inattentiveness wasnot yet known, the NRC began enhanced inspection oversight of security at PBAPS andverbally referred the information to Exelon management for investigation the same day. TheNRC had the opportunity to first view these videos on September 19, 2007, which depictedmultiple security officers inattentive to duty on four separate occasions in the station's readyroom between March and August 2007. In response to the viewing of these videos and NRCknowledge of Exelon's investigation details, it was determined on September 19, 2007, that anaugmented inspection team was warranted. A charter was developed on September 20, 2007,and the NRC commenced an Augmented Inspection Team at PBAPS on September 21, 2007. The Augmented Inspection Team concluded that your staff's prompt compensatory measuresand immediate actions, in response to the videotaped inattentive security officers, were appropriate to ensur e the station's continued ability to properly implement the Security Plan. Additionally, the NRC issued confirmatory action letter 1-07-005, dated October 19, 2007, toensure those compensatory measures remain in place until the NRC has completed its reviewof your causal evaluation and corrective action plan.
C. M. Crane2Notwithstanding the confirmatory action letter, the Augmented Inspection Team identifiedperformance issues associated with security officer attentiveness, security management andsupervisor effectiveness, implementation of the station's behavioral observation program, andthe corrective action program. The augmented inspection was a fact-finding effort and,therefore, these performance issues w ill require additional NRC inspection follow-up and furtherreview prior to determining what enforcement action, if any, is appropriate. The NRC AIT follow-up inspection will be conducted during the week of November 5, 2007.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosures, and your response (if any) will be available electronically for public ins pection in theNRC Public Document Room or from the Publicly Available Records (PARS) component of theNRC's document system (ADAMS). ADAMS is accessible from the NRC Website athttp://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/Samuel J. CollinsRegional AdministratorDocket Nos:50-277, 50-278License Nos:DPR-44, DPR-56
Enclosure:
Inspection Report 05000277/2007404 and 05000278/2007404w/Attachments
Attachments:
(A)Supplemental Information(B)Augmented Inspection Team Charter(C)Event Chronology
SUMMARY OF FINDINGS
IR 05000277/2007-404, 05000278/2007-404; 09/21/2007 - 09/28/2007; Peach Bottom AtomicPower Station (PBAPS), Units 2 and 3; Augmented Inspection.The augmented inspection was conducted by a team consisting of inspectors from the NRC'sRegion I office, special agents from the Office of Investigation, and a security specialist fromNuclear Security and Incident Response (NSIR). The NRC's program for overseeing the safeoperation of commercial nuclear power reactors is described in NUREG-1649, "ReactorOversight Process," Revision 4, dated December 2006. An Augmented Inspection Team (AIT)was initiated in accordance with NRC Management Directive 8.3, "NRC Incident InvestigationProgram," and Inspection Manual Chapter 0309, "Reactive Inspection Decision Basis forReactors," and implemented using Inspection Procedure (IP) 93800, "Augmented InspectionTeam."
Cornerstone: Physical Protection
The team concluded that Exelon's prompt compensatory measures and corrective actions inresponse to the videotaped inattentive security officers at PBAPS were appropriate and ensuredthe station's ability to satisfy the Security Plan. Overall, Security Plan implementation providedassurance that the health and safety of the public was adequately protected at all times. Notwithstanding, the security officer inattentiveness adversely impacted elements of thedefense-in-depth security strategy. In addition, actions by security guard force supervision werenot effective in ensuring that unacceptable security officer behavior was promptly identified andproperly addressed.AIT Inspection Follow-Up IssuesIn accordance with guidance in IP 93800, the AIT was principally a fact-finding inspection andthe team did not make a determination whether NRC rules or requirements were violated. However, based on the team's observations, the following issues warrant additional NRC follow-up and review:1) Corrective actions for identified security officer concerns (Section 2.4)2) Security officer attentiveness and extent of condition (Section 2.5)3) Effectiveness of security management and supervisory oversight (Section 2.6)4) Behavioral Observation Program effectiveness (Section 2.7)5) Root cause analysis and extent of condition (Section 2.9)
iii Enclosure
REPORT DETAILS
1.0Inspection Background InformationOn September 10, 2007, the NRC was contacted by representatives of WCBS-TV (NewYork City), stating that videotapes of inattentive security officers (SOs) at the PeachBottom Atomic Power Station (PBAPS) were in their possession. Based upon thisinformation, the Region I Regional Administrator directed implementation of enhancedinspection oversight of security activities by the resident inspectors at PBAPS. Thatsame day, the NRC verbally informed Exelon management of the information received,whereupon Exelon commenced an internal investigation. During the subsequent daysbefore the NRC staff made arrangements to view the videotapes, Region I engagedExelon several times to discuss the status of their investigation, results achieved, andactions taken to address the alleged security officer inattentiveness issues. OnSeptember 19, 2007, the videos were made available by WCBS-TV and viewed by theNRC staff. Based on the viewing of these videos and NRC knowledge of Exelon'sinvestigation details, it was determined on September 19, 2007, that an augmentedinspection team was warranted. A charter was developed on September 20, 2007, andthe NRC commenced an Augmented Inspection Team at PBAPS on September 21,2007. The NRC staff learned that the videos were taken by a station SO on-shift using apersonal video device and a cell phone video camera on four different occasionsbetween March and August 2007. Video images depicted multiple SOs inattentive toduty in the station's "ready room" during security shifts on March 12, June 9, June 20,and August 10, 2007. The ready room is a location within the protected area boundarywhere officers are staged for response functions, while not conducting security patrols. The videos showed a total of ten SOs all working on Security Team No. 1 that appearedto be inattentive. The video clips were taken at various times during both day and nightshifts. Exelon formed an issues management team based upon NRC information passedverbally on September 10, 2007. One of Exelon's initial actions was to re-emphasize to the PBAPS security guard force and Exelon fleet security staffs the need for continuedfitness for duty (FFD), with emphasis in the area of fati gue, and their responsibilities toremain alert on duty and report any inattentiveness to supervision. On September 19,2007, Exelon management and Wackenhut established enhanced security staffoversight at PBAPS, including Wackenhut corporate management providing 24-houroversight and observation of the security officers. On September 20, 2007, Wackenhutimplemented 24-hour on-site security supervision in the "ready room." By letter to theRegional Administrator, dated September 21, 2007, Exelon highlighted their immediateefforts to address security officer attentiveness concerns and their investigation findings,to date. Exelon removed site access privileges and placed the security officers,identified as being inattentive in the videotapes, on administrative hold, pending theoutcome of Exelon's internal investigation.Attachment C contains the detailed chronology associated with this event.
2Enclosure1.1Augmented Inspection Objectives (93800)Based on the deterministic criteria specified in Management Directive 8.3, "NRC IncidentInvestigation Program," and Inspection Manual Chapter 0309, "Reactive InspectionDecision Basis for Reactors," an Augmented Inspection Team was initiated using theinspection guidance of IP 93800, "Augmented Inspection Team." As outlined in the AIT charter (Attachment B), the inspection team's objectives were to:(1) review the facts surrounding the specific security events identified and Exelon'scorrective actions;
- (2) understand Exelon's short and long-term approach to address theobserved performance issues;
- (3) assess the Peach Bottom security program to assurethat the current security program is effective and meeting the security plan; and(4) identify any generic issues associated with the events. 2.1Independent Review of Events (AIT Charter Items No. 2 and 3)
a. Inspection Scope
The team conducted 38 interviews to understand the circumstances and factssurrounding the events, including the probable causes and extent of inattentiveness ofSOs at the site. The NRC interviewed security personnel from each of the four securityteams, Wackenhut supervision, maintenance personnel, and Exelon management togather information and evaluate the station's response to the event and currentoversight of security. In addition to interviews, the team reviewed the videotapes of theinattentive SOs; and examined station documentation, procedures, and correctiveactions associated with the security program and this event. b.ObservationsBased on a review of the videos, the team confirmed what appeared to be inattentive,on-duty SOs on four separate occasions (March 12; June 9; June 20; and August 10,2007). There were a total of ten SOs that appeared inattentive to duty while working onSecurity Team No. 1. Based upon interviews and documentation reviews, the team didnot identify any additional inattentive officers working on teams other than SecurityTeam No.1. The NRC review of inattentive SOs is on-going. The team noted that noneof the ten videotaped SOs who were interviewed admitted to being inattentive to duty orseeing anyone inattentive to duty.The team identified that a maintenance technician and maintenance supervisor weremade aware of the videos prior to NRC becoming aware of the issues on September 10,2007. The maintenance technician reported the issue to his supervisor who did notprovide the information to site management. The maintenance supervisor informed themaintenance technician to have the SO report the issue to his security supervisor. Thelicensee had initiated corrective actions to address this issue.
3Enclosure2.2Security Plan Impact (AIT Charter Item No. 6)
a. Inspection Scope
The team conducted interviews and observations of the security organization todetermine current security program effectiveness and implementation. The teamreviewed the Security Plan and verified that Peach Bottom was able to implementSecurity Plan requirements. The team performed walk downs of the site's protectivestrategy to evaluate the potential effect of degraded security officer response, due toinattentiveness, on Security Plan implementation. The team evaluated critical SOdefensive position response times, for a variety of potential threats, to evaluate thepotential significance of the SO performance issues on Security Plan effectiveness.
b.ObservationsThe team concluded that inattentive SOs would have an adverse impact on elements ofthe defense-in-depth security strategy at PBAPS. SOs in response positions arerequired, by procedure, to remain alert and attentive. Based upon the informationgathered by the team, it appears that the videotaped SOs allowed themselves tobecome inattentive and potentially compromised their ability to fulfill their dutiesregarding the site's protective strategy. However, based on the team's review of theSecurity Plan and security strategy, the level of security at PBAPS was not significantlydegraded as a result of these SO performance issues. The following observations wereused by the team to assess the significance of SO inattentiveness on station security:* All inattentive SOs were inside the plant's "ready room" and were in a responseonly function that did not involve surveillance or detection duties;*Each of the identified SOs satisfactorily conducted patrols and rounds on thedates associated with the inattentive events;* All the SOs in the "ready room" carried two communication devices at all timesthat could be used to alert the officers, if required to respond;* SOs in the "ready room" and SOs at other posts were contacted via radio at 15minute intervals on backshifts and 30 minute intervals on day shifts;* All time-lines for these responders (estimated times to reach defensive positions)were determined to be conservative, with margin built into the response time,when compared to the time-lines associated with postulated threats; and*The responders involved were part of the layered defense-in-depth strategy and were not credited as initial engagement responders.
4Enclosure2.3Probable Causes (AIT Charter Items No. 2 and 3)
a. Inspection Scope
The team used formal and informal interviews, plant walkdowns, and unannouncedobservations during day and night shifts to independently assess the extent thatinattentive SOs may go undetected at the station. The team reviewed the station'semployee concern program files, Wackenhut's Safe-2-Say program, and correctiveaction documents to determine station effectiveness in addressing security program andpersonnel issues related to the behavior exhibited during these events. The teamreviewed security corrective action doc uments, audits, surv eillances, and drilldocumentation to determine station opportunities to identify an adverse trend in securityperformance prior to the videotaping events. b.ObservationsThe team determined the following causal factors contributed to inattentive behavior inthe security organization: *Adverse behavior had developed among SOs on Security Team No. 1 thattreated inattentiveness in the "ready room" as an acceptable practice; *The "ready room" was not accessible for adequate supervisory oversight. Specifically, the room was locked and did not permit unannounced supervisorychecks, and the single room window was blocked from supervisory observationsby a file cabinet; *Management failed to effectively communicate and reinforce stationattentiveness expectations. Although generic briefings were given to securityteams on alertness and behavior observations, the communications were noteffectively received or specific to actual conditions at the plant;*Security supervisors failed to properly address concerns involving inattentiveSOs and were not receptive to these concerns being brought forward. At leasttwo security supervisors were informed that SOs were inattentive andappropriate actions were not taken;*The environmental conditions in the "ready room" were not conducive toattentiveness and station management failed to address these known adverseconditions. The "ready room" had high background noise, was dimly lit, and waspoorly ventilated; 5Enclosure*Management failed to identify human factor issues related to 12-hour shiftsspent, in part, at the "ready room" post with low physical activity. For some SOs,a significant portion of the shift could be spent sitting in the ready room when noton patrol or performing other duties; and*Management failed to provide adequate attentiveness stimuli to the SOs in the"ready room."2.4Corrective Actions and Compensatory Measures (AIT Charter Items No. 1, 8, and 9)
a. Inspection Scope
The team performed reviews to verify that compensatory measures implemented atPBAPS were appropriate, maintained, and consistent with the site's Security Plan. Theteam conducted interviews with the SOs and supervisors performing compensatorymeasures and conducted walkdowns of those measures. The team reviewedsupervisory observation and coaching documentation. The team also reviewed Exeloninitiated nuclear event reports and Exelon's transition plan for the security guard force.
b.ObservationsThe station's prompt compensatory measures and corrective actions implemented to address SOs inattentiveness were appropriate and assured Exelon's ability to implementthe security strategy. The following is a list of prompt measures implemented at PBAPSby Exelon:*Briefed all SOs on fatigue and responsibilities for self-reporting;*Enhanced Wackenhut Corporate oversight at the site for 24-hour coverage and asecurity supervisor was placed in the "ready room" 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day;*Exelon senior site management and site security oversight observationsperformed daily;*Security Team No. 1 removed from the security shift rotation, denied site access,and placed on administrative hold, pending investigation results;*Exelon issued Nuclear Event Report (NER), NC-07-034, with fleet-wide actionsand issued a generic communication to the industry;*All SOs were interviewed;*Exelon plans to terminate the Wackenhut security contract for security services,effective November 1, 2007; and*Exelon implemented enhanced radio checks on September 27, 2007, basedupon NRC observations.The team identified one corrective action improvement associated with the predictabilityof radio communication checks for the various security posts. The team noted that arandom order radio check would enhance alertness. Exelon implemented this changeon September 27, 2007. In addition, Exelon communicated that any actions to changecompensatory measures established would be discussed with the NRC, in advance.
6EnclosureThe team identified one example where the corrective actions, prior to September 2007,were not effectively implemented. The security organization did not enter instances ofinappropriate SO behavior from early 2007 into the station corrective action program(CAP). There was no indication that station corrective actions regarding unacceptableSO behavior were effectively received or acted upon by security supervisors ormanagers at PBAPS.2.5Extent of Inattentive Security Officers (AIT Charter item No. 5)
a. Inspection Scope
The team conducted 38 interviews to ascertain the extent of potential inattentive SObehavior at the site. The interview population included a sample of individuals from allsecurity teams. The team reviewed Exelon's interview results to understand theirinvestigative findings which included an interview sample of nearly 100 percent of SOs. Additionally, the team conducted unannounced backshift observations at varioussecurity posts, including the "ready room." b.ObservationsAll security officers were interviewed at least once by either NRC or Exelon. Based onvideos and interviews conducted, all ten SOs in the video, were working on SecurityTeam No. 1. None of the SOs interviewed claimed to have ever been inattentive orwitnessed inattentive behavior by fellow officers on duty. Seven of the SOs identified asinattentive by video were interviewed by the NRC during the AIT. These seven SOsdenied being inattentive or seeing anybody inattentive. 2.6Management and Supervisory Oversight (AIT Charter Item No. 7)
a. Inspection Scope
The team reviewed Exelon's and Wackenhut's actions preceding the event to assess theeffectiveness of management oversight and engagement with the PBAPS securityorganization. The team reviewed procedures, corrective actions, and nuclear eventreports related to both Exelon and Wackenhut management oversight. The teamreviewed Exelon and Wackenhut backshift and paired observation documentation toevaluate the frequency and quality of oversight activities.
7Enclosure b.ObservationsThe team identified a lack of effective supervisory oversight on Security Team No. 1 thathad a direct adverse impact on this event and prolonged identification. In addition, theteam determined that station management failed to effectively engage the securitypersonnel when adverse behavior occurred. The following examples were specificinstances of ineffective management and supervisory oversight:*Two individuals indicated that on-shift supervisors on Security Team No. 1 wereprovided information regarding inattentive SOs. Two supervisors took no actionwhen notified and one supervisor discouraged bringing forward safety concerns;*Station management failed to take appropriate corrective actions forenvironmental conditions in the "ready room" which contributed to inattentivebehavior;*Station management failed to take into consideration human factors whendetermining shift rotation of internal/external responders. Specifically, SOs wereallowed to remain on the same security post for 12-hour shifts which was notconducive to attentiveness; and*PBAPS security management staffing was not maintained to fleet standards. Fora total period of approximately six months over the past year, Exelon's fleetstandard of a security manager and two security operations supervisors was notmaintained. For that time period, Exelon maintained just one acting securitymanager and one operations security supervisor at the station.2.7Behavioral Observation Program (BOP) (AIT Charter Item No. 3)
a. Inspection Scope
The team reviewed Exelon's FFD program procedures and the station's generalemployee training manual with regards to the BOP. The team conducted interviews withSOs and supervisors to determine the level of knowledge and willingness to participatein the reporting of SO behaviors potentially adverse to safety. b.ObservationsThe team identified the following examples where the station was not effective inpromoting and supporting the BOP:*Some SOs interviewed did not consider closing their eyes or putting their headdown on a table for periods of time an example of inattentiveness or fatigue;*There were multiple opportunities for several SOs to have reported inattentiveSO behavior exhibited during the associated security events; and 8Enclosure*There were several opportunities for SOs to have reported aberrant orunacceptable SO behavior during previous security events in early 2007.2.8Overtime and Fatigue (AIT Charter Item No. 3)
a. Inspection Scope
The team reviewed schedules, payroll records, and work hour tracking documentation toidentify if any security officers that appeared inattentive in the videotape had workedexcessive hours or violated NRC work hour requirements. b.ObservationsThe team determined that the hours worked by the ten SOs, on the four eventsvideotaped, did not exceed NRC individual work hour requirements. The most hoursworked by any of these security officers was 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> on the day of the event and 57hours total for the week of the event. NRC individual limits are 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> worked in 24hours and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> worked in seven days. The majority of the ten SOs were workingthe standard work schedule with little or no overtime. The inattentive behavior occurredon both weekdays and on weekends at various times of the day and night. Additionally,the inattentive behavior was exhibited at different times throughout the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts,not just near the end of the shifts. The team did not find a strong correlation betweeninattentive behavior and work hours. 2.9Root Cause Evaluation (AIT Charter Item No. 4)
a. Inspection Scope
The team reviewed Exelon's root cause team charter and interviewed the root causeteam to understand goals and milestones associated with the performance of their rootcause evaluation, including determination of causal factors and extent of condition. Theinspectors reviewed the scope and depth of the barrier analysis associated with thecausal evaluation. b.ObservationsExelon's root cause team and charter were established during the week ofSeptember 24, 2007. The Exelon team leader discussed their preliminary eventchronology and scope of efforts with the team on September 28, 2007. Exelon has acompletion milestone for the documented root cause evaluation by October 26, 2007. The NRC AIT follow-up inspection will review Ex elon's root cause and extent of conditionwhen this evaluation is completed.
9Enclosure2.10Generic Issues and Implications (AIT Charter Item No. 11)
a. Inspection Scope
The team reviewed the methodology and content of Exelon communications to their fleetand to the industry regarding the security officer issues at PBAPS. The team alsoconsidered what potential NRC generic communications and lessons learned should bedisseminated to the industry. b.ObservationsExelon issued an NER to the Exelon fleet with actions to address inattentiveness issuesat each of their sites. This NER communicated information and directed actions for theother Exelon sites in order to ensure similar behaviors are not occurring fleet-wide. Exelon has also submitted a generic communication to the industry about the event andactions taken, to date.The NRC has submitted a security advisory (SA-07-06) to the industry regardinginattentive security officers. NRC Resident Inspectors conducted random, unannouncedchecks of ready rooms and security posts in all four Regions. Additionally, the teamidentified the following issues for generic communication consideration:*Licensee SO shift rotation frequency and susceptibility to inattentive behavior;*Licensee evaluation of attentiveness stimuli for security posts where it would beappropriate, based on the nature of their duties; *Licensee supervision of SOs with regard to utilization of supervisory tools todetect inattentiveness; and *Licensee environmental conditions for security posts.3.0MeetingsExit Meeting SummaryOn October 9, 2007, the inspection team presented the inspection results at a public exitmeeting to Mr. Ron DeGregorio and other PBAPS staff. Exelon acknowledged theteams observations and issues for follow-up.
A-1Attachment
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- J. GrimesSite Vice PresidentP. CowanDirector, Licensing and Regulatory AffairsS. CraigSecurity ManagerJ. MallonLicensing Manager
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
None
LIST OF DOCUMENTS REVIEWED
ProceduresLS-AA-125, "Corrective Action Program Procedure," Revision 11SY-AA-1016, "Watchstanding Practices," Revision 0SY-AA-1016, "Watchstanding Practices," Revision 4SY-AA-1020, "Supervisor Post Checks and Post Orders," Revision 0SY-AA-1020, "Supervisor Post Checks and Post Orders," Revision 1SY-AA-102, "Exelon's Nuclear Fitness-For-Duty Program," Revision 11SY-AA-101-130, "Security Responsibilities for Station Personnel," Revision 8SY-AA-101-130, "Security Responsibilities for Station Personnel," Revision 9SY-PB-101-124-1001, "Security Control Center Operations," Revision 3SY-AA-101-126, "Duties and Responsibilities of the St ation Security Organization," Revision 5SY-AA-103-513, "Behavioral Observation Program," Revision 6Condition Reports00673505003283480034463700354611003587030036947400425158004869030050911000525923005373330057041800613537006569460065727100670392006770890021008400504830
- A-2AttachmentMiscellaneousNER
- NC-07-034, "Inattentive Security Officer Investigation Fleet Actions," September 24, 2007NER
- NC-06-010, "Increased Field Observation and Coaching of the Site Security Force,"Revision 2SA-07-06, "NRC Security Advisory - Security officers inattentive to duty," September 27, 2007Nuclear Oversight Quarterly Reports, 2005 - 2007NOSA-PEA-06-02, Security Plan, FFD, and Personnel Access Data System, February 1, 2006NOSA-PEA-07-03, Security Plan, FFD, and Personnel Access Data System, January 21, 2007Exelon General Employee Training, FFD Module, Revision 4Exelon's Security Transition Plan, September 24, 2007
LIST OF ACRONYMS
ADAMSAgency-wide Documents Access and Management SystemAITAugmented Inspection TeamBOPBehavioral Observation ProgramCFRCode of Federal RegulationsFFDFitness For DutyIPInspection ProcedureNERNuclear Event ReportNRCNuclear Regulatory CommissionNSIRNuclear Security and Incident ResponsePARSPublicly Available RecordsPBAPSPeach Bottom Atomic Power StationSOSecurity OfficerWNSWackenhut Nuclear Services
B-1AttachmentSeptember 20,
- TEAM [[]]
CHARTER
An Augmented Inspection Team (AIT) has been established for Peach Bottom to inspect andassess several security events and assess the licensee's security program. The teamcomposition is as follows: Team Manager:M. Gamberoni,
NSIR OI Investigators: (2) Names to be DeterminedThe objectives of the inspection are to: (1) review the facts surrounding the specific securityissues identified and the licensee's corrective action; (2) understand the licensee's short termand long term approach to address the issues; (3) assess the Peach Bottom security programto assure that the current security program is effective and meeting the security plan; and(4) identify any generic issues associated with the events. For the period during which you are leading this inspection and documenting the results, youwill report directly to me. The guidance in
Inspection Procedure 93800, "Augmented InspectionTeam," and Management Directive 8.3, "NRC Incident Investigation Procedures," apply to yourinspection.Enclosure:AIT Charter
B-2AttachmentAUGMENTED
- BOTTOM [[]]
- UNITS [[]]
- AIT - Videotape provided by the alleger shows multiple instancesof multiple security officers sleeping in the former power block ready room. These events meetthe deterministic criteria for an
AIT in Management Directive 8.3, in that they involved asignificant infraction or repeated instances of safeguards infractions that demonstrate theineffectiveness of facility security provisions.Objectives of the AIT - The objectives of the inspection are to: (1) review the facts surroundingthe specific security issues identified and the licensee's corrective action; (2) understand thelicensee's short term and long term approach to address the issues; (3) assess the PeachBottom security program to assure that the current security program is effective and meeting thesecurity plan; and (4) identify any generic issues associated with the events. To accomplish these objectives, the following will be performed:
- 1.V [[erify that compensatory measures implemented by the licensee for this problem areadequate and have been implemented and maintained. Review any licensee proposalsto modify the compensatory measures.2. Independently conduct interviews and inspections to fully understand the circumstancessurrounding the event and probable cause(s).]]
- 3.AIT fact finding should include the conditions preceding the event, applicablechronology, any event precursors, human factor considerations, safeguardsconsiderations, and safety culture component considerations (as defined in
IMC 0305,paragraphs 06.07c and d).4.Assess Exelon's root cause evaluation for adequacy with respect to the identification ofperformance deficiencies, extent of condition review, root cause(s), contributingcause(s), and corrective actions.5.Determine the extent of inattentive security officers.
6.Determine inattentive security officer's impact on the Peach Bottom Security Plan.
7.Evaluate Peach Bottom's supervision and management oversight of security.
8. Evaluate adequacy of licensee response to the event.
9.Consider and evaluate any Exelon decisions regarding security force transitions.
B-3Attachment10.Document the inspection findings and conclusions in an AIT final report within 30calendar days of inspection completion (the day of the exit meeting).11.Consider providing appropriate information and feedback to the operating experienceprogram.
C-1AttachmentEVENT
- PBAPS security power block "ready room" established to support Security Planimplementation and provide increased defense-in-depth for
NRC Force on Forceexercises.*April 16, 2006 - NRC Force-on-Force exercise conducted (No findings).
- January 2007 - Wackenhut Corporation issues improvement plan for Safety ConsciousWork Environment (SCWE) improvement actions for its security forces at all sites.*February 2007 - Security Officer (SO) responsible for video recordings has firstobservation of inattentive
- SY -AA-1016, Revision 4, implemented to add 'attentiveness tools'based on attentiveness issue experienced at an Exelon plant.*March 12, 2007 - Five
- SO to inform his securitysupervisor. The following day the maintenance technician informs his supervisor whoresponds that the
- SO 's concern should be brought up to the security supervisor. *April 2007 - Wackenhut Corporate investigation reveals two separate
- SO unacceptablebehavior issues received through Wackenhut Safe-2-Say program. In the course of thisinvestigation, it was determined by Wackenhut that multiple
- SO [[on Team No. 2 wereinitially untruthful to investigators and tried to hide and cover-up the events. Severalofficers were disciplined for their lack of candor and not reporting a safety concern. *April 18, 2007 - Plant review committee rejects $150K expense of further renovations to"ready room."]]
NRC received Exelon's response stating the three referred concernsassociated with inattentive SO behavior were not substantiated. Exelon conductedinterviews that did not substantiate the issue. Exelon referenced enhancements in their
C-2Attachmentresponse that included radio check improvements and procedure changes to implementfixed post checks twice a shift. Exelon also referenced 15 minute stand-ups on backshifts and randomly on day shift.*June 9, 2007 - Three
- SO supervisor of Team No. 1 inform]]
- SO to stop bringing video devices into the plant's protected area.*July 19, 2007 - Security force transitions to new "ready room" that is considered largerand a more moderate temperature. *June 20, 2007 - One
- NRC considers Exelon response acceptable after follow-up questions. *August 28, 2007 - Exelon Corporate nuclear safety review board identified Wackenhutperformance as an area for improvement fleet-wide.*September 10, 2007 -
- NRC received and verbally referred concerns to Exelon based onWCBS-TV (New York) telephone call with information about videos that showsinattentive
NRC resident inspectors begin enhancedsecurity inspections by performing increased number of observations at various securityposts during both normal and backshift hours. *September 10, 2007 - Exelon forms an Issues Management Team based on NRCinformation passed verbally. Exelon briefed PBAPS security force regarding heightenedawareness, fatigue, and responsibilit
ies to report inattentiveness.*September 11, 2007 - Exelon briefed their fleet security regarding heightenedawareness, fatigue, and responsibilit
ies to report inattentiveness.*September 15 - 20, 2007 - Exelon corporate security interviews approximately 95percent on-site members of Wackenhut organization at Peach Bottom.*September 17, 2007 - SO responsible for videotaping inattentiveness has unescortedaccess suspended because of trustworthiness concerns and procedure violations.
C-3Attachment*September 17, 2007 - Maintenance technician acknowledged after a site communicationon inattentiveness that he had knowledge of a
SOs on dutyand showed him the videos.*September 17, 2007 - Exelon is contacted by WCBS-TV.
- September 18, 2007 -
- SO [[concerns thatwere received based upon telephone conversation that specified "ready room" as areaof concern for inattentive SOs.*September 18, 2007 - Letter from President - Wackenhut Nuclear Services (WNS), toWNS security force emphasizing fitness for duty and fatigue standards.*September 18, 2007 - Exelon makes decision for outside legal counsel to take overinvestigation in response to allegations. Exelon issues first press release at 11:00 am. *September 19, 2007 -]]
- NRC verbally refers to Exelon additional information to be considered in their investigation.*September 19, 2007 - Exelon management and Wackenhut establish enhanced securityoversight at
- PBAPS. [[Additional Wackenhut supervision brought in providing 24-houroversight and observation.*September 20, 2007 - Exelon implements 24-hour on-site security supervision in the"ready room." Additionally, on-site Wackenhut supervision providing enhanced oversightand observation.*September 20, 2007 -]]
- AIT will be dispatched to PeachBottom the following morning to begin inspection on the security events surroundinginattentive
- SO [[.]]
SO inattentiveness concerns and current fact-finding investigative efforts.*September 21, 2007 - Nine SOs inattentive to duty placed on administrative holdpending outcome of investigation.
C-4Attachment*September 22, 2007 -
- NRC Region I security inspectors supplement resident staff inconducting backshift inspection and observation of the security posts and compensatorymeasures throughout the weekend until full
- AIT arrives on-site.*September 24, 2007 - Exelon initiates termination of Wackenhut security contract atPeach Bottom. *September 24, 2007 - Exelon issues
- NER [[]]
- SO [[issues at Peach Bottom.*September 25, 2007 - Exelon places remainder of Security Team No. 1 onadministrative hold pending outcome of investigation.*September 25, 2007 - Exelon issues an Operations Experience item regarding SecurityOfficers Inattentive to Duty on the]]
NEI security web site*September 26, 2007 - Exelon announces transition of security force from Wackenhut toa proprietary guard force (Exelon).*September 27, 2007 - Exelon enhances compensatory measures for BREs.
- September 27, 2007 -