IR 05000327/1993034

Insp Repts 50-327/93-34 & 50-328/93-34 on 930712-16. Violations Noted.Major Areas Inspected:Access Authorization Program

ML20056E300
Person / Time
Site:	Sequoyah
Issue date:	08/12/1993
From:	Mcguire D, Tobin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20056E294	List: IR 05000327/1993034 ML20056E292 ML20056E295
References
50-327-93-34, 50-328-93-34, NUDOCS 9308230155
Download: ML20056E300 (12)

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UNITED STATES l

@g e.co\ NUCLEAR REGULATORY COMMISSION l h, 2% REGION if I

6 101 MARIETTA STREET, N.W., SUITE 2900

. ATLANTA, GEORGIA 30323-0199 l

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%, .....f Report No /93-34 and 50-328/93-34 ,

Licensee: Tennessee Valley Authority  ;

3B Lookout Place ,

1101 Market Street '

Chattanooga, TN 37402-2801 l Docket Nos. 50-327 and 50-328 License Nos. DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 Inspection Conducted: July 12-16. 1993 Inspector: h m ' [ dd,mnom O'/b 73 .

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William J. Tobin,(Senior Safeguards Inspector Date Signed Accompanying Personnel: 0. M. Masnyk, Safeguards Specialist D. H. Thompson, Safeguards Inspector J N. Erwin, Office of Nuclear Reactor Regulation Approved by: u /4! David R. McGuire, Chief

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'Date Signed Safeguards Section  ;

Nuclear Material Safety and Safeguards Branch  !

Division of Radiation Safety and Safeguards  !

l SUMMARY l

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Scope:

l This special, announced inspection was conducted to review the licensee's i Access Authorization Program which is required by 10 CFR Part 73.56 effective  ;

! as of May 28, 1991. The inspectors examined the licensee's process of l conducting background investigations, psychological evaluations, and their  :

i continual behavior observation progra Results: ,

In the areas inspected, violations were identified as follows: l

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One violation was identified in that the licensee granted 80 clearances without adequate fingerprint checks performed. Additionally,12 other  ;

sets of prints were categorized as non-classifiable without the licensee l providing a qualified technician to take the prints agai Three non-cited violations were identified. One dealt with the failure i to detect omitted derogatory information during adjudication. One was l for a inadequate site procedure for access authorizatio l l

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The last was issued because the auditors who performed the audit of the licensee's program were not independent of the group responsible for the progra Three Inspector Follow-up Items were opened. One concerned inadequate Minnesota Multiphase Personality Inventory 2 testing facilities. The second concerned that the licensee's continued observation program is l slanted towards Fitness For Duty and does not address personnel reliability. The last deals with the licensee's attempts to ascertain employees activities when they are away from a licensee approved ;

behavioral observation program for more then 30 day '

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One Unresolved Item was opened dealing with the employees varied i understanding of their requirements to report arrest !

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i REPORT DETAILS  ! Persons Contacted f

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Licensee Employees

• R. Casey, Security Specialist, Tennessee Valley Authority (TVA)

J. Dyer, Psychologist, TVA D. Ellanger, Project Manager, Bechtel

• P. Hammons, Licensing Engineer, TVA

• C. Kelly, Security Manager, TVA A. Miller, Medical Assistant, TVA l

• D. Moore, Security Specialist, TVA  !

R. Partridge, Project Manager, Stone and Webster 0. Reasons, Adjudicator, TVA T. Sajwaj, Psychologist, TVA ,

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D. Sandidge, Human Resources Manager, TVA

• J. Setliffe, Site Security Manager, TVA '

• R. Stanfield, Compliance Specialist, TVA

• W. Tallant, Clearance Specialist, TVA

• R. Thompson, Personnel Security Manager, TVA l S. Turner, Adjudicator, TVA C. Williams, Personnel Manager, Bechtel  ;

Other licensee employees contacted during this inspection included craftsmen, mechanics, security force members, technicians, and administrative personne '

• Attended exit interview , Access Authorization Program (AAP)

10 CFR 73.56, the NRC requirement for an AAP, was effective on May 28, 1991, and fully implemented as of April 27, 1992. The intent of the ,

Rule is to ensure that those individuals granted unescorted access to l nuclear power plants are trustworthy, reliable and do not pose a radiological threat to the safety of the publi Licensees meet the Rule's intent through pre-access background investigation, psychological evaluation, and behavioral observation, all elements of the AA By letter dated May 11, 1992, the licensee submitted Revision 28 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." As an Append 1x l to the Regulatory Guide, the NRC has provided the industry with the '

Nuclear Management and Resources Council (NUMARC) Guideline 89-01 dated August,1989, titled, " Industry Guidelines for Nuclear Power Plant

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I Access Authorization Programs" which, with a few exceptions, meets the j intent and substance of the Rule. The exceptions are noted in the  ;

l Regulatory Guid l Background Investigations l Records of completed background investigations contained a summary l of information developed during the conduct of the investigatio !

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The inspectors determined through interviews and reviews of records that these records were reviewed by responsible licensee personnel and, in those cases where questionable or derogatory  ;

information had been reported, the licensee had investigated and l documented the results of those investigations. The inspectors ,

reviewed a sample of the access authorization records and did note i that in some cases they were unable to verify through written 'i documentation that all derogatory information within the records l had been adjudicated. The inspectors did find one record where an j individual had been granted full access although the person had l failed to document on their initial application a previous. arrest a resulting in incarceratio It was noted that responsible  :

licensee personnel had reviewed the full record and had failed to f note the failure to report derogatory information. Once' informed  !

of the inspectors findings, the licensee was unable to interview i the individual to determine why he failed to list the arrest  !

referenced above since he had. terminated his employment on July 6, I 199 l

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NUMARC 89-01, paragraph 7.1, states in part, "In making a  !

determination of trustworthiness or reliability, the following i must be considered: willful omission or falsification of material  :

information submitted in support of employment or request for j unescorted access authorization."

l TVA Standard 11.1, Revision 2, paragraph 2.0, Appendix C,  !

" Evaluation Criteria for Denying, Suspending, or Revoking  !

Clearance," states in part, " Clearance for unescorted nuclear  !

plant access and clearances for safeguards information shall be l l_ denied or suspended if any one of the following conditions are  !

indicated by relevant evidence: willful omission or i falsification of m. 'erial information submitted in support of employment or request for unescorted access authorization to protected or vital areas."

Contrary to the above, on May 3,1993, the licensee failed to detect omitted derogatory information during the adjudication i process prior to granting access to an-individual-(50-327,  !

50 328/93-34-01). _

l This violation will be considered an Severity Level V non-cited j violation in that it met the criteria of the Enforcement Policy,  !

Section VII.B(2). j l

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Discussion with licensee management personnel and review of randomly selected employee records and related documentation l

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revealed that the licensee's established program for conducting background information to meet regulatory requirements had been expanded by TVA to include a local criminal conviction record check, which was conducted through state and local courts, and a local law enforcement agencies check conducted in counties where the individual had resided or worked for the past five years.

l Also, the licensee conducted a motor vehicle records check for the preceding three years. The additional National Crime Information Center (NCIC) and Motor Vehicle Checks are considered strengths to ,

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the licensee's background information progra One violation was identified in the area inspected.

l b. Psychological Evalu:ition l The licensee and its major contractors administer the Minnesota l Multiphase Personality Inventory 2 (MMPI) which, if warranted, is followed with a clinical interview. Two contractors' programs were reviewed, Bechtel Engineering Inc. and Stone and Webste All clinical interviews are done by licensed psychologists on a person-to-person basis usually at the site, outside of the protected are With respect to NRC Information Notice 88-91, " Improper Administration and Control of Psychological Tests" and 91-59,

" Problems with Access Authorization Programs," all test administrators interviewed by the inspectors either had copies of the Notices and were aware of the issues, or did not have copies but were generally aware of the criteria explained because their Corporate Headquarters personnel had briefed them on the subject matte The inspectors noted several weaknesses in the environment of the licensee's MMPI testing facility. Specifically, the licensee often uses the waiting room of its Medical Facility to administer the~ tests. This room is unsecured at both ends and thus open to the public for entrance and exit. A wall mounted public address speaker is used by the medical staff to listen for any talking by the students, and, every few minutes or so a nurse will proctor the students by opening the door to the waiting room. Positive identification is required from all students; the test media is secured in a desk at one of the nurses' stations. The licensee's psychologists had surveyed this facility and opinioned to the ,

inspectors that it was a " horrible" testing environment which was being budgeted for improvemen During their visit to the Stone and Webster testing facility the inspectors learned that positive identity is not required from the students, the test media is routinely kept in a secretary's desk (which the inspectors were told was locked at all times), and that F

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l 4 the students sat in an "every other seat" arrangement in a small ,

conference room. Proctoring of the test occurred periodically throughout the examination time by the secretary. The inspectors further learned that a locked cabinet had been ordered and upon l

purchase will be used to secure the MMPI tests and personnel

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clearance files which were also stored in the secretary's des The contractor had only recently started MMPI testing onsite, only nine individuals had been tested. In all cases, the applicants had provided a driver's license prior to being tested.

l Based upon the inspectors' observations as described above, the l licensee suspended psychological testing at its own Medical Facility as well as at the Stone and Webster office. An Inspector Follow-up Item (93-34-02), reference NUMARC 89-01, paragraph 6.3, will be opened so the licensee's corrective measures to improve their psychological testing may be tracked.

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Several strengths were noted in the licensee's psychological '

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testing program in that security officers and licensed reactor i operators are always interviewed by a psychologist regardless of '

the results of the MMPI test. Additionally, prior to taking the psychological test, the applicant answers nine questions on a Personal History Questionnaire which address suicide inclinations, mental health history, fitness-for-duty, clearances, and employment denials. This questionnaire also solicits input from i i the licensee's medical staff to assist the psychologist in his

! cli.nical interview. The inspectors noted that the Bechtel l Corporation uses Behavior Analysts and Consultants, Inc., to i evaluate its MMPI tests. This company has access to approximately  ;

150,000 personnel records at 21 other nuclear stations which i

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! identifies prior denials of access or falsifications of test There were no violations of regulatory requirements noted in this l area.

, Behavioral Observation Program The inspectors reviewed the lesson plans for Fitness-For-Duty (FFD) (General and Supervisors) Training relative to the guidance on detecting aberrant behavior. Although initially Part 26 FFD  ;

orientated, the lesson plans have been revised to incorporate Part 73.56 " behavioral observations" and contain guidance relative I to evaluating a person's trustworthiness and reliability.

I However, based upon the wide inconsistency discove cd through interview of employers and supervisors, the inspectors concluded that the licensee's program was lacking guidance in detection of non alcohol / drug related aberrant behavior that may be a potential  !

threat to interrupt the sound operations of a nuclear reactor to include the potential to control Radiological sabotage. In numerous cases the inspectors were told that continual behavior

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observation dealt with alcohol and drug abuse; this resulted in l confusion by the employees on the correct procedure for detecting )

and resolving the non alcohol / drug behavior problems of employee An Inspector Follow-up Item (93-34-03) will be opened to track-the licensee's corrective measures, which will include a survey of the industry to find the best practices of ensuring supervisors '

are adequately trained in monitoring this kind of behavior.

l l An Unresolved Item (93-34-04) will be opened regarding the

! requirement that all individuals be instructed to report "any arrest that may impact on their trustworthiness" (Paragraph 9.0 of ;

NUMARC Guideline 89-01). Based upon interviews, record review, !

and procedure review, the inspectors concluded that inconsistencies existed regarding what constitutes an " arrest" and various misconceptions about how minor traffic citations could impact on a person's status as a trustworthy employee. Both ;

employees and supervisors held varying interpretations of this '

reporting requirement. During records review the inspectors noted that the Personnel Security Questionnaire (TVA Form 9871)

instructed the applicant to report traffic violations for which a l fine of less than $100.00 was paid, whereas paragraph 3.18 of -

Nuclear 5tandard 11.1 " Clearance for Nuclear Plants" stipulated a '

$200.00 fine. Some employees recalled the $100.00 payment criteria and some recalled the $200.00 amount. A memo dated July 8,1993, was issued by the licensee to all employees at the '

facility reminding them of the $100.00 reportability limit. In '

response to the inspectors' observation the licensee will first r

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revise its procedures and forms to be consistent and secondly will survey the industry to identify a consistent approach to the NRC criteri ;

An Inspector Follow-up Item (93-34-05) is opened relative to the licensee's attempts at " ascertaining" an employee's activities while absent from a continued behavior observation program for greater than 30 days. This " ascertaining" criteria is found in Regulatory Guide 5.66 (Clarifications, paragraph 3). Currently, the licensee will review activities of those persons on medical [

leave, reassignment, or transfer if their absence exceeds 30 day ;

There could be cases of extended annual leave or temporary change ;

of duties that would allow an individual to be away from a behavior observation program for greater than 30 days. The licensee stated that they would review this concer There were no violations of regulatory requirements noted in this ,

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d. Other Elements Required of the Licensee's AAP Procedures The licensee uses three procedures to delineate the duties and responsibilities of individual who implementing their AAP. These

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i l l procedures are comprehensive and generally address all NRC l l criteria and guidance relative to such elements as appeals,  :

l records retention, adjudication of questionable information, i temporary access authorization, administering the psychological l

test, fingerprint checks, suitable inquiries, et .

TVA Nuclear Power Standard 11.1, "Providing Access Clearance for  :

Nuclear Power Plants and Safeguards Information," Revision 2,  !

I dated June 23, 1993, is the upper tier document for TVA. Nuclear -

i Security Instruction 5.6.601, Revision 1, " Personnel Screening and  ;

Badging Instruction," dated April 1, 1992, with its eight {

attachments is the implementing procedure used by the Security '

Department. Sequoyah Nuclear Plant Physical. Security a 3 Instruction 2, Revision 37, "Providing Access Clearance for  ;

i Nuclear Power Plants and Safeguards Information," dated March 24, '

i 1992, is used at the sit ;

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ihe licensee's upper tier and site procedures in Section 2.6 and j Appendix D, Section 2.5, respectively, contain a statement that  :

"Two attempts shall be considered a best effort attempt to obtain 1 this information," in reference to obtaining National Personnel l Records in the process of granting a clearance when the person has

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i been in military service. However, the licensee has committed to  !

, Regulatory Guide 5.66, which requires in Section 2.4, "The  !

temporary access authorization period may be extended in the  :

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circumstances that NPNC has not forwarded the records to the j uti'lity, provided that reasonable documented attempts are made at  ;

least every six months to obtain this information until a response from NPNC is received."  !

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The licensee's mid-level procedure was correct. This is the  !

procedure that is used by corporate security personnel to grant  ;

clearances and correct requirements were met. This violation will l be considered a Severity Level V non-cited violation (93-34-06) in i that it meats the criteria of the Enforcement Policy, Section  !

VII.B(2). The licensee has implemented corrective measure e. Fingerprinting During review of the licensee's fingerprint records and during discussion with the licensee the inspectors determined that during

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the period of October and November, 1992, approximately 80 TVA employees were granted unescorted acce;s without a fingerprint card being submitted to the FB The licensee stated that in October 1991, TVA established an agreement through OPM with the FBI to review fingerprints of TVA

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personnel. OPM agreed to be the focal point for conducting Special Agreement Checks (SACS) for TVA employees, which consisted of a fingerprint search of the FBI Identification Division criminal history check. Subsequently, TVA found that the new OPM l check did not require the fingerprint card to be submitted to the

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FBI, rather it consisted of a name check with the FBI. Upon discovery of this information, TVA requested OPM to include the submittal of the fingerprint card to the FBI for a fingerprint check in lieu of the name chec ,

Subsequently, during further review the licensee determined that 80 TVA individuals had been granted access to the site without the completion of a full fingerprint check by the FB TVA management decided, since TVA conducts an NCIC a local criminal name check, and because these personnel had been in TVA's behavior observation and FFD programs, that they would continue to allow the 80 personnel unescorted access without completing the FBI fingerprint

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l Additionally, while the inspectors were reviewing the licensee's access authorization records they found that the licensee only l submitted fingerprint cards to the FBI twice if they were returned as non-classifiable. During a discussion the licensee stated that they considered it a good faith effort if the two fingerprint results were returned as non-classifiable; however; the licensee acknowledged that one of the print cards being reviewed by the inspectors had not been properly taken. During further review the licensee determined that there were 12 fingerprint cards on file that had been returned as non-classifiabl ,

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, The licensee immediately decided to reprint the 12 individuals in i

question and to change its procedure to require second print !

rejections to be reprinted by a more qualified technicia :

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10 CFR 73.57(b)(7), states, "The licensee shall review the information received from the Attorney General and consider it in making a determination for granting unescorted access to the individual or access to Safeguards Information."

10 CFR 73.57(b)(8), states in part, "A licensee ISall use the information obtained as part of a criminal history records check solely for the purpose of determining an individual's suitability for unescorted access to the nuclear power facility or access to Safeguards Information."

l 10 CFR 73.57(d)(1), states in part, " Procedures for processing of l fingerprint checks for the purpose of complying with this section, licensees shall submit one completed, legible standard fingerprint card..."

1991 Houston Workshop Access Authorization Questions and Answers NUMARC, states "Two sets of submittals are sufficient for the FBI to determine if fingerprints are classifiable, provided the prints are properly taken. To be unclassifiable there is usually a problem associated with an individual's fingers. If the prints were smudged or not rolled properly, they need to be redone and resubmitted. Effective January 2,1992, the FBI will allow...one

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free resubmission of a fingerprint card for each processing fee paymen If the first set cannot be classified, then that set -

will be returned with notations as to the reason (s), plus I resubmittal instructions for the one free resubmission. And, if i submissions cannot be classified, the FBI recommends that a ;

qualified fingerprint technician be used to ensure that high )

quality fingerprint impressions are taken." '

Contrary to the above, the licensee granted 80 individuals unescorted access without a FBI fingerprint check being conducte i Additionally, the licensee failed to re-fingerprint 12  :

individuals' after their fingerprints were deemed non-classifiable 1 '

by the FBI on two occasion (93-34-07)

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3. Appeals The inspectors randomly reviewed six records of individuals who appealed their denial of access authorization and found that three denials were based upon falsified arrest records (felonious assault, driving under .

the influence, and rape). One denial was based upon falsification of l education, one denial was based upon failure of the psychological testing, and the last denial was based upon a fitness-for-duty issue at a non-nuclear facility. It was apparent to the inspectors, based upon these records as well as interviews with employees, and the guidance '

provided in appeal procedures, that the licensee's appeal process is timely and clearly delineated. Of interest was one appeal that was originally rejected and later approved when the employee proved an ,

arrest was expunged from his criminal record by a court order.

! The inspectors noted in a review of TVA's Nuclear Standard 11.1 that varying time limits are imposed for appealing a medical denial versus a psychological denial. Appeals must be filed within thr medical denial, as opposed to three " working" days ofpsychological a,ee days of a i denial. Additionally, records furnished by the appellant must be '

furnished within 10 days of a medical denial, as opposed to five i

" working" days of a psychological denial. The licensee was informed ;

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that the NRC does not stipulate a time limit for an appeal, the licensee l responded that appeals outside these time limits would be honore )

' 1 There were no violations of regulatory requirements noted in this are '

4. Records and Privacy Information i

The inspectors commented favorably on the licensee's orderly and complete records, professional staff (at both Corporate and Site) and of the records and staff of one of its largest contractors. The files allowed the inspectors to easily review all the ingredients of the

, various elements of the screening and access authorization process,

except as noted earlier in Paragraph A relative to the adjudication of derogatory information in an isolated case.

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Based upon the inspectors' questioning the protection afforded l

} background investigation files by one contractor (as well as the  ;

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security of the psychological tests), the licensee responded to the area '

, and found the security of the secretary's desk to be unacceptable.

1 Accordir. gly, the licensee suspended the contractor testing program and i secured the records. The NRC inspectors never verified that the privt.:y 1 of the information was violated, but based upon the weakness being ,

! identified to the licensee, the licensee found the situation I unacceptable but not in violation. The NRC inspectors concluded that an '

Inspector Follow-up Item (93-34-08) will be opened to monitor the licensee's compliance witn Paragraph 14, " Records of NUMARC 89-01."  !

5. Cold Shutdown The licensee chose not to amend its Physical Security Plan to relax its j AAP during Mode 5 operatio ;

l 6. Audits

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The in:;pectors reviewed the licensee's Access Authorization Program  !

audits to determine if the audits had been conducted as required. The  !

inspectors reviewed the licensee's audit of its own program and of '

contractor programs. Additionally, the inspectors reviewed the licensee's pre-acceptance evaluations of contractor and vendor programs prior to acceptance of their background investigation Review of randomly selected audits to include the licensee and '

contractor programs revealed that the audits were in depth, detailed, and adequately addressed all aspects of the program. Documentation ,

reflected that audit findings were appropriately identified, tracked, and necessary corrective actions implemente The licensee has implemented a program of " pre-audits" of contractor i self-screening programs prior to acceptance of " certification letters" as a basis for granting unescorted access. Prior to accepting a  ;

licensee's program, TVA mails the required program elements, including ,

an adjudication process, to the contractor, and requires the contractor j to certify that it will implement this program. Subsequent to the )

certifica~ tion letters' receipt, TVA provides the vendors with current i NRC Information Notices, etc. Audits of self-screening contractors were i thorough and covered all aspects of the AAP elements. Two self- I screening programs were suspended as a result of audit findings. The audit staff was aware of program requirements and appeared knowledgeable and capabl The licensee utilizes comprehensive checklists and questionnaires for  ;

program participants to evaluate adherence to the Rule and judge quality l of the contractor's progra The licensee conducted an audit of Equifax Employment Services in conjunction with the Institute of Nuclear Power Operations (INPO) on January 21 and 22, 1993, to assess the overall adequacy of the l l

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investigative services provided by the vendor. The review found no l issues of noncompliance but did identify several issues that merited l additional attention by Equifa The licensee utilized the Nuclear Security Compliance staff to perform i audits of the AAPs. The audit of the licensee's program was ,

accomplished on January 25-29 and April 19-22, 1993. The audit !

contained one finding, three recommendations, two good practices, and i four observations. The audit recommends that contractors be provided '

with a current contact list for personnel in the TVA AAP program and i suggests 5 year background checks for those personnel handling sensitive l information in their duties. An administrative observation was made .

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I relative to the use of a data form. The good practices noted a strength in the contractor acceptance criteria and the development of a " lessons !

learned" letter for contractor The licensee has committed to Regulatory Guide 5.66 to include NUMARC Appendix 89-01 Section 13.1, "An independent evaluation of the !

unescorted access authorization program and its conformance to these guidelines must be made within 12 months of the effective date of ,

l 1mplementation of the access authorization program." i l

The licensee's audit, while thorough and performed by knowladgeable and capable auditors, was not completely independent, in that the Nuclear Security Compliance staff is aligned under the Manager of Protective Services who also has authority over the Personnel Security Section and the AAP. This Manager of Protective Services transmitted the audit findings. This violation will be considered a Severity Level V non- !

cited violation (93-34-02) in that it met the criteria of the l Enforcement Policy,Section VII.B(2). The licensee stated th;.t future j audits of the licensee's AAP would be conducted by the Quality Assurance i group with the Nuclear Security Compliance staff available as technical advisor The licensee conducted an additional audit of its program March 18 through 27, 1993, utilizing a team of Nuclear Security Compliance ;

personnel, and one person from the Nuclear Licensing and the Nuclear !

Quality Assurance staffs. The audit disclosed no issues of l noncomplianc '

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There were no violations of regulatory requirements noted in this are . Exit Meeting The Exit Meeting was held on Friday, July 16, 1993, with those as noted in attendance. The licensee was advised of the findings of the inspection and of the potential violations relative to the failure to assure fingerprints are submitted to the Federal Bureau of Investigation. The licensec did not take exception to any of the findings. The licensee's immediate correctiva actions were discussed as noted earlier in this report.

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