ML20069J194
| ML20069J194 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 08/25/1982 |
| From: | Lee O PUBLIC SERVICE CO. OF COLORADO |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| P-82304, NUDOCS 8210250083 | |
| Download: ML20069J194 (3) | |
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PUBLIC SERVICE COMPANY OF COLORADO
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O. 80X840 DENVER, COLORADO 80200 OSCAR R. LEE August 25, 1982 s
wea *ac iore Fort St. Vrain Unit No. 1 P-82304 Y
5IS Mr. John T. Collins, Regional Administrator 3 ggg U. S. Nuclear Regulatory Commission
.y 611 Ryan Plaza Dr., Suite 1000 il
~y'i Arlington, TX 76012 M Uno-+.
SUBJECT:
Unescorted Access for Outside Contractor Personnel at Fort St. Vrain
REFERENCES:
- 1. NRC Letter dated May 7,1982, J. T. Collins to 0. R. Lee (G-82130)
- 2. PSC Letter dated May 24, 1982, O. R. Lee to J. T. Collins (P-82152)
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- 3. NRC Letter dated July 26, 1982, w[
b-J. T. Collins to 0. R. Lee (G-82230)
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Dear Mr. Collins:
l Further discussions with the Ft. St. Vrain staff concern employee
- screening of outside contractor personnel in accordance with the Fort St.
Vrain Amended Security Plan has led to the conclusion that the final negotiations with the NRC during the original writing of the, security Plan were entirely verbal and no documentation can be found 1.s to substantiate PSC's exact commitment to Section 4.3 of ANSI 18.17-1973. We will, therefore, commit to revising our Security \\
s Plan and implementing procedure APM G-4 to provide for a background investigation.
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[ 8210250083 820825
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Messrs. Don Warembourg and Milf McBride have had a telephone conversation with Messrs. G.
L'. Ra'dsen'and J.. A. F. Kelly concerning.
y our committrent tw ANSI-18.17-157h wTerein the licensee stated that a
-t commitment'woula' b made to con. duct background investigation in t
accordance with Mr. Bob Clark 4s memo 'of November 26, 1977.
PSC's.-
outside contracton employ,ee investigations will also allow the use of i
letters of eqf ver_1 hta tion from outside contractors which will.beaudited$oyment S'
" Department.
The major x concern at Ft. lA(tJSC's Q alityi Assurance'/ rain,< ds it' is at most n'oslear. power pla i.
I-is the eaployment background verificatich' of the union' cFaft I
personnel who need unescort3d access to perform plant maintenance and-modification tasks ~as' opposed to. outside contractor permanentx i
c employeeswhose employment' records are normally accessible. PSCv f
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f plarts.to employ the services of-an outside~ investigation agency to' k
- perfor'm, background, investigations" for snion craft personnel and, if '
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- ' required,soutside contractor staff.. We'-are somewhat apprehensive concerning the ability of the. licensee to acquire comprehensive L
background employment dati for unfori craft persoritiel, but we plan an s
aggfessive approach td. acquire the ' required information and'will.
l evaluate the program dud.ng the fiisi quarter of 1983.
f As was discussed in the aforecientioned.t6lephone conver~sation, P,5C is aware of proposed regulatory and industry changes to the current
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. re@irements for employee. screening gnd that some. nuclear utilities have chosen to anticipate these-preyesed changes.
We do not feel
'that anticipating changes to regulations is in our best interest and
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will, therefore, commit oWy to meeting the requirements set forth in of Novestie~r ?6,'1977 until' the applicable proposed f
. Bob Clark's memo regulatory chariges are' s officially released.
Therefore, for L
unescurted access;Jnto9.hh ' pro.tected afea, PSC is hereby committing to the following background ~ investigation for outside contracto.
personnel:
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A backgr6cnd employment i_nvestigation for_a minimum of three (3) years prior employment or to the age of e15 teen, whichever is h
less.
Any periods of unemployment'ddring the three year period
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shall-be explained,asd_documenthd.
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Exam 1' nation,
by a licensed psychologist in accordance with the
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provisions' of, Administrative Procedure APM-G4.
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Coninuedobiehation'for emotional stability in accordance~with b
Fort St. Vtain AdminiTtrative Proceduro' ASP-l.
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Outside contractors shall be allowed to submit written confirmation that they possess documentation verifying three
. ork history or that they possess documents years past w
containing _ verification of work histories from previous employers.
If a written confirmation from an outside contractor is used to allow unescorted access, the PSC Quality Assurance Department will audit 20's of the outside contractors each year.
The audits of the selected firms will be cnnducted by auditing 100*4 of the personnel files for the outside contractor permanent employees having unescorted access. -The PSC Quality Assurance Department will also audit the outside investigating agency performing background investigations biennially.
5.
There are numerous outside contractor and union personnel who have worked for PSC in various capacities for periods greater than three years. PSC will document these individuals and will exempt them due to their association, in good standing, with the licensee for periods eqtai to or greater than three years.
The employee screening program described above will require 60 days to implement due to required procedure revisions, contract approvals with an investigation
- service, etc.
PSC hereby commits to implementing the program' summarized herein within 60 days of receipt
-of your written concurrence with the proposed outside contractor employee screening program.
Should further questions arise concerning PSC's proposed employee screening program, please. contact Mr. Don Warembourg (303) 786-2223, ext.
200 or Mr. Milt McBride (303) 785-2223, ext. 202 Very truly yours, Uscar R. Lee ORL/skr
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