Information Notice No. 96-71: Licensee Response to Indications of Tampering, Vandalism, or Malicious Mischief

UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, DC 20555-0001

December 27, 1996


Information Notice No. 96-71:  LICENSEE RESPONSE TO INDICATIONS OF                                          
                                   TAMPERING, VANDALISM, OR MALICIOUS MISCHIEF


Addressees

All holders of operating licenses or construction permits for nuclear power
reactors.

Purpose

This information notice is being issued to alert licensees to the benefits of
planning a response to indications of tampering, vandalism, or malicious
mischief.  It is expected that recipients will review the information for
applicability to their facilities and consider actions, as appropriate. 
However, suggestions contained in this information notice are not NRC
requirements; therefore, no specific action or written response is required.

Description of Circumstances

Recent events at operating reactors indicate that some licensee personnel may
not recognize the potential significance of early indications of potential
tampering, vandalism, or malicious mischief.  As a result, licensee response
may be untimely and of limited scope and depth.  Failure to promptly question,
resolve the significance and implement an appropriate strategy to mitigate the
consequence of a potential tampering, vandalism, or malicious mischief
situation, could leave the plant in a vulnerable state for a significant
period of time.  Lack of detailed planning, procedures, and training
frequently plays a role in the quality of response to these events.  Brief
accounts of two events illustrate the issue:

Improperly Positioned Valve at Beaver Valley

During the conduct of a quarterly surveillance on Friday, July 14, 1995, to
verify the position of certain safety-related locked valves; the licensee
determined that the service water cross-connect valve at the discharge of the
recirculation spray heat exchanger was in the incorrect position (shut in lieu
of open), that the chain used to secure the valve in the proper position had
been cut, and that the lock appeared to have been placed back on the chain in
a manner that made it difficult to detect the condition.  The licensee's staff
initially assumed the valve had been inadvertently mispositioned during
earlier operational evolutions, but subsequent interviews and analysis were
unable to confirm this assumption.


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Licensee management first learned of the event on Tuesday, July 18, 1995. 
Consequently, licensee management was not able to oversee the licensee
evaluation of the event until considerable time had elapsed.  The licensee's
determination that potential tampering could not be ruled out was not made
until six days after the incorrect valve position was identified.  Thorough
valve lineup checks and locked valve surveillances were not completed for both
Beaver Valley units until after the plant staff made an emergency notification
system (ENS) call on Thursday evening, July 20, 1995.  The similarity of this
event to an event in the early 1980s heightened the concern of both licensee
and NRC personnel who knew of the previous events.

Misadjusted Valves and Disabled Locks at St. Lucie

In May 1996, St. Lucie personnel identified two pressure-relief valves which,
when tested, were found to have pressure setpoints 55 percent and 9 percent
above their design values.  These valves also had broken wire seals.  The root
cause could not be determined.  Although tampering could not be ruled out, it
was concluded that the more likely cause for the misadjusted valves was poor
maintenance.  Licensee management decided to alert the Security force;
however, site Security was not notified.  The failure to follow through on
alerting site Security precluded coordinated actions of Operations and
Security staffs to enhance awareness to other possible tampering events.

On July 26, 1996, St. Lucie staff identified nine padlocks and two door locks
in vital areas that were intentionally damaged to inhibit opening the locks. 
These locks controlled personnel access to various pieces of plant equipment. 
The licensee did not identify keylock switches as needing to be checked;
consequently, these switches were not checked until August 1996.  Although the
tampering of components within a vital area indicated the need to be alert to
additional tampering, other than alerting Security, the licensee failed to
consider additional measures to detect tampering.  On August 14, 1996, St.
Lucie staff identified three additional examples of tampering in vital areas
that inhibited the opening of locks associated with safety-related equipment. 


Discussion

The following factors may have contributed to these events:

(1)     The licensees' contingency plans required by 10 CFR 73.55(h)(1) and the
        implementing procedures required by Appendix C to Part 73 did not
        adequately address tampering, vandalism, and malicious mischief.  Other
        licensee procedures touched some aspects of these situations; however,
        no plan or process was used to evaluate the potential malevolent event
        and determine its importance.  Factors such as safety significance,
        overtness, intent, sophistication of method, and the history of similar
        incidents were not considered.  Information Notice 83-27, "Operational
        Response to Events Concerning Deliberate Acts Directed Against Plant
        Equipment," described events in which licensees were not prepared to
        assess the situation and take necessary steps to ensure the operability
        of systems important to safety or make decisions concerning continued
        operation.  The information notice indicated that guidelines or
        procedures prepared by the licensee outlining a process of .                                                             IN 96-71          
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        following up on both deliberate and inadvertent acts with respect to
        plant operation should be available.

(2)     The licensees' actions were limited in scope and depth, at least
        initially, in pursuing the events.

(3)     The licensees' Operations staff were not sensitive to abnormalities
        identified earlier and apparently assumed no malice.  Since the
        Operations staff may be the first to encounter signs of tampering,
        vandalism, or malicious mischief during its tours and surveillance
        activities, sensitivity to precursors plays a key role in timely
        response to events of this nature.  Therefore, licensees may wish to
        periodically refresh their Operations staff's sensitivity to and
        awareness of the evaluation process to ensure effective response to
        these acts.

(4)     The licensee's Security staff was not told about these problems until
        well into the sequence of events at St. Lucie.  Security's ability to
        identify the perpetrator(s) and institute other protective measures
        diminishes severely as time elapses.

Events of this nature are required by Appendix G to Part 73 of 10 CFR to be
reported to the NRC Operations Center within one hour of discovery.

This information notice requires no specific action or written response.  If
you have any questions about the information in this notice, please contact
one of the technical contacts listed below or the appropriate Office of
Nuclear Reactor Regulation project manager.



 
                                Thomas T. Martin, Director
                                Division of Reactor Program Management         
                                Office of Nuclear Reactor Regulation

Technical contacts:  Loren Bush, NRR
                     (301) 415-2944
                     E-mail:  llb@nrc.gov

                     David Skeen, NRR
                     (301) 415-1174
                     E-mail:  dls@nrc.gov

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