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December 21, 2007

EA-07-296 Mr. Charles G. PardeeChief Nuclear Officer and Senior Vice PresidentExelon Generation Company, LLC 4300 Winfield RdWarrenville, IL 60555

SUBJECT: NRC AUGMENTED INSPECTION TEAM (AIT) FOLLOW-UP REPORT05000277/2007405 AND 05000278/2007405; PRELIMINARY GREATER THANGREEN FINDING - PEACH BOTTOM ATOMIC POWER STATION

Dear Mr. Pardee:

On November 9, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed an AITfollow-up inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. Thisinspection was conducted to provide additional assessment and determine the significance ofissues identified by an Augmented Inspection Team (AIT) in September 2007 regarding securityofficer inattentiveness. The enclosed inspection report documents the AIT follow-up inspectionresults, which were discussed at the public exit meeting on December 3, 2007, with Mr. JosephGrimes and other members of your staff. Following the inspection exit, the NRC responded toquestions from those stakeholders in attendance. It should be noted that the findingsdocumented in this report do not represent new or different issues or incidents ofinattentiveness other than those identified during the September 2007 AIT inspection.EXEMPT FROM PUBLIC DISCLOSUREMay be exempt from public release under the Freedom ofInformation Act (5 U.S.C. 552)Exemption number: ___5____Nuclear Regulatory Commission review required beforepublic release.James Trapp, RI/DRS/PSB1/RA by D. Roberts for/_____Name and organization of person making determination.Date of determination: _____12/20/2007___Attachment C Contains SensitiveUnclassified Non-Safeguards Information. Upon separation, the cover letter,enclosure, and Attachments A and B aredecontrolled. C. Pardee2 The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license. The team reviewed selected procedures and records, observed activities, and interviewedpersonnel.As initially described in the NRC Augmented Inspection Team report dated November 5, 2007,the enclosed report documents one finding regarding inattentive security officers and anineffective behavior observation program that was preliminarily determined to be greater thanGreen, as determined by the Physical Protection Significance Determination Process (i.e., afinding of at least low to moderate security significance). The Significance DeterminationProcess analysis contains security sensitive information and will not be made publicly available(Attachment C). When notified of this issue by the NRC, compensatory measures were put inplace by Exelon that addressed this finding while longer term corrective actions were beingimplemented. In accordance with Inspection Manual Chapter 0305, "Operating ReactorAssessment Program" this finding has cross-cutting aspects in the areas of HumanPerformance and Safety Conscious Work Environment.As mentioned previously, this inspection was conducted as a follow-up to an earlier AITinspection that took place from September 21-28, 2007. Following the earlier inspection, theNRC took several actions to ensure that the overall effectiveness of the security program atPeach Bottom was not compromised as a result of the incidents of inattentiveness. Theseactions included issuing a Confirmatory Action Letter (CAL) to Exelon to ensure that immediateand long term corrective actions were being implemented at the site. The NRC supplementedits own routine inspection effort by increasing it's monitoring while Exelon transitioned to aproprietary security force at Peach Bottom in November 2007. On November 28, 2007, theNRC's Executive Director for Operations approved a Reactor Oversight Process (ROP)Deviation Memorandum allowing the NRC Region I staff to increase its inspection and oversightof Peach Bottom beyond that which would normally be prescribed by the ROP. These actionsensured that adequate NRC oversight was provided to address the performance deficienciesdescribed in this report while the NRC's significance determination and enforcement processwere being completed. The NRC has made the public aware of these actions by holding publicinspection exit meetings and making related documents publicly available in ADAMS.Before we make a final significance decision regarding this preliminary "greater than Green"finding, we are providing you an opportunity (1) to attend a Regulatory Conference where youcan present to the NRC your perspective on the facts and assumptions the NRC used to arriveat the finding and assess its significance, or (2) submit your position on the finding to the NRCin writing. If you request a Regulatory Conference, it should be held within 30 days of thereceipt of this letter and we encourage you to submit supporting documentation at least oneweek prior to the conference in an effort to make the conference more efficient and effective. Ifa Regulatory Conference is held, it will be closed for public observation because it involvessecurity sensitive information. If you decide to submit only a written response, such submittalshould be sent to the NRC within 30 days of the receipt of this letter. If you decline aRegulatory Conference and choose not to submit a written response, the NRC will proceed withits final significance determination. C. Pardee3 Please contact Mr. James Trapp of my staff at (610) 337- 5186 within 10 business days of thedate of your receipt of this letter to notify the NRC of your intentions. If we have not heard fromyou within 10 days, we will continue with our significance determination decision. You will beadvised by separate correspondence of the results of our deliberations on this matter andmatters involving future enforcement decisions. In addition, please be advised that thecharacterization of the performance issue described in the enclosed inspection report maychange as a result of further NRC review.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and Attachments A (Supplemental Information) and B (Event Chronology) will beavailable electronically for public inspection in the NRC Public Document Room or from thePublicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (thePublic Electronic Reading Room). However, because of the security-related informationcontained in Attachment C, and in accordance with 10 CFR 2.390, a copy of Attachment C willnot be available for public inspection.In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements foryour response, if any. This will ensure that your response will not be made publicly available. IfSafeguards Information is necessary to provide an acceptable response, please provide thelevel of protection described in 10 CFR 73.21.

Sincerely,/RA/

Darrell J. Roberts, Deputy DirectorDivision of Reactor SafetyDocket Nos:50-277, 50-278License Nos:DPR-44, DPR-56

Enclosure:

Inspection Report 05000277/2007405 and 05000278/2007405w/Attachments

Attachments:

(A)Supplemental Information(B)Event ChronologyNon-Public

Attachment:

(C)Physical Protection Significance Determination Process Review Results (Official UseOnly - Security Related Information)

SUMMARY OF FINDINGS

IR 05000277/2007-405, 05000278/2007-405; 11/05/2007 - 11/09/2007; Peach Bottom AtomicPower Station (PBAPS), Units 2 and 3; Access Authorization and Protective StrategyThe augmented inspection follow-up was conducted by a team consisting of inspectors from theNRC's Region I office, Region IV office, and a security specialist from Nuclear Security andIncident Response (NSIR). One finding with preliminary greater than Green securitysignificance was identified. The significance of most findings is indicated by their color (Green,White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance DeterminationProcess" (SDP). Findings for which the SDP does not apply may be Green or be assigned aseverity level after NRC management review. The NRC's program for overseeing the safeoperation of commercial nuclear power reactors is described in NUREG-1649, "ReactorOversight Process," Revision 4, dated December 2006.A.NRC-Identified and Self-Revealing Findings

Cornerstone: Physical Protection

TBD. A preliminary greater than Green finding was identified for failure tomaintain the minimum number of available responders and failure to maintain aneffective behavior observation program (BOP). The licensee implementedimmediate compensatory measures and conducted a root cause analysis thatresulted in additional corrective actions. This finding is considered more than minor because it is associated with theResponse to Contingency Events and Access Authorization attributes and itaffected the cornerstone objective to provide assurance that the licensee'ssecurity system uses a defense-in-depth approach and can protect against (1)the design basis threat of radiological sabotage from external and internalthreats, and (2) the theft or loss of radiological materials. Specifically, aninadequate BOP led to inattentive responders. With multiple inattentive responseteam members at one time, the licensee was below minimum numbers ofavailable responders, which increased the potential for degradation in theprotective strategy of the site. Using the Physical Protection SignificanceDetermination Process (PPSDP), the team determined that the finding was ofgreater than very low security significance. The cause of the finding is related tothe cross cutting elements of safety conscious work environment (SCWE)(S.1.a)and management/supervisory oversight element (H.4.c) of the humanperformance cross-cutting area. (Section 3.3)B.Licensee-Identified FindingsNone Enclosure

REPORT DETAILS

1.0Inspection Background InformationOn September 10, 2007, the NRC was contacted by representatives of WCBS-TV (NewYork City), stating that videotapes of inattentive security officers (SOs) at the PeachBottom Atomic Power Station (PBAPS) were in their possession. The NRC verballyinformed Exelon management of the information and initiated enhanced oversight ofsecurity activities at Peach Bottom that same day. On September 19, 2007, afterviewing the videos, the NRC determined an augmented inspection team (AIT) waswarranted to gather facts related to these events. On September 21, 2007, anaugmented team inspection was initiated. On September 27, 2007, the NRC issued anadvisory (SA-07-06) to the nuclear industry regarding inattentive security officers andrelated fitness for duty and behavior observation issues.On October 9, 2007, the NRC held a public exit for the AIT inspection. The teamidentified that immediate corrective actions were adequate, but also identified additionalareas for follow-up inspection. On October 19, 2007, the NRC issued a confirmatoryaction letter (CAL) to ensure immediate compensatory measures were maintained andto document a schedule for planned long term corrective actions. On October 24, 2007,the NRC instituted a weekly status call with Exelon to discuss CAL actions and thestatus of transitioning from a contract security force to an Exelon force. On November 5,2007, the AIT inspection report was issued and an AIT follow-up inspection began toreview issues identified by the AIT in detail and assess the significance of anyperformance deficiencies. On November 28, 2007, the NRC's Executive Director ofOperations approved a Deviation Memorandum which provided additional NRCinspection and oversight of Peach Bottom security beyond what would normally beprescribed by the reactor oversight process.Attachment B contains the detailed chronology associated with this issue.2.0Augmented Inspection Follow-up Objectives (93800)This inspection was conducted to provide additional NRC review and significancedetermination of performance issues identified by the NRC Augmented Inspection Team. The specifics reviewed by the follow-up inspection team and previously documented inthe AIT inspection report (IR 05000277/278-2007404) were:*Root cause analysis and extent of condition (Section 3.1) *Corrective actions for identified security officer concerns (Section 3.2) *Security officer inattentiveness and extent of condition (Section 3.3) *Effectiveness of security management and supervisory oversight (Section 3.3)*Behavioral Observation Program effectiveness (Section 3.3) Enclosure23.0AIT Follow-up Inspection Team Findings and Observations3.1Review of Exelon Root Cause Analysis and Extent of Condition

a. Inspection Scope

The team assessed the adequacy of the licensee's initial evaluation of the issue, thethoroughness of the licensee's root cause analyses, and whether the corrective actionsspecified were sufficient to prevent recurrence (see Section 3.2). This assessmentincluded a review of the licensee's investigation reports (IR), root cause analyses,completed and scheduled corrective actions, procedures, additional related documents,and interviews with key plant personnel.The team reviewed the methodology and results of Exelon's root cause analysis asdocumented in the root cause report (IR 673505), "Security program degradation due toinattentiveness." Additionally, the team reviewed the root cause analysis to determine ifExelon had appropriately identified the extent of condition to ensure that the scope andstation-wide applicability of any performance issues were appropriately evaluated.

b. Findings and Observations

The team found the level of detail of the root cause analysis, including its extent ofcondition review, to be thorough and acceptable with a self-critical review of the stationand its management of security. The team concluded that Exelon appropriatelyidentified the root and contributing causes.The analyses used several formal systematic processes to identify root and contributingcauses. Per LS-AA-125-1001, "Root Cause Analysis Manual," Exelon formed a rootcause team consisting of a Mid-Atlantic corporate manager as the lead, supported by anExelon fleet security manager, a PBAPS human performance manager, site regulatoryand licensing personnel, and three external consultants. Time line analysis, cause andeffect analysis, and barrier analysis methodologies were utilized. The root cause teamappropriately evaluated information including past history and industry experience alongwith interviews of personnel conducted by Exelon's incident investigation team. 3.2Review of Corrective Actions

a. Inspection Scope

The inspection team reviewed security condition reports, employee concerns programfiles, station cultural surveys and Exelon's root cause analysis on inattentive securityofficers to assess whether the PBAPS adequately identified security adverse conditions, Enclosure3including missed opportunities to identify unacceptable SO behavior, prior to beinginformed of the videotapes in September 2007. The team conducted interviews and reviewed corrective actions associated withprevious adverse security conditions to determine whether the actions taken by thestation properly identified and evaluated causes of the problems. The team reviewedsecurity condition reports for repetitive problems to determine whether previouscorrective actions were effective. The team also reviewed the timeliness of theimplementation of corrective actions and the effectiveness of corrective actions topreclude recurrence for significant conditions adverse to quality.

b. Findings and Observations

The team concluded that, following September 2007, Exelon has implemented ordeveloped appropriate corrective actions to prevent recurrence that address theprinciple areas of: 1) Exelon management not providing adequate contractual oversightand leadership; 2) Wackenhut failure to provide adequate management and supervisoryoversight; and, 3) security officer inattentiveness and non-compliance with the BOPwithin the PBAPS security organization.The team also concluded that Exelon's Corrective Action Program (CAP), prior toSeptember 2007, had not been an effective tool in addressing the adverse conditionsand trends which led to SO inattentiveness. The team determined that there wereseveral missed opportunities in the area of security problem identification and resolutionprior to the inattentive security officer events being made public in September 2007. The team determined that these opportunities, while not primary causal factors for theinattentive security officer events, indicated an adverse performance trend in the PBAPSsecurity organization. The following were examples of these missed opportunities: 1) the results of two safety culture surveys were not properly evaluated for indications ofnegative performance trends in the security organization; 2) longstanding environmentalissues in the ready room were not properly evaluated and resolved; and,3) attentiveness aids for security officers were not properly evaluated in the CAP. Theteam concluded that following September 2007, the corrective actions implemented orplanned by Exelon for these CAP shortcomings were appropriate. Issues involving inadequate corrective actions can be treated as findings in their ownright, however, the above stated examples of ineffective corrective actions and CAPshortcomings directly contributed to the inattentive security officers and ineffective BOPperformance deficiencies for which a preliminary greater than Green finding is discussedin Section 3.3 of this report. As such, these contributing causes and relatedperformance deficiencies were not treated as separate findings.

43.3Review of Security Officer Inattentiveness and Behavior Observation Program

a. Inspection Scope

The team conducted interviews and observations of the security organization todetermine the overall security program effectiveness and implementation during the timeframe of the inattentive security officer events. The team reviewed the Security Plan andevaluated PBAP's ability to implement Security Plan requirements. The team performedwalk downs of the site's protective strategy to evaluate the potential effect of degradedsecurity officer response due to inattentiveness. The team also evaluated critical SOdefensive position response times, for a variety of potential threats, to evaluate thepotential significance of SO inattentiveness on Security Plan effectiveness. The team reviewed Exelon's and Wackenhut's actions preceding September 2007, toassess the effectiveness of management and supervisory oversight and theirengagement with the station security organization. The team evaluated managementand supervisory inadequacies that may have contributed to the inattentiveness and BOP performance issues present in the security organization.The team reviewed implementing procedures for the BOP, the FFD program, and relatedtraining. Interviews were conducted to evaluate the level of understanding of theseprograms by the security officers and supervisors. The team reviewed records related toself reporting fatigue, work hours, deviations from normal work hours, testing for cause,and Employee Assistance Program utilization.

b. Findings and Observations

Introduction:

A self-revealing preliminary greater than Green finding was identified forfailure to maintain the minimum required number of available responders and theassociated failure to maintain an effective behavior observation program.Description: On four separate occasions (March 12; June 9; June 20; and August 10,2007), multiple security officers, who were all members of the security response team,were videotaped while they were inattentive in the security ready room. On March 12,2007, five officers were inattentive at the same time. The ready room is a location withinthe protected area boundary where officers are staged for response functions, while notconducting security patrols. The officers in the ready room are required to be readilyavailable to respond and effectively implement their role within the Security Plan'sprotective strategy.In addition, the Behavior Observation Program (BOP) was determined to be ineffective. Security officers are required to self-report to supervision when they feel fatigued andwhen they observe others who are fatigued. Although the security officers in the readyroom were in close proximity to each other, only one stated that he reported othersecurity officers being inattentive. Supervisors who had information regarding Enclosure5inattentive security officers failed to take appropriate action, as required by the BOP. The ineffective implementation of the BOP was directly linked to the events of inattentiveofficers. An effective BOP could have mitigated the inattentive officer events.The team's interviews with a number of security force members identified that securityofficers were discouraged from bringing forward safety concerns to supervision. Thesecurity officers stated that they did not raise safety issues, such as these involvinginattentive officers, because they were afraid of an adverse consequence. Based uponthese interview results, the team concluded that an adverse safety conscious workenvironment (SCWE) was a contributing cause to the finding.As discussed in Section 3.2.b above, Exelon and Wackenhut management/supervisionfailed to properly evaluate attentiveness aids for officers, failed to adequately addressenvironmental issues associated with the ready room, failed to conduct adequate andeffective post checks, and failed to ensure effective radio checks were conducted. Some of these issues were raised during previously conducted security officer surveys,but no effective action was taken to address these security-officer-identified concerns. The follow-up team concluded that each of these issues was a contributor to theinattentiveness events.The team determined that the licensee's failure to maintain the minimum number ofresponse team members and the associated failure to maintain an effective BOPconstituted a performance deficiency.

Analysis:

This performance deficiency is greater than minor because it is associatedwith the Physical Protection Cornerstone attributes of Response to Contingency Eventsand Access Authorization, and affected the cornerstone objective to provide assurancethat the licensee's security system and material control and accountability program usea defense-in-depth approach and can protect against (1) the design basis threat ofradiological sabotage from external and internal threats, and (2) the theft or loss ofradiological materials. Specifically, an inadequate BOP was a direct contributor to theinattentive responders. With multiple inattentive response team members at one time,the minimum numbers of available responders was adversely impacted. This affectedthe defense-in-depth strategy and increased the potential for degradation in theprotective strategy for the site.The team reviewed IMC 0609, Appendix E, "Baseline Physical Protection SignificanceDetermination Process (PPSDP) for Power Reactors," for security findings. Using thePPSDP, the team determined that the finding was of more than very low securitysignificance (i.e., preliminary greater than Green). The PPSDP takes into considerationthe security cornerstone key attributes, various levels of defense-in-depth, andprioritized elements of security programs to determine the significance of findings. Thedetails of the PPSDP analysis contain sensitive security information and will not bemade publicly available. The analysis is included as a security sensitive attachment tothis report (Attachment C).

6This finding has a cross-cutting aspect in the area of SCWE (S.1.a) because Exelon andWackenhut supervision did not encourage the free flow of information related to raisingsafety concerns. Security supervisors who had information regarding inattentive officersdid not respond to employee safety concerns in an open, honest, and non-defensivemanner. This finding also has a cross-cutting aspect in the area of human performance(H.4.c) because Exelon did not ensure that supervisory and management oversight ofsecurity activities supported nuclear safety. The team concluded that, followingnotification of the inattentiveness issues by the NRC, Exelon's root cause analysisappropriately identified weaknesses in the station's security management andsupervisory oversight and SCWE.Enforcement: The enforcement aspects of the security officer inattentiveness andineffective BOP issues are still under NRC review. Upon completion of this review,enforcement action will be considered, consistent with the Enforcement Policy. Thesafety significance of this finding is preliminarily greater than Green. (FIN05000277/278, 2007405-01, Failure to Maintain Minimum Available Responders and anEffective BOP.)4.0MeetingsExit Meeting SummaryOn December 3, 2007, the inspection team presented the inspection results at a publicexit meeting to Mr. Joseph Grimes and other members of the PBAPS staff. Exelonacknowledged the team's findings.

A-1ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. GrimesSite Vice PresidentP. CowanDirector, Licensing and Regulatory AffairsD. DeboerSecurity ManagerS. CraigSecurity Operations SupervisorJ. MallonLicensing Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened05000277/278-2007405-01FINFailure to maintain minimum numberof responders and an effective BOP(Section 3.3)

LIST OF DOCUMENTS REVIEWED

ProceduresLS-AA-125, "Corrective Action Program Procedure," Revision 11SY-AA-1016, "Watchstanding Practices," Revision 0SY-AA-1016, "Watchstanding Practices," Revision 4SY-AA-1020, "Supervisor Post Checks and Post Orders," Revision 0SY-AA-1020, "Supervisor Post Checks and Post Orders," Revision 1SY-AA-102, "Exelon's Nuclear Fitness-For-Duty Program," Revision 11SY-AA-101-130, "Security Responsibilities for Station Personnel," Revision 8SY-AA-101-130, "Security Responsibilities for Station Personnel," Revision 9SY-PB-101-124-1001, "Security Control Center Operations," Revision 3SY-AA-101-126, "Duties and Responsibilities of the Station Security Organization," Revision 5SY-AA-103-513, "Behavioral Observation Program," Revision 6SY-AA-150-1001, Security Training and Qualification Manual, Revision 3

A-2MiscellaneousNER

NC-07-034, "Inattentive Security Officer Investigation Fleet Actions," September 24, 2007NER

NC-06-010, "Increased Field Observation and Coaching of the Site Security Force,"Revision 2SA-07-06, "NRC Security Advisory - Security officers inattentive to duty," September 27, 2007Nuclear Oversight Quarterly Reports, 2005 - 2007NOSA-PEA-06-02, Security Plan, FFD, and Personnel Access Data System, February 1, 2006NOSA-PEA-07-03, Security Plan, FFD, and Personnel Access Data System, January 21, 2007Exelon General Employee Training, FFD Module, Revision 4Exelon's Security Transition Plan, September 24, 2007Card Reader Transaction History 3/11-12/07 - 6/09/07 - 6/20-21/07 - 8/10/07Vital Area Patrol Forms Fox 2/3/5/6/7Drill/Exercise Reports 2006 (4th Qtr) - (2007 1st Qtr-3rd Qtr) (All Teams)Weekly Work Hour Averages from March 4, 2007 through October 28, 2007

LIST OF ACRONYMS

ADAMSAgency-wide Documents Access and Management SystemAITAugmented Inspection TeamBOPBehavioral Observation ProgramCAPCorrective Action ProgramCFRCode of Federal RegulationsCRCondition ReportFFDFitness For DutyIMCInspection Manual ChapterIPInspection ProcedureNERNuclear Event ReportNRCNuclear Regulatory CommissionNSIRNuclear Security and Incident ResponsePARSPublicly Available RecordsPBAPSPeach Bottom Atomic Power StationPPSDPPhysical Protection Significance Determination ProcessSCWESafety Conscious Work EnvironmentSDPSignificance Determination ProcessSOSecurity OfficerWNSWackenhut Nuclear Services B-1EVENT

CHRONO [[]]

LOGY *2004 -

PBAPS security power block "ready room" established to support Security Planimplementation and provide increased defense-in-depth for

NRC Force on Forceexercises.*April 16, 2006 - NRC Force-on-Force exercise conducted (No findings).

January 2007 - Wackenhut Corporation issues improvement plan for Safety ConsciousWork Environment (SCWE) improvement actions for its security forces at all sites.*February 2007 - Security Officer (SO) responsible for video recordings has firstobservation of inattentive

SO s in the power block ready room but did not record theobservations.*March 2, 2007 -

SY -AA-1016, Revision 4, implemented to add 'attentiveness tools'based on attentiveness issue experienced at an Exelon plant.*March 12, 2007 - Five

SO s inattentive to duty in the ready room captured by a

SO 'spersonal cell phone. All five

SO s are on Security Team No. 1.*March 27, 2007 -

NRC receives concerns involving Peach Bottom

SO s that areinattentive to duty at

PBAPS. *April 2007 -

SO shows videotapes of inattentive

SO s to a maintenance technician at alittle league ball game. Maintenance technician tells the

SO to inform his securitysupervisor. The following day the maintenance technician informs his supervisor whoresponds that the

SO 's concern should be brought up to the security supervisor. *April 2007 - Wackenhut Corporate investigation reveals two separate

SO unacceptablebehavior issues received through Wackenhut Safe-2-Say program. In the course of thisinvestigation, it was determined by Wackenhut that multiple

SO [[s on Team No. 2 wereinitially untruthful to investigators and tried to hide and cover-up the events. Severalofficers were disciplined for their lack of candor and not reporting a safety concern. *April 18, 2007 - Plant review committee rejects $150K expense of further renovations to"ready room."]]

PBAPS senior management notified of decision to not fundimprovements.*April 30, 2007 -

NRC provided Exelon management with written referral for concernsassociated with Peach Bottom

SO s that were inattentive to duty. B-2*May 30, 2007 -

NRC received Exelon's response stating the three referred concernsassociated with inattentive

SO [[behavior were not substantiated. Exelon conductedinterviews that did not substantiate the issue. Exelon referenced enhancements in theirresponse that included radio check improvements and procedure changes to implementfixed post checks twice a shift. Exelon also referenced 15 minute stand-ups on backshifts and randomly on day shift.*June 9, 2007 - Three]]

SO s inattentive on-duty in the "ready room" captured by a

SO 'spersonal video device (

ARCOS camera).*Mid June 2007 -

SO "informs a field supervisor of inattentive guards on duty that werevideotaped. Field supervisor told lead supervisor of this information including names ofguards who were inattentive to duty on video.*Late June 2007 - Security shift supervisor and [[Atomic Element" contains a listed "[" character as part of the property label and has therefore been classified as invalid. supervisor of Team No. 1 inform]]

SO to stop bringing video devices into the plant's protected area.*July 19, 2007 - Security force transitions to new "ready room" that is considered largerand a more moderate temperature. *June 20, 2007 - One

SO inattentive on duty in the "ready room" captured by a

SO 'spersonal cell phone.*August 10, 2007 - Three

SO s inattentive on duty in the "ready room" captured by apersonal cell phone.*August 22, 2007 -

NRC reviews Exelon response that did not substantiate inattentiveSOs.

NRC considers Exelon response acceptable after follow-up questions. *August 28, 2007 - Exelon Corporate nuclear safety review board identified Wackenhutperformance as an area for improvement fleet-wide.*September 10, 2007 -

NRC received and verbally referred concerns to Exelon based onWCBS-TV (New York) telephone call with information about videos that showsinattentive

SO s on shift at Peach Bottom.

NRC resident inspectors begin enhancedsecurity inspections by performing increased number of observations at various securityposts during both normal and backshift hours. *September 10, 2007 - Exelon forms an Issues Management Team based on

NRC information passed verbally. Exelon briefed

PBAPS [[security force regarding heightenedawareness, fatigue, and responsibilities to report inattentiveness.*September 11, 2007 - Exelon briefed their fleet security regarding heightenedawareness, fatigue, and responsibilities to report inattentiveness. B-3*September 15 - 20, 2007 - Exelon corporate security interviews approximately 95percent on-site members of Wackenhut organization at Peach Bottom.*September 17, 2007 -]]

SO [[responsible for videotaping inattentiveness has unescortedaccess suspended because of trustworthiness concerns and procedure violations.*September 17, 2007 - Maintenance technician acknowledged after a site communicationon inattentiveness that he had knowledge of a]]

SO who taped inattentive

SO s on dutyand showed him the videos.*September 17, 2007 - Exelon is contacted by

WCBS-TV.

September 18, 2007 -

NRC received and verbally referred inattentive

SO concerns thatwere received based upon telephone conversation that specified "ready room" as areaof concern for inattentive

SO s.*September 18, 2007 - Letter from President - Wackenhut Nuclear Services (

WNS [[), toWNS security force emphasizing fitness for duty and fatigue standards.*September 18, 2007 - Exelon makes decision for outside legal counsel to take overinvestigation in response to allegations. Exelon issues first press release at 11:00 am. *September 19, 2007 -]]

NRC views

WCBS -TV videotapes and initiates

AIT charter.

NRC verbally refers to Exelon additional information to be considered in their investigation.*September 19, 2007 - Exelon management and Wackenhut establish enhanced securityoversight at

PBAPS. [[Additional Wackenhut supervision brought in providing 24-houroversight and observation.*September 20, 2007 - Exelon implements 24-hour on-site security supervision in the"ready room." Additionally, on-site Wackenhut supervision providing enhanced oversightand observation.*September 20, 2007 -]]

NRC informs Exelon that an

AIT will be dispatched to PeachBottom the following morning to begin inspection on the security events surroundinginattentive

SO s.

NRC issues press release announcing the augmented inspection at

PBAPS for inattentive

SO concerns.*September 21, 2007 -

WCBS -TV supplies Exelon with videos for viewing. Exelonconfirms that videos contain Peach Bottom

SO s in the "ready room." B-4*September 21, 2007 -

NRC commences

AIT and arrives on site for inattentive

SO events.*September 21, 2007 - Letter from Exelon to

NRC Regional Administrator highlightingExelon's efforts to immediately address

SO inattentiveness concerns and current fact-finding investigative efforts.*September 21, 2007 - Nine

SO s inattentive to duty placed on administrative holdpending outcome of investigation.*September 22, 2007 -

NRC Region I security inspectors supplement resident staff inconducting backshift inspection and observation of the security posts and compensatorymeasures throughout the weekend until full

AIT arrives on-site.*September 24, 2007 - Exelon initiates termination of Wackenhut security contract atPeach Bottom. *September 24, 2007 - Exelon issues

NER [[]]

NC -07-034 to fleet for mandatory fleet actionsin light of inattentive

SO [[issues at Peach Bottom.*September 25, 2007 - Exelon places remainder of Security Team No. 1 onadministrative hold pending outcome of investigation.*September 25, 2007 - Exelon issues an Operations Experience item regarding SecurityOfficers Inattentive to Duty on the]]

NEI security web site*September 26, 2007 - Exelon announces transition of security force from Wackenhut toa proprietary guard force (Exelon).*September 27, 2007 - Exelon enhances compensatory measures for

BREs.

September 27, 2007 -

NRC issues advisory

SA-07-06 regarding Security OfficersInattentive to Duty.*September 28, 2007 - AIT completes on-site portion of inspection.

October 4, 2007 -

NRC [[issues letter to Exelon requesting the actions taken or planned toassure the following: (1) security officers remain attentive at all times while on duty in allrequired locations at the facility; (2) security officers are both willing and able torecognize instances of inattentiveness and promptly take all appropriate actions; (3)supervisors and personnel take the necessary actions to encourage officers and all plantstaff to bring forward any concerns, including indications of inattentiveness, andpromptly address such concerns when raised; and (4) inattentiveness does not extendto other departments or contractors at Peach Bottom. The]]

NRC also requested thatExelon address why this issue was apparently not self-identified. B-5*October 4, 2007 - Letter from Exelon to

NRC Regional Administrator describingpreliminary results of investigation, additional interim actions taken, and actions plannedfor the near term.*October 9, 2007 -

NRC conducted a public exit for the

AIT inspection. A public questionand answer session was held following the exit meeting.*October 19, 2007 -

NRC issued Confirmatory Action Letter (CAL -

ML 072920283) toensure continued security plan effectiveness.*October 24, 2007 -

NRC instituted a weekly status call with Exelon concerning

CAL actions and the status of transitioning from a contract security force to an Exelon force.*November 1, 2007 - Peach Bottom transitioned to an Exelon security force.

NRC enhanced monitoring included observation of the transition, attendance at shift turnovermeetings, and interviews with selected officers.*November 2, 2007 - Exelon responded to

NRC October 4, 2007, inattentiveness letteron the docket (

ML 073180128).*November 5, 2007 -

AIT inspection report issued (