ML20236W149
| ML20236W149 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/30/1998 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-1170, 50-346-98-08, 50-346-98-8, NUDOCS 9808050111 | |
| Download: ML20236W149 (3) | |
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_m Daws-Bosse Nuclear Power Station y y 5501 North State Route 2 Oak Harbor Ohio 43449-9760 s
. John K. Wood 419-249-2300 Vice President-Nuclear Fax: 419-321-8337 Docket Number 50-346 License Number NPF-3 l
Serial Number 1-1170 July 30, 1998 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555
Subject:
Response to Inspection Report 50-346/98008; Reply to Notice of Violation Ladies and Gentlemen:
Toledo Edison has received Inspection Report (IR) 50-346/98008 (Log Number 1-3979) and the enclosed Notice of Violation issued on June 30,1998. The violation involved the failure to provide some of the required information for background investigation evaluations. Toledo i
Edison's response for the Davis-Besse Nuclear Power Station, Unit (1) (DBNPS) to the Notice of Violation is presented in Attachment 1.
i Should you have any questions or require additional information, please contact Mr. James L.
Freels, Manager - Regulatory Affairs, at (419) 321-8466.
1 Very truly yours,w CA ' aj cc: A. B. Beach, Regional Administra*or, NRC Region III S. J. Campbell, DB-1 Senior Resident Inspector A. G. Hansen, NRC/NRR Project Manager
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Utility Radiological Safety Board
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- Docket Number 50-346 License Number NPF-3
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Serial Number 1-1170 Attachntent 1
- Page1 Reolv to a Notice of Violation (50-346/98008)
Restatement of Allened Violation "During an NRC inspection conducted from May 26 to June 17,1998, a violation of NRC requirements was identified. In accordance with NUREG-1600, Revision 1, " General Statement of Policy and Procedure for NRC Enforcement Actions," the violation is listed below:
- Section 2 of Amendment 14, dated April 13,1979, to Facility Operating License No. NPF-3, requires the licensee to implement all provisions of the Commission Approved physical security plan, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p).
Section 1.1.1.3 of the Davis Besse Security Plan requires access authorization to the protected
- and vital areas at the plant to be granted in accordance with federal regulations and company procedures.
Section 1.3.1 of the Davis Besse Security Plan requires the Access Authorization Program to meet the requirements of Regulatory Guide 5.66, (" Access Authorization Program For Nuclear Power Plants", dated June 1991) which are specified in licensee procedure IS-AC-00516, L
" Unescorted Access Requirements." NUMARC document 89-01 is an appendix to USNRC Regulatory Guide 5.66.
. Section 1.6.1 of the Davis Besse Security Plan requires successful completion of the access authorization requirements specified in licensee procedure IS-AC-00516, " Unescorted Access Requirements", before unescorted access is granted to the protected and/or vital areas.
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. Section 6.5.1.d of licensee procedure IS-AC00516, " Unescorted Access Requirements", Revision 9, approved JLauary 30,1998, and Section 6.2.1 of NUMARC document 89-01, Industry Guidelines for Nuclear Power Plant Access Authorization Programs", August 1989,(Appendix to USNRC Regulatory Guide 5.66, " Access Authorization Program For Nuclear Power Plants",
dated June 1991) requires employment history to be obtained by contncting employers for the past five years to verify the following information for all claimed periods of employment of 30 days or i
more: Position held by the individual; disciplinary history; reasons for termination and eligibility for re-hire; and any other information that would adversely reflect upon the reliability and trustworthiness of the individual as it relates to being granted unescorted access.
i 10 CFR 73.56(f)(2) requires licensees, contractors, and vendors to make background investi-I gation personal information required by 10 CFR 73.56 available to another licensee, contractor, i
or vendor provided that the request is accompanied by a signed release from the individual.
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Contrary to the above, record reviews and interviews showed that unescorted access to the protected area was granted to two security officers without all required elements of employment j
history being provided by the licensee or evaluated. Additionally, for an indeterminate period of
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- Docket Number 50-346 l
License Number NPF-3 l
Serial Number 1-1170 Attachntent 1 '
j Page 2 time, the licensee failed to make personal inform ation available to other licensees and contractors authorized to receive such information. Required information pertaining to disciplinary history, reasons for termination and eligibility for re-hire, and any other information that would reflect l
upon the reliability and trustworthiness of the individual as it relates to being granted unescorted access would not be released.
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This is a Severity Level IV violation (Supplement III)."
Reason for the Violation The reason for this violation is inadequate communication of specific Nuclear Regulatory Commission (NRC) regulatory requirements to individuals in Human Resources responsible for employment verification for all Company personnel, including Davis-Besse Nuclear Power Station (DBNPS). All requests for employment verification and other personnel information are directed to the Human Resources Department. No other employee may provide verification information. The Corporate policy specifically limited responses to employment verification requests from outside sources to job title, continuous service date, employment status and exit date. No one questioned why specific answers were not provided to licensee inquiries because it was understood that they were to be treated as all other inquiries.
Corrective Steps Taken and Results Achieved Nuclear Human Resources along with DBNPS Security have reviewed Code of Federal Regulations (CFR) Title 10 Part 73.56 and Nuclear Management and Resources Council (NUMARC) document 89-01 and issued an interim guidance document on July 13,1998 to Human Resource and Access Control personnel to ensure that employment verification questions are answered in accordance with the regulations. Human Resources will answer employment verification questions in accordance with 10 CFR 73.56 and Access Control will respond to suitable inquiry questions in accordance with 10 CFR 26.27.
Corrective Steps to Avoid Further Violations 1
The Company's " Employment Verification" policy and DBNPS Procedure, IS-AC-00516,
" Unescorted Access Requirements" will be reviewed and revised as necessary to ensure that the requirements of 10 CFR 73.56 and NUMARC document 89-01 are implemented. The review, revisions to policies and procedures, as applicable, and the training of appropriate personnel will be completed by September 30,1998.
Date When Full Compliance Will Be Achieved Full Compliance with 10 CFR 73.56 and NUMARC document 89-01 was achieved on July 13, 1998 with the issuance of the interim guidance.
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