ML17306A398

Responds to NRC 911202 Ltr 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)

See also: IR 05000528/1991038

Text

uli uo>lr0 uD isWi (nr u vsriui Routin: Route/pppy AL;e'ILLlhM F.CONWAY CÃtbUTIV0 V40 Hl40IDCNT Nvc4EArr U.S.Nuclear Regulatory

Commission

Attention:

Dooument Control Desk Mail Station: P1.37" Washington, D.C.205M Arizona Public Service Company I,O, bOx saNe~l'r406rox,*IIIZONA 00012 a000 102-02095-MFC/TRB/P

January 2, 1992 SRI Ri.l Rl 2 Rl-3 Office ASSISTANT I IrIAI.COI FI L TDSS: rrrN TD 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 VIOLATIONS

50-528/91<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.Attachment

2 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, WF G/7Rf3/'P JC/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 PDR

e k I l 0

~~ULIU5r 2)Jc.'H'D U5 I'IPL tel U VCKLPC.DU@DhD 8 lDh I~VDAPPENDIX A e'ESTATEMENT

OF NOTICE QF VIOLATIONS

SD-528/91484'I, 528/91 4842, AND 628/9148-03

NRC INSPRGTION

CONDUCTED, OCTOBER 25-25, 1991 INSPECTION

REPORT NOS.50-528)629, 530/9148~~

Vl<VW k PJ I 1 dd V4 I~IM I~'ll V 11 IIVI gvO I MO I~V~e'TAT E 0l=I E I 8--2 D 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).A.o t 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).Page 1 of 2

V4~'ll'\4~~1I 9 4l WUI\J ms'Mu F ill A ess iol n 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).t a~Section 8,4.3.4 of the 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).Page 2 of 2

h l t I (

v~i s Oi LOVED Ls'D U3 I%4 Ct1L4 vchlJc ad='~~i~o 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

l', r 1

J.t~Ma ua nN.re U vCCuc.edd&Z r58 P.U7 Y 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.Page)of 8

Th sv Been T e n eRe hlev d k 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 will be 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.PVNl8 Security management

is closely monitoring

the results of these efforts.Page 2 of 3

s)Yh ll e ke To void urth I 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 will be 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 will be 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 will be completed by February 10, 1892.Full complfance

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

(

v t 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 ACAD of 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.Pf8 VI B 8 B HBVB 888~Ii TB B~nd The e I 8 chl ved-The terminated

employee's

ACAD was expired on October 22, 1991.A transaction

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

t II i

h lo o 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

~z

Vl<VO<l VVa i IR~dD UO I'454 I l14tJ VCRIJP oUC~au c.(~5 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.

~O*l St~Wl~k4 td h Lessons learned from this violation will be incorporated

into Security's

initial training 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.Page 2 of 2

vV Vd 1 ll W4 I hate vt I'sill AVWCHMENT 2 EVALUATION

OF ON-DUTY SECURITY SHIFT STAFFING

J

(ij EVALUATION

OF ON-DUTY SECURITY SHIFT STAFFING As the result of a contingency, response drill conducted 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

~q e

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 wiii be 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