IR 05000295/1989025

Insp Repts 50-295/89-25 & 50-304/89-23 on 890209-0807.No Violations Noted.Major Areas Inspected:Applicable Portions of Plant Security Program Re Alleged Inadequate Performance & Mgt Practices within Licensee Security Organization

ML20247L988
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	09/14/1989
From:	Christoffer G, Creed J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247L985	List: IR 05000295/1989025 ML20247L979
References
50-295-89-25, 50-304-89-23, NUDOCS 8909250103
Download: ML20247L988 (9)

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U.S. NUCLEAR REGULATORY COMMISSION l

REGION III

Reports No. 50-295/89025(DRSS);50-304/89023(DRSS)

Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Station, Units 1 and 2 Inspection At: Zion Station Region III office Inspection Conducted: Between February 9 and August 7,1989 Type of Inspec ion: S ecial Security Inspection f 4/

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Inspector: A- -

/G. M. Christoffer ///) Date Physical Security Inspector Approved By: } A J. R. Creed, Chief 6p L- f/

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Inspection Summary Inspection between February 9 and August 7, 1989 (Reports No. 50-295/89025(DRSS);

No. 50-304/89023(DRSS))

Areas Reviewed: Applicable portions of the Zion security program relative to alleged inadequate performance and management practices within the licensee's security organizatio Results: The licensee was found to be in compliance with NRC requirements in the areas inspected; however, two instdnces of guards being inattentive to duty l were verified and some instances in which guards' work hours exceeded non-regulatory NRC guidelines were identified. The licensee has taken or begun action to address these findings. The allegations are close Inspection activities showed a decline in the guard force performance in ;

implementing the security progra '

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DETAILS Key Persons Contacted T. Joyce, Station Manager,' Zion R. Bucowle, Services Director, CECO R. Smith, Security Administrator, CECO A. Torez, Assistant Station Security Administrator, CECO G. Gilliano, Site Manager, American Protective Services (APS)

Additionally, several members of the contract security organization were interviewed during all three security inspection . Entrance and Exit Interviews (IP 30703)

This inspection was conducted between February 9 and August 7, 198 During related inspections in March 1989 (50-295/89011; 50-304/89011) and July 1989 (50-295/89022; 50-304/89020), the licensee was advised that we were reviewing allegations regarding the security program at Zion Station while also completing needed inspection activities. The specific allegations were not discusse At the conclusion of our on-site and in-office inspection activities the Assistant Site Security Administrator was briefea. During a telephone conversation on August 16, 1989 he was advised of the allegations and our findings. He was informed that the allegations (AMS Nos. RIII-89-A-0021; RIII-89-A-025 and RIII-89-A-029) were close NOTE: During a subsequent meeting with the licensee, on an unrelated matter, they indicated that a substantial increase in the size of the guard force would be accomplished in the near future and will augment current resource . Security Organization (Allegation Review) (IP 81022)

The following information, provided in the form of allegations, was reviewed by the inspector as specifically noted below:

Background During the months of February and March 1989, several members of the Zion security organization contacted the NRC with allegations regarding guard performance and security practices at Zion Statio On February 9,1989, a known security officer contacted the Resident Inspector at Zion Station regarding certain contractor personnel practices which could contribute to inattentive guards. He indicated he would provide details in writin Later on March 3,1989, the individual wrote to Region III and provided additional information about the guard assignments at Zion Station. (AMS No. RIII-89-A-0021)

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On February 16, 1989, three different security officers contacted the Resident Inspector at Zion Station regarding what they considered to be poor overtime practices for security officers. (AMS No. RIII-89-A-0025)

On February 23, 1989, a fourth security officer also contacted the Resident Inspector regarding two events in which guards were allegedly inattentive to dut (AMS No. RIII-89-0025) These contacts caused NRC a concern regarding potential safety / security deficiencies as they related to alleged guard force performance. A reactive security inspection was conducted approximately one week later and identified no ongoing safety problem During the period between January and August 1989 guard performance and security practices at Zion Station were reviewed both in the office and onsite as part of our routine inspection program and in reaction to incidents or allegations. A combination routine / reactive inspection was conducted in January 1989 (50-295/89003; 50-304/89003). A special reactive inspection (noted above) was also conducted in March 1989 (50-295/89011;50-304/89011) to address statements related to the protection of the facility including a specific instance of alleged inadequate protection. In July 1989 (50-295/89022; 50-304/89020) a routine inspection was conducte During these inspections security guards were interviewed regarding their knowledge and performance of duties. To supplement that, security guards on all three shifts were observed performing such duties as access control, alarm station operations, patrols, response, and compensatory post Documents pertaining to work schedules, post logs, procedures, and incident reports were also reviewed during our inspection effort. These security inspection activities identified no obvious instances of less than adequate performance other than noted below. The following specific concerns expressed by guards were reviewed as allegation Allegation AMS No. RIII-89-A-0021: The alleger indicated that guards on the evening shift, who were stationed in the plant to watch the walls undergoing construction were there for long periods of time with nothing to d Also, watch lengths of four to six hours with "nothing to do" are conducive to falling aslee Thirdly, management was the cause of the problem of poor security practices which could result in sleeping guards. It would not help to notify the Station Security Administrator (SSA) because he I wouldn't do anything. The practices occur when he isn't around and l even if he was made aware of the problems, he would give it to the l APS Site Manager who wouldn't do anythin _ _ _ _ _ - _ - _ _ - _ _ _ _ ___ .____

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l, Review:

During the security inspections in January, March and July 1989 guards on the various shifts were observed performing functions

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such as access control, compensatory measures, patrols, response, and alarm station operations. During.these observations, the guards were found to be adequately performing'their. assigned duties and.there were no indications of guards asleep or being inattentive to duty. Some guards were acting as compensatory measures when a security system function was lost or degraded.- In those cases, we verified that specific instructions on their assigned duties were provide Security officers and security managers were interviewed about the duration of security post assignments, problems associated with compensatory measures and about their assigned duties. They indicated that they understood their duties when assigned to a-compensatory measure post. They also indicated that some of the posts were located-in' low traffic areas and at times, those assignments were boring. They also stateo the location of some posts were more difficult to work due to ten.perature and noise level 'Some indicated that they did not agree with the reasons given or the need for putting compensatory measures in place, but they followed instructions. 'Some did not feel that security managemert was concerned about the conditions the guards had to endure while on pos Some of the individuals indicated that they had " heard of" the two cases of guards being caught while inattentive to duty, but had not been inattentive while on a post themselves. They explained that in order to alleviate the boredom or environmental conditions they could call for relief, or get up and stretch if they felt they were becoming inattentiv The individuals interviewed indicated that after the February 1989 incidents of inattentive guards, (AMS No. RIII-89-A-0029) instructions were given that vital area posts must be rotated hourly and further that supervisors were encouraged to randomly observe the posted guard If supervisors felt that the posted guards needed a break or were becoming less than attentive, the supervisors were to make sure the guards were relieved or take any other actions they felt necessary to assure the guard remained attentive to duty. Security management could not recall any security officer complaining about long post hour Security documents such as " Compensatory Post Instructions" (CPI),

" Incident Reports" and " Security Post Logs," were randomly reviewe The CPI's provided instructions for a specific post and indicated the name of the individual assigned including the length of time the individual was posted. The several CPI's reviewed for the period January thru February 1989, indicated that during all shif ts guards were stationed in the plant to watch degraded vital area barrier _ _ - _ _ _ _ _ _ _ _ - _ - _ - _ - _- ._. --

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I l' Their instructions were to observe a specific area, detain any unauthorized individuals entering the area, report any unusual activity and verify authorized entry into the area. The CPI's indicated there were cases of officers posted at the same location for periods ranging from one to five hours. There was only one case of a five-hour post found during the random review and that was during the day shift. The majority of the post assignment times were-between one and two hour After the incidents (AMS RIII-89-A-002). on February 21 and 22,1989, which were documented in Incident Reports 1407 and 1408 respectively security management reviewed the their practices and in the " Security Post Log" dated February 24, 1989, issued new instructions that vital area posts must be rotated hourly. The CPI's indicated that since the new instructions were issued, guards were not posted at' vital

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areas for more than one hou On a related subject,'NRC Information Notice No. 86-88 " Compensatory Measures for' Prolonged Periods of Security System Failures" provides suggested guidelines for the number of hours to be worked. It states that studies have shown that even the most conscientious, dedicated security personnel gradually lose their effectiveness, even when posted for relatively short periods. That guidance would support the actions taken by the licensee to reduce tne length of post assignment Conclusion:

Guards on the evening shift were posted as compensatory measures which were required in order to maintain an adequate physical protection system. The length of the post assignments were generally one hour.to two hours, with some exceptions. No evidence was found that watch lengths of four to six hours occurred regularl (Note:

The two inattentive guard incidents in February 1989 see AMS No. RIII-89-A-0029 below did not occur as a result of the time length of the post assignment.)

We concluded that Security management took appropriate action after the February 1989 incidents to assure that guards were not posted for more than an hour. Prior to the February 1989 incident no specific evidence was found that management was informed that the guards were dissatisfied with the time length of post assignment This allegation is close Allegation AMS No. RIII-89-A-0025: The alleger indicated that guards were

" burning out" because they worked an excessive amount of overtime. Also one individual had worked three 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> weeks in a row and another individual had worked 31 consecutive day s

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Review During the security inspections in January, March and July 1989, guards on all three shifts were randomly observed at various times performing most of'the required security functions such as searching, badge issuance, action as various compensatory measures, conducting patrols, responding to alarms and the many varied tasks involved in alarm station operation During those observations, the guards were found to be adequately performing their assigned duties and there were no indications of less than satisfactory guard performance. In all cases they appeared awake, cognizant of their responsibilities and not " burned out."

Moreover, the March 1989 inspection (50-295/89011; 50-304/89011) was specifically conducted to address concerns expressed to the resident inspector by some guards about the potential adverse effect of excessive overtime hours on their work performance as it relates to the protection of the facility. This special inspection was conducted on an expedited basis because one of the comments made by the guards related to an alleged actual incident in which an adequate level of protection was not provided due to a sleeping guar Licensee adherence to NRC Information Notice (IN) No. 86-88, " Compensatory Measures for Prolonged Periods of Security System Failures," which provides guidance regarding maximum work hours, was reviewed. While Ce information containea in the IN does not constitute NRC requirements, it suggests that: An individual should not be permitted to work more than 16 consecutive hour . An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day perio . A break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work period A random review of weekly time sheets for a five-week period covering

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sixteen guards was conducted to determine if hours worked were consistent with the guidelines. The review included the weeks ending January 28, 1989 through February 25, 198 The results of the review indicated that although the NRC guidelines were not significantly exceeded, the number of days worked without a day off ranged from nine to thirty-five days. Additionally, there was one individual who had worked three consecutive 73-hour week We also reviewed records of guard force performance that would potentially contain indications of any adverse effects of long work hours. A review of Incident Report No. 1407 indicated that on February 21, 1989 a security guard was found inattentive to duty while on a security post and Incident Report No.1408 indicated that on February 22, 1989, a security guard was

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I also found inattentive to duty while on a contaminated area monitoring, non-security post. Our review of the licensee's investigation of these incidents showed that security management determined the causes of the two events were due to the excessive number of hours the individuals had worked on jobs away from the plant. No other incidents involving inattentive guards or " burn out" were identifie At our request the licensee did a more extensive review of the actual number of hours worked by guards compared to the guidelines outlined in IN 86-88. Subsequent to the July 1989 inspection, they provided information to the NRC, after reviewing additional time and attendance records for security guards, that indicated there were eight cases in which guards had exceeded the NRC guidelines of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> worked in a 48-hour period. The most the guidelines were exceeded were 4.21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> (28.21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> worked) and all but one case involved voluntary overtime. Also for the same period, there were two cases in which guards exceeded the NRC guidelines of more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> worked in a 7-day period. The most the guidelines were exceeded were 3.78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> (75.78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> worked). One case was voluntary and the other involved required overtime due to report writing. Additionally, the licensee provided information that indicated, for the period December 1988 through June 1989, that there were eight cases of individuals voluntarily working between 31 and 77 consecutive days without days off. The breakdown of consecutive days worked is as follows: 31, 35, 37, 45, 46, 64, 76 and 7 Conclusion:

We concluded that although there were no indications that guards were

" burning out" because of working an excessive amount of overtime, there were examples of individuals working a number of hours which exceeded NRC guidelines. Exceeding NRC guidelines increases the potential for guard performance problems. We confirmed that one individual had worked three 73-hour consecutive weeks and that one individual had worked 31 consecutive days. The amount and quality of overtime and extended work schedules will be routinely monitored in conjunction with guard force performance analysis (0 pen Item 50-295/89025 01; 50-304/89023-01). This allegation is close Allegation AMS No. RIII-89-A-0029: The alleger indicated that on February 21, 1989, at about 4:30 p.m., a guard was found with his eyes shut while on post at a degraded vital area barrier. Also, a one-hour telephone call should have been made to the NRC regarding the inadequate compensatory measure, but wasn't. Thirdly, an initial security incident report (SIR) made by the guard stated he admitted to having his eyes shut i or to being asleep, but a revised SIR stated he admitted to only being i

inattentive. Lastly, on February 22, 1989, a guard was found sleeping while posted on a non-security post at a radiation control point in the fuel buildin . _ _ _ _ _ . __ _____ - - _ _ b

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Review:

During the March 1989 inspection (refer to Paragraph (B)) we reviewed security incident reports (SIR) for January and February 1989 to determine if there were any documented problems relative to guard performance. The review showed two instances of guards who were found inattentive to duty.

l The first incident was documented in Incident Report No. 1407 dated February 21, 1989; Security Incident followup Reports dated February 21, 1989 and March 3, 1989; and a memo dated February 23, 1989, relating to l Incident Report No. 1407. Additionally, the supervisor and security manegement were interviewed on the inciden The records indicated that on February 21, 1989, a named guard was posted as a compensatory measure at a degraded vital area barrier. A supervisor was walking in ti;e area on a routine tour. The supervisor, while observing and monitoring the same area the guard was assigned to monitor, approached the guard and, standing about 5 feet from the sitting guard, noticed his eyes were closed. After an estimated one minute, the supervisor keyed a portable radio and the guard's eyes opened. The supervisor concluded the individual was inattentive and was immediately relieved from post duties. The subsequent investigation showed that approximately two minutes before the supervisor found the guard inattentive, a patrolling guard had visited and talked with the guard who was then obviously attentive. The supervisor stated that, during the intervening time when the guard could have been inattentive, she was in a position to observe and react to any intrusion into the vital area through the barrier. The supervisor provided an equal level of protection as the posted guard had he been completely attentive. The licensee determined that no one hour notification to the NRC or logging of the item was required since there had been no actual degradation of the barrier monitorin The SIR followup report written on February 21, 1989, by the posted guard contained no mention that he was sleeping and he did not admit that his eyes were closed. The document only states that the guard was on post and heard a radio being keyed and looked up and saw the supervisor standing a couple of feet away. According to the statement, the supervisor told him his eyes were closed and was then relieved from pos The SIR followup report written by the supervisor on February 21, 1989, stated that the supervisor noticed that the guard's eyes were closed and when the radio was used, the guards eyes opened. The supervisor's statement does not specifically state the guard was sleepin In a memo to the Station Security Administrator from the APS Site Supervisor dated February 23, 1989, the Site Supervisor states that he determined, after a review of all reports and an investigation, that the guard violated an internal memo dated July 11, 1989, regarding security awareness, by having his eyes closed. Additionally, Incident Report No. 1407 states, in the " Investigation Results" portion, that the guard  !

was not asleep but inattentive, and that the guard had stated that his eyes were closed.

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The second incident of an inattentive guard was documented in Incident-Report No.1408 dated February 22, 1989; SIR Followup Report dated February 22,-1989; and a memo dated February 23, 1989, referencing Incident Report No. 140 The records indicate that on February 22, 1989 a guard stationed at a non-security post was found inattentive to duty by another guard. The 4 guard had been posted at a radiation control post to make sure that no j potentially contaminated tools or equipment crossed from a contaminated area to a clean area without getting surveyed by the Radiation Protection Department. After the guard failed to answer his radio a second guard was j dispatched to the area. The dispatched guard stated that he noticed the <

posted guard's eyes were closed, and when he made a noise by hitting the !

bench, the guard acknowledged him. The posted guard was immediately {

relieved of.his post duties. The posted guard stated he was not sleeping at'the time but may have been dazed or daydreaming due to a lack of traffi Security management determined that the cause for the two incidents related to the number of hours they' worked on second jobs away from the plant. The two guards found inattentive to duty are no longer employed at ,

' Zion Statio Conclusion: _ We concluded that there were two instances of guards found inattentive to duty. The cause of the. inattentiveness was not related to the number of hours worked onsite, but rather the hours worked on a second jo The February 21, 1989 incident was not required to be reported to the NRC because there was no actual degradation of the security syste We also concluded that there was written documentation relative to the February 21, 1989 incident that the guard was inattentive and that the i documents were consistent and accurately reflected the fact This allegation is close