IR 05000324/1993037
| ML20057E378 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/17/1993 |
| From: | Mcguire D, Thompson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057E373 | List: |
| References | |
| 50-324-93-37, 50-325-93-37, NUDOCS 9310120080 | |
| Download: ML20057E378 (13) | |
Text
,.
-
.
.
.
,
.
-
.
l k Rtc UNITED STATES f
- S f
%+4 NUCLEAR REGULATORY COMMISSION
-
REGloN 11 i
y
$
%
101 MARIETTA STREET. N.W., SUITE 2900 j
%
j ATLANTA, GEORGIA 303234199
\\...../
,
i Report Nos.
50-325/93-37 and 50-324/93-37 l
Licensee: Carolina Power and Light Company
.
P. O. Box 1551 l
Raleigh, NC 27602 i
,
!
Docket Nos.
50-325 and 50-324 License Nos..DPR-71 and DPR-62
.
l Facility Name: Brunswick I and 2-j l
Inspection Conducted: August 10-12 and 16-19, 1993
Inspector:
Ali k fD b 9-/ 7 -f.3
David Thompson, Safeguard 1 Inspector Date Signed
\\
Accompanying Personnel: Nancy Ervin, Reactor Security Specialist, Nuclear
!
Reactor Regulation
'
I
) Orysia Masnyk, Safeguards Specialist Walter Stansberry, Safeguards Inspector 9!N Approved by:
o7 David Mciiuire, Chief D'a'te Signed
Safeguards Section j
Nuclear Materials Safety and Safeguards Branch
'
Division of Radiation Safety and Safeguards l
SUMMARY
- -
Scope:
'
This special, announced inspection was conducted to review the licensee's Access Authorization Program as required by 10 CFR Part 73.56. The inspectors examined the licensee's implementation of the access authorization program, to include review of records, procedures, and interview with licensee and contractor personnel.
i Results:
In the areas inspected, one non-cited violation (93-37-01) was identified as follows:
Failure to complete fingerprint checks before granting access, and failure to follow-up each six months to obtain military records
'
(Paragraph 2.f.4.).
l
i 9310120000 930917 D
i PDR ADOCK 05000324 (
l G
PDR L$
-
.
.
-
_
-
-
..
-.
..
...
_
.
-
. -
-.
._.
-. -..- -
-
..
The following strengths were identified:
Documentation and adjudication of background investigations
-
(Paragraph 2.c.).
.
,
-
Contractors sought additional. supplemental information after completion of an employment application to perform background.
investigations (Paragraph 2.c.).
j
-
Appropriate MMPI testing facilities (Paragraph 2.d.).
j
-
A detailed criminal history check program-(Paragraph 2.c.).
-
An automated fingerprint tracking system (Paragraph 2.c.).
.
-
Excellent access authorization records (Paragraph 4.h.).
!
-
Local criminal history record checks (Paragraph 2.c.).
'
-
Department of Motor Vehicles check (Paragraph 2.c.).
,
-
An aggressive self-audit program (Paragraph 4.1.).
,
l I
r
i
i
l l
t l
i
,
'
y..
9.-c...
y.q,. p 7
,.
--
'
!
L REPORT DETAILS 1.
Persons Contacted Licensee Employees l
- R. L. Barham, Manager, Safety and Occupational Health
- R. Godly, Regulatory Compliance, Brunswick Nuclear Plant (BNP)
- W. Hatcher, Manager, Corporate Nuclear Security
- J. Houck, Nuclear Licensing Engineer
- C, Ide, Human Resources Assistant l
- T. Jones, Regulatory Compliance, BNP l
- P. D. Leslie, Manager, Security, BNP
- D. Morgan, Manager, Nuclear Plant Support Services
- B. Poteat, Manager, Vendor and Equipment Quality AB. Randiett, Senior Security Specialist i
l
- F. Underwood, Director, Fitness-for-Duty
'
- G. H. Warrina, Manager, Plant Support Services, BNP i
Other licensee employees contacted during this inspection included craftsmen, engineers, operators, security force members, technicians, and administrative personnel.
t
- Attended exit interview
- Exit Interview conducted via telephone 2.
Access Authorization Program (AAP)
a.
10 CFR 73.56, the NRC requirement for an AAP, was effective on May 28, 1991. The program was required to be implemented by the licensee by April 27, 1992. The intent of the Rule is to ensure that those individuals granted unescorted access to nuclear power plants are trustworthy, reliable and do not pose a radiological threat to the safety of the public.
Licensees meet the Rule's intent through pre-access background investigation, psychological evaluation, and behavioral observation, all of which are elements of the AAP.
By letters dated April 9, 1992 and June 29, 1992, the licensee submitted Revisions 14 and 14A to its Physical Security Plan committing to an AAP that satisfies the requirements of 10 CFR 73.56, as detailed in Regulatory Guide 5.66, " Access Authorization Program for Nuclear Power Plants." The appendix to Regulatory Guide 5.66 provides the industry with the Nuclear Management and Resources Council's (NUMARC) Guidelines 89-01 dated August 1989, titled " Industry Guidelines for Nuclear Access Authorization Programs" which, with exceptions and clarifications
,
as indicated in the Regulatory Guide, meets the intent of the Rule.
-,_
_
..
_.
_
..... i
l~
2 The licensee's AAP falls under the Human Resources Department and I
is generally administered by the Director of the Fitness-for-Duty Program. The Employee Services Department administers the program at the site and handles the fingerprinting, information gathering,
'
and recordkeeping for applicants and employees. An interface document dated July 17, 1990, delegated the responsibility for the
osersight of the contractors' AAP to the Security Department, which handles the processing of access authorization for contractors. The AAP for CP&L information flow is through the
'
Human Employee Services Department to corporate Human Resources.
The Security Department adjudicates contractors' criminal histories and grants contractors unescorted access,
,
i Procedures
>
The licensee developed 27 procedures and guidelines in the corporate " Background Investigation Screening Procedures" to implement its AAP. An additional procedure, " Personnel Screening Criteria for Non-Licensee Personnel," was furnished to contractors to be used in their adherence to the licensee's program. The licensee also provided Regulatory Guide 5.66 and related Information Notices to contractors in addition to communicating through information memos as necessary. The primary procedure,
" Screening Practice and Procedures" addressed elements and responsibilities of the licensee's program. The inspectors determined during review that the procedures address only the appendix (NUMARC 89-01) to Regulatory Guide 5.66, " Access Suthorization Program for Nuclear Power Plants;" the procedure f'iled to address Regulatory Guide 5.66 Clarifications and Exceptions to NUMARC 89-01. The inspectors also noted that the Screening Practices and Procedures stated that screening for employment is required and guided by Federal Regulations such as 10 CFR Part 26 and 10 CFR Part 73.56. During discussion the licensee was informed that the rules are requirements for granting employees unescorted access to protected and vital areas of nuclear power plants, not employment requirements. The licensee
initiated measures to correct the procedures during the inspection, and provided a clarifying memo to the contractors directing them to also correct their procedures. Although the procedures contained incorrect references, the Rule was being adhered to in all cases reviewed.
c.
Background Investiaations The licensee's Human Employee Services Department processes employment applications and fingerprints. The background investigations for CP&L applicants and employees are performed by contractors, Stone and Webster or Wells Fargo. As an enhancement to the requirements contained in Regulatory Guide 5.66 the licensee also obtains motor vehicle reports; verifies any education claimed as a qualification for the job, regardless of time; and obtains local criminal history record checks from areas
-
-
-. -
l
where the individual has lived, worked or attended school in excess of 30 days. Self-screening contractors perform their own background investigation or utilize a subcontractor.
Site records
,
were reviewed for two contractors, Burns and Becon.
The Burns personnel specialist performs the background investigation after reviewing the individual's application and supplemental information. The individuals who were interviewed were knowledgeable of the CP&L and NRC AAP requirements. Those records reviewed were found to be well maintained, complete, and all required information was documented.
Becon utilizes a contractor, Private Professional Services, to complete the background investigations. The site security department takes the
.
'
contractors' fingerprints and sends them to the Employee Services Department for processing.
In all cases, the Employee Services Department pursues the disposition of all information obtained as a result of the fingerprint check. The Employee Services Department evaluates all derogatory information for licensee
.
employees. Contractors evaluate apolicant's derogatory information and submit a summary to the Site Security Department.
The Security Department utilizes this summary, the fingerprint history, and any additional information obtained from the contractor as needed to grant permanent access or revoke the temporary access authorization.
The contractors maintain files
,
for their employees. Human Resources maintains the licensee's files in addition to contractor criminal history records.
As part of the inspection, five records of individuals with unescorted access were reviewed for each of the contractors and licensee. Discussion with licensee and contractor personnel and review of employee records and related documentation revealed that the licensee's program for conducting background investigations met regulatory requirements. Adjudications of unfavorable information was documented.
The licensee followed a procedure, Criminal History Record Check i
Program, revised May 21, 1993, which very clearly delineates the l
process of obtaining and processing fingerprints and the review of resulting information. This procedure provides guidelines as to
,
what is considered adverse information and provides a matrix for
)
adjudicating unfavorable information.
This standardizes the
'
process and removes potential subjectivity. Another strength of the licensee's program is its use of an automatic Fingerprint Tracking System which allows the user to monitor fingerprint records.
As an additional enhancement the inspectorss noted that the two contractors solicited information about arrests and convictions prior to performing the background investigatio.
.
.
.
-
.
1
<
!
d.
Psycholoaical Evaluation The licensee and its contractors administer the Minnesota
!
Multiphase Personality Inventory 2 (MMPI) which, if warranted, is followed by a clinical interview. The inspectors reviewed testing procedures and facilities at the licensee's corporate office and site, and also the contractor's facilities at Brunswick. All l
personnel responsible for testing required positive identification l
from the applicant.
Facilities were appropriate and test
!
materials were secured when not in use.
Required certification of successful completion of the MMPI was present in all records reviewed. The inspectors determined that the Becon 'est administrator intermittently proctored the examination and did not stay in the room with the testees in all cases. The corporate security manager was in attendance and informed the administrator that full proctoring was required to ensure consistency with licensee requirements. A memo was provided to all contractors emphasizing the method for proctoring. NRC Information Notices 88-91, " Improper Administration and Control of Psychological Tests" and 91-59 " Problems with Access Authorization Programs" had been provided to the contractors.
The inspectors interviewed one of the psychologists utilized by the licensee. He demonstrated a knowledge of the AAP requirements in reference to psychological testing.
e.
Behavioral Observation Procram (BOP)
The inspectors reviewed the licensee's lesson plans for guidance i
for detecting aberrant behavior. Aberrant behavior training is l-provided to supervisors during the Fitness-For-Outy (FFD)
training. The licensee, as of September 1, 1993, will provide aberrant behavior training to all employees, not just supervisors I
as in the past. The training has been revised to include addressing personnel reliability and trustworthiness issues as they relate to 10 CFR 73.56.
l l
Twenty individuals were interviewed as to their understanding of l
personnel reliability, continued behavioral observation, and
!
responsibility to report arrests. These 20 individuals consisted l
of ten supervisors and ten contractors, five out of each group
'
were supervisors, and five were employees. The individuals appeared to have a better recall of the drug and alcohol training and less recall of the aberrant behavior training. Overall, those persons interviewed had an adequate memory of their training. The answers varied from reporting any contact with law enforcement agents to reporting only felony convictions. The licensee has made aggressive efforts to make employees aware of their responsibil-ities to report arrests by utilizing newsletters, memos, training, and plant information screens.
,
.
-
-
_.
_
_
, '
L
.
I l
Regulatory Guide 5.66 (Clarifications, Paragraph 3) expects the j
licensee to ascertain an-employee's activities while absent from a.
'
continued observation program for greater then 30 days.
Plant procedures assign this responsibility to the' individual's l
supervisor, but only the Burns supervisors seemed aware of the
,
l responsibility to do so. To ensure that ascertaining takes place
,
the Security Department.recently implemented two measures. One
!
initiative requires the security department to place badges' that
have not been used in 30 days in a " lost badge" status, disablinc
!
l the badge.
In order for the badge to be reactivated the employee
!
and supervisor must provide a form in which the employee attests
to his continued participation in a behavioral observation program l
I l
or the supervisor ascertains his activities. During discussion the licensee stated that they considered employees that were on-i temporary assignment to be.under their usual supervisor's i
responsibility. This supervisor may or may not be present while i
the individual is assigned to the temporary assignment. The-l
l inspectors informed the licensee that in order to meet.its B0P
,
commitment, the individual would have to be subject to chservation
by a trained supervisor where the. individual was locatet on the
!
!
temporary assignment. The licensee's current computer systems
,
l requires an individual to be actually badged at a site to be.
'
included on the FFD and AAP lists -and in the programs, resulting-
,
in unnecessary badging. Therefore, the site security staff was
!
somewhat hampered in their efforts-to use the "30 day badge pull"
'i list since numerous personnel are badged at the site without
>
l needing the badge routinely. The licensee stated that new
!
programming was being developed to maintain a pool of "badgeable" individuals, without requiring them to be badged.
l f.
Unescorted' Access Authorization - Grandfatherino, Reinstatement.
Transfer and Temporarv l
,
1.
Grandfatherina
i.
'
l Discussion with licensee and contractor personnel and' review
!
of selected records of personnel who were hired prior to October 28, 1990, by both the licensee and contractors,
!
l disclosed that these individuals were properly
!
I grandfathered. They had an uninterrupted access l
authorization for 180 days on April 25, 1991. The licensee
.
had a strong access authorization program in place prior to l
I implementation of the AA Rule.
i 2.
Reinstatement The licensee's procedures allow for reinstatement of access
'
authorization.
If unescorted access was interrupted for 30 days or less the individual can be reinstated without further action, if training is current. For interruptions greater than 30 days but less than 365 days the individual must undergo FFD testing and activities during this absence
-
.. -.
. - _,. -. - -
.-.- -.. -
-
~.-. - -... -., -. -. -. -. - - -
.
, --
.
..
.
--
-
. -.
-.
..
,
b^
.
-
i
!
h 6.
!
t i
must be ascertained to determine the impact on trustworthiness and reliability. Absences greater than 365
days require an MMPI, fingerprint submittal, background t
.
'
update and FFD testing.
Only a few reinstatement records
were available, but those that were reviewed were found to j
j be correct.
,
i i
3.
Transfer
i i
The licensee utilized NUMARC 91-03'and associated forms to
'
transfer access authorization in or out. Several records
,
were reviewed and found to be adequate.
It was noted that'
-
The licensee develops further information in some cases when accepting an access authorization transfer. At least one
'
-
contractor, Becon, also requires supplemental information
when accepting a transfer. Any derogatory supplemental
information is reviewed and adjudicated prior to granting
!
"
unescorted access. This was considered a strength to the AAP.
i 4.
Temporary i
The licensee grants temporary' access authorization for 180 l
days while waiting for the results of. fingerprint checks and
military history records. Review of records of individuals j
with temporary access authorizations disclosed that all
!
.
background investigations and MMPIs had been completed
'
,
j except in three cases, which are discussed below:
i Two examples were identified where temporary access authorization was granted prior to submittal of
'
fingerprints.
In one case the failure was attributed to a
!
communications error, in the other case the individual was i
being re-hired and a 365 day lapsed in service had occurred.
To correct the first example the licensee no longer relies l
on telephone communication to detcrmine the status of
!
fingerprint submittals. Also fax machines-were installed to l
ensure hard copy records are available prior to granting i
access. The examples listed above were discovered by the licensee.
In the second event the Human Relations l
Department discovered that a contractor had failed, (on
three individuals), to re-attempt to obtain military records
~;
every six months. To correct the deficiency the licensee
.
and contractor had initiated a " tickler" file to alert them
'
in advance to again request the military records. The i
examples of failure to complete all elements required for j
temporary access authorization will be considered a non-
'
cited violation in that the criteria of the Enforcement Policy,Section VII.B(2) has been met (93-37-01).
i l
.---.
.-..
. -.
-
-.-
-
.-.
- - _ _
._
_
.
.
__
_
.
.
-
.
.
7
i g.
Denial or Revocation of Unescorted Access j
,
1 As discussed previously, the licensee'.s guidance on denial or revocation of unescorted access is delineated in the procedure on-
processing fingerprints. Guidelines are provided as'to what constitutes derogatory information and a matrix is included for
-
adjudicating criminal histories. The licensee's Human Relations Department aggressively reviews any negative information developed during background investigations for licensee employees, and-
'
acquires dispositions for all criminal history checks. During the deliberation of denial or revocation of permanent access, the
,
applicant or supervisor for both the licensee and contractors are i
frequently interviewed during the process. Contractors are advised of their right to appeal a revocation of access'when they j
are first hired.
In all cases the letter informing the individual i
of the revocation of access also informs of the right to appeal.
!
I The inspectors reviewed several files where an individual's access -
authorization was revoked after receipt of the fingerprint criminal history record.
In most examples, the individual who was
denied access had failed to list convictions. The inspectors
'
reviewed a case where an individual had manufactured an entire
background to include false name and social security number, and i
the given and developed references were a part of his plan to deceive the contractor conducting the background investigation.
i Although the applicant indicated that there were no arrests or
convictions in his past, when the criminal history was returned it
-.
f showed numerous convictions.
Additionally, the' fingerprints had identified the individual's correct name and criminal history.
,
The licensee confronted the individual and he admitted that he was
the person whose name was on the returned fingerprint record. His
~
access was immediately revoked. This event is discussed in the
,
licensee's Security Event Report 1-93-500, dated August 20, 1993.
j l
h.
Records and Privacy Information
-
Review of records, discussion with licensee and contractor personnel and review of records storage facilities and methods disclosed that information provided or developed in the access authorization process was safeguarded against unauthorized
.
disclosure and accessible only to those involved in the access authorization process or those auditing the program. The records I
were complete, well organized, and readily available.
i.
Audits The inspectors reviewed the licensee's AAP audits to determine if the audits had been conducted as required. The inspectors reviewed the licensee's audit of the Corporate program and eight contractor programs.
,
_
. --
_ __ _
-
.
-
-
-
The licensee's Vendor and Equipment Quality Group a part of the Corporate Quality Assurance Department was responsible for conducting the audits of the contractor and corporate AAPs.
The inspectors determined that the licensee was a member of Shared Nuclear Access Authorization Audit Group (SNAAG) which is a group of licensees who have agreed to accept each others audits of
~
contractors who administer an AAP. The SNAAG auditors conducted individual or team audits.
The corporate auditors were also responsible for preparing and updating the very comprehensive checklist for SNAAG auditors.
Review of randomly selected audits to include the licensee and contractor programs revealed that the ' audits were indepth and detailed.
It was noted while reviewing the contractor audits that from January 1992 thru July 1993, the licensee had conducted 110-audits; that 10 of the contractors audited had been found unsatisfactory and nine of the 10 programs had been reinstated after re-inspections. One contractor had continued to fail to meet the licensee's AAP standards.
It was also noted that the licensee had discovered 219 'non-conformance items deMng their audits. The licensee had reviewed the non-conformance items and had categorized them into 23 specific categories in an attempt to determine if the AAP needed to be enhanced with better procedural guidance.
The inspectors determined that, although the licensee had found a significant number of non-conformmce issues with the contractors programs it was determined after further evaluation and follow-up audits that none of the non-con'ormance issues had allowed an unauthorized individual access to the site. Documentation reflected that audit findings were appropriately identified, tracked, and necessary correc'.ive actions implemented. The numerous non-conformance issies noted by the auditors were not a result of inadequate procedural guidance, rather the result of the auditors' desire for more complete and auditable records.
Therefore it appears that tne audit' program is a strength, and provides an assurance to the licensee that the contractor AAP programs are in compliance with their requirements 3.
Action on Previous Inspection Findings (92701)
(CLOSED) 93-21-01.. This violation dealt with the fact that the licensee did not have a procedure for-the adjudication of contractors' criminal history records.
The licensee has written and implemented Security Procedure Instruction SI-23, Fingerprinting and Criminal History Record Check for Non-Licensee Personnel. This is a comprehensive procedure for the processing and adjudication of criminal history record In addition to the lack of procedure, the previous inspection report noted that documentation supporting criminal history adjudication was sketchy and lacking detail, requiring the interpretation or recollection of the adjudicator.
Records generated since the previous inspection were found to be detailed and contained rationale for adjudication.
The previous report also discussed an apparent weakness in the audit program in that the licensee's adjudication process of the contractors'
records had not been audited. By letter dated May 28, 1993, the licensee stated that such an audit was performed April 12-15, 1993, by the Vendor and Equipment Quality Unit. The auditors provided recommendations to be incorporated into a procedure for use in the adjudication of licensee and contractor records. This adjudication process has been standardized. A memo dated April 26, 1993, from the Vendor and Equipment Quality Unit to the Brunswick Security Manager contained suggestions as to elements required in an adjudication process procedure.
A memo dated July 7,1993, from the Vendor and Equipment Quality Unit to the Director of the Fitness-For-Duty Director delineated the findings of the AAP audit conducted June 21-30, 1993. These findings were discussed with the Fitness-For-Duty Director and Corporate Nuclear Security Manager. The inspectors determined that corrective actions were taken where necessary.
During the previous inspection, concerns were raised with the Becon clearance program relative to recordkeeping practices.
Subsequent to the NRC inspection conducted March 29-31, 1993, the Vendor and Equipment Quality Unit conducted an audit of the Becon screening program on April 12-16, 1993. The audit findings were summarized in an report issued on April 29, 1993, to the Becon Construction Company Senior Vice President and Manager. A letter dated June 4, 1993, from the licensee to Becon partially closed some of the findings based on Becon's response dated May 27, 1993 and subsequent phone conversation of June 1, 1993.
Supplemental response was provided by Becon in a letter dated June 7, 1993. An audit of the Becon corrective measures was conducted by the Vendor and Equipment Quality Unit on July 28, 1993. A letter dated August 5, 1993 to Becon found the Personnel Screening and Fitness-For-Duty programs satisfactory and the audit was closed. The findings dealt mainly with the failure to obtain, evaluate, and adjudicate unfavorable information. Becon obtained information from all badged employees relative to criminal history, credit, and reliability and compared this information to the employee's application. All unfavorable information and discrepancies between the information gathered and that supplied in the application were reviewed and resolved.
Concurrently, the licensee obtained applications from all contractors and compared them to the criminal history records and evaluated discrepancies. A total of 387 Becon applications were reviewed with 16 discrepancies noted.
Individuals were interviewed as to why the criminal histories were left off the application. The consensus was that there was a misunderstanding as to the length of time to be
.
.
-
.
'
!r.
.
'
considered on the application. The employees thought that application queried for a five year period versus the entire adult history.
Fifty-six additional contractor records were reviewed and adjudicated. As a result of this adjudication process, seven access authorizations were revoked. Several reviews were still in progress at the time of this inspection.
l Additionally, the licensee conducted a self-assessment of the Brunswick AAP July 12-28, 1993. The findings are summarized in the licensee's j
Report Number S-93-01. The assessment disclosed strengths in the site l
security staff and in the support to the program provided by Personnel
!
Relations. The report lists several recommendations for improvements to procedures.
Several findings relative to access control were identified and corrected; they are addressed elsewhere in this report. These deal with improvements in the use of 30 day non-use badge pulls, tagging out l
of badges placed in " lost status" to preclude their use, and the l
tracking of fingerprint submittals and military service record requests.
!
!
The licensee sent a memorandum to contractors subsequent to the March NRC inspections to transmit concerns identified. A memo dated April 16, 1993, " emphasizes the responsibility of CP&L contractors regarding the evaluation of omissions or falsifications on employment applications and other information used in the process of requesting unescorted access authorization" and "provides guidance to contractors on additions, deletions, and changes to the information provided." A memo dated July 14, 1993, solicited additional information regarding the status of military history record investigations and revised the CP&L Request for
Unescorted Access Authorization. A memo dated August 16, 1993, provided I
clarification to the CP&L Personnel Screening Criteria for Non-Licensee Employees and emphasized that contractors must consider and comply with all elements of Regulatory Guide 5.66 (June 1991) in the implementation of CP&L's AAP. This memo emphasizes the clarifications to NUMARC Guideline 89-01.
It reminds the contractor of requirements for l
termination, reinstatement and transfer of unescorted access, continual behavioral observation program, and termination of access. This last memo addressed and corrected issues raised during this inspection.
4.
Exit Interview The inspection scope and results were summarized on August 19, 1993, with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed below. The inspectors noted that the licensee had established l
dual responsibilities for the AAP.
Responsibility for applicants and l
CP&L employees belongs to Human Relations and respon.ibility for contractors' AAP belongs to the Security Department. The licensee was advised of the apparent findings of the inspection. One apparent violation is relative to the failure to complete fingerprints before granting access and the other is three examples of failure to continue request military records each six months. On September 17, 1993, the CP&L Corporate Security Manager was advised that both of the above
I examples will be cited as one licensee identified non-cited violation.
l
I i
.
.
.
-
~
.
The licensee was also informed that during the inspection immediate corrective actions were noted and appeared adequate; therefore, these items would not be considered as needing follow-up action. The licensee
'
was informed that several strengths were noted concerning the AAP and J
are discussed in Paragraphs 2.c., 2.d., 4.h., and 4.1.
It was noted that the licensee exceeded the required regulations of the AAP. The licensee was advised of several inconsistences between existing procedures and Regulatory Guide 5.66 in which the licensee had failed to address the clarifications to the NUMARC guidelines. Corrective measures were in progress at the end of the inspection.
The licensee indicated that they believed the apparent violations should
be considered licensee identified violations.
Proprietary information is not contained in this report.
,