ML17306A398

Responds to NRC Re Violations Noted in Insp Rept 50-528/91-38.Corrective Actions:Security Officers at Compensatory Posts Rotated Every 2 H & Contacts by Radio & by Touring Supervision More Frequent

ML17306A398
Person / Time
Site:	Palo Verde
Issue date:	01/02/1992
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17306A397	List: IR 05000528/1991038 ML17306A398
References
102-02095-WFC-T, 102-2095-WFC-T, NUDOCS 9201240162
Download: ML17306A398 (29)

Text

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l'r406rox, *IIIZONA00012 a000 102-02095-MFC/TRB/P January 2,

1992 SRI Ri.l Rl 2 Rl-3 Office ASSISTANT I IrIAI.

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Reference:

Letter dated December 2, 1891, from R. A, Scarano, Director, Division of Radiation Safety and Safeguards, NRC to W. F. Conway, Executive Vlcc President, Nuclear, APS Gentlemen:

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION (PVNGS)

UNITS 1, 2, AND 3 REPLY TO NOTICE QF VIOLATIONS50-528/91<8-.01, 528/91-38-02, ANb 628/91-38-03 JPP7 ArizorIa Public Service Company (APS) has reviewed NRC inspection Report 50-528, 529, 530/91-38 and the Notice of Violations dated December 2, 1991, Pursuant to the provisions of 10 CFR 2,201, APS'esponses are attached, Appendix A to this letter is a restatement of the Notice of Violations APS'r responses are provided ln Attachment

1. provides the evaluation of Security On-duty Shift Staffing requested in the referenced letter.

Should you have any questions regarding these responses, please contact me.

Very truly yours, WFG/7Rf3/'PJC/dmn Attachments:

1. Appendix A - Restatement of Notice of Violations

2. Attachment 1 - Reply to Notice of Violations 3, Attachment 2-Evaluation of On-duty Security Shift Staffing cc.

J. B, Martin D. H. Coe 9201240162 920102 PDR ADOCK 05000528 8

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During an NRC Inspection conducted on October 21 through 25, and November 4 and

'l2, 1891, three violations of NRC requirements ware identified.

In accordance with the "General $tatement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1891), the vlolatlons are llsteci below; Paragraph 2.E. of the Facility Operating License No. NPF-41 for the Arizona Public Service Company's Palo Verde Nuclear Generating Station, as amended, requires the licensee to fully implement and maintain In effect all provisions of the Commission-approved physical secure, guard training and qualification, and safeguards contingency plans, Including all amendrnants made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55, and to the authority of 10 CFR 60.90 and 10 CFR 60.54(p).

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curl asure latl 1-03 Section 8,1.2 of the licensee's approved Security Plan requires in part that Immediate compensatory measures be taken upon detection of any degradation of vital area barriers, and that these measures remain In effect until the barrier is restored to full operational capability.

Contrary to the above, the licensee's Implemented compensatory measures did not remain ln effect on four occasions when the posted security officers were inattentive to duties, and on one additional occasion, when the security officer abandoned his post.

Speciflcally: on July 24, 1881, a security officer posted as

.a compensatory measure at Door 2Y-103 leading to the Unit-2 Spray Pond Pump House, was inattentive on post; on August 4, 1991, the security officer posted as compensatory measure at Doqr 38.1p3, leading to the Unit-3 Diesel Generator Building, was inattentive on post; on August 11 and October 24, 1991, the security officers posted at Doors 1C-301 and 1CA41, respectively, leading to the Unit-1 Main Steam Support Structure, were Inattentive on post', and on September 25, 1991, the security office posted as a compensatory measure at Door 38-108, leading to the Unit-3 Diesel Generator Building, abandoned his post for a short

time, This ls a Severity Level.IV Vloiatld'n )Supplement III).

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Section 1.6.6, of the ticensee's approved Security Plan requires, in part, that whenever an individual is involuntarily terminated for cause, that the individual's unesoorted facility access will be revoked prior to or strnultaneously upon notification of termination.

Contrary to the above, on October 21, 1981, card key number 5710 (slot 3080)

Issued to a previousty terminated employee, had not been revoked and remained ln the security badge rack available for issue until October 22, 1991.

This ts a Severity Level-IV Violation (Supplement ill).

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Section 8,4.3.4 ofthe licensee's approved Security Plan discusses the method that authorized employees utilize to enter plant vital areas, and requires, in part, that the card reader system ettows access only to those personnel granted access for entry to that area.

Additionally, Section 5,2,2 of the Plan requires, in part, that compensatory measures be enacted for failure of components or segments of access control devices.

Further, Section 5,0 of the Plan designates the Control Room for each unit as a vital area, Contrary to the above, on July 31, 1881, a security officer, compensating for an Inoperable card reader, at Door 1J-319 leading to the Unit-1 Control Room, allowed individuals to enter tnto the Control Room without first verifying that the individuals had been granted access for entry to that vitat area.

ThIs ls a 8everity Level-IV Violation (Supplement Ill).

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r. Vc ATTACHMENT'l REPLY TO NOTJCE OF VlOLATlONS S0-628/914841, 528/9148<<02, AND 628/91 38-03 NRC INSPBCTlON CONDUCTED OCTOBER 21-25, 1991 lNSPFCTIPN REPORT NOS. 50-528, 529) AND 530/9'f-39

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All five of the incidents Included ln this violation involved temporary contract security officer. The APS evaluation of four of the incidents identified a combination of contributing factors.

The contract officers completed initial Nuclear Security Training on July 4, 1881, and had been assigned to non-rotating 12-hour shifts.

The initial training program did not stress the frequent tedium of manning compensatory posts, the potential for inattentiveness, the need for preventive

measures, or management's specific expectations.

Three of the Incidents occurred ln late July and early August, At that time both APS and contract security supervision initiated briefings and memoranda to reinforce to personnel the necessity of being attentive whil~ on post.

The single incident In September was somewhat different in nature as it involved a contract officer who left his post to attend to urgent personal needs. The posted officer requested a break without explaining the urgency of his need, Therefore, the relief officer arrived within the routine period of 10-1 5 minutes rather than on an expedited basis.

The fifth incident, which occurred in October, was determined to be a cognitive personnel error on the part of the security officer.

ln each case described above, the officer was relieved of his post and appropriate disciplinary action was taken.

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Security officers at compensatory posts are rotated every two hours, contacts by I

radio and by touring supervision are frequent and officers are encouraged to call for breaks when needed.

Following the July and August Incidents, APS and contract shift supervision Increased post visits until B-hour shifts could be established for ail security guards.

Contract personnel on 12-hour shifts were re-assigned to 8-hour shifts on September 6,

1991.

Shift supervisors also reinforced the need for posted personnel to walk aground if they feel drowsy and, when necessary, to call shift supervision so they may be re-posted to a high traffic area or to another job which Is more conducive to attentiveness.

In addition, contract supeivisors have been vlsltlng contract security personnel on post to re-emphasize the importance of the Job being performed. This practice willbe continued as long as it ls considered to be needed.

The Security Operations Supsnrisor reviewed the circumstances surrounding the case ot the officer who left his post, The review indicated that when a security officer requests a break, the relief officer rputlnely arrives within 15 minutes, A means is available for an officer to request urgent relief lf the usual 15 minutes ls longer than the officer feels he can walt. No further action was taken.

PVNl 8 Security management is closely monitoring the results of these efforts.

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I I ns APS performed an evaluation of security personnel performance in November, 1991, As a result of that evaluation, PVNGS Security is currently conducting additional on-shift briefings to keep emphasis focused on the causes of inattentiveness, the actions personnel should take to prevent Inattentiveness, and the need for clear communication among shift personnel.

The briefings willbe completed and documented by December 27, 1891.

personnel who, for any reason fvacatfon, illness, etc}, have not been briefed by December 27, 1991, will not be assigned to a post until they have received the required briefing. The indoctrination material described above willbe incorporated as an enhancement Into Security's Initial training program and will be added to the annual requaliffcatlon training program.

As a further preventive measure, a briefing by Security supervision delineating management expectations will be included in the initial training program.

The revisions to the Security training programs willbe completed by February 10, 1892.

Full complfance was achieved when each of the officers Involved was replaced at his post, Page 3 of 8

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The Automated Control Access Device (ACAO) of a contract employee terminated for cause on October 18, 1991, was not expired in accordance with Security Plan requirements due to inconsistent guidance among the controlling procedures.

The Security Plan requirement that the ACADof an individual terminated for cause be expired prior to or simultaneously with notification of termination was not concisely and consistently restated in security procedures.

Expiration of the subject ACAO was further delayed by miscommunication between the ontract company foreman and his supervisor. Each of those individuals mistakenly believed the other had notified PVNGS Security of the termination of their employee.

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- The terminated employee's ACADwas expired on October 22, 1991. Atransaction tog was run whtch tndtcated there had beenino unauthorized use of the ACAD following the termination.

On October 23, 1991, the Security Technical Support Supervisor met with the on-site contract oornpany representatives to review the administrative controls pertaining to contract employee terminations for cause."Each contract representative provided PVNGS Security with a list of terminations for cause.

Security verified that each of the associated ACAOs had been expired in compliance with Security Plan reqQirements.

No other Page 1 of 2

incidents were Identified.

As an interim measure, the PVNGS Security Manager issued a memorandum on November 14, 1891, to PVNGS management requiring that all employee terminations be called to the Security Shift Supervisor at the time of occurrence so that the associated ACADs can be immediately expired, At the Security Manager's request, a memorandum requiring that the Security Shift Supervisor be notified immediately of terminations for cause was issued to contract company representatives by the APS Contracts Department on December 20, 1891.

@or ctlv S e s That Will Be Take To Avoid Further Violations The applicable procedures,13AC QPR02, "PYNGS Contract Personnel Request and Exiting Procedure; 20AC-OSK04, "Protected/Vital Area Personnel Access Control," and 20AC.OSK07, "PYNGS Unescorted Access Coritrol," will be revised to clearly state the requirement that all involuntary terminations of APS and contract employees for cause will be called into the Security Shift Supervisor at the time of the occurrence so that the associated ACADs can be Immediately expired.

These procedure changes will be completed by February 15, 1992, Date Wh ull o

Ila ce Will Be Achieved Full compliance was achieved on October 22, 1991, when the terminated contract employee's ACAD was expired, Page 2 of 2

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This violation was the result of a cognitive personnel error by the Security Officer who was the first to arrive at door 1-J319 to assist personnel who were unable to enter the Unit 1 Control Room due to an inoperable card reader.

White awaiting a second officer who had been dispatched with the Automated Control Access Device (ACAD)

Access Level List, the officer on the scene recognized two NRC inspectors and a PVNGS opet'ator.

The officer assumed these individuals had control room access authorization and permitted the three individuals to enter the Unit 1 Control Room.

He recorded their ACAD numbers, but failed to verify their access levels using either the access level list or a radio verification with the Central Alarm Station (GAS) or the Secondary Alarm Station (GAB) to ensure they were authorized entry. A fourth individual whom the officer did not recognize was denied access pending access level verification in accordance with Security procedures.

The officer was relieved from his post and security personnel searched the area, No unauthorized personnel were found to have gained access to the Control Room,.

Review of the ACAD Access List confirmed that the two NRC inspectors and the PVNG$

operator. were authorized access through vital area door 1-J319.

On the day of the incident (July 31, 1991), the Security Sh1ft Captain conducted Page 1 of 2

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r. la one. on-one retraining with the involved officer on the administrative controls for personnel access level verification during Security computer reconfiguration/failures, An informal briefing on access level verification was conducted for personnel on each security shift cturing the week of August 1, 1891.

The Security Operations Super visor issued a memorandum on December 16, 1991, to the Shift Captains instructing each of them to conduct a formal briefing session with the personnel on their shifts to discuss the proper methods for accessing personnel into the protected/vital areas during security computer reconfiguration/failures.

The formal on-ehlft briefings have been completed.

Personnel who, for any reason (illness, vacation, etc.), were not briefed wilt not be assigned to a post until they have received the requisite indoctrination.

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Lessons learned from this violation willbe incorporated into Security's initialtraining and annual regualification training programs beginning with the requalification training cycle scheduled to start on January;6, 1992.

a When F I Com Ilance Will Be A hl v d Full compliance was achieved on July 31, 1991, when access level authorization was confirmed for the three individuals 'wh'o were erroneously permitted entry to the Unit 1 Control Room.

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vV Vd 1 llW4 I hate vt I'sill AVWCHMENT2 EVALUATIONOF ON-DUTY SECURITY SHIFT STAFFING

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(ij EVALUATIONOF ON-DUTY SECURITY SHIFT STAFFING As the result of a contingency, response drillconducted at Palo Verde in April 1990, NRC staff identified both strategic and tacticai response weaknesses.

Principally, Palo Verde response personnel were trained to locate and contain adversaries rather than to protect vital areas and prevent or limit adversary access to vital equipment.

As a consequence of that strategy, response personnel were dispatched to the zone of intrusion rather than to defensive positions close to vital areas; therefore, when the intruders reached the target, sufficient response personnel were not present in the vital area to confront and Interdict them.

The 1990 Site Services Division Security Action Plan was established to address desired Improvements to the PVNGS Design Basis Threat Training Program.

A portion of the Action Plan Included the development of a lesson plan to train Security personnel in deployment and response activities for a design basis threat.

Revision 0 of that Ie "on plan included a drill scenario that used several armed responders in excess of the number that had been determined as required and that is documented in the PVNGS Security

Plan, The Security Department's upgraded training program includes improvements In both strategy and tactics.

properly trained and deployed, the number of armed responders required by the Security Plan can defend vital equipment.

The Design Basis 1'hreat Lesson Plan is being revised to reflect Security Plan-required staffing.

However, training provisions for the utilization of potentially available, additional armed responders will be incorporated into the lesson plan. The lesson plan will be revised by January 10, 1892.

I The mobile patrol post order which designates a minimum of two mobile patrols por shift was the result of a "delay factor" concern which was identified in April 1980, prior Pnqe 1 of 2

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to the Installation of the 12-foot tooer security fence.

VVhen' inner security fence installation was completed in September 1989, the delay factor concern was resolved.

Therefore, the practice of keeping two mobile patrols on duly ls no longer necessary.

The post order guidance pertaining to the assignment of two mobile patrols per shift has been revised to state that the number and/or combination of patrols assigned to a shift will be at the discretion of the Security Shift Supervisor.

The appropriate security procedure wilt be revised to include the requirement that at least one mobile patroi wiiibe on duty at aii tirnee.

Patrol documentation wiiibe completed in accordance with established policy.

ln addition, a program ls in place to review all post orders for relevancy, accuracy, and useabllily, Completion is expected by June 1, 1992, TOTAL P. 16