IR 05000280/1995012
| ML18153A722 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 07/19/1995 |
| From: | Tobin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153A721 | List: |
| References | |
| 50-280-95-12, 50-281-95-12, 50-338-95-13, 50-339-95-13, NUDOCS 9508020119 | |
| Download: ML18153A722 (8) | |
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Report Nos.:
UNITED *sTATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900 ATLANTA, GEORGIA 30323-0199 50-280/95-12, 50-281/95-12, 50-338/95-13 and 50-339/95-13 Licensee: Virginia Electric and Power Company Glen Allen, VA 23060 Docket Nos.:
50-280, 50-281, 50-338 and 50-339 License Nos.:
DPR-32, DPR-37, NPF-4 and NPF-7 Facility Name:
Surry and North Anna Power Stations Inspection Conducted: Jue 26-30, 19~5
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< LL nior Safeguards Inspector Inspector Approved by :J....:.~~_k.!...!...~O::!:::!::~----------
Davi d McGuire, ief Safeguards Section Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This announced inspection was conducted at both the Surry and North Anna Nuclear Stations, as well as at the corporate office in Glen Allen, Virgini The licensee's Access Authorization Program, as required by 10 CFR 73.56, was inspected. Specifically, background investigations, psychological evaluations, and the training of supervisors were evaluate The inspectors also reviewed the licensee's appeal process, and, the protection afforded personal information. Audit of contractors and of its own program were reviewe Results:
No violations were identified. Several strengths were noted (the licensee conducts local and State Police, as well as, motor vehicle records reviews prior to granting unescorted access), however, two weaknesses were identified as the following:
o Employees and contractors did not fully understand their responsibility to report any arrest o The Supervisor Behavior Observation Training Program, which addresses such Fitness For Duty considerations as drug and alcohol abuse, did not address Access Authorization considerations such as a persons continued trustworthiness-and reliabilit PDR ADOCK 05000280 G
- Persons Contacted Licensee Employees REPORT DETAILS
- D. Barden, Corporate Director, Nuclear Access (Acting)
- M. Clark, Corporate Quality Assurance Auditor R. Cogar, North Anna Access Coordinator M. Gill, North Anna, Personnel Specialist D. Hayes, Surry Administration Supervisor D. Heacock, North Anna Assistant Plant Manager T. James, Surry Human Resources Coordinator
- M. Kansler, Corporate Nuclear Vice President J. Leberstein, North Anna Licensing Engineer C. Luffman, Surry Security Manager T. Maddy, North Anna Security Manager J. Mann, 'North Anna Associate Instructor J. McCarthy, Surry Assistant Plant Manager
- W. Runner, Corporate Nuclear Security and Administration Manager
- C. Schulz, Corporate Quality Assurance Supervisor R. Spivey, Surry Senior Instructor W. Walker, Surry Associated Instructor 0. Wegman, Surry Access Coordinator
- G. Wilson, Corporate Supervisor of Nuclear Access Program Contractor Employees C. Candee, Westinghouse Manager, North Anna M. Clark, Atlantic Group Manager, North Anna S. Harms, Westinghouse Manager, Surry L. Thompson, Bechtel Coordinator, North Anna U. S. Nuclear Regulatory Commission M. Branch, Senior Resident Inspector R. McWhorter, Senior Resident Inspector
- Attended exit interview The NRC Inspectors also interviewed 25 randomly chosen licensee and contractor personnel, to include supervisors, at the Corporate Office and both Nuclear Station.
Access Authorization Program (TI 2515/127)
On April 25, 1991, the Commission published 10 CFR 73.56, Personnel access authorization requirements for nuclear power plants, which required licensees to fully implement their AAP by April 27, 199 By letter dated April 27, 1992, the licensee submitted Revisions 27 to the
- North Anna and Surry Physical Security Plans committing to the requirements of 10 CFR 73.56 and NRC Regulatory Guide 5.66, Access Authorization Program for Nuclear Power Plant AAP Administration The licensee's AAP is solely managed and implemented at the Corporate level by the Manager of Nuclear Security and Administrative Services. All AAP functions, procedures and records are found at the Corporate Office, specifically at the office of the Supervisor of the Nuclear Access Progra There are no AA personnel, procedures nor records at the nuclear station Contractors, who self-screen, are required to furnish the licensee with any derogatory informatio The Supervisor of the Nuclear Access Program makes the determination as to the suitability of the applicant. Appeals (See paragraph "g") are the sole responsibility of the Director, Nuclear Access Services who reports to the Manager of Nuclear Security and Administrative Service The licensee's AAP administration appeared to be well managed and effective. There were no violations of regulatory requirements identified in this are Background Investigations The licensee's Supervisor of the Nuclear Access Program is responsible for the Unescorted Access Authorization Progra The four Nuclear Access Specialists who report to this Supervisor are responsible for processing the applications for authorization of acces The background investigations for the licensee and some contractor personnel are conducted by the Corporate Security Investigations personne As an enhancement to the requirements contained in Regulatory Guide 5.66, the licensee also conducts a
"Limited Background Investigation" on personnel who are seeking employment in the Nuclear Department which includes a Financial Responsibility, a Division of Motor Vehicle and a State Police criminal history check, and a credit check with Virginia Power/North Carolina Power if the applicant resides in the company service are Self-screening contractors perform their own backgrounds investigations or utilize a subcontracto The Nuclear Access Specialists who prepare the Access Authorization documentation were interviewed and found very knowledgeable of the licensee's and NRC's AAP requirement Records of adjudication of unfavorable termination were reviewed and the documentation was found to be in accordance with NRC and the licensee's requirement The licensee follows several procedures, (Evaluation Criteria for Unescor~ed Access Authorization, Procedure ASCP-0109, Revision 1, dated August 31, 1994; Fingerprint Administration, Procedure ASCP-0110, Revision 4, dated January 3,
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1995; and Background Information, Procedure ASCP-0111, Revision 1, dated August 31, 1994) which clearly delineated the process of obtaining and processing fingerprints and the review of resulting information. These procedures provide a matrix for adjudicating unfavorable informatio Background investigations appeared to be thorough and well documente The licensee's practice of conducting the "Limited Background Investigation" is a strength that exceeds NRC criteri Procedures were adequat There were no violations of regulatory requirements noted in this are Behavioral Observation Program (BOP)
The Nuclear Management and Resources Council (NUMARC) has published the Industry Guidelines for Nuclear Power Plant Access Authorization Programs (No. 89-01) adopted by NRC's Regulatory Guide 5.66 titled,
"Access Authorization Programs for Nuclear Power Plants".
Paragraph 9.0 of NUMARC No. 89-01, Continual Behavior Observation Program, requires that supervisors be given training in the detection of aberrant behavior, to include signs of drug and alcohol abuse as well as observing personnel for changing behavioral traits and patterns indicative of an adverse trend of their trustworthiness and reliability. Additionally, Paragraph 9.0 also requires that individuals with unescorted access authorization must be notified of their responsibility to report any arrest that may impact upon their trustworthines The inspectors reviewed the licensee's lesson plans for training supervisors in detecting aberrant behavio The inspectors verified that aberrant behavior training is provided to supervisors when they are appointed to a supervisory position and annually during the site Nuclear Employee trainin It was noted during this review (and substantiated during interviews of 13 supervisors) that the training for detecting aberrant behavior is largely based upon detecting the signs of drug and alcohol abuse. These appeared to be little training relative to the behavioral changes indicative of a lack of trustworthiness and reliability of personne The licensee acknowledged the inspectors observation and, upon receipt of this Report, will further evaluate their actions. This issue will be tracked as an Inspector Followup Item No. 50-280 and 281/95-12-01 and 50-338 and 339/95-13-0 Additionally, twenty five individuals were interviewed as to their understanding of personnel reliability and their responsibility to report any arres The individuals appeared to have a vague recall of this responsibility but were confused as to the extent necessary to report any arres The inspectors reviewed the Nuclear Employee Lesson Plan and found it states, "Report any felony or misdemeanor conviction or any arrest which may impact their trustworthiness".
Overall, the personnel interviewed recalled that their responsibility for reporting any arrest varied from any contact with *.. *:.,.:...,,..
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law enforcement personnel to the need to report only felony conviction The licensee acknowledged the inspectors observation and, upon receipt of this Report, will further evaluate their actions. This issue will be tracked as Inspector Followup Item N and 291/95-12-02, and, 50-338 and 339/95-13-0 There were no violations of regulatory requirements noted in this are Psychological Testing The licensee and the contractors administer the Minnesota Multiphasic Personality Inventory 1 or 2 (MMPI}, which if warranted, is followed by a clinical intervie The inspectors reviewed testing procedures and visited facilities at the licensee's corporate office, at the sites and also at the contractors facility at the North Anna Nuclear Station. All personnel responsible for testing required positive identification from the applican Facilities accommodated the proctoring of the tests, were appropriately secure, and test materials were secured when not in us The Flour Daniels contractor had an adequate facility at North Anna except when there was a large number of personnel to be teste The inspectors learned that prior to outages, the overflow of applicants being psychologically tested is placed in a storage room which has an unlocked door leading to the outside. Although the contractor assured the inspectors that the door is locked during testing, the inspectors noted that the door is an emergency exit and cautioned that locking the door may cause a fire safety concer The contractor agreed that other arrangements were appropriat Required certification of successful completion of the MMPI was present in all records reviewed. A memo was provided to licensee and contractor AAP personnel who administer the MMPI emphasizing the method for proctorin The inspectors noted that although NRC guidance regarding problems with psychological testing had not been fµrnished to one licensee AAP person, she had been previously trained regarding the guidance and was very knowledgeable of the proctoring requirements. Another AAP licensee employee indicated that in the past she had allowed personnel to be alone when taking the MMPI for an extended period of time, but had ceased that practice upon learning of NRC guidanc The licensee's practice of psychological testing appears to be adequat There were no violations of regulatory requirements noted in this are Records and Privacy Information Review of records, discussion with licensee and contractor personnel and review of records storage facilities and methods disclosed that information was safeguarded against unauthorized disclosure and
- accessible only to those involved in the access authorization process or those auditing the progra The records were complete, well organized, and readily availabl There were no violations of regulatory requirements noted in this are Clearances Prior to the onsite portions of this inspection, the NRC's Resident Inspectors provided randomly chosen names of 45 individuals (licensees and contractors) who had authorized unescorted access to each of the licensee's nuclear station The clearance files for these individuals were reviewed at the corporate offic The inspectors reviewed clearance records for personnel who had been
"grandfathered, transferred, reinstated, newly hired, updated, and temporarily authorized acces Records were accurate and supported a decision to authorize or deny authorizatio It was noted that prior to this year no contractors were processed for a temporary authorizatio All contractors are required to provide any derogatory information to the licensee who evaluates and adjudicates the informatio Contractors are not permitted to certify the suitability of applicants for access. The inspectors reviewed Procedure No. 0109
"Evaluation Criteria for Unescorted Access Authorization" which delineates the three Levels (A, B, and C) of activities that pose a negative impact on a person's reliability and trustworthines One of the strengths of the licensee's AAP is the electronic database used to track FBI fingerprint requests, military records requests (DD 214) and temporary backgrounds which have been outstanding for 150 day This allows the licensee a 30 day grace period before the NRC required 180 day limit for such request Also facilitated by this electronic database is the generation of data transfer forms to other licensees relative to Fitness For Duty, health physics certifications, or medical trainin The inspectors determined that an employee (not a contractor) could be absent from a nuclear station, or the Corporate Office, for greater than 30 days but less than 365 days for such reasons as military leave or pregnancy and, upon return, would not be psychologically retested nor reinvestigate However, in accordance with Regulatory Guide 5.66, Clarification, paragraph 3, the licensee utilizes other sources for information to ascertain the activities of the employee while absent (i.e. insurance/medical records, telephone conversations with supervisors, etc.)
In any cases the employee's AA would not be "terminated", nor a badge removed from the station entry poin However, that decision is left to the supervisor most knowledgeable of the situatio *,;". *-
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The inspectors noted inconsistency in the questions on the AA questionnaires used by contractors and the licensee relative to criminal histories; o
One major contractor inquired about charged or convicted felonies, misdemeanors, court martials and traffic violations including dismissed charge o Another major contractor inquired only about any convictions "of any law" o
A third major contractor inquired about convictions of
"criminal proceedings, regulations or ordinances" o
The licensee inquired about arrests and convictions for misdemeanors and felonies, to include traffic violations involving alcohol or drug While these inconsistencies may cause the confusion of those individuals required to report any arrest (See paragraph "c"), the required criminal history check is accomplished through the FBI fingerprint chec Clearances were well documented and supporte There were no violations of regulatory requirements noted in this are Revocations/Denials and Appeals The inspectors reviewed several revocation or denial of access requests issued in 1994 and 199 It was noted that in all occasions the reasons were explained to the applicant, and, the review process for appeal was clearly state Two examples of appeals being upheld (and the original denial overturned) were also reviewe It was noted that the Acting Director of Nuclear Access Services is the sole and final appeal authorit Working directly for this manager is the supervisor who has the authority for denying initially the authorizatio Very few of the 25 individuals interviewed on a random basis knew of the appeal process, in fact, several believed that there was no appeal proces Contractors universally believed they could only appeal through their "home offices." Union members would rely on the grievance procedur The inspectors further determined that there is no mention of the appeal process during Nuclear Employee Trainin The licensee advised the inspectors (and it was verified in various documents) that at the time a person is informed of the denial or revocation the licensee provides in writing the right to appea The appeal process was adequate. There were no violations of regulatory requirements noted in this are...
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7 Audits The inspectors randomly reviewed two audits of contractors AA programs; one was a small local vendor, and the other was a major industry-wide contracto The auditors utilized audit procedures furnished by the Nuclear Energy Institute (NEI).
Contractor records, procedures and processes were reviewe Interviews were conducted with knowledgeable personnel. Activities were observe Both AA programs were found to be acceptable, although the major contractor was found to have numerous "Findings" of administrative discrepancies and inaccuracie Twb "unresolved open" items were identified regarding fitness for duty events and overall program managemen Audits of the licensee's AA program were also reviewed and found to be acceptabl The most recent audit (C95-0l) reviewed Fitness For Duty and other security regulations, along with the AA progra The audit found the licensee to have programs that meet regulatory requirement There were no violation The audit requirements are being adequately met by the licensee for it's own AA program as well as those programs from vendors and contractor.
Exit Interview The Exit Meeting was held at the corporate office on June 30, 1995, with those so noted in paragraph I in attendanc The licensee was advised of the results of the inspection, and the finding of issues for which the licensee planned further action and various strengths. Dissenting comments were not received from the licensee.