ML20140C244
| ML20140C244 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/30/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20140C208 | List: |
| References | |
| 50-321-97-04, 50-321-97-4, 50-366-97-04, 50-366-97-4, NUDOCS 9706090173 | |
| Download: ML20140C244 (8) | |
See also: IR 05000321/1997004
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U.S. NUCLEAR REGULATORY COMMISSION
REGION 11
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Docket Nos:
50-321, 50-366
License Nos:
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
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Special Inspection Branch .
Division of Radiation Safety
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EXECUTIVE SUMMARY
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Plant Hatch, Units 1 and 2
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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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Compensatory posts were appropriately established and were in accordance with the
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licensee's Physical Security Plan and applicable procedures.
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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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The licensee's failure to adhere to 10 CFR 26.20 and their Fitness For Duty procedure
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resulted in a violation of regulatory requirements. The inspector also noted that the
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practice of utilizing a mandatory Employee Assistance Program referral should be
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documented and communicated to the workforce population.
Security officers were knowledgeable in their duties and complied with the licensee's
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Physical Security Plan and implementing procedures by performing effective searches
of packages, material, and hand-carried items.-
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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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Conduct of Security Facilities and Equipment
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S1.1
Comqqnacter Measures
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a.
Insoection Scope (81700)
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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
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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.
c.
Conclusions
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The inspector determined that compensatory posts were appropriately established and
in accordance with the licensee's PSP and applicable procedures.
S1.2 Access Authorization
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a.
Inspection Scope (Tl 2515/127)
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
be made as soon as possible but no later than the first day or first shift after the
employee returns to work.
Additionally, the licensee's Personnel History Question clearly states that it is the
responsibility of all individuals with unescorted access authorization to report any
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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
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
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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
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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
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of regulatory requirements. The inspector also noted that the practice of utilizing a
mandatory EAP referral was not defined, documented and communicated to the
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workforce population.
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S2
Status of Security Facilities and Equipment
S2.1
Protected Area Access Control
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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
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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
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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.
Security Safeguards Staff Training and Qualification
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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.
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However, this must be accomplished within 31 days.
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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
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physical fitness test. However, on April 1,1997, the security lieutenant failed the 100
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yard run on the first and second attempt. The lieutenant was placed in a watchperson
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
Hatch security officers were appropriately trained and qualified in accordance with the
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licensee's T&OP.
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V. Manaaement Meetinas
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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
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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
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Licensee
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L. Adams, Security Supervisor
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D. Davis, Manager
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O. Fraser, SAER Supervisor
B. Mcginn, Security Supervisor
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NRC
B. Holbrook, Senior Resident inspector
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INSPECTION PROCEDURES USED
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IP 81700:
Physical Security Program for Power Reactors
IP 81502:
Fitness for Duty Program
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T12515/127: Access Authorization Program
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ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-321, 50-366/97-04-01
Failure to maintain confidentiality of Employee
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Assistance Program information
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