ML082190530
| ML082190530 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/04/2008 |
| From: | Minahan S Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BL-07-001, NLS2008057, TAC MD7588 | |
| Download: ML082190530 (9) | |
Text
H Nebraska Public Power District "Always there when you need us" NLS2008057 August 4, 2008 U. S. Nuclear Regulatory Commission Attention: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
Subject:
Response to Request for Additional Information Re: NRC Bulletin 2007-01, Security Officer Attentiveness Cooper Nuclear Station, Docket No. 50-298, DPR-46
Reference:
- 1.
Letter from Carl F. Lyon, U. S. Nuclear Regulatory Commission, to Stewart B. Minahan, Nebraska Public Power District, dated June 30, 2008, "Cooper Nuclear Station - Request for Additional Information Re: NRC Bulletin 2007-01, Security Officer Attentiveness (TAC No. MD7588)"
- 2.
Letter from Stewart B. Minahan, Nebraska Public Power District, to U. S. Nuclear Regulatory Commission, dated February 7, 2008, "60-Day Response to NRC Bulletin 2007-01, Security Officer Attentiveness"
- 3.
NRC Bulletin 2007-01, Security Officer Attentiveness,, dated December 12, 2007
Dear Sir or Madam:
The purpose of this letter is for the Nebraska Public Power District (NPPD) to submit a response to the U. S. Nuclear Regulatory Commission (NRC) Request for Additional Information provided by letter dated June 30, 2008 (Reference 1). NPPD had submitted a response in Reference 2 to provide the information requested in NRC Bulletin 2007-01, Security Officer Attentiveness (Reference 3).
If you have any questions regarding this response, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.
COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www nppd.com
NLS2008057 Page 2 of 2 I declare under penalty of perjury that the contents of this response are true and correct.
Executed On Aj*(#eg 0L2O'
"(Date).
Sincerely, Stewart B. Minahan Vice President - Nuclear and Chief Nuclear Officer
/lb Attachment cc:
Regional Administrator w/attachment' USNRC - Region IV CNS Project Manager w/attachment USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/attachment USNRC - CNS.
NPG Distribution w/o attachment
NLS2008057 Attachment Page 1 of 6 NEBRASKA PUBLIC POWER DISTRICT'S RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING NRC BULLETIN 2007-01, SECURITY OFFICER ATTENTIVENESS QUESTION 1 The U.S. Nuclear Regulatory Commission (NRC) staff reviewed your response to Question lb, and requests the following additional information.
- 1.
Describe any licensee processes or programs that are in place-to identify problems in climate controlled security areas. What methods are used to track, inspect, and ensure timely repairs are completed?
Include the following information in your response:
A description of how the security areas are maintained, including, but not limited to. (1) a discussion of the maintenance and/or preventive maintenance process andprograms in place for these security areas including an overview and brief discussion on routine inspection schedules by maintenance personnel, (2) a discussion on the process a security officer can follow to report concerns with the up keep and maintenance of his or her post; and, (3) a discussion on the timeliness of repairs and any follow up actions taken by the licensee to ensure the repairs are completed and resolved adequately.
RESPONSE
(1)
Maintenance on the, heating, ventilation, and air conditioning (HVAC) equipment in security areas at Cooper Nuclear Station (CNS) is driven by both the corrective and preventive maintenance programs. HVAC equipment in security areas is maintained by the site Maintenance Department. Areas in need of corrective maintenance are identified by work requests or condition reports. Bullet Resistant Enclosures (BREs) have self-contained HVAC units. Routine quarterly preventive maintenance is performed on HVAC units in the BREs. The site also maintains spare HVAC units for most BREs. In the event of an HVAC failure, the unit is promptly replaced by the Maintenance Department. The Central Alarm Station and Secondary Alarm Station have preventive maintenance tasks assigned for HVAC components that are performed on various frequencies ranging from monthly to every two years. Internal security posts are part of larger building maintenance plans for HVAC. In addition, Security management routinely assesses the material condition and appearance of posts to determine if conditions, including environmental conditions, could negatively impact attentiveness or vigilance, and determines appropriate mitigation measures. Adverse conditions or enhancements to a post are documented using the corrective action program (CAP) and/or work management system and corrected, as appropriate.
NLS2008057 Attachment Page 2 of 6 (2)
Security officers can enter a condition report into the CAP to bring forward a concern or can initiate a notification to request that work be performed.
(3)
Prioritization of work at CNS is controlled by Station Procedure 0.40, Work Control Program. Deficiencies in security are evaluated against a prioritization matrix in.this document and repairs are scheduled accordingly. Security management interfaces with Work Control as necessary to ensure repairs are scheduled and completed in a timely manner. Items classified as security deficiencies are normally worked in the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; minor security issues are evaluated for inclusion into the site work process. -In addition, Security management attends a daily Plant Production Meeting that provides an opportunity for Security to discuss any emergent security equipment issues, influence the work priority, and convey the urgency in correcting security equipment issues.
QUESTION 2 The NRC staff reviewed your response to Question 1c, and requests the following additional information:
- 2.
What is the level of involvement from management who do not have direct responsibility for the security program (including executive and corporate management) in conducting behavior observations of security personnel?
Include the following information in your response:
A description of any processes in place for licensee and/or contract management, who work day to day at the site or visit the site on a routine basis from a corporate office or other applicable offsite location, for conducting behavior observations of security personnel while on duty at their assignedposts. Examples should include,, but are not limited to, 'a discussion of random or scheduled observations conducted by licensee and/or contract management such as the Plant Operations Shift Managers or' other Plant Operations Shift Supervisors, Plant Maintenance Supervisors (licensee and contractor),
or Quality Assurance Supervisors etc.. The discussion should include whether these random or scheduled observations are proceduralized and the required 'or recommended levelof licensee and/or contract management involvement.
RESPONSE
Administrative Procedure 0-CNS-07-MGMT, Management ObservationProgram, contains requirements for conducting behavior observations of site personnel, including Security personnel. The personnel who perform observations in accordance-with this procedure are site managers and supervisors. The observation program is composed of two parts: Leadership Logbook and' Backshift Observations. The Leadership Logbook program requires managers and supervisors to perform a minimum of 30 individual
NLS2008057 Attachment Page 3 of 6 observations/logbook entries each month. A representative sample of ten logbook entries per person per month is entered into an electronic database to support trending. These observations are of personnel in other departments, as well as their own department. The Backshift Observation program assigns a member of management to perform abackshift or weekend observation nominally each week. The assignment and completion of these backshift/weekend observations is tracked in an electronic database. The assignments include a specific focus on attentiveness. In addition to documenting observations in the Leadership Logbook and the electronic tracking database, condition reports are to be generated if conditions warrant.
QUESTION 3 The NRC staff reviewed your response to Question 1 and requests the following additional information:
- 3.
How is the licensee's policy regarding site employee attentiveness and/or inattentiveness communicated to personnel, both licensee and contractor, and at what frequency?
RESPONSE
CNS does not have a specific site policy document on attentiveness. However, procedures and training communicate the expectations related to attentiveness. The primary method of communicating the site's policy on attentiveness is. through: General Orientation Training. All badged personnel, both licensee and contractor, receive annual Plant Access Training and Fitness for Duty (FFD) Training which includes discussion of FFD responsibilities, including reporting personnel sleeping on the job, recognizing fatigue, and the plant sleeping policy. CNS Procedure 0-FFD-01, NPG Fitness for Duty Program and Behavioral Observation Program, identifies the responsibility of employees to report any instance when they are not fit for duty for, any reason, including fatigue. It also contains the employee's responsibility to report if they believe another individual is not fit for duty. This procedure is available to all personnel and is also an input to FFD training.
Security Officers and.Security Supervisors receive initial awareness level training on-the effects of fatigue and fatigue management, and subsequent tailgate training as appropriate. A shift briefing paper on "Attentiveness to Duty and Reporting Requirements" was presented to the Security force in early 2008. This material is also presented to newly hired Officers. Security Procedure 1.2, Security Working Hours Limitations, provides Security personnel with direction related to fatigue monitoring, self-declaration of being unfit for duty due to fatigue, and fatigue evaluations. ý This information is also included in Security Officer requalification training. In addition,at Security shift turnover briefings, Officers are specifically asked if they are sufficiently rested so they are not in danger of becoming less than alert during the shift.
NLS2008057 Attachment Page 4 of 6 QUESTION 4 The NRC staff reviewed your response to Question 2 and requests the following additional information.
- 4.
Can the employees view the status and disposition of reports directly, or must this information be requested? Ifyes, please describe the process.
RESPONSE
The employee's ability to view the status and disposition of a report varies depending on the method used to make the report. Concerns that are entered into the CAP can be viewed at any time in an electronic tracking program by all personnel with access to a plant computer. There are no restrictions on the ability to view the status or disposition of concerns in CAP. If an employee used an alternative means of reporting such as the Employee Concerns Program, Human Resources, the Quality Assurance organization, or FFD/Access Authorization, then the employee would need to follow-up with the organization that the concern was reported'to. If a report deals with a personnel FFD issue, the associated personal information is not made public in an electronic database.
An individual's FFD/Access Authorization file would include a history of any inattentiveness issues and associated FFD evaluations. An individual may contact FFD/Access Authorization to view their file.
QUESTION 5 The NRC staff reviewed your response to -Question 5 and requests the following additional information.
- 5.
How do you assess the effectiveness of your oversight of contractors and subcontractors?
Include the following information in your response:
Describe the licensee's program for oversight of contractors and subcontractors including, but not limited to. (1) a brief overview and description of licensee procedures that describe the oversight process; (2) include a detailed list (bulleted is preferred) of assigned dutiesfor the licensee supervisor(s) or manager(s) responsible for overseeing contractors and subcontractors at the site; (3) include a detailed list (bulleted is preferred) of the assigned duties for the contractor and subcontractor supervisor(s) or manager(s) responsible for overseeing the contractor and subcontractor staff at the site; and (4) a brief discussion of the corporate (management) -involv:ement with, the oversight of contractors and subcontractors at the site.
NLS2008057 Attachment Page 5 of 6
RESPONSE
Note: CNS does not have a contract security force; therefore, this response pertains to oversight of contractors and subcontractors in general.
(1)
Administrative Procedure 1 -CNS-MP-106, Contract Management, provides instructions to contract managers and other CNS personnel responsible for supplemental personnel in regard to oversight responsibilities. It includes: initial indoctrination of supplemental personnel, check-out process for supplemental personnel, performance standards and expectations of supplemental personnel, safety expectations, contract manager training, responsibilities of contract managers, and guidance for initiating and implementing contracts.
(2)
Duties of licensee supervisors or managers responsible for overseeing contractors or subcontractors at the site include:
clearly communicate standards and expectations to supplemental personnel to ensure they understand and strive to meet the standards and expectations at the site, ensure supplemental personnel meet job qualification requirements, enforce safety rules with workers, ensure compliance with contract documents and station procedures, make workers aware of their responsibility to raise issues related to nuclear safety or quality, direct overall activities to achieve acceptable quality..
(3)
The duties of contractor and subcontractor supervisors or managers responsible for providing oversight of contractors and subcontractors at the site are generally the same as those of licensee supervisors or managers. Procedure 1 -CNS-MP-106 states that supplemental supervisors overseeing the work for supplemental personnel are made fully aware of station standards for the conduct of work and must hold workers accountable to those standards. During outages, supplemental supervisors receive CNS outage supervisor training to ensure their understanding of station standards and oversight expectations. In addition, a recent revision to Procedure 1 -CNS-MP-106 requires supplemental contract managers to take the same contract manager training as licensee contract managers. This training includes Procedure 1-CNS-MP-106 which includes the responsibilities listed above.
(4)
Senior Management for CNS is located onsite, rather than at an offsite corporate location, thereby affording them the opportunity -to directly observe contractors and subcontractors working at the site. Department Managers are responsible for selecting contract managers to meet the company's business needs. They provide oversight of contract managers and supplemental personnel as part of their normal
NLS2008057 Attachment Page 6 of 6 management function.. They also observe the performance of contract personnel as part of the Management Observation Program.
Effectiveness of contractor and subcontractor oversight can be assessed by the CAP, human performance evaluation results, field observations,. and nuclear oversight observations. In addition, Procedure 1-CNS-MP-106 contains a form to be filled out upon closeout of a contract that evaluates contract performance based upon factors such as schedule, cost, on-site supervision, quality, safety, and procedural compliance.
ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS@
ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS0 Correspondence Number: NLS2008057 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None PROCEDURE 0.42 REVISION 22 PAGE 18 OF 25