IR 05000305/1988004

Insp Rept 50-305/88-04 on 880125-29 & 0202-04.One Open Item Identified Re Security Contractor Continuing Observation Program.Major Areas Inspected:Access Control - Personnel & Personnel Training & Qualifications

ML20153C409
Person / Time
Site:	Kewaunee
Issue date:	04/20/1988
From:	Creed J, Funk D, Madeda T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20153C386	List: IR 05000305/1988004 ML20153C384
References
50-305-88-04, 50-305-88-4, NUDOCS 8805060224
Download: ML20153C409 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-305/88004(DRSS)

Docket No. 50-305 License No. OPR-43 Safeguards Group IV Licenseet Wisconsin'Public Service Corporation Post Office Box 1200 Green Bay, WI 54305 Facility Name: Kewaunee Nuclear Power Plant Inspection At: Kewaunee Site, Kewaunee, Wisconsin Inspection Conducted: January 25-29 and February 2-4, 1988 Type of Inspection: Reactive Physical Security Inspection Date of Last Physical Security Inspection: March 16-20, 1987 Inspector: n frodi,t+ 4/19/t?

TerryfJ/ Madeda D&te/

Physical Security Inspector

'"M'@ D. &c A - Donald E. Funk, J vinin Date Physical Security Inspector Approved By: kAmb 88 es R. Cre'ed, Chief Date

@feguardsSection sa Inspection Summary Inspection on January 25-29 and February 2-4, 1988 (Report No. 50-305/88004(DRSS))

Areas Inspected: Included a review of Access Control - Personnel; Personnel Training and Qualifications - General Requirements and allegations pertaining to the licensee's fitness for duty program and inappropriate on-duty activities

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by guard Results: The allegations were not substantiated and the licensee was found to

be in compliance with NRC requirements within the areas examined during this

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inspection. One open item was identified pertaining to the security j contractor's continuing observation program.

l Attachment Contains , 8805060224 880503 Upon Separation This

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{DR Pa6e 18 Docontrolled L

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DETAILS

' Key Persons Contacted In addition to the key members of the licensee's staff listed below, the inspectors interviewed other licensee employees and members of the security organizatio The asterisk (*) denotes those present at the Exit Interview conducted on February 4,198 *C. Steinhardt, Plant Manager

• C. Schrock, Nuclear Engineering, Assistant Manager

• D. Nalepka, Plant Licensing Supervisor

• D. Dow, Plant Security Supervisor

• R. Draheim, Plant Services, Assistant Manager D. Ropson, Nuclear Licensing, Superintendent

• D. Molzahn, Nuclear Licensing, Assistant Superintendent

• D. Andrews, Projects Hanager, Burns Security

• Rhode, CAS Supervisor, Burns Security B. Pagel, Security Officer, Burns Security E. Anderson, Assistant States Attorney, Kewaunee County D. DeCramer, Chief of Police, City of Kewaunee R. Gardner, Investigator, Kewaunee County Sheriff's Department

• R. Nelson, NRC, Senior Residc.nt Inspector J. Stewart, NRC, Resident Inspector Entrance and Exit Interviews (IP 30703) At the beginning of the inspection, the Plant Security Supervisor was informed of the purpose of this visit and the functional areas to be examined, The inspectors met with the licensee representatives denoted in Section 1 at the conclusion of the inspection on February 4,198 No written material pertaining to the inspection was left with the licensee or contractor representatives. A general description of the scope of the inspection was provided. Briefly listed below are the findings discussed during the exit interview. The details of these findings are referenced, as noted, in this repor Included below is a statement provided by or describing licensee management's response to each findin (1) No violations were identified regarding NRC requirement (2) Three specific allegations pertaining to excessive alcohol use and affairs between security force members / post performance were reviewed. None of the allegations were substantiate (Refer to Section 4)

Af,tachment Contains 2 SAFEGUARDS IEFORMATION Upon Separation This l' age Is Decontrolled

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(3) Licensee representatives were advised that our inspection activities concluded that the security contractor's continuous observation program should be strengthened. The licensee was requested to respond to this issue. (Refer to Section 2 of the attachment for detailed information.)

Licensee representatives acknowledged the inspector's comment Licensee management personnel commented that they had already begun a review of the security contractor's observation program as a result of both licensee and NRC concern . Clear Functional / Program Areas Inspected (MC0610)

Listed below are the areas which were examined by the inspectors within the scope of these inspection activities. These areas were reviewed and evaluated as deemed necessary by the inspectors to meet the specified

"Inspection Requirements" (Section 02) of the applicable NRC Inspection Procedure (IP) as applicable to the security plan. Sampling reviews included interviews, observations, testing of equipment, documentation review and at times drills or exercises that provide independent verification of your ability to meet security commitments. The depth and scope of activities were conducted as deemed appropriate and necessary for the Program Area and operational status of the security syste Number program Area and Inspection Requirements Reviewed

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81070 Access Control - Personnel: (01) General Access Control Requirements; (02) Protected Area Access Control; (06)

Searching and Search Equipment; (08) Access Control Facilities a.1d Equipmen Training and Qualification - General Requirements: (01) General Requirements; (02) Training and Qualification Program; (03)

General Training; (05) Documentation; (06) Employment Suitability and Qualification Criteri . Investigation - Allegation Review (IP 99014)

The following information, provided in the form of allegations, was reviewed by the inspectors as specifically noted below: Background: (Closed) Allegation No. RIII-87-A-0158. The allegation was received by NRC:HQ on Decemoer 1, 1987, in the form of an unsigned, undated letter. They forwarded it to Region III by memorandum dated December 2, it37. It mentions an opinion that the company has a "lack of concern about employees." It uses as examples alleged high rates

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of divorce, separations, troubled marriages, excluding a spouse from Attachment Contains SAFEGUARDS INFCRMATION Upon Separc. tion Thia 3 Pago I0 Docontrolled

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a party, and on duty relation between guards. The alleger suggests that NRC conduct a survey on these matters. While of concern to the alleger, these non-safety related matters fall outside the scope of NRC responsibility and were not specifically pursue Three specific matters also alluded to in the letter do fall within NRC's purview and were addressed. The first three deal with the Fitness for Duty program and on-duty performance of guards. The last alluded to matters independently identified by Region III staff as a potentiel concern before this letter was receive The conce-n dealt with the required behavioral observation program and its implementation relating to the homicide of a security guard that occurred several months ago. The letter mentions the homicide as another example of perceived problems. The significance of that issue is handled separately and is reviewed from a programmatic stand point in Section 2 of the attachment to this report. The following represents our review of the three identifiable matters culled from the unsigned lette b. NRC Review Action:

(1) Allegation: Licensee plant personnel have a high rate of alcohol problem Allegation Review: Inspection results determined that in mid 1984 the licensee developed the Kewaunee "Fitness for Duty" program and by November 1984, the program was reviewed and approved by licensee senior corporate management for implementation and was in effect at the time of this inspectio The program includes a alcohol abuse program that outlines the action to be taken to identify alcohol abuse problems and action to be taken when a problem is identifie The action to address identified alcohol use problems includes initial counseling by a company employee trained in alcohol abuse identification and further assistance from a independent professional counseling organization. Employees were briefed on the company's drug and alcohol abuse policy in January 198 The briefing included a description of supervisory guidelines for administering the company policy regarding alcoholic beverages and drugs; supervisor's role in identifying problems; and the referral proces In order to show support for the program and to demonstrate the high level of interest, senior licensee nuclear managers participated in conducting these meeting Specific site supervisory training sessions were begun in January 198 Based on a review / comparison between the licensee's program and

, the EEI guidelines, the licensee's policy was developed and generally complies with the NRC supported Edison Electric Institute (EEI) "Drug and Alcoholic / Fitness for Duty Policy,"

dated August 198 (NOTE: Cn August 4, 1986, the NRC l

Attachment Containa SAFZGUMIDS IllygB01 TION 4 30Taration This Pa6e la Decentrolled

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published the "Commission Policy Statement on Fitness for Duty of Nuclear Power Plant Personnel" in the Federal Register. The policy comments favorably on the EEI guidelines as a means for licensees to establish a program. Those guidelines are not mandatory.) Inspection activities also confirmed that the drug and alcoholic training program is conducted on a recurring basi Statistics obtained from the licensee's Human Resources Department, which is the administering group for the licensee's

"Fitness for Duty" program, showed that during 1987, six company employees were admitted to the licensee's alcohol abuse program. Only one of the six employees worked at the Kewaunee site. That employee had voluntarily entered the licensee's program. The licensee also stated that there are currently 2,474 employees company wide, of which 287 are currently assigned to the Kewaunee site. The data supplied by the licensee shows a rate of identification and treatment within the company of approximately .002%. At the Nuclear Plant the rate is approximately .003%.

Conclusion: The inspector confirmed that the licensee has developed and implemented a "Fitness for Duty" program which includes an alcohol abuse identification and treatment program. This program generally follows the NRC supported EEI guideliner,.

The allegation that licensee plant personnel have a high rate of alcohol problems was not substantiated. A small number of company workers appeared to have alcohol problem They were identified and treated and pose no apparent threat to the safe operation of the facility.

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(2) Allegation: The company encourages the use of alcohol at l partie Allegation Review: We reviewed the licensee's alcohol abuse policy, which is found in the Personnel Manual and is entitled

"Alcoholic Beverages and Drugs" (Policy Number 55.10, dated April 16, 1986). The policy requires that employees not be

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allowed to work under the influence of alcoholic beverages nor

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work. Employees must also comply with the intent and letter of driving laws for the State of Wisconsin as they relate to alcohol consumption. The policy states that the company will not purchase alcoholic beverages for social events whether they be company or non-company sponsore The policy does, however, acknowledge the use of alcoholic beverages at those events, in moderation, and only if voluntary employee contributions are used to purchase alcoholic beverage Mtachment conbina I SAF7.GU:J s y,;(,.,3 n ,

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Inspection activities showed that during 1987, ten company or non-company events were held at which beer was consume The purchase of beer was partially funded by the "Kewaunee Nuclear Plant Social Fund," which includes a finance percentage of vending machine sales and by the sale of "souvenir" item Interviews with senior site management personnel confirm that the' actions of the social fund are independent of the company and that the company provides no financial support for alcoholic

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beverages. Further interviews with site senior management personnel and the site security supervisor confirmed that tney were aware of the fact that alcoholic beverages were consumed at those social events. Supervisors have a responsibility-to monitor party activities. The site security supervisor also confirmed that during a non-company sponsored function (post-refueling outage party on March 27,1987) beer, ribs, and chicken were served and that the social fund purchased the beer. Review of social function records confirmed this fac None of the interviewed senior site managers indicated that the company had purchased alcoholic beverage Conclusion: The allegation that the company encourages the use of alcohol was not substantiated. The inspectors confirmed that the licensee has a company policy, that allows the use of alcoholic beverages in moderation at company sponsored and non-company sponsored events. The policy states that the company will not purchase alcoholic beverages for those event Alcoholic beverages are not funded by the company. Interviews confirmed that alcoholic beverages are consumed at company related event (3) Allegation: An "affair" took place on company property during the midnight shift. (NOTE: this implies required duties were not accomplished.)

Allegation Review: The implications of a potential "affair" or other personal relationship between guards is beyond the scope of NRC's interest. However, the potential that an "affair" may take the form of actions that would be inconsistent with adequate duty performance is relevant to NRC's interest. This implied aspect of the anonymous allegation was reviewe Inspection activities included a review of the security contractor's method for monitoring effectiveness of security guard performance and a review of the specific training that security supervisors and guards receive to assure that job functions are being adequately performed. Interviews with ten supervisors and guards were conducted to assure that the program is being adequately implemented.

l Attachment Contains SAFEOUARDS IIiFORMATION Upon Separation This

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-The licensee's contract security management (Burns) utilizes a combination of electronic and programmatic practices such as personal observation techniques, to assure that an adequate level of post performance is being maintained. Electronic measures includes the Access Control System (ACS) which electronically monitors and records most required guard activities through keycard use. Programmatically, individual post assignments (compensatory measures) are rotated hourl Post assignments are changed daily without advance notic Supervisors conduct multiple unannounced post assignment checks per shift to assure post performanc Interviews with security supervisors showed that no post performance problems attributable to "affairs" have been identifie Interviews with the Burns contract security manager and a review of records showed that Burns has a "Code of Conduct" procedure, dated May 31, 1985, and a "grounds for dismissal" policy. Neither document specifically addresses action to be taken against an employee involved in an onsite affai However, the documents do address disciplinary action for instances of negligent work performance and failure or delay in carrying out assigned work. The Burn's site manager stated that engaging in an "affair" onsite would be addressed as a negligent performance. The Burn's site manager stated that disciplinary action would be taken if a Burns employee did participate in an affair onsit Eight randomly selected security force members (supervisors and guards) were interviewed individually regarding their knowledge of the policy of disciplinary action related to failure to perform their duties and if they were personally aware of any such occurrences. All indicated that on-duty affairs would not be condoned by supervisors and that disciplinary action would be taken if duties were not performed. None were aware of any such occurrence Interviews with senior site security management confirmed that during the early part of 1986, rumors had circulated that a female security guard and contractor were involved in sexual activities onsite. The licensee and the security contractor at the time (RRS Inc.) initiated an inquir Results of the inquiry could not confirm the rumor However, the guard was terminated in March 1986 for poor work performance not related to the rumored affair. (NOTE: Upon termination of RRS's contract with the licensee, the security contractor removed all security contract related records. One of which involved the investigation of this event.) Since that time, neither the licensee nor security contractor have received indications of any other onsite social affai Attachment Containe Upon Separation Thia 7 Page IS Docontrolled

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Conclusion: The inspection confirmed that the licensee has a multi-faceted program which utilizes a combination of electronic and supervisory observation / management techniques to assure that an adequate level of on-site performance is being maintained. Action has been taken when poor performance was identified although none of the cases of poor performance were attributed to "affairs." The allegation was not substantiated.

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