IR 05000261/1998010
| ML14181B018 | |
| Person / Time | |
|---|---|
| Site: | Harris, Brunswick, Robinson  |
| Issue date: | 06/29/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14181B017 | List: |
| References | |
| 50-261-98-10, 50-324-98-12, 50-325-98-12, 50-400-98-12, NUDOCS 9807080254 | |
| Download: ML14181B018 (14) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos:
50-325, 50-324, 50-400, and 50-261 License Nos:
DPR-71, DPR-62, NPF-63, and DPR-23 Report Nos:
50-325, 324/98-12, 50-400/98-12, and 50-261/98-10 Licensee:
Carolina Power & Light Company Facilities:
Brunswick, Harris, and H. B. Robinson Nuclear Plants Location:
Carolina Power & Light Company P. 0. Box 1551 Raleigh, North Carolina 27602 Dates:
June 1-4, 1998 Inspector:
D. Thompson, Safeguards Inspector Approved by:
George A. Belisle, Chief Special Inspection Branch Division of Reactor Safety 9807080254 980629 PDR ADOCK 05000261 G
EXECUTIVE SUMMARY
Brunswick, Harris, and H. B. Robinson Nuclear Plants 50-325, 324/98-12, 50-400/98-12 and 50-261/98-10 This special announced inspection was conducted in the area of Plant Support by a regional safeguards specialist. The specific areas evaluated were the Access Authorization (AA) and Fitness For Duty (FFD) programs.
The inspector noted that extensive corrective actions had been implemented and activities at the Corporate Office relating to the current AA and FFD programs wereconsidered excellent. The licensee had currently implemented and staffed an organization that was very capable of managing and implementing the AA and FFD program requirements.
(Section S1.2)
Based on review of the licensee's newly developed training program, AA Procedures, Desk Top Instructions, records, and interviews with personnel responsible for administering and implementing the AA and FFD programs, the inspector concluded that the licensee's sites were currently very capable of continuing to provide assurance that the personnel who were granted unescorted access to the nuclear facilities met regulatory requirements.
(Section Si.2.1)
The inspector concluded that the FFD organization and management control systems met regulatory requirements and that the recent changes did not adversely affect the FFD program. FFD personnel were aware of their individual responsibilities and were trained to perform their intended functions.
(Section S1.3)
The licensee's AA/FFD audits were complete and effective in terms of uncovering weaknesses in the AA/FFD programs, procedures, and practices.
The inspector.determined that audit items were reviewed, appropriately assigned, analyzed and prioritized for corrective action. The corrective actions were technically adequate and performed in a timely manner. The AA/FFD audits were considered a strength. (Section S1.3.2)
REPORT DETAILS
S1.2 Access Authorization S1.2.1 Program Administration and Implementation
a. Inspection Scope
(81700)
The inspector determined how the Access Authorization (AA) program was administered including applicable organizational and contractor responsibilities.
b. Observations and Findings
The NRC conducted an inspection of the AA and Fitness For Duty (FFD)programs, June 1-4, 1998. as a followup to the licensee's corrective actions to Violations identified in NRC Inspection Report Nos. 50-325/
97-01, 50-324/97-01, 50-400/97-02; 50-400/98-02 and 50-261/97-02. The following corrective actions were initiated by the licensee and verified, by the inspector:
-
Disciplinary action was taken for involved personnel.
-
The interview results form used by the psychologist was redesigned to more clearly differentiate between recommendations to grant unescorted access and recommendations to deny or hold in abeyance unescorted access.
-
The AA procedures were revised to require a first and second (independent) review of background files prior to the granting of unescorted.access.
-
-The Personnel History Questionnaire form was enhanced.
-
Corporate Security hired additional experiencedAA personnel.
-
The practice of having the supervisor, AA (or designee), audit samples of background reviewers' completed background investigation (BI) reviews has been proceduralized.
-
Errors identified during independent and management reviews were documented and evaluated for trends and personnel performance.
The formal AA training program has incorporated discussions of lessons learned from the event occurrences (reviewer errors) and management emphasis on the importance of quality job performance over other nonquality affecting factors, including quality of access file reviews over badge need dates.
Carolina Power and Light Company's (CP&L's) expectations were reinforced to AA personnel regarding applicable NRC regulations and governing procedures used to determine suitability of unescorted access at CP&L's nuclear facilities. Background investigations were reviewed by the manager, Corporate Security, until the training was completed. Retraining was completed on August 2, 1996.
Management stressed both the expectations and the importance of procedural compliance and attention to detail. This was communicated on August 5, 1996.
On August 12, 1996, CP&L's expectations for performing best-effort suitable inquiries and additional.CP&L's expectations were issued to the background agencies. By October 30. 1996, contracts with background agencies were revised to include more detailed.
requirements.
Access Authorization performed an audit of the BI files of personnel badged as of July 31, 1996. This audit was completed on November 8, 1996. A total of approximately 3,427 records were reviewed and assessed in accordance with Nu!clear Energy Institute (NEI) guidance.
Examples of some deficiencies identified during this review include missing fingerprint records, psychological testing documentation, credit interview documentation, contractor "request for unescorted access" documentation, and discrepancies in the-BI content. The identified discrepancies were corrected and 203 were logged in the applicable plant Security Safeguards EventLog.
On March 12, 1997, a subsequent Corporate Security review of.BIs identified a file which was missing a fingerprint card. It was determined that this file was included as part of the audit completed November 8, 1996.' Further investigation identified that 102 files included in the original audit had received only a partial review, and 12 files had received no review. A condition report was initiated to investigate why this occurred with the initial review.
The 114 files were reviewed and assessed in accordance with NEI guidance and 111 were determined to be acceptable. Three files were
missing fingerprint cards. Carolina Power and Light computerized fingerprint tracking system indicated that the original access criminal histories, provided by the FBI, had no derogatory information on these individuals. Corrective actions for these discrepancies were identified and completed by March 14, 1997.
The BI review process procedure and desk instructions were revised by July 25, 1996, to require reviewers to place particular emphasis on access reinstatements for confirmation of prior periods of access. The procedure and desk instructions are SEC-NGGC-2101, "Nuclear Worker Screening Program For Unescorted Access," AA-DI-07, "Nuclear & Employment Clearance -Processing," and AA-DI-08, "Clearance Transfers."
Ongoing periodic assessments of BIs were added as part of the annual AA self-assessment plan. This item was completed November 13, 1996.
A training program on AA and FFD was developed including classroom and task specific requirements. The training program procedure was approved December 31, 1996. The AA background review personnel have completed this training. Additionally, NGGS-SEC-0004, "Access Authorization, Fitness For Duty, and Occupational Health Screening Personnel Training Skills Development and Certification Program" Revision 1, effective March 27, 1997, requires newly hired AA/FFD personnel to complete the training prior to assuming job responsibilities.
The AA processes and interfaces were evaluated, and procedures revised on October 11, 1996. An internal CP&L evaluation of the AA/FFD organization was completed on.December 27, 1996. These recommendations have been reviewed and accepted by AA/FFD management.
Applicable instructions and procedures will be revised to improve the effectiveness of the FFD work processes. Fitness For Duty collectors will be provided with additional training, and Plant Access Authorization lead personnel will receive training in work scheduling, organization, and planning skills. These actions will be completed by July 31, 1997.
As part of the background review, the inspector noted that in April 1994, the AA and FFD programs were organized and staffed with managers, and a decision was made to centralize the AA and FFD functions at the Corporate Office. From April 1994 to February 1995, the licensee established the plant in-processing facilities, developed a Computerized Access Tracking System (CATS), and moved Health Screening into AA. In September 1994, the licensee also initiated a transition from using self-screening contractors to a licensee function in January 1995.
Procedure SEC-NGGC, "Nuclear Worker Screening Program for Unescorted Access," Revision 5, provided guidance for grandfathering, reinstating, updating, transfer, and granting temporary access. This procedure was reviewed by the inspector and found to be well-written and to have clearly defined the licensee's program requirements and regulatory requirements. However, the licensee continued to refine and attempted to centralize both FFDand AA program requirements into single documents.
The AA and FFD programs were organized under the manager of Corporate Security. According to the organizational chart, the superintendent of the AA position has the supervisor AA program and the senior support analyst for FFD reporting to him.
During the inspection, the superintendent was found to be experienced and fully capable of administering their portion of the programs. The staff was interviewed during the inspection and found to have been well-trained and capable of performing the specific requirements they are tasked to perform.
Although the AA and FFD programs had been centralized at the Corporate Offices, the licensee continued to use outside screening agents to conduct the BIs and credit checks. The licensee had reviewed the outside screening agent's programs to ensure that they met requirements.
c. Conclusion The inspector noted that extensive corrective actions had been implemented and.activities at the Corporate Office relating to the current AA and FFD programs were considered excellent. The licensee had currently implemented and staffed an organization.that was very capable of managing and implementing the AA and FFD program requirements.
S1.2.2 Background Investigations (BI) Elements
a. Inspection Scope
(92904)
The inspector reviewed the BI elements and verified that the program had been adequately designed and implemented in accordance with the licensee's approved plans and procedures.
b. Observations and Findings
The inspector determined that the licensee could verify true identity and develop information concerning employment, education, credit, criminal history, military service, and the character and reputation of
.individuals prior to granting unescorted access to protected and vital areas.
The inspector requested and received approximately 40 background files from the licensee. The inspector reviewed some files and at his request, licensee personnel responsible for first and second review activities demonstrated how they reviewed and validated the background, FFD, MMPI, and vehicle driving record information prior to granting unescorted access.
The files were found to be complete and the clearance granting information thoroughly reviewed before access was granted.
The inspector reviewed the licensee's newly developed training program, AA procedures, Desk Top Instructions, records, and interviews with personnel responsible for administering and implementing the AA/FFD programs, the inspector concluded that with current practices, the licensee i.s very capable of continuing to provide assurance that the personnel who were granted unescorted access to the nuclear facilities met regulatory requirements. Therefore, violations 50-325, 324/97-01-01, 50-325, 324/97-01-02, 50-325, 324/97-01-03, 50-261/97-02-01, 50-400/97 02-01, 50-400/98-02-01, and 50-400/98-02-02 were closed.
The inspector also reviewed the licensee's actions related to Licensee Event Report (LER) 50-400/98-S01-00, dated March 2, 1998, concerning a contractor who falsified his Personnel History Questionnaire (PHQ) and was granted temporary unescorted access from March 21, 1997 through May 20, 1997. The inspector determined that the licensee was unaware of the falsification of the PHQ until the fingerprints were returned. The individual had falsified information five times on the initial PHQ. Had the licensee been aware of the all background information, they would have denied unescorted access as required by their procedures. Based on the information concerning the falsification of the PHQ the inspector determined that the individual by falsifying the PHQ caused the licensee to be in non-compliance; however, the licensee when they became aware of the situation took appropriate actions. The individual has been identified *in the Personal Access Data System to preclude his gaining access to other nuclear facilities. Based on the inspectors review, LER 50-400/98-SO1-00 was closed.
c. Conclusion The inspector reviewed the licensee's newly developed training program, AA procedures, Desk Top Instructions, records, and interviews with personnel responsible for administering and implementing the AA/FFD programs. The inspector concluded that with current practices, the licensee is very capable of continuing to provide assurance that the personnel who were granted unescorted access to the nuclear facilities met regulatory requirements.
S1.3 Fitness For Duty Program S1.3.1 Program Administration and Implementation
a. Inspection Scope
(81502. 92904)
The inspector ensured that the licensee developed procedures to be utilized in testing for drugs and alcohol, including procedures for protecting the employee and the integrity of the specimen, and the quality controls to ensure that the test results were valid and attributable to the correct individual.
b..Observations and Findings The inspector reviewed documentation and interviewed FFD managers and key personnel and determined that through the organizational changes-to the FFD program, individuals assigned the task to administer the FFD program were aware of the FFD program requirements and were capable of continuing to ensure that the FFD program was operated in accordance with regulatory requirements.
The inspector observed that the selection process for personnel to be tested under the FFD system continued to be administered at the Corporate Office. Fitness For Duty records were also maintained at the Corporate Office. While reviewing the FFD records at the Corporate Office, the
7. inspector noted that approximately 1924 personnel were processed in 1998
without any recordkeeping errors.
The inspector verified that the responsibilities and authorities of key personnel responsible for the FFD program were delineated in procedures as described above.
The medical review officer (MRO) continued to receive and review drug test results from the certified laboratory andidetermined if the results were positive or negative.
The inspector determi-ned, through discussion and review of available records, that the MRO has a great deal of experience and was actively involved in administering the FFD program and was very pro-active to ensure that CP&L plants were drug (illegal and legal) and alcohol free environments.
The inspector verified that the licensee delivers each notification for testing to the appropriate supervisor and instructs them to inform the individual no more than two hours before the test is scheduled. Review of documentation revealed that personnel were arriving at the laboratory for testing within their required time frame. The acceptable drug and alcohol cutoff levels were within regulatory requirements. The inspector observed one collection and noted that collection personnel were well aware of their responsibilities and each collection observed was conducted in a professional and efficient manner.
The inspector verified that the CP&L Brunswick Steam Electric Plant found and documented in Plant Condition Report No. 95-00569, event date, February 21. 1995. that two individuals were granted access beginning May 9, 1994 and April 26, 1994, respectively, without being included in the random drug and alcohol testing program. The corrective actions taken in response to this condition report included the following which were considered adequate to close the violation:
On February 21, 1995, the badges were placed in "lost status,"
thereby preventing unescorted access by subject individuals.
The individual.who was not included in the random testing pool beginning April 26, 1994, was drug.screened with the results evaluated as satisfactory by February 22, 1995.
According to the condition report, the individual who was not included in the random testing pool beginning May 9, 1994, was not on-site during this period, and unescorted access was terminated on February 28, 1995.
On February 22, 1995, an entry was made in the Brunswick Steam Electric Plant Safeguards.Event Log.
The badge prefix for the contract company was changed..
On August 4, 1995, a new computer system. was installed at Brunswick Steam Electric Plant which removes the alphabetic badge prefixes so this condition no longer exists.
Additionally, CP&L Brunswick Steam Electric Plant Condition Report No. 96-00891, dated March 5, 1996, documents the self-identification of the individual who was granted unescorted access according to the condition report from January 24, 1996 to March 4, 1996, without being included in the random drug and alcohol testing program. The individual's unescorted access was terminated on March 6, 1996, for reasons unrelated to AA/FFD requirements, prior to identification of this issue, and the individual has not since been granted unes.corted access to a CP&L nuclear facility. The following corrective actions taken in response to this condition report were completed by April 3, 1996:
-
It was determined that a program error occurred in CATS which terminated an individual's access in CATS thus removing the individual from the random pool.
-
An overlay report was written to detect any records that were
.impacted by the system error. This report was run to detect any other errors, and it was determined this incident was limited to the one occurrence.of this error affecting the random testing program.
The application was modified to add "data refresh" and "do events" to force the plant access screen in CATS to update transactions in the proper sequence.
-
The data overlay report is generally run on a weekly basis, at a minimum, to verify that the problem does not recur until it is determined that the problem no longer exists.
The inspector concluded that the FFD organization and management control systems met regulatory, requirements and that the recent changes did not adversely affect the FFD program. The FFD personnel were aware of their individual responsibilities and were trained to perform their intended functions. Therefore, violations 50-325, 324/97-01-04, 50-325, 324/97 01-05, 50-400/97-02-02, and 50-261/97-02-02 were closed.
c. Conclusion The inspector concluded that the FFD organization and management control systems met regulatory requirements and that the recent changes did not adversely affect the FFD program. The FFD personnel were aware of their individual responsibilities and were trained to perform their.intended functions.
S1.3.2 Audits
a. Inspection Scope
(81700).
O Determine if the licensee's audit program is of sufficient depth'and whether the audits had been conducted.
b. Observations and Findings
The inspector reviewed the last annual audit of the AA and FFD programs which was conducted July 7-18, 1997. The audit was thorough and the findings were two strengths, two weaknesses, and three items for management consideration. The licensee took the proper corrective actions to close the weaknesses. The inspector determined that audit items were reviewed, appropriately assigned, analyzed, and prioritized for corrective action. The corrective actions were technically adequate and performed in a timely manner.
c. Conclusion The licensee's AA/FFD audits were complete and effective in terms of uncovering weaknesses in the AA/FFD programs, procedures, and practices.
The AA/FFD audits were considered a strength.
O X1
Exit Meeting Summary
The inspection scope and findings were summarized to licensee management at the conclusion of the inspection on June 4, 1998. The inspector described the areas inspected and discussed the inspection results.
Proprietary information is not contained in this report. Dissenting comments were not received from the li'censee.
PARTIAL LIST OF PERSONS CONTACTED Licensee D. Braund, Harris Superintendent, Security A. Brittain, Brunswick Superintendent, Security J. Campbell, Senior Support Analyst H. Chernoff, Robinson Manager, Licensing D. Crook, Robinson Plant Access Authorization Supervisor L. Benner-David, Senior Support Analyst R. Gill, Corporate Security Manager W. Hatcher, Brunswick Plant Access Authorization Supervisor
. W. Ison, Harris Plant Access Authorization Supervisor R. Kester, Corporate Superintendent, Access Authorization M. Lanhart, Senior Support Analyst B. Pope, Corporate Access Supervisor P. Phillips, Support Analyst P. Morales, Senior Analyst, Corporate Regulatory Affairs R. Newsome, Corporate Principle Support Analyst
0. Oglesby. Brunswick Project Analyst
M. Smith, Corporate Senior Analyst M. Taylor, Harris Senior Analyst R. Watson,'Senior Engineer, Performance Evaluation Support S. Young, Robinson Superintendent, Security NRC D. Thompson, Safeguards Inspector INSPECTION PROCEDURES USED IP 81502:
Fitness For Duty Program IP 81700:
Physical Security Program for Power Reactors
. IP 92904:
Follow-up - Plant Support
LIST OF LICENSEE
DOCUMENTS REVIEWED
SEG-NGGC-2101, Nuclear Worker Screening Program For Unescorted Access,
Revision 9
SEC-NGGC-2140, Fitness For Duty Program, Revision 7
ITEMS OPENED,
CLOSED,
AND DISCUSSED
Opened
Type
Item Number
Status
Description and Reference
50-325/324/97-01-01
Closed
Failure to complete background
97-056 (01023)
investigation (Section S1.2.2)
VID
50-325/324/97-01-02
Closed
Failure to complete fingerprint
97-056 (01013)
checks (Section S1.2.2)
50-325/324/97-01-03
Closed
Failure to complete AA documentation
97-056 (01043)
(Section S1.2.2)
50-325/324/97-01-04
Closed
Failure to properly complete FFD
97-056 (01063)
documentation (Section S1.3.1)
50-325/324/97-01-05
Closed
Failure to include personnel in the
'EEI
97-056 (01053)
random drug/alcohol program
(Section S1. 3.1)
50-400/97-02-01
Closed
Failure to remove access for
97-057 (010430
terminated employees
(Section S1.2.2)
50-400/97-02-02
Closed
Failure to properly complete FFD
97-057 (01063)
documentation (Section S1.3.1)
50-261/97-02-01
Closed
Failure to complete AA documentation
97-058
(Section S1.2.2)
50-261/97-02-02
Closed
Failure to properly complete FFD
97-058
documentati-on (Section 51.3.1)
50-400/98-02-01
Closed
Failure to follow procedures
98-020 (01013)
(Section S1.2.2)
50-400/98-02-02
Closed
Failure to follow AA procedures on
98-020 (02014)
separate occasions
(Section.S1.2.2)
LER
50-400/98-S01-00
Closed
Falsification of Personal History
h
Questionnaire (Section S1.2.2)