On September 10, 2007, representatives of WCBS-TV (
New York City) contacted the NRC stating that they possessed videotapes of
inattentive security officers at the Peach Bottom Atomic Power Station (
PBAPS). Based upon this information, the NRC Region I Regional Administrator directed implementation of enhanced inspection oversight of security activities by the resident inspectors at
PBAPS, and verbally informed Exelon management of the information received. Exelon commenced an internal investigation based upon this information. On September 19, 2007, WCBS-TV shared the videotapes with the NRC staff, which viewed the videos and determined that the situation warranted an Augmented Inspection. An Augmented Inspection Team (
AIT) completed an inspection at
PBAPS from September 21 through 28, 2007. The team concluded that Exelons prompt compensatory measures and corrective actions in response to the videotaped
inattentive security officers at
PBAPS were appropriate and ensured the stations ability to satisfy the Security Plan. However, the team determined that the security officer inattentiveness affected the defense-in-depth strategy, and that security force supervisors were not effective in ensuring unacceptable behavior was promptly identified and corrected. The
AIT inspection results were published on November 5, 2007 in NRC Inspection Report 2007404 (
ADAMS accession number
ML073090061). On October 4, 2007, Exelon sent a letter to the NRC Region I Regional Administrator (
ML072850708) which described their completed actions and initiatives to address the issues identified by the
AIT. These initiatives included terminating the current security contract with their contractor and transitioning to a proprietary security force. Exelon also described plans to complete a root cause analysis of the security officer inattentiveness, identify corrective actions, and perform safety conscious work environment (
SCWE) surveys of the Peach Bottom Security organization. On October 19, 2007, the NRC issued a Confirmatory Action Letter (
CAL) to confirm Exelons commitments to assure that security officers remain attentive at all times while on duty (
ML072920283). Exelon completed their root cause analysis in October 2007 and identified several causal factors related to the security officer inattentiveness issues and specific corrective actions to address the causal factors. One of the corrective actions was to perform a systematic
SCWE assessment of all work groups at
PBAPS (including the Security work group) based on an integrated review of information from the
PBAPS Corrective Action Program (
CAP), Employee Concerns Program (
ECP), publicly available NRC allegation statistics, and
SCWE surveys. The NRC conducted an
AIT follow-up inspection from November 5 through 9, 2007, to review Exelons root cause analysis report and their planned corrective actions. The inspectors concluded the corrective actions were appropriate. With regard to the security officer inattentiveness issue, the
AIT follow-up inspection identified a finding regarding Exelons failure to maintain the minimum required number of available security officer responders and an associated failure to implement an effective behavior observation program. The
AIT follow-up inspection determined that the finding was related to
SCWE because it involved security supervisors who did not encourage the free flow of information related to raising safety concerns, and who did not respond to security officer safety concerns in an open, honest, and non-defensive manner. The NRC determined the finding was of low to moderate safety significance (White). This was documented in a subsequent letter to Exelon dated February 12, 2008 (
ML080440012). The
AIT follow-up inspection results were issued in NRC Inspection Report 2007405 (
ML073550590) dated December 21, 2007. Region I determined that Exelons actions to address the
PBAPS inattentive security officer issues and their plans to transition to a proprietary security force warranted additional inspection and oversight beyond that specified in the Reactor Oversight Process (
ROP) baseline inspection program. On November 28, 2007, the Regional Administrator recommended, through a Deviation Memorandum to the NRCs Executive Director for Operations (
EDO), that
PBAPS warranted additional inspection resources (
ML073320344). One additional inspection activity was to conduct inspections of Exelons efforts to address
SCWE issues, including a review of the results of
SCWE surveys conducted at the site. The
EDO approved this request on November 28, 2007. Consistent with the planned corrective actions from their root cause evaluation, Exelon arranged for a third party to conduct a survey of the
SCWE at
PBAPS. The survey was in the form of a series of questions provided to the staff in January 2008. The survey was completed and the results provided to Exelon in February 2008. A separate
SCWE survey of the security organization was also conducted during November 2007. Exelon utilized the survey results to complete a self-assessment of the
SCWE at
PBAPS. In accordance with the NRC Action Matrix Deviation Memorandum, this inspection was conducted onsite from March 24 though 28, 2008, to review Exelons self-assessment of the
PBAPS SCWE, including a review of the results of their
SCWE survey. Other completed Deviation Memorandum activities included a security organization performance monitoring inspection (
ML080720038) and a root cause corrective action evaluation (
ML081090161).
