ML17306A398
| ML17306A398 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/02/1992 |
| From: | CONWAY W F ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17306A397 | List: |
| 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
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
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