ML20005E533

Responds to NRC 891127 Ltr Re Violations Noted in Insp Rept 50-298/89-33.Corrective Actions:Manual Search of Training Records Performed to Identify All Badged Personnel & Training Status & Tracking Sys Developed

ML20005E533
Person / Time
Site:	Cooper
Issue date:	12/27/1989
From:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS8900473, NUDOCS 9001080082
Download: ML20005E533 (3)

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GENERAL OFFICE - .

M,_:Nebraska Public Powe'r District

" "Mi%"nS4'""^M^ *** '"

'NLS8900473 December ^ 27,_1989f

U;S. Nuclear Regulatory Commission

-Document Control Desk-Washington, DC- 20555

Subject:

- NPPD Response to NRC Inspection Report- 50-298/89-33 Centlemen:

This letter is written in __ response to your letter dated.-November 27,-1989, transmitting Intpection . Report 50-298/89-33. Therein you indicated- that-certain of our activities:were in violation of NRC requirements.

Following is the - statement of the violation and our; responto in = accordance with 10 CER 2.201:

' STATEMENT OF VIOLATION

,-  ; Inadeaunte Access Control Technical Specification 6.3.2.B requires that security procedures shall bei established and implemented.

Plant- Services Procedure 1.1, " Station Security," Revision 12, dated August 24,: 1989,Section V.D. 3.b , requires that the Security Department temporarily inactivate an individual's badge when retraining requirements -

'have not been accomplished.

Contrary to the above, on October 12, 1989, it was discovered that the Security Department had not temporarily inactivated the badge of an individual whose retraining requirements had not been accomplished, and the individual had been allowed unescorted access to protected and vital areas for 114 days after his training had expired. Subsequently, it was determined that the Security Department had not inactivated the badges of 19 other personnel whose training had expired. This is a repeat violation of one identified in October 1988.

.t This is a Severity Level IV violation. (Supplement III)(298/8933-01)

REASON FOR VIOLATION As. stated in our response to an identical violation cited in NRC Inspection Report 88-31, the Nuclear Training Department is responsible for notifying CNS of overdue training requirements. This notification is developed from records of training maintained by the Nuclear Training i 9001080082 891227 PDR ADOCK 05000298 Q PDC 't I

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• De'cember 27, 1989 -l Page 2' Department. The training records in ~ question, _ namely those that are ,

related to receiving. and maintaining unescorted access to CNS, are l

contained in computer files backed up by "hard copy" files.. One of the ,

corrective actions completed in response to the 1988 violation was to validate the computer data against the "hard copy" files and to-initiate a monthly report notifying appropriate management levels of due-and overdue 3 CNS access training requirements. This monthly- report was prepared from data contained in the computer files.

This violation was the result of clerical errors made in the entry and retrieval of unescorted access training data from the computer files.

These errors were transmitted in the monthly reports which were - typed up using the computer generated data. The method being-used to validate and verify the training data being entered into the computer was not effective in eliminating errors in the data base. 1 a

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED ,

i A manual search of the subject "hard copy" training records was performed '

to identify all badged personnel and their training status, It was during this review that nineteen (19) other individuals were identified with expired access training. This information was forwarded to CNS management and appropriate action was taken to temporarily inactivate access to CNS for these individuals until the training requirements were met. 9 5

CORRECTIVE STEPS WHICH WILL BE TAKEN TO' AVOID FURTHER VIOLATIONS l

In recognition of the difficulties that were being experienced in the use of the computerized training records system, and as discussed in our response to NRC Inspection Report 88-31, the District conducted a thorough  :

review of training tracking activities during the first quarter of 1989. <

As-a result of this review a Nuclear Power Group Training Tracking System Task Force was established in May 1989 to oversee the development of an entirely new computerized training records system for the Nuclear Power Group. This system is named the Training Tracking System (TTS).

Following approval of the TTS Design Report in July the system installation phase was commenced in August 1989. The design of this new system provides for improved validation and verification of data. It was anticipated that this system would be fully operational during the final quarter of 1989. System acceptance testing during November and December, however, uncovered flaws in the program which required design rework.

These discrepancies have been corrected and the TTS is expected to be back in final acceptance testing during the first week of January 1990. The Training Tracking System is scheduled to be fully functional for training records related to CNS site access by March 1, 1990.

In the meantime, site access training requirements are being tracked manually and the monthly due and overdue management reports are being developed from a search of the "hard copy" files.

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i December 27, 1989  ;

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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The District is currently in compliance with station security procedures relative to training requirements.

Sincerely,

. A.

Oc0V revors Division Manager -

Nuclear Support

/rg i cc: U.S. Nuclear Regulatory Commission

-Regional Office - Region IV NRC Resident Inspector Cooper Nuclear Station 1

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