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Insp Repts 50-321/97-04 & 50-366/97-04 on 970428-0502. Violations Noted.Major Areas Inspected:Fitness for Duty, Access Authorization & Physical Security Program for Power Reactors
	ML20140C244
Person / Time
Site:	Hatch
Issue date:	05/30/1997
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20140C208	List: ML20140C203; ML20140C230; ML20140C244;
References
	50-321-97-04, 50-321-97-4, 50-366-97-04, 50-366-97-4, NUDOCS 9706090173
	Download: ML20140C244 (8)
	v • d • e

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U.S. NUCLEAR REGULATORY COMMISSION

REGION 11 j

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Docket Nos: 50-321, 50-366

License Nos: DPR-57 and NPF-5

Report Nos: 50-321/97-04, 50-366/97-04

Licensee: Southern Nuclear Operating Company, Inc. (SNC)

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Facility: E. l. Hatch Units 1 & 2

Location: 11030 Hatch Parkway North

Baxley, Georgia 31513

Dates: April 28 - May 2,1997

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Inspector: L. Stratton, Safeguards Inspector !

Approved by: P. Fredrickson, Chief ,

Special Inspection Branch . l

Division of Radiation Safety

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EXECUTIVE SUMMARY

, Plant Hatch, Units 1 and 2

NRC Inspection Report 50-321/97-04,' 50-366/97-04 ;

This routine announced inspection was conducted in the area of plant support by a regional

safeguards specialist. The specific areas evaluated were Fitness for Duty, Access

Authorization, and the Physical Security Program for Power Reactors.

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o Compensatory posts were appropriately established and were in accordance with the l

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o The licensee clearly documented and communicated the requirement to report arrests !

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for all employees as outlined in their implementing procedures.

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o The licensee's failure to adhere to 10 CFR 26.20 and their Fitness For Duty procedure

resulted in a violation of regulatory requirements. The inspector also noted that the

i practice of utilizing a mandatory Employee Assistance Program referral should be ,

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o Security officers were knowledgeable in their duties and complied with the licensee's

Physical Security Plan and implementing procedures by performing effective searches

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of packages, material, and hand-carried items.-

o Security officers were appropriately trained and qualified in accordance with the

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licensee's Training and Qualification Plan.

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REPORT DETAILS

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S1 Conduct of Security Facilities and Equipment

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S1.1 Comqqnacter Measures 1

, a. Insoection Scope (81700) I

The inspector evaluated the licensee's implementation of open and closed

compensatory measures to determine compliance with applicable procedures and the

licensee's Physical Security Plan (PSP).

b. Observations and Findinas

The inspector toured the protected area and interviewed officers that were currently

performing compensatory post duties. All officers had compensatory post orders

available and were knowledgeable of their duties and responsibilities.

The inspector performed a random review of documentation for compensatory posts

established during the period of January 1 to May 1,1997. The following ,

circumstances were noted by the inspector ;

On February 13,1997, a compensatory post was established for Warehouse 6 due to

major roof repairs being performed. Procedure S2SS-SEC-027-5S, " Security ,

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Compensatory Actions," Revision 5, dated February 22,1996, outlines the process

and practices that allows compensatory posts to be established. Section 4.1.1 states,

" Personnel performing this procedures shall be trained and qualified in accordance

with the Hatch Nuclear Security Training and Qualification Plan."

The inspector verified, through review of training records, that the three security

officers who performed compensatory duty on February 13,1997, for the degraded

Warehouse 6 roof, were appropriately trained and qualified in accordance with the

licensee's Training and Qualification Plan (T&QP).

The inspector reviewed applicable plan cornmitments and procedures to determine if

the correct location and number of officers utilized during the Warehouse #6 roof

moair was in compliance. Procedure S2SS-SEC-027-5S, " Security Compensatory

Actions," Revision 5, Section 4.3.4 and 7.6.1, dated February 22,1996, states

respectively:

The total number of security officers and/or watchpersons posted to provide direct

observation of affected areas in the event of failure of the barriers, intrusion detection

system, or assessment aids, will be determined by the Supervisor, Nuclear Security

(Captain). In the event of a failure or reduced effectiveness of no more than two

protected intrusion detection zones, CCTV(s) may be positioned in the affected

area (s) with a dedicated monitor and/or security officer (s) posted to compensate for

the failed zones. One security officer may cover more than one zone if the zones are

adjacent to each other and can be viewed entirely from one location.

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Through documentation and interview of security and warehouse personnel, the ;

inspector determined that the officus were positioned appropriately so that the

degraded zones due to the Warehouse #6 roof repair were being viewed in their

entirety.

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c. Conclusions

The inspector determined that compensatory posts were appropriately established and

in accordance with the licensee's PSP and applicable procedures.

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S1.2 Access Authorization

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a. Inspection Scope (Tl 2515/127) l

The inspector reviewed the licensee's Access Authorization Program (AAP) with

respect to the reporting of arrests.

b. Observations and Findinas

Southern Nuclear Corporate Guideline 752, " Reporting of Custodial Arrest," dated

April 30,1996, outlines the requirements and process for all employees to report !

arrest during their employment with Southern Nuclear Operating Company. The !

inspector noted that the procedures required that the reporting of anest to supervision i

be made as soon as possible but no later than the first day or first shift after the i

employee returns to work. l

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Additionally, the licensee's Personnel History Question clearly states that it is the

responsibility of all individuals with unescorted access authorization to report any l

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arrest to their supervisor in order for an evaluation to be made regarding

trustworthiness as it relates to access authorization.

The inspector verified that training was conducted in the area of reporting of arrests

by reviewing checkoff sheets for directives issued in 1995 and 1996. Additionally,

through interview of licensee representatives, the inspector concluded that employees

were aware of the requirements to report arrests and the licensee's policies were

widely communicated throughout the plant workforce.

c. Conclusions

The inspector determined that the licensee clearly documented and communicated the

requirement to report arrests for all employees as outlined in their implementing

procedures.

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S1.3 Fitness for Duty

a. Inspection Scope (81502)

The inspector reviewed the licensee's process and procedures which implemented

10 CFR 26.

b. Observations and Findinas

Upon a random review of fitness for duty (FFD) records and interview of licensee

representatives, the inspector noted the following:

On February 21,1997, an individual was referred to the Employee Assistance

Program (EAP). However, prior to signing a medical release form, the EAP evaluation

was released during the period of February 24-28,1997, to select FFD staff members.

On March 5,1997, the individual signed a consent form with a stipulation that no

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personal information be released. Another consent form without a stipulation was

signed by the individual on March 11,1997.

10 CFR 26.20(b) states in part that the licensee shall establish and implement written

policies and procedures designed to meet the general performance objective of this

part;...a description of programs which are available to personnel desiring assistance

in dealing with drug, alcohol, or other problems that could adversely affect the

performance of activities within the scope of this part.

Southern Nuclear Corporate Guideline 720-001, " Fitness For Duty," Revision, dated

July 12,1996, Employee Assistance Program, states in part that referrals to the

Employee Assistance Program are maintained in confidence, and discussion of the

problem is treated as a confidential matter between the employee and the counselor.

Information will not be released without written permission from the employee unless

required by law.

The licensee's failure to maintain confidentiality of the individual's EAP evaluation

prior to receiving written permission from the employee is a violation of regulatory

requirements. (97-04-01)

Upon further discussion with licensee representatives, the inspector determined that a

" mandatory EAP referral" process was utilized in this individual's case. The licensee

stated that under a mandatory EAP referral, which applies to security officers and

licensed operators, the release of confidential information without a consent form is

waived due to the requirements that licensed operators and security officer be

physically and mentally fit. However, the licensee had rio written guidance,

procedures, or description of what constituted a mandatory EAP referral or the

i process to follow in the event a mandatory EAP referral was warranted. All

documentation reviewed by the inspector, which is also available to employees,

maintains that the EAP is a confidential program.

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c. Conclusions

- The licensee's failure to adhere to 10 CFR 26.20 and its FFD procedure is a violation {

of regulatory requirements. The inspector also noted that the practice of utilizing a l

mandatory EAP referral was not defined, documented and communicated to the 1

workforce population.

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S2 Status of Security Facilities and Equipment

S2.1 Protected Area Access Control

i a. Inspection Scope (81700)

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The inspector evaluated the licensee's process of searching packages, materials, and

hand-carried items being carried into the protected area (PA).

b. ' Observations and Findinas

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The licensee's PSP, dated June 1991, Section 5.3.3 outlines the requirements for j

searching packages, materials, and hand-carried items entering the PA. !

Additionally, licensee procedure S2SS-SEC-019-SS, Vehicle and Cargo Search, ,

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Revision 4, dated April 10, implements the provisions of Section 5.4.4 of the

licensee's PSP.

The inspector observed, during the course of the inspection, that packages, materials,

and hand-carried items that could not be effectively searched and were not

categorized as Category 1, il, lil, or IV, were hand-searched in detail in accordance

with the PSP and procedure S2SS-SEC-019-5S.

c. Conclusions

The inspector concluded that security officers were knowledgeable in their duties and

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complied with the licensee's PSP and implementing procedures in order to perform

effective searches of packages, material, and hand-carried items.

SS Security Safeguards Staff Training and Qualification

.a. Inspection Scope (81700)

The inspector evaluated the licensee's Training and Qualification Program for security

officers in accordance with the licensee's Training and Qualification Plan (T&QP),

dated March 1993.

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b. Observations and Findinas

The inspector reviewed licensee procedure 72TR-SEC-001-0S, " Security Training

Program," Revision 4, dated October 22,1996, to determine if security officers and

Tactical Response Team (TRT) members were adequately trained and assigned

appropnate duties and tasks.

Section 7.2.7 of procedure 72TR-SEC-001-0S documented that the physical fitness

test of armed members of the security force will be administered by a member of the

Security Training Section or a security force supervisor in accordance with Annex 1-1

of the T&QP. In an individual fails any portion of the test, the individual must be

tested on the failed portion only prior to returning to duty or be temporarily reduced to

an unarmed /watchperson status pending retesting.

Additionally, Section 7.7 of procedure 72TR-SEC-001-OS outlines the provisions of

performance deficiencies. If an individual has failed any portion of a task, not to

include firearm qualification, the individual will be reassigned to a position not

requiring qualification in the failed area. Remedial training will be available for the

individual, as well as a second attempt and a third attempt at the failed qualification. ,

However, this must be accomplished within 31 days. j

The inspector randomly reviewed eight training files to ascertain whether qualification

scores and assigned duties, physical fitness test results, and weapons requalification

scores met the requirements of the T&QP. All records reviewed reflected accurate

recordkeeping and compliance with the provisions outlined in the licensee's TPQ and

implementing procedure. Notwithstanding, the following circumstances were noted by

the inspector.

A security lieutenant performed a physical fitness test on June 26,1995, and failed

the required 100 yard run within the specified time (25 seconds). However, a second

attempt was immediately performed and the lieutenant completed the 100 yard run in

21 seconds. On June 26,1996, the security lieutenant passed all aspects of the ,

physical fitness test. However, on April 1,1997, the security lieutenant failed the 100 l

yard run on the first and second attempt. The lieutenant was placed in a watchperson l

position. On April 26,1997, the lieutenant made a third attempt to perform the 100

yard run and successfully completed it within the required timeframe.

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c. Conclusions

Through document review, interview of security personnel, and observation of security

officers performing their duties and tasks, the inspector determined that the Plant

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Hatch security officers were appropriately trained and qualified in accordance with the I

licensee's T&OP. )

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f V. Manaaement Meetinas I

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X1 Exit Meeting Summary

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The inspector presented the inspection results to rnembers of licensee management at the

conclusion of the inspection on March 7,1997. The inspector discussed in detail the

, . circumstances surrounding the violation in the area of Fitness For Duty. The licensee l

acknowledged the inspector's findings. Although reviewed during this inspection, proprietary !

information is not contained in this report, Dissenting comments were not received by the

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licensee.

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PARTIAL LIST OF PERSONS CONTACTED l

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Licensee !

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L. Adams, Security Supervisor j

D. Davis, Manager

1 O. Fraser, SAER Supervisor

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B. Mcginn, Security Supervisor

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B. Holbrook, Senior Resident inspector

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INSPECTION PROCEDURES USED

IP 81700: Physical Security Program for Power Reactors

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IP 81502: Fitness for Duty Program

T12515/127: Access Authorization Program

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ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

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50-321, 50-366/97-04-01 VIO Failure to maintain confidentiality of Employee

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Assistance Program information

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ML20140C244

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