ML20135C040

Partially Deleted FOIA Request for Documents Re Six Security Violations at Salem/Hope Creek Nuclear Power Plants

ML20135C040
Person / Time
Site:	Salem, Hope Creek
Issue date:	11/20/1996
From:	Solomon D AFFILIATION NOT ASSIGNED
To:	Linton T NRC
Shared Package
ML20135C024	List: ML20135C021 ML20135C040
References
FOIA-96-492 NUDOCS 9703030317
Download: ML20135C040 (3)

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CaseNo: #4%E Date Rec'd. /I - Jt # 4 I ~

Ac6on0t From douglas d solomon <DSOLO88394@gnn.comeh%dCaso:

To: TWD2.TWP6 (tdl)

Date: 11/20/96 8:47pm

Subject:

Re: To whom it may concern, -Reply

>Date: Tue, 19 Nov 1996 11:26:51 -0500

>From: Teresa Linton <TDL@nrc. gov >

>To: DSOLO88394@gnn.com

Subject:

To whom it may concern, -Reply

>Your request fer information was forwarded to the Local Public

> Document Room Staff. The only public PSE&G meeting

> scheduled for November 12 that we are aware of was one

>concerning motor operated valves at the Salem Nuclear Power

> Station. There was a closed enforcement conference

>concerning Hope Creek on November 14. Are either of these

, > meetings the one you are interested in?

>Teresa Linton, Information Services Librarian

> Local Public Document Room Program

>US NRC The date of information I am requesting should be November 14,1996 The subject matter was inreference to 6 Securit/ Violations at the salem / hope creek nuclear power plants. We were told that such

, a meeting took place at Region I , in fact our siLn manager for Wackenhut even wanted one of our people to go but 'a posed a problem . I've been told that we will know what went on concerning us and the security department. A full report or atleast a briefing on the matter. But I'm not sure coming from those sources that we'll get the full story. Any help will be appreciated. Also I am in need of the addresse to send official Freedom of Information Request .

Thanking You for your time and reply, Douglas D. Solomon 9703030317 970226 PDR FOIA SOLOMON 96-492 PDR

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POWER REACTOR EVENT NUMBER: 30890 FACILITY: SALEM REGION: 1 NOTIFICATION DATE: 08/19/96 l UNIT: [1] [2] [] STATE: NJ NOTIFICATION TIME: 09:03 [ET) 08/19/96 RX TYPE: [1] W-4 -LP, [2] W-4-LP EVENT DATE:

l EVENT TIME: 06 : 29 [EDT)

NRC NOTIFIED BY: JOHN KONOVALCHICK LAST UPDATE DATE: 08/19/96 HQ OPS OFFICER: JOHN MacKINNON NOTIFICATIONS EMERGENCY CLASS: NOT APPLICABLE I 10 CFR SECTION: JOHN CARUSO RDO

, DUNE 73.71(b) (1) UNAUTHORIZED ENTRY AL CHAFFEE EO  ;

LOREN BUSH (NRR) IAT JOHN DAVIDSON NMSS) IAT  ;

UNIT SCRAM CODE RX CRIT INIT PWR INIT RX MODE CURR PWR CURR RX MODE 1 N N O REFUELING 0 REFUELING 2 N N O REFUELING 0 REFUELING EVENT TEXT UNAUTHORIZED ENTRY INTO PROTECTED AREA BY A CONTRACT EMPLOYEE.

A MAINTENANCE CONTRACTOR HIRED BY THE LICENSEE ENTERED A PROTECTED AREA BEFORE BEING SEARCHED. IMMEDIATE COMPENSATORY ACTIONS WERE TAKEN UPON DISCOVERY. THIS CONTRACTOR DID NOT ENTER ANY VITAL AREAS. SECURITY SEARCHED THE CONTRACTOR, HIS LOCKER, AND THE ROUTE HE TOOK WHILE HE WAS IN THE PROTECTED AREA. NOTHING WAS FOUND DURING THE SEARCH. THE CONTRACTOR WAS TAKEN OFFSITE AND IS BEING INTERVIEWED BY SECURITY.

THE RESIDENT INSPECTOR WILL BE INFORMED BY THE LICENSEE OF THIS EVENT.

SEE HOPE CREEK EVENT # 30891. HOPE CREEK AND SALEM SHARE THE SAME SECURITY ENTRY POINT.

SEE HOO LOG BOOK FOR FURTHER DETAILS. l i

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e 1 POWER REACTOR EVENT NL'MBER: 30891 '

, FACILITY: HOPE CREEK' REGION: 1 NOTIFICATION DATE: 08/19/96  ;

I UNIT: [1] [] [] STATE: NJ NOTIFICATION TIME: 09:13 [ET) i RX TYPE [1] GE-4 EVENT DATE: 08/19/96 4 EVENT TIME: 06:29(EDT] ,

i NRC NOTIFIED BY: ARCHIE FAULKNER LAST UPDATE DATE: 08/19/96 3 HQ OPS OFFICER: JOHN MacKINNON l' NOTIFICATIONS EMERGENCY CLASS: NOT APPLICABLE

, 10 CFR SECTION: JOHN CARUSO RDO

DUNE 73,71(b) (1) UNAUTHORIZED ENTRY AL CHAFFEE EO l LOREN BUSH (NRR) IAT.

l! JOHN DVAIDSON NMSS- IAT l i

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.. UNIT SCRAM CODE RX CRIT INIT PWR INIT RX MODE CURR PWR CURR RX MODE 1 N Y 100 POWER OPERATION 100 POWER OPERATION 4

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EVENT TEXT i

UNAUTHORIZED ENTRY INTO PROTECTED AREA BY A CONTRACT EMPLOYEE. ,

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! A MAINTENANCE CONTRACTOR HIRED BY THE LICENSEE ENTERED A PROTECTED AREA l BEFORE BEING SEARCHED. IMMEDIATE COMPENSATORY ACTIONS WERE TAKEN UPON

! DISCOVERY. THIS CONTRACTOR DID NOT ENTER ANY VITAL AREAS. SECURITY SEARCHED.

THE CONTRACTOR, HIS LOCKER, AND THE ROUTE HE TOOK hMILE HE WAS IN THE '

j. PROTECTED AREA. NOTHING WAS FOUND DURING THE SEARCH. THE CONTRACTOR WAS

! TAKEN OFFSITE AND IS BEING INTERVIEWED BY SECURITY. l SEE SALEM EVENT # 30890. SALEM AND HOPE CREEK SHARE THE SAME SECURITY ENTRY POINT.  ;

i i SEE HOO LOG BOOK FOR FURTHER DETAILS.  ;

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' ATTACHMENT 2

i.  !(p'* *%k'g UNITED STATES NUCLEAR REGULATORY COMMISSION

$ REGloN 1

'"l 475 ALLENDALE ROAD -

o, KING oF PRUSSIA. PENNSYLVANIA 194061415 i a

%..... i September 30, 1996 j i

! EA 96-344 j Mr. Leon R. Eliason i

Chief Nuclear Officer & President

Nuclear Business Unit

~ Public Service Electric and Gas Company P. O. Box 236 Hancocks Bridge, New Jersey 08038 1

SUBJECT:

INSPECTION REPORT NOS. 50-272/96-14,50-311/96-14 AND i

50-354/96-08

Dear Mr. Eliason:

1 This refers to the inspection conducted August 15 - September 3,1996, at the Salem / Hope Creek Nuclear Generation Station. The purpose of that inspection was.to l

review the implementation ~of your Physical Security Program. At the conclusion of the

' inspection, an exit meeting was conducted at our King of Prussia, Pennsylvania office and the findings were discussed with Mr. L. Storz and other members of your staff.

Areas examined during the inspection are identified in the attached report. Within these

areas, the inspection consisted of selective examinations of procedures and representative

records, interviews with personnel and observations by the inspectors.

Based on the results of this inspection, six apparent violations were identified and are .j

being considered for escalated enforcement action in accordance with the " General I j Statement of Policy and Procedure for NRC Enforcement Actions." (Enforcement Policy),

! (60 FR 34381);(June 30,1995). The apparent violations involved: 1) the failure to control photo badge key cards; 2) the failure to properly search an individual prior to granting access to the protected area; 3) the failure to notify the nuclear shift supervisor of l

. a potential threat event; 4) the failure to deactivate photo badge key cards for individuals l who no longer required site access; 5) the failure to complete training for security  !

supervisors prior to assigning them supervisory duties; and 6) the failure to test an Intrusion detection system in accordance with procedures. The NRC is seriously concerned j l

about the_ implementation of the security program, particularly the access contral function, j since three of the apparent violations were in that area. l i

'At the exit meeting on September 3,1996, members of your staff provided specific short- '

term corrective actions that had already been implemented for the apparent violations pending completion and review of investigations being conducted by Public Service Gas &

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Electric Company and the Wackenhut Company, the security contractor. Your staff also  ;

committed to meet with us in the future to discuss the results of the investigations. The  !

> hand-out provided by your staff at that meeting is enclosed with the inspection report.

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1 Mr. Leon R. Eliason 2 Because specific corrective actions were provided at that meeting, it may not be necessary to conduct a predecisional enforcement conference in order to enable the NRC to make an i enforcement decision. However, a Notice of Violation is not presently being issued for these inspection findings. 4 Before the'NRC makes its enforcement decision, we are providing you an opportunity to either: -(1) respond to the apparent violations addressed in this inspection report within 30 days of the date of this letter, or (2) request a predecisional' enforcement conference. If you choose not to provide a response and would prefer participating in a predecisional I enforcement conference, please contact Mr. L. Nicholson of this office at (610) 337-5128 j within 7 days of the date of this letter.

Your response should be clearly marked as a " Response to Apparent Violations in Inspection Report Nos. 50-272/96-14, 50-311/96-14 and 50-354/96-08 and should  ;

L include for each apparent violation (1) the reason for the apparent violation, or, if j contested, the basis for disputing the apparent violation, (2) the corrective steps that have i been taken and the results achieved, (3) the corrective steps that will be taken to avoid j further violations, and (4) the date when full compliance will be achieved. Your response .l should be submitted under oath or, affirmation and may reference or include previous _j docketed correspondence, if the correspondence adequately addresses the required j response. If an adequate response is not received within the time specified or an extension j

of time has not been granted by the NRC, the NRC will proceed with its enforcement l

- decision or schedule a predecisional enforcement conference.

l In addition, please be advised th'at the number and characterization of apparent violations f

for the events described in the enclosed inspection report may change as a result of further  !

NRC review. You will be advised by separate correspondence of the results of our i deliberations on this matter.  !

l Based on our review of the information provided to us during the exit meeting, we find that l the additional interim measures implemented by your staff to address the performance issues in this report are appropriate. Those interim measures, if implemented well, provide assurance that the safety objectives of the security program are being achieved for the Salem / Hope Creek Station. From the discussions during the exit meeting, we understand that your staff agreed not to make substantive changes to those interim measures prior to contacting us. If this understanding is incorrect, please notify us immediately.

Nonetheless, the NRC will remain concerned about security area performance until your -

staff implements comprehensive, durable corrective actions responsive to the root causes l of problems found. Consequently, NRC considers closeout of concerns in the security j program to be a restart item for Salem. ,

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Mr. Leon R. Eliason 3 t In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, l its enclosure (s), and your response (if you choose to provide one) will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include i i

any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.

i Sincerely,

_h!, '

f James T. Wiggins, irector j Division of Reactor Safety .

Docket Nos. 50-272; 50-311; 50-354 License Nos. DPR-70, DPR-75, NPF-57 j i

Enclosures-  !

1. Inspection Report 50-272;96-14,50-311/96-14 and 50-354/96-08  ;

' 2. Handout provided by licensee at exit meeting  !

cc w/ encl:

L. Storz, Senior Vice President - Nuclear Operations E. Simpson, Senior Vice President - Nuclear Engineering E. Salowitz, Director - Nuclear Business Support  !

C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.  !

j D. Garchow, General Manager - Salem Operations J. Benjamin, Director - Quality Assurance & Nuclear Safety Review D. Powell, Manager, Licensing and Regulation l

'i R. Kankus, Joint Owner Affairs '

A. Tapert, Program Administrator ,

R. Fryling, Jr., Esquire  !

i M. Wetterhahn, Esquire M. Bezilla, General Manager - Hope Creek Operations P. MacFarland Goelz, Manager, Joint Generation Atlantic Electric

- Consumer Advocate, Office of Consumer Advocate l William Conklin, Public Safety Consultant, Lower Alloways Creek Township Public Service Commission of Maryland State of New Jersey State of Delaware 4

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Mr. Leon R. Eliason 4 Distribution w/ encl: l Region I Docket Room (with concurrences)  ;

Kay Ga!!agher, DRP '

• G. Smith R. Keimig  !

) L Nicholson, DRP

S. Barber, DRP ,

G. Kelly, DRS_ -

N. Della Greca, DRS

' ~ D. Screnci, PAO.

{ NRC Resident inspector  ;

i PUBLIC

! Distribution w/ encl: (Via E-Mail)

L. Olshan, NRR

! W. Dean, OEDO  ;

t J. Stolz, PDI-2, NRR M. Callahan, OCA

s. D. Jaffee, Project Manager, NRR 1 Inspection Program Branch, NRR (IPAS) ,

L. Cunningham, NRR i

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t EXECUTIVE

SUMMARY

! Salem / Hope Creek Nuclear Station  !

NRC inspection Report Nos. 50 272/96-14, ,

50-311/96-14 and 50-354/96-08  !

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' An inspection of the physical security program was conducted during the period of i i

August 15-September 3,1996. Areas inspected included: protected area detection equipment; alarm stations and communications; testing maintenance and compensatory l measures; access control of personnel; training and qualification; management support;  ;

audits; and fitness-for-duty. The purpose of this inspection was to determine if the security program, as implemented, met the licensee's commitments and NRC regulatory requirements.

i Six apparent violations were identified during the inspection. The violations included: 1) the failure to control photo badge key cards; 2) the failure to properly search an individual t prior to granting access to the protected area; 3) the failure to notify the nuclear shift supervisor of a potential threat event: 4) the failure to deactivate photo badge key cards for individuals who no longer required site eccess: 5) the failure to complete training for i security supervisors prior to assigning thern supervisory duties; and 6) the failure to test an intrusion detection system in accordance wkh procedures.

The exit meeting for the inspection was held in the NRC's Region I office, in King of j Prussia, PA on September 3,1996. Senior management from the licensee's organization  ;

and from Region I were in attendance. The scope and findings of the inspection were l discussed. The licensee presented some preliminary information from its investigation and j the investigation by its contractor which were initiated shortly after events occurred on August 14 and 19. Those events brought into question the performance of several security force members. The licensee also present short-term corrective measures for the apparent violations 1,2,4, and 5 identified above. Apparent violations 3 and 6 were identified subsequent to the inspection and brought to the licensee's attention on September 25,1996, via a telephone call.

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U. S. NUCLEAR REGULATORY COMMISSION i

REG!ONI f

Docket Nos: 50-272, 50-311, 50-354  ;

i License Nos: DPR-70, DPR-75, NPF-57  !

l Report Nos: 50-272/96-14, 50-311/96-14, 50-354/96-08 i

Licensee: Public Service Electric and Gas Company Facilities: -

Salem ano Hope Creek Nuclear Generating Stations i Location: Hancocks Bridge, New Jersey I

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Dates: August 15 - September 3,1996 l

1 Inspectors: G. C. Smith, Senior Security Specialist l E. B. King, Physical Security inspector I D. F. Limroth, Senior Reactor Engineer Approved by: R. R. Keimig, Chief Emergency Preparedness and Safeguards Branch Division of Reactor Safety l

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DETAILS l i

S2 Status of Security Facilities and Equipment >

l S2.1 Protected Area Detection Aids I

a. 'Insoection Scone  !

The inspectors conducted a physical inspection of the protected area (PA) intrusion  ;

detection systems (IDSs) on August 21,1996. -

b. Observations and Findinos j I

The inspectors observed that the IDSs were installed and maintained as described in the NRC-approved security plan (the Plan). .

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c. Conciusion No deficiency or weakness was identified.

S2.2 Alarm Stations and Communications l

- a. Insoection Scope I The inspectors observed central alarm station (CAS) operations and interviewed CAS operators to assess the effectiveness of the alarm station operations.and the  !

familiarity of the operators with the operations,

b. Qh,pervations and Findinas The inspectors observed that the CAS was being maintained and operated as committed to in the Plan. Inspector interviews with operators found them to be knowledgeable of their duties and responsibilities. The inspectors also found that the operators were not required to engage in activities that would interfere with assessment and response functions.

c. Conclusion No deficiency or weakness was identified.

S2.3 Testina. Maintenance and Comoensatory Measures

a. Inspection Scope The inspectors reviewed commitments related to the testing of intrusion detection systems delineated in the licensee's NRC-approved security plan and implemented j through security procedures. Additionally, the inspectors reviewed the results of )

five such tests in order to determine the acceptability of test results.

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b. Observations and Findinas i

On April 3,1996, at 8:51 a.m., security force members commenced testing of -

, Salem perimeter intrusion detection system (IDS) zone 16. When a series of .

undefined tamper alarms that interfered with the intrusion clarms occurred, testing >

l . was terminated and corrective maintenance was initiated to investigate the cause of the tamper alarms. At about noon, with no maintenance having been performed, the personnel involved in the testing and maintenance departed the zone. <

Concurrently, the security force member who had been posted as a compensatory measure for the zone, which was anticipated to be in an alarm condition during the test, was also released from the compensatory post.

I At 1:45 p.m., a technician commenced maintenance on the system consisting of  !

opening, trouble-shooting, and tightening termination in a sensor status concentrator and in transmitter and receiver boxes for the zone. Following completion of the maintenance, the zone was challenged by three " walk" intrusions, following which, at 3:31 p.m., the personnel involved in the testing and maintenance and the security force member assigned as a compensatory measure departed the area. Security Procedure SP 12 (Revision 9), Security System Testing '

and Maintenance, requires, in part, that three " crawl" tests be performed following maintenance. ,

On June 5,1996, at 2:38 p.m., following use of the " crane gate" for the transition ,

of a vehicle, the security force members controlling access through the gate and satisfying compensatory posting requirements (since the zone would be in an alarm condition) were released after the IDS zone had been tested with a " walk test."

The two security force members proceeded on their security rounds. Approximately 18 minutes later, the zone was properly tested in accordance with security procedures by means of three " crawl tests." Records indicate that the security force members who had functioned as compensatory measures actually left the immediate area during the 18 minute period in question; however, records do not reflect whether the field operations supervisor was in the vicinity of the zone (and therefore physically in a position to function as a compensatory measure) or not.

The field operations supervisor was not available for interview regarding the details of the event in question.

Security Procedure 8, Vehicle Access Control, Revision 8, requires, in part: "10.

Use of Crane Gate... Security Shift Supervisor / designee... Direct that the zone be crawl tested after the vehicle passes and prior to securing the patrol." This procedure further states, "SFM 1: Remain posted at the gate until the zone passes the crawl test."

c. Conclusions The securing of the compensatory post on April 3,1996 when undefined tamper l

alarms should have raised the question of the operability of the zone's IDS is  !

considered a weakness. j l

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! The failure to test the IDS zone following maintenance in accordance with Security ,

Procedure 12 on April 3,1996, and the failure of the Security Shift l Supervisor / designee to cause the zone to be tested in accordance with Security )

Procedure 8 on June 5,1996, compounded by the security force members' failure to remain at their post until the zone had been tested in accordance with Security '

f Procedure 8, constitute an apparent violation, i.e., failure to follow procedures.

i S2.4 Access Control of Personnel

. a. Insoection Scooe The inspectors reviewed the licensee's program for access control of persons i i granted access to the Protected and Vital Areas. The inspectors reviewed the

, security plan and implementing procedures, interviewed poisonnel implementing the access control program and observed implementation of the program.

b. Observations and Findinas a

Control of Terminated Personnel The inspectors reviewed the access control process and found that individuals are granted access to the protected area and to specific vital areas (VA) of the plants based on specific needs. However, the inspectors' review of the process to -

Inactivate access authorizations for persons that'no longer require access to those areas disclosed several deficiencies. In June,1996, seven employees were terminated; however, their access to the plants was not terminated until July, 1996, when the 31 day VA revalidation !ists were returned to the Access Control Department. In July,1995, five employees were terminated; however, their access to the plants was not terminated until August,1995, when the 31 day VA revalidation lists were returned to the Access Control Department. The inspectors' review further disclosed that the terminated employees had access to the plants for periods ranging from 5 to 30 days after their employment had been terminated.

The PSE&G Security Procedure 4, " Personnel Access, Revision 3," dated November 1,1994, in Section 4.13, states, in part, "when a person granted .

unescorted access terminates employment or no longer requires access to the PA, the cognizant department shall notify the screening supervisor within two work days. The Screening Supervisor ensures the administrative actions required to inactivate the security photo badge and personnel access clearance are -

accomplished." The failure to inactivate the badge and clearance access

. authorization for those persons that no longer require access within two work days is an apparent violation.

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4 Control of Access Badoes and Kev Cards i On August 14,1996, an NRC resident inspector observed that the locking i mechanism on the door to one of the bullet resistant photo badge issue areas that was not occupied by security force personnel (SFP) at the time had been taped over

. rendering the lock inoperative. The notified PSE&G management of the situation.

! and immediate action was taken to remove the tape and restore the lock to an.

i operable condition. Security management also implemented actions to determine if the inoperative lock, which compromised the positive control of the photo badges,

. had resulted in an unauthorized entry into the PA or VAs. This event was reviewed further during this inspection, and the inspectors determined that, at the time the

! lock was inoperative, no compensatory measures were in place. After being l- notified of the event, security personnel conducted sweeps to serify that_all i personnel in the VAs were authorized. This was done by comparing the picture on the photo badge of personnel in the VAs to the person in possession of the badge.

i No unauthorized personnel were identified. Security persor;nel also conducted photo badge key card transaction histeries for all badges located in the i compromised badge issue area for the period the lock had been inoperable l (approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />). The card-transaction histories were then compared against j

other documentation to verify that the photo badge key card had only been used by

- the person to whom it was issued. The reconciliation of the transaction histories-was completed on September 3,1996, and no discrepancies were identified.

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The NRC-approved security plan states, in part, in Section 5.6, " vital area access

control is positively controlled by the photo badge key card system which permits access into specific areas to persons designated on the current access list contained i in the system computers. Positive access control is accomplished by SFP prior to i j issuance of the photo badge / card key." The failure to provide positive control of l'

j. the photo badge key cards by SFP is an apparent violation.

l' l Control of Search Train r  ;

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On August 19,1996, a contractor en route to the plant protected area caused the i metal detector in the personnel search train to alarm. The contractor was directed j

, thr'ough a second metal detector that also alarmed. After failing to clear the second i' metal detector, the contractor was allegedly told by SFP to stand aside and await a l pat-down (hands-on) search to determine the cause of the alarm. However, the  !

I. contractor went to the badge issue area, was issued a photo badge / key card and entered the PA. When the secunty supervisor in the area was notified of the event,

{ he initiated actions to identify the individual, but did not initiate the actions specified j l- in the licensee's NRC-approved Security Contingency Plan for a potential threat to I the plant. The individual was identified by the officers performing the search ,

- function using the file copies of the photo badge photographs about 50 minutes l

! later. After identification of the individual, his supervisor was notified of the i problem and the contractor was returned to the process facility and searched again i with negative results about 30 minutes later. Additionally, the individual's locker, work area, and route to and from his work location were searched with negative

!q results. However, the control room was not notified of the potential security threat I.

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5 so that the appropriate emergency action level could be evaluated to determine the proper response, the contractor's badge / key card was not deactivated by SFP, which would have precluded him entering any VAs, nor was he paged on the plant l paging system, once he was identified to expedite locating him.

The NRC-approved security plan states, in part, in Section 4.2.1.4, " searches at the guardhouses are performed by locally alarming portal or hand held metal and explosive detectors. When there is reasonable cause to suspect that a person is attempting to introduce firearms, explosives, incendiary devices or other

. unauthorized material into the protected area, the person is given a physical pat-down search." The failure to conduct a physical pat-down search of the contractor after he caused the portal metal detectors to alarm, which should have resulted in reasonable cause to suspect that person was attempting to introduce unauthorized materialinto the protected area, is an apparent violation.

l The NRC-approved Security Contingency Plan states, in part, in Section 8.1.3.2, "it will be assumed that a security threat exists until it is known otherwise."

Section 8.1.4 of the Contingency Plan defines " Intruder: A person present in a _

i protected or_ vital area without authorization." Section 8.2.2.6 of the Contingency Plan states " Discovery of intruders or Attack" notify SNSS (Senior Nuclear Shift Supervisor) of implementation of Contingency Event 6 (Discovery of _ Intruders...).

j Provide concise situation report. Request SNSS to classify the event per Event  !

Classification Guide Section 16." The failure to notify the SNSS of the event so l

t. that it could be classified per the Event Classification Guide is an apparent violation.

c. Conclusion Tires apparent violations were identified in access control of ps.sonnel. The- i inspectors concluded that the apparent violations indicate a lack of knowledge or l understanding of fundamental nuclear plant security principles, serious 1

l complacency, or both, on the part of the SFPs.

L S5. Security and Safeguards Staff Training and Qualification

a. Insoection Scoce On August 19,1996, the inspectors selected at random and reviewed the training, physical, and firearms qualification /requalification records of three security monitors, three armed security officers, three alarm station operators and three new security

supervisors.

b. Observations and Findinos i The inspectors found that training for the security monitors, armed security officers, l and alarm station operators had been conducted in accordance with the NRC-approved security training and qualification (T&O) plan and that it was properly 1- documented. However, the inspectors also found during their review of training records and shift activity logs, that two of the three contractor security supervisors

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were performing independent Field Operations Supervisory duties prior to qualifying

' satisfactorily on all of the required critical security tasks necessary for the

! performance of their related security duties.  ;

The Salem-Hope Creek (Artificial Island) T&Q Plan, Section 3.3, states, in part, "the  ;

qualification matrix identifies the courses of instruction by job classification., .sich

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, each person shall pass in order to qualify for performance of related security - i duties." Section 3.8, titled Supervisory Training, states that supervisors are -!

required to qualify in all security force tasks. Critical Security Task #5, titled l

! Conduct Patrols, states, in part, in Element 05-A, that the examinee will l l demonstrate knowledge of the site by responding correctly to the location of several

protected and vital area alarms.

The inspectors found that the supervisors were signed off as qualified and given a  ;

i 90 day period to complete Element 05-A satisfactorily. However, during the 90 day.  !

i period, the supervisors were assigned independent Field Operations Supervisor duties, to include contingency response coordination, Contingency response coordination is an extremely important function and requires extensive knowledge of the protected and vital area alarm locations. These supervisors were assigned those duties without demonstrating requisite knowledge. The failure to qualify the supervisors in accordance with the requirement of the NRC-approved T&Q Plan is

}- an apparent violation.

l The inspectors also found noteworthy degradations in two past good practices, i Based on a review of security training lesson plans, they noted that the lesson plans were not being kept current. This was apparent by numerous annotations in the margins. Additionally, continuing self-assessments of security performance by the

training staff had been discontinued. The training supervisor stated that the lesson i plans would be updated in the near future.

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c. Conclusion -

b The inspectors concluded that the training of SFP conformed to the licensee's NRC-approved Training and Qualification Plan, except for the two new supervisors.

i However, based on the problems identified in personnel access control and testing,

< the effectiveness of the training appears to have decreased. l

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-S6: Security Organization and Administration l

1  : S6.1 Manaaement Suooort ,

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a. Insoection Scope The inspectors reviewed implementation of the security program to determine the j level of management support.

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b. -Observations and Findinas i Management support for the physical security program was found to be generally  !

adequate. However, weaknesses in management oversight were identified as  !

evidenced by the problems in the access control, testing, and training and l qualification identified in this report. l l

c. Conclusion i C

The inspectors concluded that in certain areas of the security program management {

oversight had been ineffective _or lacking. .

S7 Quality Assurance in Security and Safeguards Activities  !

S7.1 Audits l

a. Inspection Scone l

The inspectors reviewed the licensee's 1995 Quality Assurance (QA) audit of the  !

security program conducted from May 6-17,1996. j i

b. Observations and Findinas j The audit was documented in Audit Report 96-031, dated June 20,1996. {

Weaknesses identified in the audit report that required further management l attention were in the areas of VA documentation, preventive maintenance' for l security equipment, CCTV improvements and a potential weakness for allowing  :

contraband into the PA during a drill. At the time of the inspection, security management had taken immediate short- term corrective actions to correct the  ;

specific problems but had not completed long-term programmatic corrective actions. l

c. Conclusion The inspectors concluded that the audit was comprehensive in scope and depth and included an independent technical specialist on the team. Findings were reported to the appropriate levels of management and the audit ogram was being properly implemented. The findings were indicative of the .for additional management 1 oversight of the program; however, the audit failed to identify, and cause to be addressed, the specific issues disclosed in this report.

S8 Miscellaneous Security and Safeguards issues Fitness-For-Duty Prooram

a. Insoection Scope During this inspection, the inspectors reviewed portions of the licensee's Fitness-for-Duty (FFD) Program.

_ . _ _ . - ___ _._ ~ _ _ _ _ _ _ - - . _ . _ . _ _ _ _ _ _

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b. Observations and Findinos - l l- ' The inspectors randomly selected and reviewed r'ecords of pre-employment and for- l cause alcohol tests, the methodology 'used for screening and confirmation tests, and j the actions taken when a individual tested positive. The inspectors found from the  ;

l records reviewed that the testing and follow-up programs were being conducted in accordance with 10 CFR Part 26 and the licensee's FFD policies and procedures.  ;

i  !

c. .C. onclusion t  !

! No discrepancy or weakness was identified in the FFD program area reviewed.  ;

' i l .X1 Exit Meeting Summary i

! The inspectors and NRC Senior Management met with licensee representatives in the >

+ Region i Office in King of Prussia, PA, at the conclusion of the inspection on .

! September 3,1996. At that t!rne, the purpose and scope of the inspection were reviewed  ;

and the findings were presented. The licensee acknowledged the inspection findings.  !

I During the exit meeting, the licensee presented short-term corrective actions for the >

l 5

apparent violations and provided information from the Root Cause Team that had been -l

established to investigate the problems. Since neither the licensee's nor its contractor's  !

j investigations had been concluded at the time of this meeting, the licensee offered to meet '  ;

[ with the NRC to provide the results of those irivestigations when they are available. The  !

licensee committed to contact NRC Region I prior to making any substantive changes to l

. those short-term corrective actions that provide interim measures to assure security l

! program safety objectives are being met. The handouts provided by the licensee during 4

their presentation are attached to this inspection report as Attachment 1.

l 'During a review of the inspection findings subsequent to the September 3,1996 exit

. meeting, two additional apparent violations were identified. They were:' failure to test an ,

intrusion detection system in accordance with security procedures; and failure to notify the l

nuclear shift supervisor of a potential threat to the plant. Details of these apparent violations are contained in paragraphs S2.3 and S2.4, respectively. The licensee was notified of these additional apparent violations in a telephone conversation, on j j September 25, between Mr. G. Smith, NRC RI and Mr. M. Trum, PSE&G Co.

i j X2 ' Review of Updated Final Safety Analysis Report (UFSAR) 1-

[

A recent discovery of a licensee cperat. .g its facility in c manner contrary to the UFSAR l description highlighted the need for a special focused review that compares plant practices,

. procedures, and parameters to the UFSAR description. Since the UFSAR does not j specifically include security program requirements, the inspectors compared licensee

i. activities to the NRC-approved physical security plan, which is the applicable document.

The inspectors reviewed the licensee's control of Licensee Designated Vehicles (LDVs) in

, the protected area. The licensee previously had a provision for temporary LDVs in their I NRC approved Security Plan, however, the NRC determined that the provision was

inappropriate and notified the licensee in early August of that determination. The

! inspectors' review disclosed that the licenses took immediate action to discontinue the use i

o

. . - . - . . . - - - - - _ _ _ _ - - . _ . - _ , ~ ~ - - - - -

_ - - . . - , . , - - ._~ _ - -

[ -

9 reviewed the revised procedures and interviewed members of the security organization responsible for the control of vehicles onsite. The inspectors' review concluded that the <

, procedures adequately reflected the change and that members of the security organization '

, were knowledgeable of the revised procedures. The inspectors' review also disclosed that -

the licensee's control of LDV was in accordance with applicable regulatory requirements.

PARTIAL LIST OF PERSONS CONTACTED.

Licensee and Contractor D. Renniek, Security Manager J. Benjamin, Director, QA/NSR D. Garchow, Salem General Manager  :

M. Bezilla, Hope Creek General Manager L. Storz, Senior Vice President Nuclear Operations M. Trum, Director, Nuclear Operations Services D. Powell, Licensing Manager -

J. Pollock, Hope Creek QA Manager G. Grime, Security Consultant R. Ritzman, Licensing Engineer M. Ivanick, Security Coordinator P. Macconi, Operations Services NRC

'W. Kane, Deputy Regional Administrator J. Wiggins, Director, Division of Reactor Safety R. Keimig, Chief, Emergency Preparedness and Safeguards Branch R. Cooper, Director, Division of Reactor Projects ,

E. King, Security inspector  !

L. Nicholson, Reactor Projects Branch Chief I C. Marschall, Senior Resident inspector, Salem G. Smith, Senior Security Specialist .

S. Morris, Resident inspector, Hope Creek J. Kenna, Special Agent J. Joustra, Senior Enforcement Specialist R. Summers, Senior Resident inspector, Hope Creek D. Limroth, Senior Reactor inspector l

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ENCLOSURE 2 Handouts Provided i By Public Service Electric & Gas Company l At the Exit Meeting For inspection 50-272/96-14, 50-311/96-14 and 50-354/96-08 Conducted on September 3,1996 i

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i Tae Power of Commitment O PSI 4G i

PUBLIC SERVICE ELECTRIC & GAS COMPANY

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i SECURITY EXIT MEETING SEPTEMBER 3,1996 N

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i The Power of Commitment APPAM3T WOMUQ'M /

O PSEG CONCERNS

_ l' Failure to adequately control badges Failure to perform a required patdown Failure to adequately qualify supervisors Failure to deactivate badges within required time

• Concern - Overall use of procedures 2

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The Power of Commitment O PSEG SPECIFIC CORRECTIVE ACTIONS I . _ . - - . . . . _ . . _ _ . . . . _ ls Failure to adequately control badges

- Restored the locks to operability

- Security informed SNSS's of possible badge compromise

.

• Heightened awareness

- Searched vital and protected areas

- Established positive identification at Hope Creek and Salem vital areas

- Conducted badge inventory - all badges accounted for

- Reported as a loggable event t

3

t The Power of Commitment O PSEG SPECIFIC CORRECTIVE ACTIONS I l ll

• Failure to perform a required patdown

-Supervisor promptly notified of event

-Individual identified within 51 minutes of event

-Individual removed from site within an additional 27 minutes i

i

- Searched individual's locker, work area, access and

! egress route

- Confirmed individual's location during period of time within the Protected Area

- One Hour report 4 '

E The Power of Commitment O PSEG SPECIFIC CORRECTIVE ACTIONS I , . . ,

. . . . . . . . h i

• Failure to adequately qualify supervisors

- Historical finding

- Supervisors were fully qualified prior to discovery

- Reviewed qualification of security force members (in progress)

- Reinforced expectation on qualification cards to training and PSE&G personnel 5

5 4 e

The Power of Commitment O PSEG SPECIFIC CORRECTIVE ACTIONS 1

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• Failure to deactivate badges within required time

- Active badges were reviewed

! - Badges were deactivated as appropriate

- Review all active badges weekly

- Face to face communications with all R/C managers to review procedure and checklist

- Reported as a loggable event 1

6

The Power of Commitment SHORT TERH COMGNE 0

l PSEG ACTIONS Communications with security force personnel

- Reinforcement of mission

- Reviewed recent events

- Stressed.need for procedural adherence

-Introduced 3-way communications

- Heightened awareness

• Increased supervisory presence in the workplace Reinstate Guard Mount (face to face shift turnover) 7

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The Power of Commitment MORT TERM COMGIW O PSIEG ACTIONS ,

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Management mentor

• Security procedure

- Compliance

- Revisions

• Root Cause Investigation Team established Corrective actions have stabilized performance, long term corrective actions under development l

8

The Power of Commitment O PSEG ROOT CAUSE TEAM i

• Chartered a root cause investigation of the badging incident

• Charter expanded to address additional security issues l

• Expectations

- Determine if security force understand mission and if .

actions are aligned with mission

- Evaluate effectiveness of PSE&G and contractor security management, independent oversite and self assessments  !

l -Identify programmatic, cultural, and generic issues

- Recommend corrective actions 9

i The Power of Commitment 7

O PSEG AREAS OF FOCUS i I

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• Understanding of security mission i

• Professionalism of the security force ,

• PSE&G reinforcement of expectations through daily supervision

• Security team interface i

• Adequacy and implementation of security procedures  ;

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• Corrective maintenance of security hardware t

• Implementation of corrective action process

• Communications 10 r

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i The Power of Commitment O PSEG os.conu conarenvE ACEoNS I

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• Completion of Root Cause investigation Evaluate Root Cause team recommendations and implement corrective actions as appropriate Conduct security awareness training for plant managers, managers, SNSS's, and others-11

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The Power of Commitment N-GOING CORRECEVE ACHONS O PSIEG

• Provide an update to NRC Management in October

- Recovery to Excellence Plan

- Status of actions

- Performance indicators We are. committed to the return of the security program to excellence 12

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! PSE&G NUCLEAR BUSINESS UNIT ENFORCE MENT CONFERENCE NUCLEAR SECURITY NOVE MBER 14,1996

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LOU STORZ l

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i SENIOR VICE PRESIDENT -

NUCLEAR OPERATIONS ,

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MARTY TRUM  :

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DIRECTOR - OPERATIONS SERVICES P

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1 AGENDA Independent investigations Root Causes and Corrective Actions Grouping of Conimon Issues t Overall Root Causes and Corrective Actions QA Oversight Conclusion i am t

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t INDEPENDENTI3VESTIGATIONS

t PSE&G i Independent root cause evaluation E x p a n d e d s c'o p e Global and programmatic issues Wackenhut '

Second independent evaluation j Chartered by PSE&G

( We identified weaknesses in the organization h i

and in programmatic control from j 1

( the collective assessment  !

)  ;

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i ACCESS CONTROL ISSUES  ;

Control of photo-badge card keys (NRC identified)

Proper search of an individual (Self-revealing) s i

i Deactivation of photo-badge card keys (PSE&G identified) i l

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PROCEDURAL ADHERENCE ISSUES Timely notification of the nuclear shift supervisor of a potential threat (PSE&G identified)

Completion of training for security supervisors (NRC identified) -

Testing an intrusion detection system properly (NRC identified) l 7

L A

ACCESS CONTROL I  !

N Principle causes

- Command & Control

-- Communications & Teamwork

- Corrective Action Program

-Job skills & Knowledge t

-Work culture Contributing causes

-Job commitment

- Mission & Goals

- Procedural adequacy 8

=

u PROCEDURALADHERENCE i Principle causes

-Work culture  !

- Management oversight & expectations

- Procedural adequacy & compliance

- Job skills & Knowledge Contributing causes

- Self assess, ment

- Communications & Teamwork t

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i OVERALL CORRECTIVE ACTIONS I

k Replacing security management ,

Re-establishing expectations & direction Senior managem'ent involvement Reinforced the use of the Corrective Action Program Performing monitoring & evaluation Increased maintenance focus Upgrading training Focus on security mission restored

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ACCESS CONTROL '

Corrective actions

- Communicate Mission Done On-going l

- Communicate' lessons learned Done On-going

- Dedicated oversight of access control Done Evaluating

- Revise procedures Underway

- Upgrade training Underway

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- Consolidate Out-processing Underway 11

PROCEDURALADHERENCE Corrective actions

- Communicate Mission Done On-going

- Communicate' lessons learned Done On-going

- Upgrade job performance expectations Underway

- Upgrade training Underway

- Process / Procedural improvements Underway i

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JOE POLLOCK MANAGER- QUALITY ASSESSMENT ,

NBU .

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OVERSIGHT FINDINGS L

k May 1996 Security Audit Results  ;

Audit techniques ~ did not detect cultural changes t

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3 The Quality Assurance i,QA> Program did not detect cultural issues

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. _ . . . . _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ . _ , _~

OVERSIGHT CORRECTIVE ACTIONS Developing vertical slice interview assessment process i

Improving our critical attributes list to include O & P items i

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SUMMARY

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We.ta!:e security seriously We understand the implications of recent security events We have initiated comprehensive corrective actions t

( 3 Security will be affirmed prior to Salem restart '

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• pa hios

• , uNm;D STATES

g NUCLEAR REGUI.ATORY COMMISSION i r REGloN 1 1."

% [ 475 ALLENDALE ROAD KING oF PRUsslA, PENNSYLVANIA 19406-1415 December 11, 1996 i EA 96-344 i

Mr. Leon R. Eliason Chief Nuclear Officer and President  !

Nuclear Business Unit Public Service Electric and Gas Company Post Office Box 236 Hancocks Bridge, New Jersey 08038

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES -

$100,000

- (NRCinspection Reports No. 50-272/96-14,50-311/9614 and 50-354/96-08)

Dear Mr. Eliason:

This letter refers to the NRC inspections conducted at the Salem and Hope Creek Nuclear 2 Generating Stations between August 15-September 3,1996. Four apparent violations were discussed with you at an exit meeting in the Region 1 office on September 3,1996. Two additional apparent violations were identified subsequent to the September 3,1996 exit meeting and were discussed in a telephone conversation with your staff on i Se~ptember 25,1996. The inspection report was sent to you on September 30,1996. On November 14,1996, a predecisional enforcement conference was conducted with you and members of your staff to discuss the apparent violations identified during the inspection, their causes, and your corrective actions.

Based on our review of the inspection findings, and information provided during the conference, six violations are being cited and are described in the enclosed Notice of Violation and Proposed imposition of Civil Penalties (Notice). Three of the violations relate to two specific events which occurred involving the failure to control access to the facility. One event involved a security force member taping a photobadge keycard area door lock, due to problems with the lock, thereby allowing any individual who had gone through the search process the opportunity to obtain a photobadge keycard and use it to access the protected area. This failure to control photobadge key cards for entry into the protected area, which constitutes the first violation, could have allowed unauthorized access to the protected area.

This violation, which is set forth in Section I.A. of the enclosed Notice, was identified when an NRC inspector observed' that the locking mechanism on the door to that specific photobadge issue area had been taped over rendering the lock inoperable. At the time the lock was observed as inoperable by the inspector, the area was not occupied by security force personnei (SFPL and no compensatory measures were in place for this degradation. You subsequently took immediate action to remove the tape, restore the lock to an operable condition, and verify that this degradation had not resulted in an unauthorized entry into the protected or vital areas of the f acilities. Nonetheless, this condition created an opportunity for unauthorized individuals to gain access to the protected and vital areas, and, as such, represented a significant degradation of the security program at the facility. Therefore, the violation has been categorized at Severity Leveilllin accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), NUREG-1600 3 b d 9%l23/oDG5 pop k k

a j- .

• Public Service Electric sad 2 Gas Company-The second event involved a contractorindividual accessing the protected area without a pat- i down search, as required, after the individual had, on three occasions, alarmed two separate i

- metal detectors at the access control point. In addition, your staff's initial followup after the second event was poor. In this case, although the contractor employee was allegedly told by ,

security force personnel to stand aside and await a hands-on search to determine the cause of the alarms, the contractor employee went to the badge issue area, was issued a photo badge / key card, and entered the protected area without being detained by security force personnel, contrary to NRC requirements. This violation is described in Section I.B.1 of the  !

Notice. Subsequently, althouch a security supervisor initiated actions to identify the contractor individual once notified of the eventi the~ security supervisor did not notify the l Senior Nuclear Shift Supervisor onsite, which was required since the contractor individual (

. should have been considered an intruder. Your NRC-approved Security Contingency Plan l

' requires such notification whenever there is an intruder at the facility. This violation is l described in Section I.B.2 of the Notice. The contractor individual was not identified by the  !

officers performing the search function until 50 minutes after his entry.

Although appropriate searches were conducted once the contractor was located, including' i searches of the individual, his locker, and his whereabouts while uncontrolled in the protected .[

area, the NRC is concerned that the control room was not notified, as required, of the potential }

security threat that existed, and the contractor's badge / key card was not deactivated during  !

that time, which would have precluded him from entering any vital areas. In addition, the l

contractor was not paged on the plant paging system, once he was identified, to expedite locating him. These failures also constitute a significant regulatory concern regarding your regard for control of access to the facilities, and therefore, the two violations are categorized j

. in the aggregate as a Severity Level lli problem in accordance with the " General Statement of j ~

Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), NUREG-1600.

i These three violations of fundamental access control requirements at nuclear power plants i represent a significant degradation in the security program at the facility, that during the prior SALP, had been recognized as a strength at the facility. At the enforcement conference, you  ;

acknowledged problems in the work culture at the facility, and also noted that deficiencies in i

~

procedural adequacy, procedural adherence, job skills, and management oversight contributed to these violations, it is important that these causes are fully corrected to ensure that only ,

authorized individuals are granted entry to protected and vital areas.  ;

in accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is considereo for a Severity Level ill problem or violation. ' Your facilities have been the subject  ;

of escalated enforcement actions within the last 2 years. For example, Severity Level lli violations and cumulative civil penalties in the amount of $600,000 were issued on October l 16,1995 for,in part,'severalinstances of the failure to identify and correct conditions adverse  ;

to quality at Salem (

Reference:

EAs 95 62/95-65/95-117). In addition to these Salem

~

violations, a Severity Level ill violation and a civil penalty in the amount of $100,000 was issued to your Hope Creek facility on August 24,1995, for inadequacies in shutdown cooling ,

t system operations. Therefore, the NRC considered, for each Severity Level 111 violation and problem, whether credit was warranted for /denti// cation and Correct /ve Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. .>

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p ,.. '

s Public Service Electric and *3 Gas Company

. 1 With respect to the violation in Section I.A., credit is not warranted for /dentification because

! the violation was identified by the NRC. Credit is warranted for Corrective Action because at .;

the time of the enforcement conference, your actions were considered both prompt and

[ comprehensive. These actions, which were discussed' during your presentation- at the

!. ' conference, include, but are not limited to the following: (1) replacement of security j management; (2) reestablishing expectations and direction in the security department; (3) j- ensuring management involvement in the program; and (4) upgrading the training of security 1 personnel.

i

As to the problem in Section I.B, credit is not warranted fer hfentification because the violation

[ was self revealing when security personnel could not locate the individual, and then failed to j notify the control room as required.- Credit is warranted for Corrective Action because at the -

l time of the enforcement conference, your actions, as already described, were considered both prompt and comprehensive.

i l Accordingly, to encourage prompt identification and correction of violations, I have been authorized, after consultation with the Director, Office of Enforcement, to propose a separate i civil penalty of $50,000 for each of the Severity Level ill violations and problems in Sections -

j i and ll of the enclosed Notice. The total civil penalties proposed for this action is $100,000.

i j The three other violations identified during.the inspection are described in Section 11 of the j- enclosed Notice and are classified at Severity LevellV. Those violations involve (1) the failure i to deactivate photo badge key cards for individuals who no longer required site access after  ;

j being terminated; (2) the f ailure to complete training for security supervisors prior to assigning )

them to perform supervisory duties; and (3) the failure to test an intrusion detection system in accordance with procedures.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the spech'ic actions taken and any additional actions you plan to' prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the  !

results of future inspections, the NRC willdetermine whether further NRC, enforcement action l is necessary to ensure compliance with NRC regulatory requirements. i in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,its enclosure, and your response will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or j safeguards information so that it can be placed in the PDR. If redactions are required, a proprietar/ version containing brackets placed around the proprietary, privacy, and/or j i

safeguards information should be subm.itted. In addition, a non-proprietary version with the information in the brackets redacted should be submitted to be placed in the PDR.

Sincerely, n

Hu ert J. Miller Regional Administrator

1 j

Public Service Electric and 4 -

l Gas Company .

l l,

L Docket Nos. 50 272, 50-311, 50-354' l License Nos. DPR 70, DPR-75, NPF-57  ;

i

Enclosure:

Notice of Violation and Propored imposition  !

of Civil Penalties cc w/ encl: l L. Storz, Senior Vice President - Nuclear Operations -l E. Simpson, Senior Vice President - Nuclear Engineering i E. Salowitz, Director - Nuclear Business Support -

C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.

D. Garchow, General Manager - Salem Operations i M. Bezilla, General Manager - Hope Creek Operations  !

J. Benjamin, Director - Quality Assurance & Nuclear Safety Review  !

D. Powell, Manager, Licensing and Regulation l R. Kankus, Joint Owner Affairs i A. Tapert, Program Administrator R. Fryling, Jr., Esquire M. Wetterhahn,' Esquire' P. MacFarland Goelz, Manager, Joint Generation Atlantic Electric Consumer Advocate, Office of Consumer Advocate  ;

W. Conklin, Public Safety Consultant, Lower Alloways Creek Township i Public Service Commission of Maryland i State of New Jersey i State of Delaware l i

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4 l 1 ENCLOSURE l

l l NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES 1

1 Public Service Electric and Gas Company. Docket Nos. 50-272, 50-311, 50-354  !

Salem Nuclear Generation Station ,

License Nos. DPR-70, DPR-75, NPF-57 l

Hope Creek Nuclear Generating Station' EA 96-344.

t

! ' During an NRCinspection conducted between August 15-September 3,1996, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and

[ Procedure for NRC Enforcement Actions," NUREG 1600, the Nuclear Regulatory Commission

j. proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, 'I

as amended (Act), 42 U.S.C. 2282,' and 10 CFR 2.205. The particular violations and i associated civil penalties are set forth below

i-i 1. VIOLATIONS ASSESSED A CIVIL PENALTY

A. License Condition 2.E of License Number NPF-57 for the Hope Creek facility, .j f and License Conditions 2.E of License Numbers DPR 70 and DPR-75 for Salem,  ;

require that PSE&G fully implement and maintain in effect all provisions of the  !

l physical security, guard training and qualification, and safeguards contingency

plans approved by the Commission and all amendments and revisions to such

plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

i l The Public Service Electric and Gas Company (PSE&G) Salem - Hope Creek Security Plan, Revision 7, dated June 21,1996, states,in Section 5.6, " Access Control to Vital Areas" that " Vital area access is physically controlled by the photobadge-keycard system which permits access into specific areas to persons

~

i designated on the current access list contained in the system computers.

Positive acce.ss control is accomplished by [ Security Force Personnell (SFP) j j prior to issuance of the photobadge-keycard. Persons are positively identified by requiring them to request the badge by number, and visually, by comparing j the picture to the person before issuing the keycard."

i Contrary to the above, on August -14,1996, vital area access was not physically controlled in that positive access control over photobadge keycards l was compromised, thereby creating the opportunity for unauthorized access to l

the vital areas. Specifically, on that date, an NRC inspector identified that the .

lock mechanism on a door to one of the badge issue stations had been taped l

i. over, rendering the lock incapable of performing its locking function, and at the i time, the badges were left unattended in the issue station, and no I compensatory measures were in place for the inoperative lock to preclude an

' unauthorized individual from gaining access to the badges and the protected and vital areas. (01013) l

]

l This is a Severity Level 111 Violation (Supplement 111).

Civil Penalty - $50,000.

16 /23/ oc6P SPP - . . . . - _ _ ._ .-. - -

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Enclosure 2  ;

l B. License Condition 2.E of License Number NPF-57 for the Hope Creek facility,-  !

and License Conditions 2.E of License Numbers DPR-70 and DPR-75 for Salem, l require that PSE&G fully implement and maintain in effect all provisions of the .i i

physical security, guard training and qualification, and safeguards contingency  !

plans approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(pl. l

1. The PSE&G Salem - Hope Creek Security Plan, Revision 7, dated June l 21,1996, states, in Section 4.2.1.4, " Personnel Search and Access  !

Control," that " Searches at the guardhouses are performed by locally f alarming portal or hand-held metal and explosives detectors. When there l i

Is reasonable cause to suspect that a person is attempting to introduce firearms, explosives, incendiary devices or other unauthorized material i into the protected area, the person is given a physical pat-down search. l When the metal and/or explosives detectors are not in service and i operating in accordance with equipment test standards, physical pat-down searches are performed." j{

Contrary to the above, on August 26,1996, a contractor employee  ;

entering the protected area caused two portal metal detectors to alarm j on three different attempts to pass through them, and although these j alarms provided reasonable cause to suspect that the contractor was  !

attempting to introduce firearms, explosives, incendiary devices or other  !

unauthorized material into the protected area, no physical pat-down l search was performed, and the contractor was given his photobadge-keycard and entered the protected area. (02013)

2. The PSE&G Salem - Hope Creek Security Contingency Plan, Revision 4, y dated February 12,1996, states, in part, in Section 8.1.3.2, that it will  !

be assumed that a security threat exists until it is known otherwise. i Section 8.1.4 of the Contingency Plan defines an intruder as a person f i

present in a protected or vital area without authorization. Section 8.3.2.6 of the Contingency Plan states that in the event of discovery of intruders or attack, notify the Senior Nuclear Shift Supervisor (SNSS) of implementation of Contingency Event 6 (Discovery of intruders), provide ,

j a concise situation report, and request SNSS to classify the event per the Event Classification Guide in Section 16. t Contrary to the apon. on August 26,1996, a contractor who had )

alarmed the two portal me+al detectors on three occasions, entered the l protected area without receiving a pat-down search, was not authorized to enter the protected area witnout having received a search, and, therefore, should have been ass.amed to be an intruder and security threat until it was known othe; wise; however, the SNSS was not notified of the threat, and the event was not classified per Event Classification Guide 16.(02023)

This is a Severity Level lli problem (Supplement lill.

Civil Penalty - $50,000.

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6 Enclosure 3 II. VIOLATIONS NOT ASSESSED A civil PENALTY  ;

' A. License Condition 2.E of License Number.NPF-57 for the Hope Creek facility, e and License Conditions 2.E of License Numbers DPR-70 and DPR-75 for Salem, require that PSE&G fully imp!ement and maintain in effect all provisions of the l physical security, guard training and qualification, and safeguards contingency ,

plans approved by the Commission and all amendments and revisions to such l plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

j 1. The PSE&G Salem - Hope Creek Security Plan, Revision 7, dated L June 19,1996, states, in part, in the introduction Section that the implementing documents of this plan are the Security Plan Procedures and Post Orders. Security Plan Procedure 4, Revision 3, dated November 1,1994, states, in Section 4.13, that when a person granted "

l unescorted access terminates employment or no longer requires access l to the site Protected Area, the cognizant department shall notify the l Screening Supervisor. within two working days, and the Screening Supervisor ensures that the administrative actions required to inactivate  ;

the security photobadge and personnel access clearance are accomplished.

( Contrary to the above, the Screening Supervisor was not notified within two working days that 12 employees had been terminated in June and July 1996. Specifically, notification of five employees that were terminated in June 1996 was not made until the 31-day revalidation list was issued in July 1996, and notification of seven employees that were terminated in July 1996 was not made until the 31-day revalidation list was issued in August 1996.(03014) l L This is a Severity Level IV Violation (Supplement 111).

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2. The PSE&G Salem - Hope Creek Security Training and Qualification Plan, Revision 3, dated February 12,1996, Section 3.3, states, in part that, the qualification matrix identifies the' courses..of instruction by job classification, which each person shall pass in order to qualify for performance of related security duties. Section 3.8, titled, Supervisory Training, states that supervisors are required to qualify in all security force tasks.

i Critical Security Task No. 5, titled, " Conduct Patrols," states, in Element 05-A, that the examinee will demonstrate knowledge of the site by l responding correctly to the location of several protected and vital area alarms.

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- Enclosure 4 Contrary to the above, on August 20,1996, the inspectors determined by a review of training records and shift activity logs, that two supervisory personnel were performing Field Operations- Supervisor duties prior to qualifying on all of the required critical security tasks for the performance of their 'related security duties. Specifically, the supervsors were signed off as qualified supervisors by the security training department and given a 90-day period to complete Element 05-A. However, during the 90-day period, the supervisors were assigned independent Field Operations Supervisor duties, to include contingency response coordination, requiring extensive knowledge of the protected and vital area alarm locations. (04014)

This is a Severity Level IV Violation (Supplement til).

3. The PSE&G Salem - Hope Creek Security Plan, Revision 7, dated June ,

1996, states, in part, in the introduction Section, that the implementing j documents of this plan are the Security Plan Procedures and Post l Orders. Security Plan Procedure 8, Vehicle Access Control, Revision 8,  !

dated February 28,1996, requires, in part, in Section 10, Use of Crane  !

Gate, that the Security Shift Supervisor / designee direct that the zone be  !

crawl tested after the vehicle passes anu prior to securing the patrol. ]

This procedure further states, that the security force member (SFM) No.  ;

1 shall remain posted at the gate until the zone passes the crawl test. I Contrary to the above, on June 5,1996, a vehicle passed through the Crane Gate, and a crawl test was not conducted prior to SFM 1 being released from the post. (05014)

This is a Severity Level IV Violation (Supplement lil).

Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalties (Notice). This reply should be clearly marked as a :" Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and 1 (5) the date when full compliance will be achieved. )

I If an adequate reply is not received within the time specified in this Notice, an Order or a j Demand for information may be issued as to why the license should not be modified, j suspended, or revoked or why such other action as may be proper should not be taken.

Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under ,

oath or affirmation.

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. Enclosura 5 i

i Within the same time as provided for the response required above under 10 CFR 2.201, the 1 i

Licensee may pay the civil penalties by letter addressed to the Director, Office of Enforcement, l

.U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer p payable to the Treasurer of the United States in the cumulative amount of the civil penalties, or may protest imposition of the civil penalties in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.

Should the Licensee fail to answer within the time specified, an order imposing the civil

. penalties will be issued. Should the Licensee elect to file an answer in accordance with 10

l. CFR 2.205 protesting the civil penalties, in whole or in part, such answer should be clearly p marked as an " Answer to a Notice of Violation" and may: (1) deny the violation (s) listed in -

this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in F

this Notice, or (4) show other reasons why the penalties should not be imposed. In addition j to protesting the civil penalties in whole or in part, such answer may request remission or j mitigation of the penalties.

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in requesting mitigation of the proposed pencities, the factors addressed in Section VI.B.2 of i the Enforcement Policy should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalties.

Upon failure to pay any civil penalties due that subsequently have been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act,42 U.S.C. 2282c.

The response noted above (Reply to Notice of Violation, letter with payment of civil penalties, and Answer to a Notice of Violation) should be addressed to: James Lieberman, Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North,11555 Rockville Pike, Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S.

Nuclear Regulatory Commission, Region I, and a copy to the NRC Senior Resident inspector at the facility that is the subject of this Notice.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR. If redactions are required, a proprietary version containing brackets placed around the proprietary, privacy, and/or safeguards information should be submitted. In addition, a non-proprietary version with the information in the brackets redacted should be submitted to be placed in the PDR.

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Dated at King of Prussia, Pennsylvania this 11th day of December 1996 l i

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• S Pubhc Servce Electre and Gas Company Louis F. Storz P O Box 236, Hancocks Bridge, PU OB038 009-339-5700 s.- m. ~e.., .

.. n, Public Service ElectricUAN and Gas Compa"i 01997 LR-N96432 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO A NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES INSPECTION REPORT No. 50-272/96-14, 311/96-14, and 354/96-08_

FACILITY OPERATING LICENS5 DPR-70, DPR-75, and NPF-57 SALEM NUCLEAR GENERATING STATION UNITS 1 AND 2 HOPE CREEK GENERATING STATION UNIT 1 DOCKET NOS. 50-272, 50-311, and 50-354 Pursuant to the provisions of 10CFR2.201, this letter submits the response of Public Service Electric and Gas Company (PSE&G) to the Notice of Violation and Proposed Imposition of Civil Penalties described in a letter from the NRC dated December 11, ,

1996. These issues were previously identified in Inspection  !

Report No. 50-272/96-14, 50-311/96-14, and 354/96-08, dated ,

September 30, 1996. Information pertaining to the description of the event, the reason for the violation, and the corrective actions taken is provided in Attachment 1.

In the cover letter that transmitted the Notice of Violation and Proposed Imposition of Civil Penalties, the NRC stated that the violations of fundamental access control requirements represent a significant degradation in the Salem - Hope Creek security program.

In response, PSE&G has implemented comprehensive corrective l actions. These corrective actions include the replacement of security management. reestablishing expectations and direction in the security departnvnt, ensuring management involvement in the program, and upgrading the training of security personnel. An additional initiative is a security awareness program to communicate management's expectation that security is everyone's responsibility. These corrective actions are in addition to the corrective actions associated with each of the cited violations.

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. . . l JAN101997 i t .

Document Control Desk LR-N96432 L

Should you nave questions or comments on this transmittal, do not ,

hesitate to contact us. l 4 Sincerely, ,

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Attachment I Affidavit l 1

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95-4933

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UAN101997

' Document Control Desk' 4 LR-N96432 l

C Mr. H. J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475-Allendale Road  ;

j King of Prussia, PA 19406 -

I Director, Office of Enforcement U. S. Nuclear Regulatory Commission a

One White Flint North 11555 Rockville Pike Mail Stop 07H5 Rockville, MD 20852 Mr. L. N. Olshan, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike ,

Mail Stop 14E21 ~

Rockville, MD 20852 Mr. D. Jaffe, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike )

Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall - Salem USNRC Senior Resident Inspector (X24) 1 Mr. R. Summers - Hope Creek USNRC Senior Resident Inspector (X24)

Mr. K. Tosch, Manager IV l Bureau of Nuclear Engineering i 33 Arctic Parkway CN 415  ;

Trenton, NJ 08625  :

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REF: LR-N96432 STATE OF NEW JERSEY ) ,

) SS. ,

COUNTY OF SALEM' )

b L. F. Storz, being duly sworn according to law deposes and~says:

I am Senior Vice President - Nuclear Operations of Public Service l Electric and Gas Company, and as such, I find the matters set forth_in the above referenced letter, concerning Salem Nuclear Generating Station and Hope Creek Generating' Station, are true to I

the best of my knowledge, information and belief.

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Subscribed'and S to before me i this /0M day e

-Min; t a 4A' 1997 U

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KIMBERLY JO BROWN NOTARY PUBUC OF NEW JERSEY My Commission Espires Apr3 21,1998 My Commission expires on 4

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ATTACHMENT REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NO. 50-272/96-14, 311/96-14, and 354/96-08 FACILITY OPERATING LICENSE DPR-70, DPR-75, and NPF-57 SAU4 NUCLEAR GENERATING STATION UNITS AND 2 HOPE CREEK GENERATING STATION UNIT 1 DOCKET NOS. 50-272, 50-311, and 50-354 LR-N96432 I. INTRODUCTION On December 11, 1996, the NRC issued a letter to PSE&G. This letter included a Notice of Violation and Proposed Imposition of civil Penalties. The issues that were cited as violations were previously identified in Inspection Report 50-272/96-14, 50-311/96-14, 50-354/96-08, dated September 30, 1996. In that inspection report, these issues were cited as apparent violations of NRC requirements.

As noted f.n the Notice of Violation and Proposed Imposition of Civil Penalties, overall corrective actions have been initiated.

These overall corrective actions include the replacement of s'ecurity management, reestablishing expectations and direction in the security department, ensuring management involvement in the program, and upgrading the training of security personnel. In addition, security has initiated actions to address cultural issues. These actions include items that are focused on security such as an increased number of security drills as well as actions that are focused on the rest of the organization. One of these initiatives is a security awareness program to communicate the message that security is everyone's responsibilf.ty. These  !

corrective actions are in addition to the correstive actions associated with each of the cited violations.

In accordance with the provisions of 10CFR2.201, PSE&G hereby submits a written response to the notice of violation which includes: 1) the reason for the violation; 2) the corrective steps that have been taken and the results achieved; 3) the corrective steps that will be taken to avoid further violations; and 4) the date when full compliance will be achieved.

In this response, the failure to control photobadge key cards for entry into the protected area will be referred to as Violation A; the contract individual accessing the protected area without a patdown search and poor initial follow-up will be referred to as Violation B; the failure to deactivate photo badge key cards for individuals who no longer require site access will be referred to as violation C; the failure to complete training for security supervisors prior to assigning them to supervisory duties will be j

1 of 15

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REPLY TO A NOTICE OF VIOLATION LR-N96432 referred to as Violation D; and the failure to test an intrusion detection system in accordance with procedures will be referred to as violation E.

II. REPLY TO THE NOTICE OF VIOLATIONS A. Violation A

1. Description of the Notice of Violation

" License Condition 2.E of License Number NPF-57 for the Hope Creek facility and License Conditions 2.E of License Numbers DPR-70 and DPR-75 for Salem, require that PSE&G fully implement and maintain in effect all provisions of the physical security, guard training and qualification, and safeguards contingency plans approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10CFR50.90 and 10CFR50. 54 (p) .

The Public Service Electric and Gas Company (PSE&G) Salem - Hope Creek Security Plan, Revision 7, dated June 21, 1996, states in Section 5.6, " Access Control to Vital Areas" that " Vital area access is physically controlled by the photobadge-keycard system which permits access into specific areas to persons designated on the current access list contained in the system computers.

Positive access control is accomplished by Security Force Personnel (SFP) prior to issuance of the photobadge-keycard.

Persons are positively identified by requiring them to request the badge by number, and visually, by comparing the picture to the person before issuing the keycard."

Contrary to the above, on August 14, 1996, vital area access was

, not physically controlled in that positive access control over j

=photobadge keycards was compromised, thereby creating the 1 opportunity for unauthorized access to the vital areas.

Specifically, on that date, an NRC inspector identified that the lock mechanism on a door to one of the badge issue stations had been taped over, rendering the lock incapable of' performing its locking function, and at the time, the balges were left unattended in the issue station, and no cornpensatory measures i were in place for the inoperative lock to preclude an I unauthorized individual from gaining access to the badges and the protected and vital areas.

This is a Severity Level III Violation." l l

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REPLY _TO A NOTICE OF VIOLATION LR-N96432

2. Response to the Notice of Violation ,

PSE&G does not dispute the violation.

i. Description of the Event On August 14, 1996, a Security Force Member (SFN '

ped the locking mechanism of a badge issue booth door bt;: .,e the lock was malfunctioning. The condition of the malfunctioning '

lock was not effectively communicated to security supervision; therefore, no action was taken to repair the lock. The SEMs assigned to this badge issue booth later in the day did not report the condition of the lock to security supervision at turnover because they believed that the SFM that had taped the lock had already reported the condition.

An NRC inspector, during a routine observation, noticed a SEM

, open the badge issue booth door, apparently without the use l of a key. Later the same day, another NRC inspector physically challenged the door and found it to be unlocked due to the taped latch. While the NRC inspector was opening the door on a subsequent attempt, a SFM questioned the NRC inspector regarding his actions and discussion ensued about the taped lock. At this point, the tape was removed from the door lock. The Security Department implemented compensatory l- measures and initiated Action Requests to evaluate the event

and repair the lock.

'l Subsequent investigative interviews determined that the

. security door lock taping practice was limited to the badge issue booth doors and not the physical manipulation of other security equipment in the protected area. However, it was also determined that taping of the badge issue booth doors had been done in the past and had since become common practice even though it is prohibited by a security directive.

ii. Reason for the Violation The reason for this violation was personnel error in that the

- SFM that taped the lock did not follow an approved security directive. The reasons that immediate repairs were not initiated for the locking mechanism were ineffective intradepartmental communications in that the security supervisor was not made aware of the malfunctioning lock and lack of confidence in the effectiveness of the Corrective Action Program.

In addition, supervision and management have tolerated similar situations in the past. Interviewees indicated that a 3 of 15 1

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.l REPLY TO A NOTICE OF VIOLATION LR-N96432 i b i

!. ' security supervision was knowledgeable of previous taping of <

, the locking mechanism.  !

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111. Corrective'Steos That Have Been Taken and Results Achieved i

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The involved security personnel were disciplined and/or a remediated. .

1 A' heightened supervisory and management presence has been  !

i established in the lobby area.

Communications meetings were held with security force-  !

personnel to review this event, including stressing j- procedural compliance, use of the Corrective Action Program, i and reinforcing the security' force's. mission. j e

i Three-part communication training was conducted for the security force. 1 i --

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A formal turnover process has been implemented.

" A maintenance team has been formed to provide timely resolution 5 i~ of issues related to security equipment.

.The Access Operations Supervisor checklist has-been revised i

j. to ensure that key. physical security and personnel l l performance parameters are checked frequently during each j shift. The Access Operations Supervisor checklist also provides a place to indicate that-discrepancies.have been processed in accordance with'the Corrective Action Program.

iv. Corrective Steos That Will be Taken to Avoid Further l Violations t

A standards and expectation manual will be developed and

provided to the security. force by May 1, 1997. This manual l will reinforce expectations that have already been rolled out j to the security force.

.PSE&G is currently initiating the appropriate submittals-to j implement a hand geometry access system which will preclude

! . future similar violations.

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v. Date When Full Conoliance Will Be Achieved  !

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[  : Compliance was achieved on August 14, 1996, when the tape was  !

removed from the locking mechanism.  ;

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REPLY TO A NOTICE OF VIOLATION LR-N96432 B. Violation B

1. Descriution of the Notice of Violation

" License Condition 2.E of License Number NPF-57 for the Hope Creek facility and License Conditions 2.E of License Numbers DPR-70 and DPR-75 for Salem, require that PSE&G fully implement and maintain in effect all provisions of the physical security, guard training and qualification, and safeguards contingency plans approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10CFR50.90 and 10CFR50.54 (p) .

1. The PSE&G Salem - Hope Creek Security Plan, Revision 7, dated June 21, 1996, states, in Section 4.2.1.4, " Personnel Search and Access. control," that " Searches at the guardhouses are performed Ly locally alarming portal or hand-held metal and explosives detectors. When there is reasonable cause to suspect that a person is attempting to introduce firearms, explosives, incendiary devices or other unauthorized material into the protected area, the person is given a physical pat-down search. When the metal and/or explosive detectors are not in service and operating in accordance with equipment

. test standards, physical pat-down searches are performed."

Contrary to the above, on August 26, 1996, a contractor employee entering the protected area caused two portal metal detectors to alarm on three different attempts to pass J through them, and although these alarms provided reasonable I cause to suspect that the contractor was attempting to introduce firearms, explosives, incendiary devices or other unauthorized material into the protected area, no physical ,

pat-down search was performed, and the contractor was given i his photobadge-keycard and entered the protected area.

2. The PSE&G Salem - Hope Creek Security Contingency Plan, i Revision 4, dated February 12, 1996, states, in part, in l Section 8.1.3.2, that it will be assumed that a security '

threat exists until it is known otherwise. Section 8.1.4 of j the Contingency Plan defines an intruder as a person present I in a protected or vital area without authorization. Section 8.3.2.6 of the Contingency Plan states that in the event of l discovery of intruders or attack, notify the Senior Nuclear shift Supervisor (SNSS) of implementation of Contingency Event 6 (Discovery of Intruders), provide a concise situation report, and request SNSS to classify the event per the Event I Classification Guide in Section 16.

Contrary to the above, on August 26, 1996, a contractor who had alarmed the two portal metal detectors on three occasions, entered the protected area without receiving a ,

1 5 of 15

REPLY TO A NOTICE OF VIOLATION LR-N96432 pat-down search, was not authorized to enter the protected area without having received a search, ano, therefore, should have been assumed to be an intruder and security threat until j it was known otherwise; however, the SNSS was not notified of the threat, and the event was not classified per Event Classification Guide 16.

This is a Severity Level III problem."

2. Resnonse to the Notice of Violation PSE&G does not dispute the violation.

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i. Descrintion of the Event At approximately 0628 hours0.00727 days <br />0.174 hours <br />0.00104 weeks <br />2.38954e-4 months <br /> on August 19, 1996, a male contractor was accessing the site through the Security Center by normal means. The contractor was successfully screened for explosives and hand-carried items; however, he set off the metal detector alarm. As noted, the contractor 1 cooperated with the instructions to re-enter the metal detector on several occasions. As a result of the unsuccessful screening, a female security force member (SFM) requested the contractor to wait for a hands-on search. The SFM did not effectively communicate with the contractor; l consequently, the contractor did not realize that security was expecting him to wait for a hands-on search.

Because the SFM was a different gender than the contractor, .

the first-line security supervisor directed the SFM to switch  !

with a same gender SFM to perform the hands-on search.

During this transition, no one from security maintained positive control of the contractor. The contractor proceeded to obtain his badge and enter the protected area at 0629 hours0.00728 days <br />0.175 hours <br />0.00104 weeks <br />2.393345e-4 months <br />, without the hands-on search. A non-fully qualified security trainee, during his first morning of in-plant training, observed this evolution. He did not react because he had previously been instructed to merely observe on-going activities because of his qualification status.

The contractor left the area before the assigned same gender SFM arrived. The other SFMs in the area unsuccessfu)1y attempted to locate the contractor in the Security Cs ar.

The first-line security supervisor obtained a descript.sn of the contractor from the SFMs and the SFM trainee who had observed the incident. Tne supervisor then briefly entered the protected area in an attempt to locate the contractor.

The supervisor was not able to locate the contractor and returned to the Security Center. He then informed his management of the incident.

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REPLY TO A NOTICE OF UIOLATION LR-N96432 In an attempt to identify the contractor, a computer report was generated at approximately 0633 hours0.00733 days <br />0.176 hours <br />0.00105 weeks <br />2.408565e-4 months <br /> to determine who entered the protected area between 0615 hours0.00712 days <br />0.171 hours <br />0.00102 weeks <br />2.340075e-4 months <br /> and 0630 hours0.00729 days <br />0.175 hours <br />0.00104 weeks <br />2.39715e-4 months <br />.

This list of names was narrowed down based on the badging booth that the contractor had used ~ (as observed by the SFM trainee). At approximately 0715 hours0.00828 days <br />0.199 hours <br />0.00118 weeks <br />2.720575e-4 months <br />, the SFM who originally processed the contractor and the PSE&G security supervisor went to the processing center to determine the identity of the contractor via a review of badge photos.

Upon determination of the contractor's identity, the SFM and the PSE&G security supervisor returned to the Security Center. The PSE&G security supervisor attempted to reach the contractor's supervisor at approximately 0730 hours0.00845 days <br />0.203 hours <br />0.00121 weeks <br />2.77765e-4 months <br />. After Security contacted the contractor's supervisor, the contractor was located and escorted outside the protected area to the Security Center at 0747 hours0.00865 days <br />0.208 hours <br />0.00124 weeks <br />2.842335e-4 months <br />. A badge. history was run that showed the contractor did not enter any vital areas and his whereabouts were accounted for by coworkers.

The contractor's locker, work area, and access and egress.

routes were searched; no contraband was discovered.

The contractor fully cooperated with security and remained in the Security Center while the search was being conducted. At approximately 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br />, the contractor again passed through the metal detector, causing it to alarm. After removing i loose items from his person, the contractor successfully passed through the metal detector. A hands-on search of the contractor was also conducted. Nothing unusual was detected.

Security notified the Salem Control Room of the incident at 0818 hours0.00947 days <br />0.227 hours <br />0.00135 weeks <br />3.11249e-4 months <br /> and the Hope Creek Control Room at 0820 hours0.00949 days <br />0.228 hours <br />0.00136 weeks <br />3.1201e-4 months <br />. At this point, security informed the Control Rooms of the event and the applicable contingency plan, and made an Event Classification Guide classification recommendation that included a one-hour notification. Both Control Rooms concurred with this classification. Salem notified the NRC Operations Center at 0903 hours0.0105 days <br />0.251 hours <br />0.00149 weeks <br />3.435915e-4 months <br />. Hope Creek notified the NRC Operations Center at 0913 hours0.0106 days <br />0.254 hours <br />0.00151 weeks <br />3.473965e-4 months <br />. These notifications were made pursuant to the requirements of 10CFR73.71. However, they were not made within one hour of the start of the event (0629 hours0.00728 days <br />0.175 hours <br />0.00104 weeks <br />2.393345e-4 months <br />).

Nuclear power plant access control consists of three parts:

authorization requirements delineated in 10CFR73.56 and 10CFR73.57, the fitness for duty provisions of 10CFR26, ahd the positive access controls described in 10CFR73.55.

The authorization requirements consist of a background investigation, psychological assessment, and behavioral observation. In addition, 10CFR26 requires on-going i.

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REPLY TO A NOTICE OF VIOLATION LR-N96432 compliance with fitness for duty regulations. The contractor involved in this event was granted unescorted access authorization based on a request for unescorted access by a PSE&G manager and his completion of, and compliance with, I these requirements.

In addition to the authorization and fitness for duty requirements, personnel seeking access to Salem or Hope Creek are subjected to positive access control requirements. These include metal detectors, explosive detectors, x-ray machines, and observation. The contractor involved in this instance l was successfully screened for explosives and any hand-carried i items. He was not successfully screened through the metal detectors, which represents a failure of the positive access ,

controls. i l

Generic Letter 91-03 was issued to provide regulatory I guidance relative to the reporting of safeguards events. The 1 Generic Letter discusses partial failure of an otherwise I satisfactory access authorization or access control program. l The Generic Letter states that licensees should properly I compensate for these partial failures within 10 minutes of discovery, unless extenuating circumstances prevent l compensation within that time. If the partial failures are i properly compensated for, the event need not be reported  !

within one hour provided there was no malevolent intent, nothing adverse resulted from the delay, and appropriate measures are taken to ensure a more timely response in the future. It should be noted that the regulatory guidance l provided in Generic Letter 91-03 does not require the  ;

contractor involved in this event to be classified as an  !

intruder.

The contractor was identified, located, and removed from the  !

protected area; however, additional measures such as immediate notification of the Control Room and deactivation of the contractor's badge, should have been taken to completely compensate for this incident. The investigation, both during and after the incident, demonstrated that there was no malicious intent on the contractor's part, and that his behavior while onsite was normal and routine. The contractor has been employed at this site off and on for over 20 years. Interviews with the SFMs indicated that the contractor cooperated with the original instructions to re-enter the metal detector. Further, the SFM did not observe any unusual behavior or deceit by the contractor. The contractor was identified, removed from the protected area, and re-searched. The contractor cooperated with the investigation and volunteered his locker combination. His locker, work area, and access and egress routes were searched. No contraband was found. Therefore, it was 8 of 15

REPLY TO A NOTICE OF VIOLATION LR-N96432 l l

l determined that no malevolent intent was involved and no adverse events resulted from the delay in implementing compensatory measures.

ii. Reason for the Violation The cause of this event was personnel error on the part of security personnel. This error involved the failure to maintain positive control of the contractor until the hands-on search was conducted.

The cause for the failure to notify the Control Rooms in a timely manner is personnel errors on the part of the first line security supervisor and the PSE&G security supervisor.

The security supervisors focused on retrieving the contractor from the protected area and did not refer to security contingency procedures until after the contractor was escorted outside the protected area. Therefore, notification was not made in a timely manner.

PSE&G agrees that the notification to the Control Rooms was not made until the event was essentially over.

iii. Corrective Steos That Have Been Taken and Results Achieved The contractor was identified and removed from the protected area. The contractor's locker, work area, and access and egress routes were searched.

The involved security personnel were retrained on the proper method of maintaining positive control over an individual prior to conducting a hands-on search.

The contractor and the involved security personnel were disciplined.

Communications meetings were held with security force personnel to review this event, including stressing procedural compliance and reinforcing the recur!.ty force's mission.

Instruction and expectations relative to maintaining positive control of individuals that require a hands-on search and communications with the Control Room have been reinforced with security supervisors.

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REPLY TO A NOTICE OF VIOLATION LR-N96432 )

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iv. Corrective Steos That Will be Taken to Avoid Further l Violations A standards and expectation manual will be developed and provided to the security force by May 1, 1997. This manual will reinforce expectations that have already been communicated.

Security procedures have been reviewed. The revisions identi#ied by this review will be completed by March 1, 1997.

v. Date 4 hen Full Comoliance Will Be Achieved Compliance was achieved when the contract individual was removed from the protected area and the 10CFR50.72 notification was made.

C. Violation C

1. Description of the Notice of Violation

" License Condition 2.E of License Number NPF-57 for the Hope Creek facility and License Conditions 2.E of License Numbers DPR-  ;

70 and DPR-75 for Salem, require that PSE&G fully implement and '

maintain in effect all provisions of the physical security, guard training and qualification, and safeguards contingency plans approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10CFR50.90 and 10CFR50. 54 (p) .

The PSE&G Salem - Hope Creek Security Plan, Revision 7, dated June 19, 1996, states, in part, in the Introduccion Section that the implementing documents of this plan are the Security Plan Procedures and Post Orders. Security Plan Procedure 4, Revision 3, dated November 1, 1994, states, in Section 4.13, that when a person granted unescorted access terminates employment or no longer requires access to the site protected area, the cognizant department shall notify the Screening Supervisor within two working days, and the Screening Supervisor ensures that the administrative actions required to inactivate the security photobadge and personnel access clearance are accomplished.

Contrary to the above, the Screening Supervisor was not notified within two working days that 12 employees had been terminated in June and July 1996. Specifically, notification of five employees that were terminated in June 1996 was not made until the 31-day revalidation list was issued in July 1996, and notification of seven employees that were terminated in July 1996 was not made until the 31-day validation list was issued in August 1996.

This is a Severity Level IV Violation."

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' REPLY TO A NOTICE OF VIOLATION LR-N96432

2. Response to the Notice of Violation PSE&G does not dispute the violation.

i. Descriotion of the Event i

Between July and August 1996 there were several incidents of the failure of various departments to notify security within '

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of an employee's termination. These incidents resulted in the above violation. In addition to the examples cited by the NRC, PSE&G has self-identified other instances >

of occurrence. Review of the specific individual cases where unescorted site access was not terminated within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> as required did not reveal any specific patterns (e.g., multiple ,

departments were involved and the terminations included l seasonal layoffs, contractor layoffs and permanent PSE&G personnel resignations or retirements). None of the specific I cases included "for cause" terminations. The badges for  ;

individuals who have been terminated "for cause" have '

consistently been deactivated appropriately. 1

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ii. Reason for the Violation The cause of the failure to deactivate badges within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of termination is less than adequate management standards, policies, and administrative controls. The responsible departments did not follow the established process for deactivating badges; in addition, the enforcement and implementation of the process have been lax. This has been an on-going issue that security management did not effectively take a leadership role in resolving.

iii. Corrective Steos That Have Been Taken and Results Achieved Revised expectations for deactivating badges have been communicated to department managers.

A "last-day" badge drop program has been initiated. A badge drop location has been provided where badges can be dropped for employees who no longer have a need to gain site access.

As an interim action, the protected area access authorization l review is being done on a weekly basis. Additional instances j of non-compliance have been found since the identification of this issue. When these instances are discovered, an action request is initiated in the Corrective Action Program and the responsible manager is held accountable for the non-compliance.

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REPLY TO A NOTICE OF VIOLATION LR-N96432 The cut-processing process has been enhanced to clarify the process for deactivating badges of terminated employees.

iv. Corrective Steos That Will be Taken to Avoid Further Violations The actions stated in part (iii) above are considered to be sufficient to avoid further violations.

v. Date When Full Compliance Will Be Achieved The out-processing program is in full compliance with NRC regulations. Additional emphasis is being placed on the implementation of the program to ensure compliance with the program.

D. Violation D

1. Description of the Notice of Violation

" License Condition 2.E of License Number NPF-57 for the Hope Creek facility and License Conditions 2.E of License Numbers DPR-70 and DPR-75 for Salem, require that PSE&G fully implement and maintain in effect all provisions of the physical security, guard training and qualification, and safeguards contingency plans approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10CFR50.90 and 10CFR50. 54 (p) .

The PSE&G Salem - Hope Creek Security Training and Qualification Plan, Revision 3, dated February 12, 1996, Section 3.3, states, in part that, the qualification matrix identifies the courses of instruction by job classification, which each person shall pass in order to qualify for performance of related security duties.

Section 3.8, titled, Supervisory Training, states that supervisors are required to qualify in all security force tasks.

Critical Security Task No. 5, titled, " Conduct Patrols," states, in Element 05-A, that the examinee will demonstrate knowledge of the site by responding correctly to the location of several protected and vital area alarms.

Contrary to the above, on August 20, 1996, the inspectors determined by a review of training records and shift activity logs, that two supervisory personnel were performing Field Operations Supervisor duties prior to qualifying on all of the required critical security tasks for the performance of their related security duties. Specifically, the supervisors were signed off as qualified supervisors by the security training l

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REPLY TO A NOTICE OF VIOLATION LR-N96432 j l

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department and given-a 90-day period to complete Element 05-A.

However, during the 90-day' period, the supervisors were assigned independent Field Operations Supervisor duties, to include contingency response coordination, requiring extensive knowledge of the protected and vital area alarm locations. ,

I This is a Severity Level IV Violation." I

2. Response to the Notice of Violation i l

PSE&G does not dispute the violation.

i. Descriotion of the Event The qualification process for the Security Force consists of -

a series of Performance Certification Components (PCC) that l must be completed. The number of PCCs to be completed varies f depending on the security position of an employee. Each PCC l is further broken down into specific tasks.

Four recently hired contract supervisors did not complete a )'

portion of a _ PCC prior to assuming a supervisory role on shift. For this task, " Demonstrate Knowledge of Site Layout and Features," a 90-day grace period was granted by security management to complete the task. This 90-day grace period was not allowed by procedure; however, it was granted to provide the newly hired employees time to become familiar with the site and stations prior to qualification.

As a result of the above described discretion, two of four recently hired security supervisors were inappropriately assigned work prior to completion of qualification requirements.

ii. Reason for the Violation l

I The root cause of this violation was personnel error by security management in granting a grace period to qualification requirements without controlling assignments.

This alloweo the supervisors to supervise work for which they were not qualified.

iii. Corrective Steos That Have Been Taken and Results Achieved The SFM qualification cards were reviewed for completeness. j The discrepancies were limited to the supervisors discussed in this response.

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The security lesson plan has been revised to specifically state that there is no grace period for supervisors and armed response officers. ,

iv. Corrective Steos That Will be Taken to Avoid Further Violations l

A standards and expectation manual will be developed and )

provided to the security force by May 1, 1997. This manual j will reinforce expectations that have already been communicated.

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v. Date When Full Compliance Will Be Achieved Full compliance has been achieved. The supervisors involved in this event were completely qualified prior to the discovery of this issue.

l E. Violation E

1. Description of the Notice of Violation

" License Condition 2.E of License Number NPF-57 for the Hope Creek facility and License Conditions 2.E of License Numbers DPR-70 and DPR-75 for Salem, require that PSE&G ful]y implement and maintain in effect all provisions of the physical security, guard training and qualification, and safeguards contingency plans approved by tre Commission and all amendments and revisions to .

such plans made pursuant to the authority of 10CFR50.90 and l 10CFR50. 54 (p) .

The PSE&G Salem - Hope Creek Security Plan, Revision 7, dated  !

June 19, 1996, states, in part, in the Introduction Section, that l the implementing documents of this plan are the Security Plan Procedures and Post Orders. Security Plan Procedure 8, Vehicle Access Control, Revision 8, dated February 28, 1996, requiras, in part, in Section 10, Use of Crane Gate, that the security shift supervisor / designee direct that the zone be crawl tested after the vehicle passes and prior to securing the patrol. This procedure further states, that the security force member (SFM)

No. 1 shall remain posted at the gate until the zone passes the crawl test.

Contrary to the above, on June 5, 1996, a vehicle passed through the Crane Gate, and a crawl test was not conducted prior to SFM 1

.being released from the post.

This is a Severity Level IV Violation."

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. REPLY TO A NOTICE OF VIOLATION LR-N96432

2. Response to the Notice of Violation PSE&G does not dispute the violation.  ;

i. Descriotion of the_Ey_qr,&

On June 5, 1996, a vehicle entered the site through the crane gate. The-security supervisor believed that a crawl test would only be required if the vehicle left depressions in the i gravel. He inspected the area, determined that no depressions were there, performed a walk-through test, secured-the zone, and proceeded to an adjacent zone.

Shortly thereafter, the supervisor discussed the test with another supervisor who knew that the crawl test was required by procedure. The crawl test was then performed satisfactorily.

ii. Reason for the Violation I I

The root cause of this event was a personnel error in that the security supervisor did not follow the approved procedure  ;

for testing the erane gate. ,

iii. Corrective Steps That Have Been Taken and Results Achieved f

The involved security personnel were disciplined.

Communications meetings were held with security force personnel to review this event, including stressing l procedural compliance and reinforcing the.use of the  !

Corrective Action Program and the security force's mission.

iv. Corrective Steos That Will be Taken to Avoid Further l Violations .

l A standards and expectation manual will be developed and  !'

provided to the security force by May 1, 1997. This manual will reinforce expectations that have already been ,

communicated. )

v. Date When Full Compliance Will Be Achieved Compliance was achieved when the zone was satisfactorily crawl tested on June 5, 1996.

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