IR 05000282/1993003

Enforcement Conference Repts 50-282/93-03 & 50-306/93-03 on 930203.Areas Discussed:Apparent Violations & Areas of Concern Identified During Insp/Investigation & Corrective Actions Taken or Planned by Licensee

ML20128M268
Person / Time
Site:	Prairie Island
Issue date:	02/11/1993
From:	Christoffer G, Creed J, Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20128M200	List: IR 05000282/1993003 ML20128M196
References
50-282-93-03-EC, 50-282-93-3-EC, 50-306-93-03, 50-306-93-3, NUDOCS 9302220123
Download: ML20128M268 (28)

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U.S. NUCLEAR REGULATORY COMMISSION REGION 111 Reports No. 50-282/93003(DRSS); 50-306/93003(DRSS)

Dockets No. 50-282; 50-306 Licenses No. DPR-42; DPR-60 Licensee: Northern States Power Company 414 Nicollet Mall Minneapolis,liN 55401 Facility Name: Prairie Island Generating Plant, Units 1 and 2 Meeting Conducted: February 3, 1993 Meeting At: NRC Region 111 Office, Glen Ellyn, Illinois Type of Meeting: Enforcement Conference Inspection / Investigation Conducted: November 8, 1990 - February 2, 1993 Onsite and in Office Review Inspector: ^ '

// 1 G. M. Christof fer Date Physical Security inspector Reviewed By: 9awa Odspi./y7 Jam'es R. Creed, Chtuf Il Nu b-Date Safeguards Section Approved By: b/d/O MnN b'

(llyilthia D. Pederson, al b/)[ 2/////3 Date '

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Reactor Support Programs Branch Meetina Summary Enforcement Conference on February 3.1993 (RRE9rts No. 50-282/93003(DRSS):

50-306/93003(DRSS))

Areas Discussed: A review of the apparent violations and areas of-concern-identified during the in pection/ investigation, and corrective actions taken or planned by the licensee. The enforcement o)tions pertaining to the apparent violations were also discussed with tie licensee. The licensee provided additional information regarding the apparent violation PDR ADOCK 05000282 G: PDR

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Results: 1he licensee agreed with the apparent 10 CfR 26.27 violation I and one regarding security plan comitments. The licensee concluded that there was no willful intent or careless disregard to violate NRC regulation The NRC representatives acknowledged that the violations were licensee identified, i

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DilAILS I'trign) Present at Confere_nce Northern Stiles Power D. Antony, Vice President, Nuclear Generation M. Sellinan, Plant Manager, Prairie Island G. Miserendino, Manager, Corporate Security J. Kuhn, Supervisoc, Personnel Security R. Cleveland, Nucicar fitness for Duty Coordinator lb S. Nucl_ car _B.esglitary_Jommission 11. Miller, Deputy Regional Administrator, Rlll C. Norelius, Director, Division of Radiation Safety and Safeguardt, Rill J. Creed, Chief, Safeguards Section, Rlll G. Christoffer, Physical Security inspector, Rlli C. Weil, Enforcement Specialist, Rlll J. Isom Acting Section Chief. Division of Reactor Projects, Rlli R. Rosano, Enforcement Specialist Office of inforcement M. Gamberoni, Project Manager, Nuclear Reactor Regulation [Digreement ConfeCente An enforcement conference was held in the Region 111 office on february 3, 1993. This conference was conducted as a result of the findings of the inspection / investigation conducted on November 8, 1990 through February 2, 1993, in which apparent violations of NRC regulations were identified. inspection / investigation findings were documented in a summary and transmitted to the licensee by letter dated December 23, 199 The purpose of this conference was to: (1) discuss the apparent vioiations, causes, and the licensee's corrective actions; (2) d:scuss several areas of concern; (3) determine if there were an.y escalating or mitigating circumstances; and (4) obtain any information which would help determine the appropriate enforcement action, lhe licensee's representatives described the events which led to the violations, including root causes and corrective actions taken. Some of the corrective actions had been discussed in detail during a March 20, 1992 meeting. In summary, the corrective actions were; total revision of access authorization program; cancellation of all contractor programs with the exception of INP0; and issuance of guidance en suitable inquiry requirement __ -- _ - _ - _ - _ _ _ - - .-_

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l The licensee representatives did not contest the apparent violation l They concluded that there was no careless disregard for NRC regulations and no willful intent to violate NRC regulations. A copy of the licensee's presentation material is included as Appendix A to this repor At the conclusion of the conference, the licensee representatives were e informed that they would be notified in the near future of the final enforcement actio )

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Appendix A

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NRC REGION III FITNESS-FOR-DUTY CONCERNS AT PRAIRIE ISLAND (OI CASE NO. 3-91-001)

ENFORCEMENT CONFERENCE

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FEBRUARY 3RD,1993 ,

FACT SHEETS

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CASE FACTS 05-19-90 *

American Protective Services (APS) received Officer's employment application indicating past excessive use of alcoho * APS requested the Officer to provide a copy of his DD214 Long For * Officer provided a copy of his DD214 Long

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Form to a Prairio Island Training Instructo * The Instructor immediately faxed a copy of the DD214 to the APS Site Manager and called to discuss the informatio * NSP Corporate Screening Services granted the Officer access authorization after receiving APS request certifying completion of NSP contractor screening requirement * An NSP Security Consultant identified the -

derogatory FFD information while conducting an annual contract compliance audit of AP * The derogatory FFD information was identified in microfiche records regarding the Officer's military history which were obtained by APS from the National Personnel Records Cente OVERHEAD PAGE 4 FACT SHEET

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f REPO'RTING 10-25-90 * The event was recorded in the quarterly safeguards event lo * NRC Region III was notifie This notification was above and beyond safeguards event logging requirement OVERHEAD PAGE 5 FACT SHEET

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CORRECTIVE ACTIONS OFFICER

10-24-90 Suspended access pending determination of fitness for dut * 11-21-90 NSP received Officer's chemical dependency assessmen *

12-07-90 Officer and APS agreed to NSP management and medical return to duty conditions:

• Total abstinence from all mood altering substances during rehabilitation progra * Follow-up Testin * Unarmed status pending successful completion of rehabilitatio * Successful completion of outpatient treatment program and comply with aftercare recommendation :

12-10-90 Returned to dut * * Returned to armed status after 02-10-91 successfully completing treatment progra * No significant aftercare recommendation OVERHEAD PAGE 6 FACT SHEET l

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10-24-90 Suspended APS screening program pending

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11-01-90 Completed audit of all APS screening files'

for personnel submitted under program approved by NSP in May of 199 .

• 28 APS personnel files' audited, no further loggable events identifie * Re-investigated backgrounds. performed by-ICA.-

12-90 No significant finding * Issued letter to all approved contractors:

12-26-90

• Reiterating NSP suitable inquiry-requirement ~

• Announcing-program changes to-prevent-recurrenc "

• Required completion of worker suitable' inquiry self-disclosure  :

statement prior to' requesting aCCOs * Revised NSP Request for Unescorted Access Authorization Form to include verification-of-suitable inquiry completio *

02-20-91 APS program reinstated as upproved following ,

NSP training of APS management-personnel;on:'-

• NRC FFD suitable inquiry requirement * NSP access authorization requirements.-

• Investigations and documentatio OVERHEAD PAGE 7 FACT SREET

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NSP MANAGEMENT CONTROLS

APS PROGRAM REVIEW AND APPROVAL

5-11-90 NSP CONTRACTOR PROGRAM AUDIT CHECKLIST ,

COMPLETED INDICATING APS PROGRAM-MET SUITABLE '

INQUIRY REQUIREMENTS

• Suitable Inquiry was a separate item reviewed on the checklis *

5-18-90 NSP NOTIFIES APS OF PROGRAM APPROVAL

APS PROGRAM REQUIREMENTS

REQUIRED A SUITABLE INQUIRY BE CONDUCTED

• In addition, a suitable inauirv meeting-requirements of 10 CFR_part 26.27 must be conducted to determine whether the worker has ever been:

• Tested positive for drugs or alcohol that resulted in on-duty impairmsant. -

• Subject to a plan for treating substance abuse (except for'self referral).

• Removed from or made ineligible for-activities within the scope of 10 CFR part 2 Prior to recommending'a worker for unescorted access authorization, APS shall obtain a written statement from the worker as

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to whether activities within the scope of 10 CFR part 26 were ever denied the worke * Denied access or employment in-accordance with a fitness for. duty polic * IF SUCH A RECORD IS ESTABLISHED, APS SHALL IMMEDIATELY CONTACT NSP'S FITNESS FOR DUTY COORDINATOR (FFDC) . AT (612) 330-799 OVERREAD PAGE 9 FACT SHEET

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ROOT CAUSE CONTRACTOR FAILURE TO UNDERSTAND AND FOLLOW THEIR NSP APPROVED ACCESS AUTHORIZATION PROCEDURE

STRICT PROCEDURAL COMPLIANCE

• APS Management believed the intent of their NSP approved screening procedure was satisfied when they informed the NSP Security Consultan * Interviews conducted with APS Management personnel after the incident revealed a-lack of program knowledg *

FINANCIAL AND STAFFING CONCERNS

• The management emphasis at the regional APS office was on financial and staffing concerns. The FFD and Access Authorization programs were not high prioritie OVERHEAD PAGE 10 FACT SilEET i

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SAFETY SIGNIFICANCE

INDIVIDUAL WAS IN NSP BEHAVIOR OBSERVATION -

PROGRAM

• No positive tests for drugs or alcohol e Pro-Access Test Dates e 06/12/90 e 12/04/90

• Post Return to Duty Test Dates e 01/03/91

. 04/05/91 e 04/23/91 e 05/18/91 e 05/24l91 e 10/14/91 e 12/04/91 e 01/16/92 e 05/01/92 e 06/25/92 e 11/25/92 CONSISTENTLY AN ABOVE AVERAGE PERFORMER

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FFD EVALUATION

CHEMICAL DEPENDENCY ASSESSMENT

• Alcohol abusive - Periodic abuse of alcohol

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• Not chemically dependent

• Outpatient treatment, not inpatient

MODIFICATION OF WORK ASSIGNMENT

• Returned to duty in an unarmed status

• NSP monitored progress in outpatient program weekly

• Placed in follow up testing program for drugs and alcohol OVERHEAD PAGE 11 FACT SHEET

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OIINVESTIGATIVE CONCLUSIONS

• APS MANAGEMENT HAD KNOWLEDGE OF DEROGATORY INFORMATION REGARDING ONE OF THEIR EMPLOYEES AND DELIBERATELY FAILED TO NOTIFY NSP'S FFD OFFICE *

NSP DOES NOT AGREE WITH OI CONCLUSION THAT THE FAILURE WAS DELIBERATE NSP KNOWLEDGE e APS MANAGEMENT BELIEVED THE NSP SECURITY CONSULTANT PERFORMED FILE REVIEWS FOR DEROGATORY FFD AND ACCESS AUTHORIZATION INFORMATION e APS MANAGEMENT HAD INFORMED THE NSP SECURITY CONSULTANT OF THE DEROGATORY INFORMATION ,_

APS MANAGEMENT e NSP PROCEDURE " DUPLICATED" AND NOT UNDERSTOOD e APS STAFF NOT EXPERIENCED IN INVESTIGATIONS e EMPHASIS ON FINANCIAL AND STAFFING CONCERNS, NOT FFD AND ACCESS AUTHORIZATION

THE NSP EMPLOYEES (LEAD SECURITY INSTRUCTOR AND SECURITY CONSULTANT) HAD KNOWLEDGE OF THE DEROGATORY INFORMATION REGARDING AN APS GUARD, BUT DID NOT DELIBERATELY FAIL TO NOTIFY'THE NSP FFD OFFICER NSP LEAD SECURITY INSTRUCTOR

• APS SITE MANAGEMENT WAS IMMEDIATELY INFORMED UPON RECEIPT OF DD214 LONG FORM e This action was prudent since APS was an approved contractor

• THE NSP LEAD SECURITY INSTRUCTOR DID NOT WORK FOR NSP CORPORATE SCREENING SERVICES

• NSP AGREES WITH OI CONCLUSION THAT THE NSP LEAD SECURITY INSTRUCTOR DID NOT DELIBERATELY FAIL TO NOTIFY THE NSP FFD COORDINATOR NSP SECURITY CONSULTANT

> ALTHOUGH HE HAD KNOWLEDGE OF DEROGATORY INFORMATION, HE HAD No ACCESS AUTHORIZATION /FFD PROGRAM RESPONSIBILITIES

= NO SUPERVISORY RESPONSIBILITIES

• DID NOT WORK IN CORPORATE SCREENING SERVICES

• NSP AGREES WITH OI CONCLUSION THAT THE NSP SECURITY CONSULTANT DID NOT DELIBERATELY FAIL TO NOTIFY THE NSP FFD COORDINATOR OVERHEAD PAGE 12 FACT SHEET

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. SUMMAR' CORRECTIVE ACTIONS IMMEDIATELY INFORMED NRC REGION III

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• IMMEDIATELY SUSPENDED UNESCORTED ACCESS

• COMPLETED MEDICAL AND MANAGEMENT DETERMINATION OF FITNESS APS CONTRACTOR PROGRAM

• IMMEDIATELY SUSPENDED APS PROGRAM

• AUDITED ALL APS SCREENING FILES

• RE-PERFORMED ALL INVESTIGATIONS PERFORMED BY ICA

• TRAINED APS MANAGEMENT ON FFD RULE AND ACCESS AUTHORIZATION PROGRAM ALL CONTRACTOR PROGRAMS

• ISSUED GUIDANCE ON SUITABLE INQUIRY REQUIREMENT * REVISED CONTRACTOR REQUEST FOR UNESCORTED ACCESS FORM TO INCLUDE SUITABLE INQ'1IRY AS A SEPARATE ITEM e TOTALLY REVISED PROGRAM (WINTER 1992 AS PRESENTED TO RIII IN MARCH OF 1992)

• CANCELLED ALL CONTRACTOR PROGRAMS WITH THE EXCEPTION OF INPO. WITH THE IMPLEMENTATION OF INDEX AND NUMARC TRANSFERS, CONTRACTOR PROGRAMS ARE NO LONGER ECONOMICALLY FEASIBL J CARELESS DISREGARD FOR NRC REGULATIONS NO WILLFUL INTENT TO VIOLATE NRC REGULATIONS

• NSP PERSONNEL

• NSP agrees with the OI conclusion that NSP employees did not deliberately fail to notify the FFD Coordinator

• The Lead Security Instructor immediately informed APS Management upon review of DD-21 * This action was prudent since APS was an approved contracto * The NSP Security Consultant immediately notified Corporate Screening Services when the entire military record was reviewed on 10/24/9 * APS PERSONNEL

• NSP disagrees with the OI conclusion that APS management deliberately-failed to notify the FFD Coordinator

• APS Management believed the intent of the procedure was met when the NSP Security Consultant was informed

• APS Management was not knowledgeable in the FFD regulation and did no give FFD_a high priority in the regional offic SUCCESSIRIL AUDIT RESULTS OF NRC FFD AUDIT IN FALL 1990 OVERHEAD PAGE 14 FACT SHEET

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NRC REGION II !

l FITNESS-FOR-DUTY CONCERNS AT a PRAIRIE ISLAND (OI CASE NO. 3-91-001)

ENFORCEMENT CONFERENCE

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INTRODUCTION 1990 PRAIRIE ISLAND SECURITY OFFICER FFD CONCERNS IN ATTENDANCE FROM NSP DOUG ANTONY VP NUCLEAR GENERATION MIKE SELLMAN PLANT MANAGER, PRAIRIE ISLAND GEORGE MISERENDINO MANAGER CORPORATE SECURITY JIM KUHN SUPV PERSONNEL SECURITY -

RANDY CLEVELAND FFD COORDINATOR EVENT CHRONOLOGY GEORGE MISERENDINO EVENT ANALYSIS JIM KUHN SUMMARY DOUG ANTONY PAGE 2 OF 14

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EVENT CHRONOLOGY CASE FACTS REPORTING CORRECTIVE ACTIONS -

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CASE FACTS 05-19-90- American Protective Services (APS)

receives employment application.-

06-12-90 Officer commences training 06-28-90 Unescorted-access to Prairie Island granted-10-24-90 NSP-Corporate-Screening. Services became-aware of derogatory information.andl suspends unescorted access .

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On 10-25-90:

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. NRC Region III was_ notifie e Not a regulatory requirement :

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CORRECTIVE ACTIONS

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10-24-90 Suspended unescorted access

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12-07-90 Completed determination of management an medical assurance of fitness--

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12-10-90 Returned to duty in an unarmed statu %

02-10-91 Returned to armed status after successfully completing treatment program

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CORRECTIVE ACTIONS

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CONTRACTOR PROGRAMS

E 10-24-90 Suspended APS screening program 11-01-90 Completed audit of'APS screening files'- .

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Re-performed all background investigations performed by ICA

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Reiterating NSP suitable inquiry-.

requirement *

Announcing program changes to_ prevent recurrenc Implemented revised _ Contractor Request fo Access Authorization form

02-20-91- APS program reinstated

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i EVENT ANALYSIS NSP MANAGEMENT CONTROLS ROOT CAUSE SAFETY SIGNIFICANCE OI INVESTIGATIVE CONCLUSIONS

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l NSP MANAGEMENT CONTROLS

1 PROGRAM REVIEW AND APPROVAL

5-11-90 NSP CONTRACTOR PROGRAM AUDIT CHECKLIST COMPLETED

5-18 90 NSP NOTIFIES APS OF PROGRAM APPROVAL APS PROGRAM REQUIREMENTS REQUIRED A SUITABLE INQUIRY BE CONDUCTED IN '

ACCORDANCE WITH 10CFR 26.27.TO DETERMINE WHETHER THE WORKER HAS EVER BEEN ...

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IF SUCH A RECORD IS ESTABLISHED ... CONTACT THE NSP FFD COORDINATOR AT 330-799 PAGE 9 OF 14

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CONTRACTOR FAILURE TO UNDERSTAND .

AND FOLLOW THEIR NSP APPROVED ACCESS AUTHORIZATION PROCEDURE STRICT PROCEDURAL COMPLIANC *

FINANCIAL AND STAFFING CONCERNS- ,

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SAFETY SIGNIFICANCE INDIVIDUAL WAS IN NSP BEHAVIOR OBSERVATION PROGRAM

No positive tests for drugs or alcohol CONSISTENTLY AN ABOVE AVERAGE-PERFORMER

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FFD EVALUATION

- CHEMICAL DEPENDENCY ASSESSMENT-

MODIFICATION OF WORK ASSIGNMENT PACE 11 OF 14

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f OI INVESTIGATIVE CONCLUSIONS

APS MANAGEMENT HAD KNOWLEDGE OF DEROGATORY INFORMATION REGARDING ONE OF THEIR EMPLOYEES AND DELIBERATELY FAILED TO NOTIFY NSP'S FFD OFFICE NSP DOES NOT AGREE WITH OI CONCLUSION THAT THE FAILURE WAS DELIBERATE

THE NSP EMPLOYEES (SECURITY CONSULTANT AND SECURITY INSTRUCTOR) HAD-KNOWLEDGE OF THE DEROGATORY INFORMATION REGARDING AN APS GUARD, BUT DID NOT DELIBERATELY FAIL TO NOTIFY THE NSP FFD OFFICER

NSP AGREES MTI'H OI CONCLUSION

• 'NSP LEAD SECURITY INSTRUCTOR

NSP SECURITY CONSULTANT i

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msg enne nuee:a cruTra .

wwEn MARE ISLND CORPORATE SECURITY (5/90) TRMMC NTER MANAGER E M TY

~#GTAUCTOR CORPORATE gg7y SECURITY rcTnuctoa FFD SECURITY SUPERVISOR ADMINISTRATIVE ADMINISTRATIVE COORDINATOR CORPORATE ADMINISTR ATOR SCREENING SP ECI All8T SP ECI AllST SERVICES SECURITY SCREENING CONSULTANT CONSULTANT SECURITY SCREENING CONSULTANT COORDINATOR SECURITY ADMIN

- CON 8ULTANT 8PECIAll8T l SECURITY ANALYST f ADMIN

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SUMMARY

CORRECTIVE ACTIONS

IMMEDIATELY INFORMED NRC REGION III

OFFICER

APS CONTRACTOR PROGRAM

ALL CONTRACTOR PROGRAMS

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NO CARELESS DISREGARD FOR NRC REGULATIONS -

NO WILLFUL INTENT TO VIOLATE NRC REGULATIONS PAGE 14 OF 14

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