ML082320814
| ML082320814 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/07/2008 |
| From: | Gambhir S Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BL-07-001, GO2-08-118, TAC MD7585 | |
| Download: ML082320814 (6) | |
Text
ENERGY NORTHWEST Sudesh K. Gambhir Vice President, Technical Services P.O. Box 968, Mail Drop PE04 Richland, WA 99352-0968 Ph. 509-377-8313 F. 509-377-2354 sgambhir@energy-northwest.com August 7, 2008 G02-08-118 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING ENERGY NORTHWEST'S RESPONSE TO NRC BULLETIN 2007-01
Reference:
Letter dated July 7, 2008, CF Lyon (NRC) to JV Parrish (EN), "Columbia Generating Station - Request for Additional Information RE: Response to NRC Bulletin 2007-01 (TAC NO. MD7585)"
Dear Siror Madam:
Transmitted herewith in Attachment 1 is the Energy No'rthwest response to a Request for AdditionalInformation.
The responses attached hereto describe measures that are currently in place. No additional actions are planned and no nieWcommitments are included in this response.
If you have, any questions or require additional information, please contact M. C.
Humphreys at (509) 377-4025.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.
pectfully.
S.G am wbhi r
Vice President', Technical Services Atachment
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NRC RIV CF Lyon'-_NRC NRR NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399 WA Horin - Winston'& Strawn 74 f 2),a Kf E4<
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING ENERGY NORTHWEST'S RESPONSE TO NRC BULLETIN 2007-01 Page 1 of 5 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Item 1 The NRC staff reviewed your response to Question lb. and requests the following additional information:
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 and programs 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
Energy Northwest performs preventative maintenance (PM) activities on a semi-annual basis for all facility buildings. The scope of the PM activities includes but is not limited to cleaning, belt inspections and replacement, pressure checks, refrigerant level checks, heating element checks, and air filter changes. Informal walk-down inspections of security posts are performed periodically to identify personnel safety hazards, material condition, and climate control/environmental issues.
All Energy Northwest personnel, including Nuclear Security, can-report any facility related issues to the facility support call center. All Energy Northwest personnel can initiate Work Requests (WRs) on equipment or facility deficiencies. An additional program available to Energy Northwest personnel to report problems and deficiencies is the corrective action program. Energy Northwest's corrective action program is the means for all personnel to initiate corrective actions, and track progress of those actions to closure.
A review of th~e past six months has identified 10 WRs that have been generated on climate controlled security areas, eight of which involved the heating or air conditioning issues. All eight of these WRs involving heating and air conditioning were corrected.
WRs that remain open are reviewed bi-weekly for determination of additional actions that may be needed to resolve the issue.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING ENERGY NORTHWEST'S RESPONSE TO NRC BULLETIN 2007-01 -
Page 2 of 5 Item 2 The NRC staff reviewed your response to Question 1c. and requests the following additional information:
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 assigned posts. 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 level of licensee and/or contract management involvement.
Response
Managers (including executive management) and supervisors at Columbia Generating Station are engaged in behavior observation and performance management through a station observation program. The Observation Program, Standard 02, provides guidance for performing observations and stipulates that all managers and supervisors are expected to perform a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of observations per month. These observations may be performed on personnel from any department including Nuclear Security department personnel.
Quality Services provides regular inspections of Security as discussed in more detail in the response to Item 4 below. Typically, monthly meetings are conducted between the Nuclear Security and Quality Services departments. Observations of security personnel by Quality Services are a subject of discussion at these meetings. Informal random observations are performed by the Plant General Manager and Shift Operations Manager. These observations have focused on break room and bullet resistant enclosure posts, however all nuclear Security posts are within the domain of these observations.
A number of the external observations were conducted as part of the Management Safety Observer program that was implemented in May 2007 in which all levels of Energy Northwest management participate. There are no specific requirements to perform observations on any specific frequency on Nuclear Security personnel in the Management Safety Observer program; however, management team members who are Safeguards qualified are encouraged to attend Security Officer daily briefings and
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING ENERGY NORTHWEST'S RESPONSE TO NRC BULLETIN 2007-01 Page 3 of 5 activities. Non-Safeguards Qualified observers are encouraged to observe nuclear security officers in routine activities, including routine rounds, checkpoint duty, and other activities. None of the observation activities described in this paragraph are implemented by procedures nor are there specific expectations on the frequency of the observations.
Item 3.a The NRC staff reviewed your response to Question 1 and requests the following additional information:
Are security personnel provided opportunities to participate in any personnel surveys regarding the work environment? If so, what is the frequency of the surveys, the average participation rate of security personnel as compared to the general site average, and the process for providing feedback and addressing the results from the survey?
Response
As Energy Northwest employees, security personnel are provided an opportunity to participate in a Safety Conscious Work Environment (SCWE) survey. These surveys are generally conducted annually and results are made available in the company newsletter and internal website. Since respondents are not identified by organization, security participation is not measured. The SCWE survey results are discussed with senior managers and any resultant actions are addressed through Energy Northwest's corrective action program.
Another example of Security personnel being provided an opportunity to participate in a survey regarding work environment is the Institute of Nuclear Power Operator (INPO) first time survey titled "Organizational Effectiveness" which is currently in progress. At this time, Security personnel participation is less than general site participation.
Feedback from the survey will be provided from INPO and results addressed by Energy Northwest management.
Item 3.b The NRC staff reviewed your response to Question 1 and requests the following additional information:
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
All Energy Northwest employees, vendors and contractors who require unescorted access to the protected area are required to complete annual training on fitness for duty
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING ENERGY NORTHWEST'S RESPONSE TO NRC BULLETIN 2007-01 Page 4 of 5 policy and behavior observation (including fatigue). The fitness for duty program is documented and implemented by plant procedures.
The Security Sergeant that leads the Security shift brief discusses fitness for duty (FFD) at every shift briefing. All on-shift Security personnel are asked for any FFD concerns during shift briefing or if issues related to fatigue are experienced any time during shift to report them to a security supervisor. A permanent question on the security brief form asks the following: "Are you fit for duty? If not, please notify your supervisor after this briefing."
The Vice President Technical Services (VPTS) conducted a discussion and dialogue with each security squad at turnover shift briefs on the importance of industrial safety and attentiveness. Random post-checks of security personnel are performed by the VPTS and Security Manager. During these random post-checks coaching is provided on safety and attentiveness requirements.
An additional informal process that Security employs is reminders on "Attentiveness Controls" cards that are kept with each individual's security badge. These "Attentiveness Controls" cards indicate thatRoutine Shift Briefing will cover the Fatigue Declaration policy as discussed above, as well as a reminder that if personnel feel drowsy, that they need to contact the shift supervisor.
Item 4 The NRC staff reviewed your response to Question 4 and requests the following additional information:
Are formal assessments of the security program conducted by organizations/individuals that do not have direct responsibility for the security program? If so, provide information on the process, including, but not limited to, the organizations and levels of management involved, the frequency of such activities, and any tracking of how findings are resolved.
Response
Formal assessments (audits) of the security program are performed by the Quality Services department to verify compliance with all aspects of the Quality Assurance Program described in the Energy Northwest Operational Quality Assurance Program Description. The audits are conducted by trained personnel who are not directly responsible for the activities in the area to be audited. All levels of management within the auditing organization as well as the organization being audited are involved in this activity. Energy Northwest's Corporate Nuclear Safety Review Board reviews the audit results. As a minimum, audits are scheduled to satisfy the frequencies required by regulatory requirements (e.g., 10 CFR 73.55(g)(4i)) and license commitments. Audit results are reviewed by managers having responsibility in the area audited to determine and schedule appropriate corrective actions including any corrective actions to prevent recurrence.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING ENERGY NORTHWEST'S RESPONSE TO NRC BULLETIN 2007-01 Page 5 of 5 Item 5 The NRC staff reviewed your response to Question 5 and requests the following additional information:
How do you assess the effectiveness of your oversight of contractors and subcontractors?
Include the following information in your response:
Describe the licensees' program for oversight of contractors and subcontractors including, but not limited to: (1) a brief overview and description of licensee's procedures that describe the oversight process; (2) include a detailed list (bulleted is preferred) of assigned duties for 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) involvement with the oversight of contractors and subcontractors at the site.
Response
Energy Northwest employs a formal procedure that governs the oversight of supplemental personnel who will perform manual or non-manual work involving Independent Spent Fuel Storage Installation and Power Block systems, structures, and components at Columbia Generating Station, whether performed on or offsite.
Considering the subject of NRC Bulletin 2007-01 is central to security force personnel, Energy Northwest questions the relevance of this question to Columbia Generating Station. As stated in the transmittal letter, the security force at Columbia Generating Station is comprised solely of Energy Northwest employees as opposed to contractors or subcontractors (supplemental personnel). Therefore the controls in place for oversight of contractors and subcontractors are not applicable to the security force.