L-HU-08-024, Northern States Power Company - Minnesota Confirmation of Compliance with Confirmation Order EA-06-178

Northern States Power Company - Minnesota Confirmation of Compliance with Confirmation Order EA-06-178

ML090270795
Person / Time
Site:	Monticello, Prairie Island
Issue date:	01/27/2009
From:	Werner M Northern States Power Co, Xcel Energy
To:	Carpenter C NRC/EDO
References
3-2005-010, EA-06-178, L-HU-08-024
Download: ML090270795 (5)

Text

January 27,2009 414 Nicollet Mall - MP4 Minneapolis, MN 55401 United States Nuclear Regulatory Commission Cynthia A Carpenter, Director of the Office of Enforcement MS 04 A1 5A White Flint North 11 555 Rockville Pike Rockville, Maryland 20852 Prairie Island Nuclear Generating Plant, Monticello Nuclear Generating Plant Units 1 and 2 Docket 50-263 Dockets 50-282, 50-306 Renewed License No. DPR-22 License Nos.

DPR-42 and DPR-60 Northern States Power Companv - Minnesota Confirmation of Compliance with Confirmatow Order EA-06-178

Reference:

Letter from C. Carpenter (NRC) to D. Cooper (NMC), "Confirmatory Order (Effectively Immediately) (Office of Investigation Report No. 3-2005-01 O)", dated January 3,2007 Pursuant to the requirements contained in Section IV of the referenced Confirmatory Order ("Order") issued by the Nuclear Regulatory Commission (NRC) regarding Nuclear Management Company, LLC (NMC)(now Northern States Power Company, a Minnesota corporation (NSPM))

on January 3, 2007, this correspondence constitutes NSPM1s written notice that it has successfully fulfilled each of the applicable requirements contained in Section IV of the Order for the above listed plants.

In compliance with the instructions contained in Section Ill of the Order, the enclosure to this letter summarizes the specific actions taken by NSPM to comply with the applicable requirements in Section IV of the Order. As NSPM now only owns and operates the Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant, this response is therefore limited to the actions taken in regards to these two sites. The licensees of the remaining plants affected by the Order will be responsible for submitting separate responses1 Document Control Desk Page 2 Summarv of Commitments The letter makes no new commitments or revisions to existing commitments. Michael Werner General Manager, Nuclear Oversight Northern States Power Company-Minnesota Enclosure cc: Administrator, USNRC, Region Ill USNRC NRR Project Manager, PlNGP USNRC Senior Resident Inspector, PlNGP USNRC NRR Project Manager MNGP USNRC Senior Resident Inspector, MNGP Enclosure Section IV, ltem One (1) of the Order required that by no later than nine (9) months after the issuance of the Order, [Nuclear Management Company, LLC]

NMC review, revise, and communicate to NMC employees and managers its policy relating to the writing of corrective action program (CAP) reports, and provide training to NMC employees and managers to clarify management's expectation regarding the use of the program with the goal to ensure employees are not discouraged, retaliated against, or perceived to be retaliated against, for using the CAP. NSPM Response: Corporate Directive 3.3, "Performance Assessment Program" was revised on I~arch 8, 2007 to provide more explicit expectations on how to write corrective action process requests (CAPS). In addition, fleet procedure FP-PA-ARP-01, "CAP Action Request Process" was revised on February 26, 2007 to include specific expectations on what should be included, and what should be avoided in the CAP description. Training for most managers and employees to clarify management's expectation regarding the use of the CAP program was completed by July 26, 2007. During validation of training records, one employee was identified as having missed the initial training and has since received the required training.

Section IV, ltem Two (2) of the Order required that by no later than June 30, 2007, NMC shall communicate its safety culture policy (including safety conscious work environment (SCWE)) to NMC employees, providing employees with the opportunity to ask questions in a live forum. NSPM Response: Safety Culture Meetings with most NSPM employees was completed by August 3, 2007. A small group of individuals was found to have not completed the initial training by the required due date. Those individuals received remedial training upon being identified.

Section IV, ltem Three (3) of the Order required that by no later than nine (9) months after the issuance of this Confirmatory Order, NMC shall train its employees holding supervisory positions and higher who have not had formal training on SCWE principles within the previous two years of the confirmatory order.

NMC agrees to use a qualified training instructor (internal or external) for such training.

NMC shall review and enhance, if necessary, its refresher SCWE training consistent with NMC's refresher training program and provide such refresher training to its employees.

New employees holding supervisory positions and higher shall be trained on SCWE principles within nine (9) months of their hire dates unless within the previous two years of their hire dates, they've had the same or equivalent SCWE training.

NSPM Response: Training for all employees and contractors at the supervisor level who had not attended a SCWE class since January 3, 2005 completed training by July 26, 2007 with the exception of one individual who was subsequently identified during the validation of training records. That individual has since completed training.

The class material was presented by senior managers using material developed by an industry recognized subject matter expert.

In addition, computer-based refresher training on SCWE principles was developed by May 31, 2007 and will be provided annually to employees and supervisors. Training for new supervisors and Page 1 of 3 temporary maintenance supervisors on SCWE principles has been developed and is required to be completed within six months of their hire dates.

Section IVY ltem Four (4) of the Order required that by no later than March 30, 2007, NMC shall develop action plans to address significant issues identified as needing management attention in the NMC 2004 and 2006 Comprehensive Cultural Assessments at [Point Beach Nuclear Plant]

PBNP; to conduct focus group interviews with Priority I & 2 organizations to understand the cause of the survey results; and to review and, as appropriate, reflect nuclear industry best practices in its conduct of focus groups and action plans to address the issues at PBNP. As part of the development of the action plans, NMC shall also assess and address any legacy issues identified in prior safety culture assessments (i.e. CAP report ,AR00510074 and Synergy Safety Culture Assessment) that impact the safety culture at PBNP. The executive summary, analysis, and contemplated action plans shall also be submitted to the NRC. NSPM Response:

~NSPM no longer operates the Point Beach Nuclear Plant (PBNP)(now "Point Beach Nuclear Generating Station") and therefore cannot provide a response.

Section IVY ltem Five (5) of the Order required that by no later than December 31, 2008, NMC shall perform another survey at PBNP comparable to the 2004 and 2006 surveys to assess trends of the safety culture at the site and the overall effectiveness of corrective actions taken in response to prior year assessments (i.e. CAP report AR00510074 and 2006 Synergy survey). NSPM Response: NSPM no longer operates the Point Beach Nuclear Plant (PBNP)(now "Point Beach Nuclear Generating Station") and therefore cannot provide a response.Section IV, ltem Six (6) of the Order required that by no later than 3 months after the receipt of the next cultural survey results at PBNP, NMC shall submit the executive summary, analysis of the results, and the contemplated corrective actions to the NRC. NSPM Response:

NSPM no longer operates the Point Beach Nuclear Plant (PBNP)(now "Point Beach Nuclear Generating Station") and therefore cannot provide a response.

Section IVY ltem Seven (7) of the Order required that NMC shall continue to implement a process which ensures that adverse employment actions are in compliance with NRC employee protection regulations and principles of SCWE. NSPM Response:

Policy CP0087, "Material Employment Action Review" was issued on July 2, 2007 that outlines the review of pending adverse employee actions against NRC employee protection regulations. This policy includes a panel consisting of the site Human Resources Manager, Legal Counsel, a representative of line management and the Site or Corporate Vice President. This policy also extends to each project or outage contract employee upon termination (unless the contracting company's contract has been completed or because the affected individual Page 2 of 3 violated a safety policy or rule) to ensure that NRC employee protection regulations are satisfied.

Section IV, ltem Eight (8) of the Order required that in the event of the transfer of the operating license of any NMC operated facility to another entity, the commitments shall survive for the NMC fleet generally and PBNP specifically. NSPM Response:

NSPM is committed to meeting and maintaining the obligations of this Order for the Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant.

Section IV, ltem Nine (9) of the Order required that by any reference to NMC employees includes all NMC employees fleet wide. The Director, Office of Enforcement, may relax or rescind, in writing, any of the above conditions upon a showing by the Licensee of good cause.

NSPM Response: NSPM has interpreted this requirement to include all station and non-station personnel located at a site or in the corporate offices, including contractors.

NSPM is not requesting relaxation or rescission of this requirement.

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