ML17310A534

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Enforcement Conference Repts 50-528/93-20,50-529/93-20 & 50-530/93-20 on 930510.Major Areas Discussed:Description of Violations Associated W/Three Investigations Conducted by OI from 910722-930226 at Plant
ML17310A534
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 06/08/1993
From: Pate R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17310A532 List:
References
50-528-93-20-EC, 50-529-93-20, 50-530-93-20, NUDOCS 9308160072
Download: ML17310A534 (52)


See also: IR 05000528/1993020

Text

U. S.

NUCLEAR REGULATORY COMMISSION

REGION

V

Report Nos.

Docket Nos.

License

Nos.

Licensee:

Facility Name:

Meeting at:

Meeting Date:

50-528/93-20,

50-529/93-20,

and 50-530/93-20

50-528,

50-529,

and 50-530

NPF-41,

NPF-51,

and NPF-74

Arizona Public Service

(APS)

Company

P.O.

Box 53999, Station

9082

Phoenix,

Arizona 85072-3999

Palo Verde Nuclear Generating Station, Units 1,

2 and

3

APS Corporate

Headquarters

Building, Phoenix,

Arizona

May 10,

1993

Type of Meeting:

Announced,

Enforcement

Conference

Prepared

By:

D. Schaefer,

Physical

Security Inspector

Approved by:

Robert J,

at

,

hief, Safeguards,

Emergency

Preparedness,

and Non-Power Reactor

Branch

at

Signed

Meetin

Summar

Enforcement

Conference:

An enforcement

conference

was held on May 10,

1993, at the

APS Corporate

Headquarters

Building, Phoenix, Arizona, to discuss

the fol'towing:

())

Description of the violations associated

with three investigations

conducted

by the

NRC Office of Investigations

(OI) from July 22,

1991, through February

26,

1993, at the Palo Verde Nuclear Generating Station,

as

documented

in the

NRC Region

V letter to Arizona Public Service

Company dated April 23,

1993;

(2)

NRC concerns;

and

(3) Licensee corrective action planned

and implemented.

9308<60

2

00528""

cypp7 i2

PDR

ADQCK 050

DR

6

REPORT DETAILS

l.

Enforcement

Conference Partici ants

2.

Arizona Public Service

Com an

(APS)

J. Levine, Vice President,

Nuclear Productions

P. Caudill, Director, Services Division

T. Bradish,

Nanager,

Licensing

and Compliance Division

R. Fullmer, Hanager, guality Audits and Nonitoring

E. Lumley, Supervisor,

Performance

Assessment,

Security Department

A. Huttie, Supervisor,

Training and Support, Security Department

T. Ford, Security Shift Supervisor,

Security Department

W. Hendrix, Security Shift Supervisor,

Security Department

K. Simonson,

Security Shift Supervisor,

Security Department

B. Whitney, Technical Specialist,

equality Assurance

P. Coffin, Engineer,

Nuclear Regulatory Affairs

J. Napier,

Engineer,

Nuclear Regulatory Affairs

W. Lohse, Shift Sergeant,

Nuclear Security Department

N. Benac, Site Representative,

El Palo Electric

R. Henry, Site Representative,

Salt River Project

Nuclear

Re ulator

Commission

(NRC)

R. Scarano,

Director, Division of Radiation Safety

and Safeguards,

Region

V

R. Pate,

Chief, Safeguards,

Emergency

Preparedness

and Non-Power

Reactor

Branch,

Region

V

L. Tran,

NRR

F.

Huey, Enforcement Officer, Region

V

K. Logan, OI, Region

V Field Office

D. Schaefer,

Security Inspector,

Region

V

Enforcement

Conference

3.

On Nay 10,

1993,

an enforcement

conference

was held at the Corporate

Headquarters

Building of Arizona Public Service

Company

(APS), Phoenix,

Arizona Qith the individuals listed above participating.

The conference

related to

NRC concerns

and apparent violations identified in a Region

V,

NRC letter to APS, dated April 23,

1993.

This letter documented

findings from three investigations

conducted

by the

NRC Office of

Investigations

(OI) from July 22,

1991, to February 26,

1993

(OI Case

Nos. 5-91-009,

5-92-011,

and 5-92-012), at the Palo Verde Nuclear

Generating Station.

0 enin

Remarks

Nr. Scarano

opened the enforcement

conference

by stating that the

.

purpose of the meeting

was to allow APS and

NRC an opportunity to

discuss

the results of three

OI Investigation Reports

(Case

Nos. 5-91-

009, 5-92-011,

and 5-92-012),

which identified apparent violations of

NRC requirements.

It was noted that the allegation of harassment

and

intimidation of security officers by security management

discussed

in OI

Investigation

Case

No. 5-92-011,

was not substantiated,

and was not

a

regulatory concern.

Mr. Levine indicated that

APS had completed

a thorough investigation of

all issues

discussed

in the Region

V letter dated April 23,

)993.

This

investigation included

a thorough review of requirements

of the Security

Plan, Training and gualification Plan, appropriate

Palo Verde Security

Procedures,

and pertinent training records for members of the

1991

initial (basic) security training classes

A and

B.

As a result of this

investigation,

he and his staff had identified important issues for

discussion.

Licensee Discussion of Issues.

Messrs.

Caudill, Huttie,

and Bradish

presented

the major portion of the licensee's

briefing.

NRC Re ion V Letter

Mr. Caudill

began

by indicating that the issues

(and apparent

violations) addressed

in the

NRC Region

V April 23,

1993, letter

indicated:

(1) there

was

no indication of deliberate

misconduct;

(2) that the issues

were of marginal safety significance;

(3) that

there

was

no indication that the apparent violations were

symptomatic of a current programmatic

problem;

(4). that in some

instances

the issues

were further examples of issues

identified

and corrected

in response

to the February

1992 enforcement

conference

at Region V; and (5) the apparent violations

do not

indicate repeat security program problems..

(See attached

APS

slide PJC-2).

APS Investi ation

Mr. Caudill indicated that during the investigation of these

issues,

APS had completed the following:

(1) reviewed

10 CFR 73,

~ . Appendix B; (2) reviewed

NRC inspection reports;

(3) conducted

licensee

and contract security employee interviews to include

interviews of the remaining

18 security officers that had

-previously been

members of the

1991 initial (basic) security

training classes

A and B; (4) reviewed the course curriculum,

firing range records,

and crucial task forms audit;

(5) reviewed

post assignment

rosters;

(6) reviewed quality assurance

documents;

and (7) reviewed the February

1992 enforcement

conference

corrective actions.

(See attached

APS slide PJC-3).

Results of APS Investi ation

Further,

Mr. Caudill indicated that the results of the

APS

investigation determined that the following situations existed

during the conduct of training for members of the

1991 initial

security classes

A and

B:

(1) there were inconsistencies

between

the requirements

of the

NRC approved Security Plan

and the

APS

security procedures,

and that these

inconsistencies

affected the

content of classroom instruction;

(2)

some of the crucial/critical

task forms were inaccurate;

and (3) that

APS had not followed

portions of the range firing procedure.

Additionally, Mr Caudill

indicated that the June

17,

1991, safeguards

event

had

been

properly reported

and declassified

{determined to be not

reportable)

per standard

practice,

however, the July 20,

1991,

safeguards

event

had not been properly recorded in a log within 24

hours of discovery.

(See attached

APS slides

PJC-4

and PJC-S).

(Note:

As requested,

APS will provide Region

V a copy of the

documents utilized by APS (during their investigation) to

determine that this event

had

been properly declassified.

Additionally, Mr. Caudill indicated that,

as discussed

during the

February

1992 enforcement

conference

at Region V, the

APS training

provided to members of the

1991 initial security training classes

A and

B mistakenly included shortened

classroom instruction,

and

performance testing of students

in groups.

Further,

due to

unforeseen

circumstances,

these

students

were not later afforded

an opportunity for on-the-job

(OJT) training.

For this reason,

in

February

1992,

APS had provided detailed task/post

performance

training to former member of Classes

A and

B.

During this enforcement

conference,

Mr . Caudill

added that many of

the student training records pertaining to tasks

associated

with

hand-held

metal detectors,

hand-held explosive detectors,

and

baton,

were administratively incorrect in that

a portion of these

records

indicated that this training had

been completed,

when in

fact

APS had not provided (nor intended to provide) this training

to members of these

two 1991 classes

(see

APS slides

PJC-S,

PJC-9,

PJC-10,

and PJC-11).

(Note:

On May 12,

1993, the Region

V staff

(Mr. D. Schaefer)

advised the

APS staff

(Mr . A.. Huttie) that there

was no apparent

regulatory basis for APS to have discontinued

providing the training in the two tasks

associated

with the hand-

held metal detector.)

In discussing

the training records,

Mr.

Caudill further indicated that it was the intention of APS that

the signature of the instructor

and the student at the bottom of

the training records,

meant that the specific training

-requirements

{of the critical tasks/subtasks)

of the Training and

gualification Plan had been completed.

Mr. Caudill also indicated that contrary to Security Training

Procedure

20DP-OTROl, that five students

in the

1991 initial

security training classes

A and

B 'had

been (improperly) permitted

more than three

weapons qualification attempts

per weapon.

(See

attached

APS slide PJC-12).

Mr. Caudill indicated that the range

instructors

had confused the weapons qualification program of the

initial training officers {classes

A and B) with the weapons

qualification program for other

(annual requalification) security

officers.

Mr. Caudill also noted that the

1991 initial training classes

A

and

B were assigned

to shift duty on July 10 and July 15,

1991,

respectively.

,I

4

Trainin

and

uglification Pro ram - 1992 Initiatives

Nr Caudill then discussed

the

1992 initiatives of the Palo Verde

Training and gualification Program,

and indicated that these

initiatives, discussed

during the February

1992 enforcement

conference

at Region V, have

improved the overall effectiveness

of

the current training provided to members of the Palo Verde

security force.

(See attached

APS slide PJC-6).

Trainin

and

uglification Conclusions

In conclusion,

Nr. Caudill indicated that even though

some

inaccuracies

were identified in the crucial task training records,

that the

APS investigation

had not identified any members of the

security force that had

been

assigned on-shift security duties

without receiving necessary training to perform assigned

tasks.

Nr. Caudill also noted that the

APS investigation

had resulted in

a composite review of the Security Plan, Training and

gualification Plan,

and Security Procedures.

As a result,

APS had

identified additional

areas

and specific items that will be

corrected.

For example, APS-identified inconsistencies

between

the above documents that will be corrected.

(See attached

APS

slide PJC-14).

~ER

Nr. Caudill then discussed

the manner in which Palo Verde

maintained their safeguards

event log in 1991,

as well as the

manner in which this log is maintained in 1992

and

1993.

(See

attached

APS slide PJC-15).

Nr. Caudill noted that due to poor communication

between security

shift supervisors,

and improper handling of the initial event

'eport, that the July 20,

1991, event at Door 16-103

had not been

logged until three

days latet

.

However, this event

was properly

gubmitted in the subsequent

quarterly event report to the

NRC (see

attached

APS slide PJC-)6).

Hr. Caudill

and staff also concluded

that the second

event involving the security officer leaving his

safeguards

post orders unattended for two and one-half minutes,

was not

a separate

event

and therefore did not need to be

reported.

(Note:

On Nay ll, 1993, the Region

V staff (Nr . D.

Schaefer)

advised the

APS staff (Nr .

E. Lumley) that after

verifying with NRR, it was determined that the two events at door

1G-103 were caused

by separate

types of failures.

Therefore,

each

of these

two events

should

have

been separately

reported.)

Nr. Caudill also noted that the safeguards

event

on June

17,

1991,

had

been properly evaluated,

and had

been determined to be not

reportable.

For this reason, this event

was not included in the

. Palo Verde quarterly safeguards

event report to the

NRC.

(See

attached

APS slide PJC-18).

I

Safet

Si nificance

Nr Bradish indicated that there is minimal safety significance

with the administrative discrepancies

in the student training

records for the

1991 initial security training classes

A and

B.

Further the safety significance involving the problems with the

logging and reporting of the June

17 and July 20,

1991 events is

also minimal.

(See attached

APS slide TRB-l).

'Current Securit

Trainin

Pro ram

Mr . Huttie then discussed

Palo Verde's current security training

program to include the basic training requirement in Section 3.4

of the Training and gualification Plan, the required crucial

tasks,

the initial on-the-job

(OJT) training program,

the on-shift

enhancement

training program, the random selection crucial testing

program,

the security training (monthly) advisory board,

and the

customer (security officer) training feedback questionnaire.

These

ongoing

programs

have resulted in improved security officer

performance,

a continued reduction in security officer human error

events,

overall

improved communications

and teamwork,

and

an

overall better understanding

of security requirements

by members

of the security force.

(See attached

APS slides

ADH 1-4).

NRC Discussion of A

arent Violations.

During the enforcement

conference,

NRC discussed

the following regulatory concerns

and issues.

Trainin

Re uirements

Section 3.2.3 of the licensee's

approved Training and

gualification (Th)),Plan requires that security personnel

successfully

perform before assignment,

all crucial (critical)

security tasks identified for that assignment,

under the

conditions

and to the standards

specified in the TSg Plan.

During interviews

by OI, licensee security management

stated that

upon completion of training, all of the students

in the

1991

initial security classes

A and

B had

been trained

and qualified

for all of the security critical tasks,

and that the primary

purpose of the students

was to assume all security duties in the

event of a strike or a labor action by the bargaining unit.

APS Trainin

Failed To Neet

Re uirements

The OI investigations

determined that

APS provided incomplete

training to members of the

1991 initial security training classes

A and

B.

During interviews by OI, four members of licensee

security management

and instructor staff described

the following

training for these

classes

as being completed without having met

the tasks,

conditions

and standards

specified in the Twg Plan.

,I

t

1

I

f

I

a ~

b.

C.

d.

0 crate

Communication

E ui ment.

During the licensee's

conduct of training of this critical task,

due to a shortage

of radios,

some of the students

admittedly were unable to

perform the sub task of Operate

A Hand-Held Radio.

These

students

were required to simulate turning on the radio,

setting the squelch,

and selecting the radio channel.

As

such, the required training standard of being able to

"communicate clearly" was not met.

Conduct X-ra

Packa

e Search.

During the licensee's

conduct

of training of this critical sub task,

students

admittedly

were trained to only operate

the equipment,

and were not

trained or tested to meet the training standards

of being

able to "recognize objects

by image

on the X-ray screen,"

or

"recognize explosives

or incendiary devices."

Conductin

Vehicle Searches.

During the licensee's

conduct

of training of this critical sub task,

group training and

testing admittedly did not allow all students

to

individually conduct

a vehicle search.

Res

ond To and Assess

Alarms.

During the licensee's

conduct

of training of this critical task

an alarm situation

was

admittedly simulated,

and students

were thus not trained or

tested to perform the sub task of Hove To Point of Alarm as

Directed by the

CAS/SAS Operator,

under the conditions of

"utilizing techniques

of deployment, tactical

movement,

and

withdrawal."

Additionally, the required training conditions

of "being

a team member,

operate

a vehicle, running,

carrying

a portable radio and weapon,

and wearing

a bullet-

proof vest

and riot helmet" were not met.

Additionally, the OI investigation determined that the training of

,classes

A and

B did not include the critical tasks/subtasks

of:

Adjust and Test Hand-Held Hetal Detectors,

and Conduct Hand-Held

Metal Detector Search.

Further, during the OI investigation,

nine of the eleven students

interviewed stated that they completed their training without

having performed two or more of the critical tasks/subtasks.

During this enforcement

conference,

messrs

R. Scarano

and

P.

- Caudill agreed that the APS training provided to these

two classes

(A and B), was not up to standards.

The licensee

did not identify

that portions of their training provided to classes

A and

B, had

not met all of the training conditions

and standards

specified in

their approved

Tbg Plan.

This represents

an apparent

(licensee

and

NRC identified)

violation.

APS Prior Difficult With OJT

Region

V noted that during the February ll, 1992,

enforcement

conference

(as well as during this conference),

the licensee

discussed their 'previous intentions of providing students

in

classes

A and

B with on-the-job Training (OJT).

Additionally, it

was noted that the licensee

had previously acknowledged that

weaknesses

in their OJT for these

students

had partially

'contributed to the decline in security officer performance,

and

that approximately seven

months later, they completed

a task/post

performance training program to supplement

the OJT program.

Following the

May 10,

1993,

enforcement

conference,

a review of

the licensee's

Security Post Assignment Rosters

noted that during

these

seven

months

(from Mid July 1991 to mid February 1992), the

licensee

had assigned

some of these security officers (former

"graduates" of classes

A and

B) to security shift assignments

that

required their performance of critical tasks/subtasks

for which

they had received

incomplete training.

In particular, the

officers had

been

assigned

to security posts that required

them in

part, to have knowledge of,

and

be able to perform the following

tasks/subtasks:

Operate

a Hand-Held Radio,

Conduct X-ray Package

Search,

Conduct Vehicle Searches,

and

Respond

To and Assess

(security) Alarms..

APS Securit

Trainin

Procedure

The OI investigations

determined that two members of classes

A and

B were allowed to attempt to qualify up to six times per range-

firing day with their assigned

weapons,

rather than the maximum

three qualifying attempts

per day provided by Security Procedure

20DP-OTR01.

This represents

an apparent

(NRC identified)

violation.

,Additionally, the licensee's

Security Training Procedure

(20DP-

OTR01) incorrectly interpreted the requirements

of the Th) Plan,

in.,that the procedure did not insure that instructors

adequately

trained student to perform all of the required critical security

tasks

under the conditions

and to the standards

specified in the

T8g Plan.

For example,

the proce'dure incorrectly allowed students

to successfully

demonstrate their knowledge of many critical tasks

through practical tests

(verbal scenario-testing)

and written

tests,

and

made incomplete reference to the specific tasks,

conditions

and standards

specified in the TLg Plan.

Securit

Trainin

Records

The OI investigations

determined that security training records

for the

1991 initial security training classes

A and

B were not

complete

and accurate

in all material respects.

Specifically,

signatures

of students

and instructors

on training records

documented

completion of "qualifying performance

demonstration,"

in that they incorrectly indicated that the students:

had

)I

ltl

f

communicated clearly with a hand-held radio;

had operated

an X-ray

machine

and were able to recognize objects,

explosives

or

incendiary devices

on an X-ray screen;

had (individually)

conducted vehicle searches;

had responded'o

an alarm by moving to

.

the point of alarm as directed

by the alarm station operator,

utilizing techniques

of deployment, tactical

movement,

and

withdrawal,

and while being

a team member, operating

a vehicle,

running, carrying

a portable radio and weapon,

and wearing

a

bullet-proof vest

and riot helmet;

and

had adjusted,

tested

and

conducted

a search with a hand-held

metal detector.

This

represents

an apparent

(licensee

and

NRC identified) violation.

Safe uards

Events

and

Re ulator

Issues

June

17

1991.

The OI investigations

determined that

on June

17,

1991, the licensee

had identified that

a compensatory

security

officer was improperly posted at the perimeter

fence in such

a

manner that during the hours of darkness,

the officer could not

provide

a full field of vision for the two adjacent

inoperative

perimeter

alarm zones.

A security sergeant

and

a security shift

supervisor

prepared

an initial 73.71 report,

however, this event

was not included in the quarterly event log submitted to the

NRC.

The regulatory issues

involved in this event include:

(1)

The improper posting of a compensatory security measure.

(2)

The licensee's

failure to include this event in the

quarterly safeguards

event log submitted to the

NRC.

(Note:

Upon review of the material

used

by the licensee to

evaluate this event,

Region

V agreed that this event

was not

reportable to the

NRC.

The licensee's

documents

confirmed that

multiple (cascading)

alarms

had

been received

from two perimeter

alarm zones,

and that

a compensatory

security officer had

been

posted in the vicinity of these

alarm

zones.

These

documents

also confirmed that during this period of time, the two perimeter

. alarm zones

had remained operational

(in the security mode),

and

that the security officer had

been prepositioned

in the vicinity

to simply assess

the cause of any security alarms

from this

vicinity.

2

l.

Th Ii

tlg

i

h

d

i dtht

ai1

20,

1991, the licensee

had identified that

a security officer,

posted

as

a compensatory

measure for an unlocked vital Door 1G-

103, leading to the Unit-1 Diesel

Generator Building, left his

post for approximately two and one-half minutes to make

a call

from a telephone

located

on the other side of the building.

The

officer also left his safeguards

post orders

unattended.

From

this event,

the following apparent violations were identified:

(1)

The failure of a compensatory security measure.

(licensee

identified)

(2)

Failure to record the officer departing his assigned

compensatory

post in the safeguards

event log within 24

.hours.

Instead this event was recorded three

days later.

(NRC identified)

(3)

Failure to properly protect safeguards

information.

(licensee identified)

(4)

Failure to record the officer's failure to properly protect

safeguards

information in the event 'log,

and subsequent

failure to include this event in the quarterly safeguards

event log submitted to the

NRC.

(NRC identified)

6.

Closin

Remarks

In closing Nr. Levine indicated that

APS has worked hard investigating

the issues

involved in the Region

V letter dated April 23,

1993,

and

that as

a result of the

APS ongoing corrective actions in security

training, that the present training program far surpasses

the security

training program that was presented

to the

1991 initial security,

training classes

A and

B.

Nr. Levine confirmed that all identified

inconsistencies

between the approved Security Plan

and

APS security

procedures

would be corrected.

Nr. Scarano

indicated that

APS seems to be headed

in the right direction

in their approach to continue resolving the security training problems

and issues

presented

in the Region

V letter dated April 23,

1993.

Attachment:

A Licensee slides for enforcement

conference

1'

ENFORCEMENT

CONFERENCE

MAY 10,

1993

AttachmeIlt A

)I

ENFORCEMENT CONFERENCE

SECURITY

MAY 10,

1993

AGENDA

~

OPENING

REMARKS

R. A.

SCARANO

3.

M.

LEVINE

NRC REVIEW OF APPARENT

VIOLATIONS

~

NRC REVIEW OF SAFETY

SIGNIFICANCE

. ~

APS

INTRODUCTION

~

APS

RESPONSE

TO

NRC ISSUES

~

APS

REVIEW OF SAFETY

SIGNIFICANCE

~

CURRENT TRAINING PROGRAM

~

REVIEW OF

NRC

ENFORCEMENT

POLICY

~

CLOSING REMARKS.

NRC

NRC

P. 3.

CAUDILL

P. 3.

CAUDILL

T.

R.

BRADISH

A. D.

HUTTIE

F.

R.

HUEY

J.

M.

LEVINE

R. A.

SCARANO

PJC

1

05/10/93

REVIEW OF APRIL 23

1993

NRC

LETTER

~

NO INDICATION OF DELIBERATE MISCONDUCT

~

MARGINAL SAFETY SIGNIFICANCE

~

NO INDICATION APPARENT VIOLATIONS ARE

SYMPTOMATIC OF A CURRENT PROGRAMMATIC

PROBLEM

~

FURTHER

EXAMPLES OF ISSUES

IDENTIFIED

AND CORRECTED IN RESPONSE

TO

FEBRUARY

1992

ENFORCEMENT

CONFERENCE

~

APPARENT VIOLATIONS DO NOT INDICATE

REPEAT SECURITY PROGRAM PROBLEMS

PJC

2

05/10/93

I

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APS

EVALUATION

~

REVIEW OF lOCFR73

APPENDIX B,

SECURITY

PLAN,

TRAINING. AND QUALIFICATION PLAN,

AND iMPLEMENTING PROCEDURES

~

REVIEW OF

NRC INSPECTION

REPORTS

~

APS

AND CONTRACT EMPLOYEE INTERVIEWS

~

COURSE

CURRICULUM, FIRING RANGE

RECORDS,

AND CRUCiAL TASK FORMS AUDIT

~

REVIEW OF

POST

ASSIGNMENT ROSTERS

~

REVIEW OF

PVNGS QUALITY ASSURANCE

DOCUMENTS

~

REVIEW OF

FEBRUARY 1992

ENFORCEMENT

CONFERENCE

CORRECTIVE ACTIONS

PJC

3

05/10/93

I

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EVALUATION RESULTS

TRAINING AND QUALIFICAT10N

~

PLAN/PROCEDURE

INCONSISTENCIES

~

CRUCIAL/CRITICAL TASK FORM INACCURACIES

~

RANGE FIRING PROCEDURE

EVENT REPORTING

~

JUNE 17,

1991 -

REPORTED

AND

DECLASSIFIED PER

STANDARD PRACTICE

~

JULY 20,

1991 - FAILURE TO

LOG WITHIN

24-HOURS

AS

REQUIRED

PJC

4

05/10/93

1

i

1

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NRC COMMENTS ON TRAINING

(JUNE/JULY 1991 - PTI TEMPOMZUES)

~

LENGTH OF CLASSES

~

PERFORlVlANCE TESTING FOR CRITICALTASKS

~

OPPORTUNITIES FOR OJT

~

INSTRUCTOR PRESENCE IN CLASS

~

ACCURACY OF TRAININGRECORDS

PJC

5

05/10/93

(

I

l

TRAINING AND QUALIFICATION PROGRAM

1992 INITIATIVES

~

INTERIM POST

AND TASK-SPECIFIC CRUCIAL

TASK TESTING

FOR PTl A L B CLASSES

USING SHIFT SUPERVISION

~

CRUCIAL TASK PERFORMANCE

INTO

REQUALIFICATION

~

INSTRUCTORS

ON SHIFT

e

SECURITY TRAINING ADVISORY BOARD

~

SPECIFIC

CRUCIAL TASK PERFORMANCE

CRITERIA

~

FORMAL ON-THE-JOB TRAINING PROGRAM

PJC

6

05/10/93

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t

NRC APRIL 23

1993

LETTER

TRAINING AND QUALIFICATION ISSUES

~

MEMBER

AI

AI

NI

NE

S

OF 1991 INITIALSECURITY

NG CLASSES

A AND

B MERE

NOT

D

TO

PERFORM ALL CRUCIAL SECURITY

ASKS

PRIOR

TO ASSIGNMENT

~

CRUCIAL TASK TRAINING FORMS

MERE NOT

ACCURATE IN ALL MATERIAL RESPECTS

REFLECTING A FALSE LEVEL OF SKILL

.PJC

7

05/10/93

TRAINING AND QUALIFICATION

EVALUATION RESULTS

~

PLAN/PROCEDURE

INCONSISTENCIES

~

CRUCIAL/CRITICAL TASK FORM INACCURACIES

HAND-HELD EXPLOSIVES DETECTOR

HAND-HELD METAL DETECTOR

BATON DEPLOYMENT

~

RANGE FIRING PROCEDURE

PJC

8

05/10/93

II

I

L

ll

h

i

HAND-HELD EXPLOSIVES DETECTORS

o

HAND-HELD EXPLOSIVES

DETECTOR SEARCH

AND FUNCTIONAL TEST

SUBTASKS

NOT

PERFORMED

IN 1985

HAND-HELD EXPLOSIVES

DETECTORS

TAKEN OUT OF SERVICE

HANDS-ON SEARCHES

CONDUCTED IN LIEU

OF HAND-HELD EXPLOS1VES

DETECTOR

SEARCHES

HAND-HELD EXPLOSIVES

DETECTORS

DELETED

FROM 1985

SECURITY PLAN,

TRAINING PROCEDURE,

AND CRUCIAL

TASK FORM

SUBTASKS

REMAINED IN TRAINING &

QUALIFICATION PLAN

PJC

9

05/10/93

- HAND-HELD METAL DETECTORS

~

HAND-HEI D METAL DETECTOR SEARCH

AND

FUNCTIONAL TEST

SUBTASKS

NOT

PERFORMED

IN 1989

HAND-HELD METAL DETECTORS

TAKEN OUT OF SERVICE

HANDS-0

OF

HAND

SEARCHE

N SEARCHES

CONDUCTED IN LIEU

-HELD METAL DETECTOR

S

HAND-HELD METAL DETECTORS

REMAINED

IN SECURITY DOCUMENTS

SUBTASKS

REMAINE

QUALIFICATION PL

CRUCIAL TASK FOR

D IN TRAINING 5

AN;

AND REMAINED ON

M

PJC

10

05/10/93

BATON DEPLOYMENT

~

DEPLOYMENT OF

BATON SUBTASK NOT

PERFORMED

CONSISTENTLY

IN 1990

BATON USE

DELETED

FROM

PRACTICE

CHEMICAL AGENT (MACE) INSTITUTED IN

LIEU OF

BATON DEPLOYMENT

SUBTASK REMAINED IN TRAINING AND

QUALIFICATION PLAN AND ON CRUCIAL

TASK FORM

PJC

11

05/10/93

'I

RANGE FIRING PROCEDURE

~

FIVE CONTRACT EMPLOYEES P

THAN THREE WEAPONS QUALIF

ATTEMPTS IN ONE

DAY CONTR

PROCEDURE

ERMITTED

ICATION

ARY TO

MORE

PJC

12

05/10/93

RELATED TRAINING ISSUES

~

TERRORISM TRAINING

~

HOSTAGE NEGOTIATION

~

EXAMINER/EXAMINEE SIGNATURES

PJC

13

05/10/93

TRAINING AND QUALIFICATION CONCLUSIONS

~

AP

ME

PR

NE

S INVESTIGATION REVE

MBERS

OF

TH

IOR TO

COMP

CESSARY

FOR

E SECURIT

LETION OF

ASSIGNED

ALED NO EVIDENCE

Y FORCE

POSTED

TRAINING

DUTIES

~

INACCURACIES IN SOME CRUCIAL TASK FORMS

CORRECTIVE ACTIONS

~

IN DEPTH

REVIEM OF PLANS,

PROCEDURES,

AND FORMS

TO

ENSURE

CONSISTENCY

~

REVISION OF

DOCUMENTS

TO

CORRECT

INCONSISTENCIES

~

IMPLEMENTATION OF

MORE

FORMAL

CHANGE,

CONTROL,

PROCESS,

AND

ACCOUNTABILITIES

~

LESSONS

LEARNED MEETINGS MITH SECURITY

PERSONNEL

PJC

14

05/10/93

EVENT REPORTING

lOCFR73.71

EVENT REPORTING

REQUIREMENTS

~

MAINTAIN A CURRENT

LOG AND RECORD

THE

SAFEGUARDS

EVENT WITHIN 24

HOURS

OF

DISCOVERY

~

SUBMIT. QUARTERLY REPORT

TO INCLUDE ALL

EVENTS

NOT PREVIOUSLY SUBMITTED

~

IMPLEMENTATION GOVERNED

BY PVNGS

EVENT

REPORTING

MANUAL

STANDARD PVNGS

PRACTICE (1991)

o

COMPLETED WITHIN 24

HOURS

CONDUCTED

FACT FINDING,

GATHERED

STATEMENTS,

AND DOCUMENTED IN EVENT

REPORT

--SIGNED/APPROVED

BY SHIFT CAPTAIN

FILED (CURRENT

LOG) IN CAPTAINS

OFFICE

SUBMITTED QUARTERLY REPORT

TO

NRC

PJC

15

05/10/93

DIESEL GENERATOR

DOOR

POST

G103

0 /20/91

~

EVENT NOT

LOGGED WITHIN 24-HOURS

OF

DISCOVERY

~

SECURITY MANAGER AND OPERATIONS

SUPERVISOR

CONDUCTED

FACT FINDING

,~

EVENT LOGGED

ON JULY 23,- 1991

~

EVENT SUBMITTED IN QUARTERLY REPORT

~

CAUSE

OF

LATE ENTRY

POOR

COMMUNICATION BETWEEN UNIT 1

POWER

BLOCK SERGEANT AND SHIFT

CAPTAIN

IMPROPER

HANDLING OF INITIAL EVENT

REPORT

AND BACKUP DOCUMENTATION

~

CORRECTIVE ACTION

CAPTAIN AND

REGARDING

P

DOCUMENT CL

SE

ROP

OSU

GEANT WERE

COACHED

R COMMUNICATIONS AND

E

PJC

16

05/10/93

ISOLATION ZONE

6/17/91

~

NO EVIDENCE TO

CONCLUDE CHANGE OF

POST

LOCATION CONSTITUTES

IMPROPER

POSTING

~

POSTING

CONCERN IDENTIFIED

~

73.71

EVENT REPORT

GENERATED

e

REPORT MAINTAINED IN LOG DURING

INVESTIGATION

PJC

17

05/10/93

ISOLATION ZONE

6/17/91

(CONTINUED)

~

EVENT DETERMINED NOT REPORTABLE

BASED

UPON THE

FOLLOWING

FACTS OBTAINED FROM POSTED

OFFICER

. AND INDIVIDUALS INVOLVED

VISUAL INSPECTION

OF INITIAL

POSITION

BY SECURITY MANAGEMENT

SECURITY MANAGER DETERMINED SWING

SHIFT POSTING

WAS APPROPRIATE

THE EVENT WAS NOT REPORTABLE AND

DECLASSIFIED

PJC

18

05/10/93

SAFETY SIGNIFICANCE

~

TRAINING AND QUALIFICATION PLAN

ADMINISTRATIVE DISCREPANCIES

NO

PERFORMANCE ISSUES

TRAINING ON EQUIVALENT MEASURES

NOT INTENTIONAL

NO SAFETY SIGNIFICANCE

~

EVENT LOGGING/REPORTING

LICENSEE IDENTIFIED

NOT INTENTIONAL

,NO SAFETY SIGNIFICANCE

~

MANAGEMENT AWARENESS

OF POTENTIAL

VIOLATIONS

.TRB 1

05/10/93

CURRENT TRAINING PROGRAM

~

SECTION 3. 4

OF TRAINING AND

QUALIFICATION PLAN

~

CRUCIAL TASKS

'

INITIAL/REQUALIFICATIONARE THE SAME

TASKS

BROKEN

DOWN INTO SPECIFIC

SUBTASKS

GUIDELINE FOR

PERFORMANCE CRITERIA

PERFORMANCE

BASED/WRITTEN EXAM

INCREASED TEST

SCORE

REQUIREMENTS

ADDRESSES

INDIVIDUALNEEDS

OFFICERS'LUE

HANDBOOK

ADH 1

05/10/93

CURRENT TRAINING PROGRAM

(CONTINUED)

~

INITIALON-THE-JOB TRAINING (OJT)

PROGRAM

INSTRUCTORS

GUIDE

SPECIFIC

TASK COMPLETION

REQUIREMENTS

CONSISTENCY

~

ON SHIFT

ENHANCEMENT TRAINING

CONDUCTED

BY INSTRUCTORS

ON SHIFT

SUPERVISORY

INPUT

FOCUSES

ON INDIVIDUAL/SHIFTNEEDS

CONTINGENCY DRILLS

E-PLAN EVENTS

EQUIPMENT TESTING

SEARCHES

-

WEAPONS FAMILIARIZATION

RANDOM SELECTION CRUCIAL TASK

TESTING

ADH 2

05/10/93

i(

CURRENT TRAINING PROGRAM

(CONTINUED)

~

COMMUNICATIONS

TRAINING ADVISORY BOARD

(MONTHLY)

CUSTOMER

FEEDBACK QUESTIONNAIRE

FRONTLINE INVOLVEMENT IN ALL AREAS

OF TRAINING PLANNING AND DEVELOPMENT

AOH 3

05/10/93

CURRENT TRAINING PROGRAM

(CONTINUED)

~

RESULTS

IMPROVED TEST

SCORES

IMPROVE PERFORMANCE

-

NO 73.71

OR

HUMAN ERROR

EVENTS

(NEW

OUTAGE OFFICERS)

OVERALL IMPROVED COMMUNICATIONS AND

TEAMWORK

THOROUGH UNDERSTANDING AND KNOWLEDGE

OF JOB

AND PERFORMANCE CRITERIA

ADH 4

05/10/93

t

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