ML20055G687

Insp Repts 50-498/85-05 & 50-499/85-05 on 850408-12.No Violations or Deviations Noted.Major Areas Inspected: Security Program Development Involving Personnel Fitness for Duty,Handling of Reported Quality Concerns & Security Sys

ML20055G687
Person / Time
Site:	South Texas
Issue date:	05/21/1985
From:	Everett R, Jaudon J, Joseph Kelly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20055C208	List: ML20055C207 ML20055G674 ML20055G687 ML20055G700 ML20055G702 ML20055G710 ML20055G715 ML20055G719 ML20055G725 ML20055G731 ML20055G734 ML20055G740 ML20055G744 ML20055G748 ML20055G753 ML20055G765 ML20055G769 ML20055G773 ML20055G775 ML20055G780 ML20055G782 ML20055G783 ML20055G786 ML20055G788 ML20055G797 ML20055G805
References
FOIA-89-540 50-498-85-05-01, 50-498-85-5-1, 50-499-85-05, 50-499-85-5, NUDOCS 9007240071
Download: ML20055G687 (7)

See also: IR 05000498/1985005

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, APPENDIX

U. S. NUCLEAR REGULATORY COMMIS$10N

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NRC Inspection Report: 50-498/85-05 -Construction Permits: CPPR-128

50-499/85-05 CPpR-129

Dockets: 50-498; 50-499 Category: A2 )

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licensee: . Houston Lighting & ?ower Company (HL&D) J

P. O. Box 1700

Houston,. Texas 77)01

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Facility Name: South Texas Project, Units 1 and 2

Inspection At: South Texas Project, Matagorda County, Texas

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Inspection Conducted: April 8-12, 1985

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_ Inspector: v e ) be I. ._ ' 17tdo i 6I

J. .-F.Kel19,SeniorPhysAlSecurity 9a te .- #

pecialist

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R. J. Everett, Acting Chief,. Nuclear Materials Da'te

Safety and Safeguards Branch

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Approved:  % -- - Mz///'C- -l

/).d.P.Jaudon, Chief,ProjectSectionA Date i

a Reactor Project Branch 1

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inspection Summary

inspection Conducted April 8-12, 1985 (Report 50-498/85-05; 50-499/85-05)

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Areas Inspected: Routine, announced inspection of preoperational security

program development involving personnel fitness for duty, handling of reported

quality concerns, security organization c.'evelopment, and the coordination of

physical security systems. The inspection involved 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of direct

inspection by one NRC inspector.

Results: Within the four areas inspected, no violations or deviations were

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1. Persons Contacted

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J. G. Dewease, Vice President

W.; Palmer, Consulting- to Computer Engineering (Computer Technician)

W. Kinsey, Plant Manager

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G. Parkey, Technical Suppert Superintendent

B. Philips, Manager, Saf 4team

S. Dew, Deputy Project Manager

T. Godsey, Reactor Engineer

B. Thiele, Reactor Engineer

G. Parker, Security Department Manager

'A. Hill, Nuclear Security Division Manager

• J. R. Moore, General Supervisor, Site Security

'A. Fields Senior Coordinator

A. Woods, Supervisor Administrative / Construction -

• L. George, Senior Coordinator

D. Ellis, Supervisor, Personnel Record.s

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B. Brookshire, Employment Specialist, Personnel Relations

A.- Gomez, Supervisor, Personnel Relations

M. Segel, Bechtel Safety / Security Supervisor

J. Sparks, Ebasco Security Supervisor

J. W. Sirles, Ebasco Training Supervisor

NRC

• C. Johnson, Senter Resident inspector

• Denotes those attending the exit interview conducted on. April 12, 1985.

2. Personne1' Fitness for Duty Program

.This review examined the content of the licensee's fitness for duty

program and the progress of implementation. The jurpose'of the review was

to ensure that the program would likely prevent' tie employment of

undesirable persons, assist in early detection of aberrant behavior, and.

provide for treatment of employees suffering from stress.

The. inspection was conducted by reviewing the directives and procedures

which describe the program elements, inspection of selected personnel

files and lesson plans for some of the required training, interviews of

supervisors in principal disciplines, discussions with principal licensee-

staff charged with administering the project, and inspection of records

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.' and results of the activities of the security department in preventing or

detecting the use of contraband material on the site.

The elements and method of implementation of a fitness for duty program

are not prescribed by NRC regulation. Guidelines for acceptable programs

are in place in the military and in other industries; and have been-

outlined for adoption within the nuclear utility industry by Nuclear .i

Utilities Management Human Resources Committee, a committee of senior

utility executives. The NRC inspector compared the HL&P programs with .!

the nuclear industry guidelines as well as.the specifics of personnel

selection and fitness for duty programs at a variety of nuclear power

plants, j

The HL&P fitness for duty program consists of the following elements:  ;

a. Personnel Screening - Prospective employees undergo a background

investigation.- The background investigation includes a records

check. All new hires must undergo a physical examination which

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includes a urinalysis which is checked for certain types of drugs.

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Esch person requiring access to the protected area undergoes *

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psychological screening (MMPI) and clinical interviews.

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l' b. Employee Assistance - A confidentiai employee assistance program is '

available to all-HL&P personnel associated with the South Texas

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Project. This program includes _ the employee and their family for any

type of problem that sight impact performance. The program is

described in a number of pamphlets. Referrals by supervisors or the

clinical staff have also occurred.

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L c.- Alcohol / Drug Abuse Awareness - HL&P nuclear department employees will

l1 participate in alcohol / drug abuse-awareness education programs.

Signs and posters may now be.found prominently displayed.

d. Minimum On-Duty Performance Requirements - The licensee has published

a clear policy on the minimum on-duty requirements which is mandatory

reading for all employees. These requirements address, in a positive

fashion, the question of off-duty use of illegal drugs or controlled  :

substances. Prohibitions on illegal = items on company property are

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published.and advertised through numerous signs on the site.  ;

e. Behavioral Observation - All contractor supervisors undergo a

training program on how to observe their employees for indicators of

impacted performance. Interviews with supervisors estabitshed that

this was generally useful training. Plans for retraining in this '

subject are being considered by the licensee.

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f. Security Organ 1:ation - T'se security organization also plays a strong -

' role in the fitness for duty program. . Prompt investigation, strong

emphasis on prevention, and close cooperation with local law-

enforcement authorities were apparent. Unannounced searches of-

personnel, packages, and vehicles have resulted in' numerous

suspensions, terminations, seizures, and referrals to the local law

enforcement agencies. These searchea have included the use of drug

dogs on occasion.-

Many disciplines and organizations and their sub-divisions are

involved in this effort. Events could be better centrally reco.Med'

for future reference and management representatives from the- ,

respective units could improve coordination by organizing a

multi-discipline committee. In addition,-specific direction should I

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be given to the contractors and subcontractors concerning the develop-

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ment of programs for their people and the reporting of violations.

No violations or deviations were identified.

3. Security Organization . .

The South Texas Project is currently in an active construction mode.

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Therefore the security of the site has ' multiple facets. The. constructor

has a major responsibility for industrial security. A contract security

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firm provides a uniformed guard service. That service is supervised.by .j

the onsite HL&P security superintendent through his staff.

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The Vice President of Administration for HL&P oversees the corporate

security program. Its manager has two divisions reporting. One division

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is the Nuclear Security Division which has a headquarters staff and an 1

onsite staff. The division manager, while directly reporting to the i

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corporate security manager,- also-maintains liaison with the Vice President

for. Nuclear Operations. The plant Jnanager reports to the same Vice

President while the: site security superintendent reports to the Nuclear

Security 01 vision (NSD) Manager. The NSD manager has staffed three

developmental areas: plans coordination, access control, and an internal

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inspections program. .

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Currently on site are the supervisor of the construction force contract,

o supervisor of security training development, and the supervisor of

security operations development.

Currently at the corporate office are personnel who develop plans and

procedures and who are working with the access control program. This

staff-maintains liaison with NRC, HL&P licensing staff, personnel

management, and the engineering groups responsible for the design and

implementation of the security hardware and software systems.

No violations or deviations were identified.

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4. Handline of Identified Quality Concerns

HL&P has formed an onsite group entitled Safeteam. This program was

established to identify and investigate nuclear quality-related concerns.

The' techniques employed to obtain information are exit interviews for

terminated employees; scheduled quality interviews for key current

employees; onsite posters soliciting information which may be anonymously

given by telephone; and to cover those persons who have departed the

project, post-exit surveys have been conducted through the mail with past

employees. . ,

The Safeteam group' manager had been reporting directly to the Group Vice

President Nuclear. A restructuring of the organization established a

Nuclear Assurance unit. It is headed by a manager who reports to ths

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group vice president. Corporate quality assurance and Safeteam report to

the Corporate Nuclear Assurance manager. The stated purpose is contrasted

by pointing out that the program is not a substitute for management and

that supervisors must still act on concerns.

Within the Safeteam, there is an investigative unit. and an interview unit.

The manager oversees all the incoming reports, makes the assignments, and_.

controls the actions through a combined file and data management system.

Referrals are made to the appropriate technical staff for review. Some

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drug related allegations come into the system and are referred in like

manner. It appeared that these were not being closed out after referral

and the licemee's security superintendent was not being notified. The

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constructor is running an independent investigative unit on site and the

result of a meeting between these parties was an agreement to improve

coordination between the responsible parties.

No violations or deviations were identified.

5. Testing and Maintenance _of Security Systems

The Bechtel Corporation serves as the project architect-engineer. They

are the coordinators of engineering changes that relate to the development

of the security system design, installation, implementation and

procedural development for the testing and maintenance of the system. They

also have the responsibility for coordination of the compatibility of

security, fire, and health physics barriers, portals, and detection systems.

This is a safety and safeguards interface matter.

Arvin Otamond is the contractor who designed the intrusion detection and

personnel accountability system. They are responsible for maintaining the

electrical diagrams for the installation of the system. The software for

the security system management is to be designed around a canned package

as opposed to be site specific. The system, equipment, and methodology as

currently configured is far behind the current state of the art.

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-TheHL&Pelectilcalengineeringgroupisresponsibleforreviewingte-h NRC

requirements for electronic systems and electrically supported elements of

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the security. system. It appears that an oversite role is necessary to

ensure that the system will allow security operations to comply with NRC

regulations. '

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The HL&P operation: group contains the technical support and computer

supportidivisions. It is intended that there be a dedicated security'

systems l&C maintenance team that will have direct' involvement with

startup. Inspection experience reflects that a computer software

specialist will also be required as a part of this team to make the-

selected system function as a site specific. program.

.It was not clear what group is responsible for reviewing the civil

engineering requirements of. design and specifications control related to q

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fences and gates, the grading and surfacing of isolation zones and road

l. beds, and the location and design of mounts for security related '

equipment. Some errors have already been identified.

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A program for coordinating the proper integration of all of the security

L system sub-elements is not visible. Experience reflects that an early .  ;

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formation of a' coordinating committee consisting of representatives from  !

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- 6 ', Exit Interview-

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L An exit 1nterview was conducted on April 12, 1985, with those personnel

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denoted in paragraph 1 of this report. At this exit interview the The NRC'

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inspector summarized the scope and findings of this inspection.

licensee acknowledged his understanding of the inspection findings. g

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