ML20024H836

Responds to Violations Noted in Insp Rept 50-298/93-21. Corrective actions:in-processing Questionnaire Used for All Future Employees & Contractors Towards Granting Unescorted Access Revised

ML20024H836
Person / Time
Site:	Cooper
Issue date:	08/12/1993
From:	Horn G NEBRASKA PUBLIC POWER DISTRICT
To:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NSD930956, NUDOCS 9308250273
Download: ML20024H836 (3)

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r- _ GENERAL OFFICE I P.O. BOX 499, COLUMBUS. NEBRASKA 68602-0499  ;

~ Nebraska Public Power District "T&"!#d2 R*" t

.NSD930956 August 12, 1993 p, i pc ~

Mr. James L. Milhoan f.I -w !U:

Regional Adcinistrator 7 ,. ,

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U.S. Nuclear Regulatory Commission  % I ~[r^o#" y f/

i Region IV I -

611 Ryan Plaza Drive, Suite 1000 / -

Arlington, TX 76011 ' ' - #

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Subject:

Reply to a Notice of Violation l Cooper Nuclear Station l NRC Docket No. 50-298, DPR-46

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Reference:

NRC Inspection Report 50-298/93-21 dated July 14, 1993  !

Dear Mr. Milhoan:

l This letter is written in response to Inspection Report 50-298/93-21 which transmitted

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l l a Notice of Violation concerning the Access Authorization Program for the Cooper Nuclear Station. The statement of violation and our response in accordance with 10 CFR 2.201 is given below.

I The reference also identified a significant weakness regarding the District's audit program concerning Access Authorization. The reference requested that the District respond in writing with our evaluation of this weakness and to identify any actions taken or planned to address this weakness. The District's response to this concern is i also being provided in this letter.

i STATEMENT OF VIOLATION i

10 CFR 73.56 requires that licensees must follow an access authorization plan  :

incorporated into their site Physical Security. Plan.  ;

Paragraph 1.2.1 of the licensee's NRC-approved Physical Security Plan states, in part, I

( "All elements of Regulatory Guide 5.66 will be implemented to satisfy the requirements i of 10 CFR 73.56."

Paragraph 9.0 of Regulatory . Guide 5.66 states, " Individuals with unescorted access

! authorization must be notified of his/her responsibility to report any arrest that may impact upon his/her trustworthiness."

Contrary to the above, the inspectors determined that the licensee only notified individuals that those arrests involving drugs and alcohol have to be reported ( 0!

(298/9321-01).  ;

This is a Severity Level IV violation (Supplement III).

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NSD930956

. Page 2 of 3 l ' REASON FOR VIOLATION 1

l The District had instructed its employees and contractor personnel during Fitness for l Duty and Continual Behavioral Observation Training of their responsibility to notify  :

l District management of any arrests made involving drugs and alcohol. In implementing l l

its Access Authorization Program for Cooper Nuclear Station, the District defined too narrow a scope of arrests that may impact upon a person's trustworthiness, and therefore was not in full compliance with the criteria specified in Reg. Guide 5.66.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED All personnel with unescorted access to the Cooper Nuclear Station were formally notified in a letter on June 17, 1993, from the Nuclear Power Group Manager, of their responsibilities to notify District management of any arrest they may experience. In addition, the in processing questionnaire used for all future District employees and contractors toward granting unescorted access has been revised to incorporate statements informing applicants of their responsibility in this area and signatures certifying their understanding of this requirement.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The District's Fitness for Duty training lesson plan procedures and directives will be reviewed and revised, as necessary, to provide the proper instruction on this matter.

This will be accomplished by December 1993.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED With the issuance of the letter from the Nuclear Power Group Manager on June 17, 1993, 7 discussed above, the District is presently in full compliance. The review and, as necessary, revision of the District's lesson plan for periodic training for Fitness for Duty procedures and directives discussed above will be completed by December 1993.

1 WEAVJJESS NOTED IN THE AUDIT PROGRAM FOR ACCESS AUTHORIZATION Section 1.8 of NRC Inspection Report 93-21 identified a significant program weakness in the area of access authorization audits. Specifically, it was noted that access authorization audit checklists did not list Regulatory Guide 5.66 as a primary reference document, and therefore, the audits did not review the access authorization program against all regulatory requirements. In addition, the access authorization program procedures and training lesson plans were not a part of the audit.

REASON FOR THE IDENTIFIED WEAKNESS The primary cause of the identified program weakness was determined to be the lack of a formal review of Regulatory Guide 5.66 by the Quality Assurance Division. As a result, the clarification and exceptions to the NUMARC Guidelines by the NRC were not  ;

fully recognized. Initially, Quality Assurance Audit and Surveillance Checklists were '

revised to address NUMARC 89-01, Guidelines for Nuclear Plant Access Authorization Programs. When Regulatory Guide 5.66 was subsequently received by the Quality Assurance Division in June 1991, a cursory review of this document was performed and l it was determined that no checklist revisions were necessary. This was an inaccurate  !

determination.

CORRECTIVE STEPS BEING TAKEN The corrective actions being taken regarding this concern include a thorough review of Regulatery Guide 5.66, and the subsequent upgrading of applicable access authorization i

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l audit'an'd surveillance checklists. These revisions will address (at a minimum) those  ;

l ite'as identified in 1R 93-21 as not being included in the audit program. These actions 1 l will be completed by September 30, 1993. Additionally, beginning in the fourth quarter of 1993, quarterly Quality Assurance Surveillances will be conducted to review the access authorization records of individuals granted unescorted access at CNS to ensure the requirements of Regulatory Guide 5.66 and the appropriate sections of NUMARC 89-01  ;

Guidelines are being met. The results of these surveillances will be periodically evaluated and the frequency of future surveillance performance will be determined ,

accordingly. l i

CORRECTIVE STEPS TO PREVENT RECURRENCE To further ensure that documents such as Regulatory Guides are formally reviewed and evaluated for Quality Assurance Program applicability in the future, an administrative process is being developed to provide guidance to the NPPD QA Staff for their review and evaluation of Regulatory Guides to determine their effect upon the QA audit and surveillance functions. The process will be formally approved and in use by September 30, 1993. .

t DATE WHEN CORRECTIVE ACTION WILL BE COMPLETED September 30, 1993.

Should you have any questions concerning this information, please call.

Sin rel ,

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C. . Horn N r Power Group Manager

/ dis cc: U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 NRC Resident Inspector Cooper Nuclear Station l

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