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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20211D7501999-08-23023 August 1999 Responds to NRC Re Violations Noted in OI Rept 3-98-043 & EA 99-183.Corrective Actions:Oversight of Training Program & Contractor Policies That Implement Parts of Security Program Have Been Increased by Addl Position ML20205M9421999-04-13013 April 1999 Forwards Emergency Response Data System Implementation Documents.Data Point Library Updates for Kewaunee (271), San Onofre (272) & Clinton (273) Encl.Also Encl Plant Attribute Library Update for Grand Gulf (274).Without Encls ML17230A3661999-03-18018 March 1999 Forwards Listed Nelia Insurance Policy Endorsements for Kewaunee Nuclear Power Plant,Per Requirements of 10CFR140.15 ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function ML20155F7951998-11-0303 November 1998 Second Partial Response to FOIA Request for Documents. Records Subj to Request Encl & Identified in App C ML20154F1481998-10-0202 October 1998 Forwards Insp Rept 50-305/98-15 on 980831-0904.No Violations Noted.Insp Exam of Activities Conducted Under License Re Physical Security & to Compliance with Commission Rules & Regulations & with Conditions of License ML20237E0881998-08-24024 August 1998 Clarifies Info Provided Re Containment Ventilation Sys & Use of Mixing Factor of 0.5,in Response to NRC Request Made During Telcon ML20237A2301998-08-0707 August 1998 Forwards Original & Three Copies of Rev 11 to Knpp Security Manual.Screening Criteria Form for Each Change W/Description & Criteria of Review Has Been Included as Attachment A. Reissued Security Manual Included in Attachment B.W/O Encls ML20236R9051998-07-21021 July 1998 Informs That Document Entitled, WCAP-14677,Rev 1 F* & Elevated F* Tube Alternate Repair Criteria for Tubes W/Degradation within Tubesheet Region of Kewaunee Sgs, Will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20249B7471998-06-23023 June 1998 Forwards RAI Re 980601 Proposed Amend to Revise F* & Ef* Criteria for SG Tubes in Kewaunee Tss.Proposed Amend Would Revise Existing F* & Ef* Distances in TS 4.2.b to Reflect Changes to Primary to Secondary Differential Pressure ML20249A8751998-06-16016 June 1998 Forwards Request for Addl Info Re Proposed Amend to Redefine Parent Tube Pressure Boundary for Westinghouse Mechanical Hybrid Expansion Joint SG Tube Sleeves,Submitted by Util ML20248M2521998-06-0909 June 1998 Forwards Assessment of Kewannee Cycle 22 Alternate Repair Criteria 90 Day Rept,For Info ML20217F3401998-04-23023 April 1998 Forwards Annual Environ Monitoring Rept Jan-Dec 1997, Per TS 6.9.b.1.Results of 1997 Land Use Census,Iaw Plant ODCM, Section 3/4.7.1,included in Rept ML20216B3281998-04-0707 April 1998 Discusses Amend 132 to License DPR-43.Requested Revised Analysis Reflecting Higher Source Term Encl.Results of Analysis Conclude That Potential Thyroid Doses to Public Continue to Be Less than Guideline Values of 10CFR100 ML20217J2131998-04-0202 April 1998 Forwards Copy of Each Revised Forms 398,personal Qualifications Statement & 396,certification of Medical Exam by Facility Licensee.Due to Error on Instructions for Form 398,addendum for Completing Form Are Provided ML20217H4031998-03-27027 March 1998 Informs That NRC Staff Has Initiated Variety of Activities Re Mgt of Licensing Basis Info as Result of Problems Encountered at Millstone & Maine Yankee Facilities ML20217G1461998-03-25025 March 1998 Responds to NRC Re Violations Noted in Insp Rept 50-305/98-03 on 980128-0203.Corrective Actions:Controlling & Properly Securing SGI ML20203C8481997-12-10010 December 1997 Forwards Emergency Response Data Sys Implementation Documents for Plants.W/O Encl ML20212H0121997-11-0404 November 1997 Forwards Insp Rept 50-305/97-14 on 970915-19.No Violations Noted.Rept Identifies Areas Examined within Security Program ML20217P3511997-08-26026 August 1997 Ack Receipt of & Check for $50,000 in Payment for Civil Penalty Proposed by NRC in . Corrective Actions Will Be Examined During Future Insp ML20217J9641997-08-11011 August 1997 Responds to NRC Re Violations Noted in Insp Rept 50-305/97-02 on 970106-31.Corrective Actions:Will Revise IST Procedures to Use More Accurate Instrumentation Satisfying Requirements & to Include Acceptance Criteria ML20140E8861997-06-0707 June 1997 Forwards Amend 133 to License DPR-43 & Safety Evaluation. Amend Establishes New Design Basic Flow Rate for AFW Pumps Consistent W/Assumptions Used in Reanalysis of Limiting Design Basis Event for AFW Sys ML20140F2171997-04-30030 April 1997 Final Response to FOIA Requests for Documents.Records in App B Encl & Will Be Available in PDR IA-97-130, Final Response to FOIA Requests for Documents.Records in App B Encl & Will Be Available in PDR1997-04-30030 April 1997 Final Response to FOIA Requests for Documents.Records in App B Encl & Will Be Available in PDR ML20140F2211997-04-0404 April 1997 FOIA Request for Documents Re Recently Issued TIA for Plant Concerning Safety Question on Auxiliary Feedwater Sys ML20137A2111997-03-14014 March 1997 Transmits Info Pertaining to NRC Staff Review of Weld Defects in CE Designed SG Tube Sleeves ML20134Q0981997-02-21021 February 1997 Ninth Partial Response to FOIA Request for Documents. Forwards Documents Listed in App P.App Q Documents Partially Withheld (Ref FOIA Exemption 6).Documents Also Available in PDR ML20134Q1251997-02-20020 February 1997 Forwards Original & Three Copies of Rev 10 to Knpp Security Manual.Manual Is Being Changed to Incorporate Use of Vehicle Barrier Sys,Per 10CFR73.55 & 73.1(a).Encl Withheld ML20133E7031997-01-0606 January 1997 Forwards Insp Rept 50-305/96-12 on 961118-27 & Notice of Violation ML20133G2291997-01-0606 January 1997 Ltr Contract:Task Order 115, Kewaunee Safety Sys Operational Performance Insp, Under Contract NRC-03-93-026 ML20129K1131996-11-0505 November 1996 Forwards Copy of Master Bwr/Pwr Gfes Exam W/Answer Key for Info.W/O Encl ML20129J2641996-10-29029 October 1996 Ack Receipt of 960613 & 1024 10CFR50.54(a) Submittals Re Changes to Quality Assurance Program Description.Based on Review,Nrc Concludes That Revision Continues to Meet Requirements of 10CFR50,App B & Acceptable ML18065B0081996-10-14014 October 1996 Informs That Overheads Will Be Presented by Licensee at 961016 Meeting at NRC Headquarters in White Flint.Encl Withheld ML20117P6861996-09-20020 September 1996 Forwards Rev 9 to Security Manual.Encl Withheld ML20117L7171996-09-0505 September 1996 Forwards Proposed Tech Specs Re Amend for Use of Westinghouse Laser Welded Steam Generator Tube Sleeves,Per Discussion W/Nrc ML20100M7451996-02-29029 February 1996 Provides Revised Description of Proposed Vehicle Control Measures.Encl Withheld ML20217H4281996-01-24024 January 1996 Discusses Review of Nuclear Energy Inst Guidance Document, Guideline for Managing NRC Commitments, Rev 2,dtd 951219 ML20094H8491995-11-0606 November 1995 Forwards Rev 8 to Security Manual.Rev Withheld ML20091P4951995-08-28028 August 1995 Forwards Clarification of Rev 7 to Security Manual.Encl Withheld ML20094D9291995-08-10010 August 1995 Forwards Scenario Package for 951011 Emergency Exercise at Plant,Per from Cj Paperiello ML20087K2451995-08-0202 August 1995 Forwards Revised Description of Proposed Vehicle Control Measures.Primary Change in Design Is Use of Jersey Barriers in Lieu of Combination Cable & Rock Design.Encl Withheld ML20084L1091995-05-30030 May 1995 Forwards Rev 7 of Kewaunee NPP Security Manual.Encl Withheld ML20080N0061995-02-28028 February 1995 Forwards Summary Description of Plant Proposed Vehicle Control Measures & Results of Vehicle Bomb Comparison.Encl Withheld ML20078R3291994-12-19019 December 1994 Discusses Results & Conclusions of Osre Conducted During 940815-18.Weakness Noted as Being Unique & Only Possible During Specific Time Periods ML20072J3401994-08-22022 August 1994 Responds to NRC Re Violations Noted in Insp Rept 50-305/94-09 on 940516-0704.Corrective Actions:Memo,Stating That Turbine Driven AFW Pump Should Be Declared Inoperable Whenever AFW-10A or 10B Closed or Inoperable,Issued ML20070P5811994-03-29029 March 1994 Requests Meeting W/Nrc & Appropriate Members of NRC Dept Re Disposal of high-level Radwaste from NPP ML20059E9511994-01-0707 January 1994 Requests Addl Info Re Graded Approach for GL 89-10, Safety-Related Motor-Operated Valve Testing & Surveillance ML20058E6581993-12-0101 December 1993 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 940209.Informs That Facility Must Submit Ltr Identifying Individuals Who Will Take Exam ML20058A1291993-11-16016 November 1993 Forwards Safeguards Info Referenced in Preliminary Draft Guide Re Proposed Rule for Protection Against Manevolent Use of Vehicles at Nuclear Power Plants.Encl Withheld ML20059D2761993-10-26026 October 1993 Forwards Copy of Master Bwr/Pwr Gfes Exam W/Answer Key.W/O Encl 1999-08-23
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20211D7501999-08-23023 August 1999 Responds to NRC Re Violations Noted in OI Rept 3-98-043 & EA 99-183.Corrective Actions:Oversight of Training Program & Contractor Policies That Implement Parts of Security Program Have Been Increased by Addl Position ML17230A3661999-03-18018 March 1999 Forwards Listed Nelia Insurance Policy Endorsements for Kewaunee Nuclear Power Plant,Per Requirements of 10CFR140.15 ML20237E0881998-08-24024 August 1998 Clarifies Info Provided Re Containment Ventilation Sys & Use of Mixing Factor of 0.5,in Response to NRC Request Made During Telcon ML20237A2301998-08-0707 August 1998 Forwards Original & Three Copies of Rev 11 to Knpp Security Manual.Screening Criteria Form for Each Change W/Description & Criteria of Review Has Been Included as Attachment A. Reissued Security Manual Included in Attachment B.W/O Encls ML20217F3401998-04-23023 April 1998 Forwards Annual Environ Monitoring Rept Jan-Dec 1997, Per TS 6.9.b.1.Results of 1997 Land Use Census,Iaw Plant ODCM, Section 3/4.7.1,included in Rept ML20216B3281998-04-0707 April 1998 Discusses Amend 132 to License DPR-43.Requested Revised Analysis Reflecting Higher Source Term Encl.Results of Analysis Conclude That Potential Thyroid Doses to Public Continue to Be Less than Guideline Values of 10CFR100 ML20217G1461998-03-25025 March 1998 Responds to NRC Re Violations Noted in Insp Rept 50-305/98-03 on 980128-0203.Corrective Actions:Controlling & Properly Securing SGI ML20217J9641997-08-11011 August 1997 Responds to NRC Re Violations Noted in Insp Rept 50-305/97-02 on 970106-31.Corrective Actions:Will Revise IST Procedures to Use More Accurate Instrumentation Satisfying Requirements & to Include Acceptance Criteria ML20140F2211997-04-0404 April 1997 FOIA Request for Documents Re Recently Issued TIA for Plant Concerning Safety Question on Auxiliary Feedwater Sys ML20134Q1251997-02-20020 February 1997 Forwards Original & Three Copies of Rev 10 to Knpp Security Manual.Manual Is Being Changed to Incorporate Use of Vehicle Barrier Sys,Per 10CFR73.55 & 73.1(a).Encl Withheld ML18065B0081996-10-14014 October 1996 Informs That Overheads Will Be Presented by Licensee at 961016 Meeting at NRC Headquarters in White Flint.Encl Withheld ML20117P6861996-09-20020 September 1996 Forwards Rev 9 to Security Manual.Encl Withheld ML20117L7171996-09-0505 September 1996 Forwards Proposed Tech Specs Re Amend for Use of Westinghouse Laser Welded Steam Generator Tube Sleeves,Per Discussion W/Nrc ML20100M7451996-02-29029 February 1996 Provides Revised Description of Proposed Vehicle Control Measures.Encl Withheld ML20094H8491995-11-0606 November 1995 Forwards Rev 8 to Security Manual.Rev Withheld ML20091P4951995-08-28028 August 1995 Forwards Clarification of Rev 7 to Security Manual.Encl Withheld ML20094D9291995-08-10010 August 1995 Forwards Scenario Package for 951011 Emergency Exercise at Plant,Per from Cj Paperiello ML20087K2451995-08-0202 August 1995 Forwards Revised Description of Proposed Vehicle Control Measures.Primary Change in Design Is Use of Jersey Barriers in Lieu of Combination Cable & Rock Design.Encl Withheld ML20084L1091995-05-30030 May 1995 Forwards Rev 7 of Kewaunee NPP Security Manual.Encl Withheld ML20080N0061995-02-28028 February 1995 Forwards Summary Description of Plant Proposed Vehicle Control Measures & Results of Vehicle Bomb Comparison.Encl Withheld ML20078R3291994-12-19019 December 1994 Discusses Results & Conclusions of Osre Conducted During 940815-18.Weakness Noted as Being Unique & Only Possible During Specific Time Periods ML20072J3401994-08-22022 August 1994 Responds to NRC Re Violations Noted in Insp Rept 50-305/94-09 on 940516-0704.Corrective Actions:Memo,Stating That Turbine Driven AFW Pump Should Be Declared Inoperable Whenever AFW-10A or 10B Closed or Inoperable,Issued ML20070P5811994-03-29029 March 1994 Requests Meeting W/Nrc & Appropriate Members of NRC Dept Re Disposal of high-level Radwaste from NPP ML20056C5071993-02-19019 February 1993 FOIA Request for Documents Re Meeting Minutes,Summaries, Transcripts or Other Documents Resulting from NRC Meeting Held 930209 at Region III Ofc in Glen Ellyn,Il to Discuss Kewaunee Engineering Activities & Other Items of Interest ML20128H9271993-02-13013 February 1993 Advises That All Actions Necessary to Ensure Compliance W/ 10CFR50,App E,Section VI Re ERDS Completed.Installation of ERDS Hardware in Technical Support Ctr Complete & Temporary Telephone Line Replaced W/Permanent Line ML20128D2721993-02-0202 February 1993 Provides Listed Submittal Describing Actions Currently Being Performed & Schedule for Completion of Actions Associated W/ Resolution of long-term Recommendation GL-4,per ML20126E7221992-12-28028 December 1992 Forwards Response to NRC Re Weaknesses & Followup Items Noted in Insp Rept 50-305/92-21 of Annual Emergency Plan Exercise.Corrective Actions:More Mgt Involvement Will Be Provided & Emergency Plan Will Be Revised ML20095G9561992-04-27027 April 1992 Forwards Rev 5 to Security Manual,Revised to Reflect Requirements of New Access Authorization Rule.Rev Withheld ML20091M5531992-01-27027 January 1992 Forwards Rev 4 to Security Manual,Reflecting Recent Organizational & Title Changes & Adding Vehicle Insp Portal on North Gate.Rev Withheld ML20086E3411991-11-21021 November 1991 Forwards Response to Security Concern RIII-91-A-0056,per NRC .Investigation Determined That No Violation of Burns fitness-for-duty Program Occurred & That Burns Program Meets NRC Guidance for Overtime ML20079L0391991-10-29029 October 1991 Forwards Rev 3 to Security Manual to Address Issues Identified in NRC .Manual Withheld ML20079K8081991-10-28028 October 1991 Forwards Emergency Response Data Sys Implementation Program Plan.Implementation Program Plan Indicates That Sys May Be Operational as Early as Feb 1992 Provided No Obstacles Encountered During Hardware/Software Implementation ML1116610971991-08-30030 August 1991 Forwards Rev 3 to WCAP-11476, Handbook on Flaw Evaluation Kewaunee,Unit 1 Steam Generators Upper Shell to Cone Weld. Proprietary Suppl 1 to Kewaunee Unit 1 Steam Generator Upper Shell to Cone Welds Steam Generator... Withheld ML20091B6991991-07-25025 July 1991 Forwards Exercise Scenario Manual Minus Inject Messages Addressing Ingestion Pathway Objectives on Day 2 & 3 of 910924 Annual Emergency Exercise at Plant,Per NRC Requesting Advance Submittal of Exercise Objective.W/O Encl ML20073C2761991-04-0505 April 1991 Forwards Rev 2 to Security Manual,Reflecting Expanded Protection Area Boundary.Rev Withheld (Ref 10CFR73.21) ML1116610051990-10-0909 October 1990 Forwards Nonproprietary WCAP-12712 & Proprietary WCAP-12711, Reevaluation of U-Bend Tube Fatigue for Kewaunee Plant Steam Generators, Per NRC Bulletin 88-002 ML1116610071990-09-17017 September 1990 Requests Withholding of Proprietary WCAP-12711, Reevaluation of U-Bend Tube Fatique for Kewaunee Plant Steam Generators. ML1116506681990-08-17017 August 1990 Forwards Pages Inadvertently Deleted from 1990 Rev to Updated FSAR Submitted on 900720 ML20055C9811990-06-29029 June 1990 Forwards Response to Violations Noted in Insp Rept 50-305/90-04.Response Withheld (Ref 10CFR73.21) ML1116609691990-04-11011 April 1990 Requests That WCAP-12558 Kewaunee Steam Generator Tubesheet Crevice Indications Return to Power Rept, Be Withheld (Ref 10CFR2.790) ML1116609671990-04-0606 April 1990 Forwards Nonproprietary WCAP-12559 & Proprietary WCAP-12558, Kewaunees Steam Generator Tubesheet Crevice Indications Return to Power Rept, as Followup to 900328 Meeting. Proprietary Version Withheld (Ref 10CFR2.790) ML20012A4031990-03-0101 March 1990 Informs That Revised Listed Drawings Sent to Region III for Filing ML20006E8641990-02-19019 February 1990 Suppl Response to NRC 890725 Ltr Re Safeguards Info Violation Noted in Insp Rept 50-305/89-09.Corrective Action: Section V of General Employee Training Manual Security Removed ML1116609341990-01-15015 January 1990 Forwards Nonproprietary WCAP-12441 & Proprietary WCAP-12440, Presentation to NRC Re Kewaunee (Wps) SECY-83-472 LOCA Analysis Effort. Wiesemann 891204 Request for Withholding Also Encl.Proprietary Rept Withheld (Ref 10CFR2.790) ML20005D9601989-12-27027 December 1989 Forwards Response to Allegation RIII-A-89-A-0137.Encl Withheld (Ref 10CFR73.21) ML20005D8131989-12-22022 December 1989 Forwards Status & Proposed Schedule for Security Mod Completion.Implementation Schedule for Proposed Mods Extended Until Oct 1990 Due to Several Major Project Increases.Encl Withheld (Ref 10CFR73.21) ML20011D9111989-12-20020 December 1989 Forwards Executed Amend 8 to Indemnity Agreement B-53 ML19332E6091989-12-0404 December 1989 Forwards Rev 1 to Security Manual.Rev Withheld (Ref 10CFR73.21) ML1116609361989-12-0404 December 1989 Submits Application for Withholding of Proprietary WCAP-12440, Presentation to NRC Re Kewaunee (Wps) SECY-83-472 LOCA Analysis Effort, Per 10CFR2.790.Affidavit Supporting Request Encl ML20247J7721989-07-19019 July 1989 Forwards Rept for Unannounced off-hours Drills on 881020 for State of WI,site-specific to Zion,Point Beach,Kewaunee & Prairie Island Nuclear Power Stations.No Deficiencies or Areas Requiring Corrective Actions Noted 1999-08-23
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- Green Ba, WI 54307 9302 November 21,1991 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:
Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Respanse to Security Concern AMS No. RIII-91-A-0056
Reference:
- 1) Letter from C.E. Norelius to K.H.Evers dated September 17,1991 In AMS No. Rlli-91-A-0056 the U.S. Nuclear Regulatory Commission (NRC) received information concerning activities at the Kewaunee Nuclear Power Plant (KNPP). In reference 1, Wisconsin Public Service Corporation (WPSC) was requested to review and disposition this matter and submit the results within 60 days. Enclosed in attachment I are the results of our investigation into these concerns. As a result of our investigation WPSC has concluded that the concerns identified in reference 1 are unfounded.
Sincerely,
- 6. d[TI C. A. Schrock Manager - Nuclear Engineering DJM/jms l Attach.
t cc - US NRC - Regica III Mr. Patrick Castleman, US NRC J QO 9112O20014 91112l l PDR ADOCK 03000305 \ _
l F POR
i ATTACHMENT To Letter from C. A. Schrock (WPSC) to Document Control Desk (NRC)
Dated November 21,1991
.i I
l Document Control Desk
. Svember 21,1991 Page !
NRC COMMENTS AMS No. RIII-91-A-0056 Region III recently received concerns regarding the security program at the Kewaunce Nuclear Station. The concerns are:
- 1. Security Officers are frequently required to work double shifts, without cause, and at times have felt they were unfit for duty due to fatigue.
- 2. The Supervisor's fitness-for-duty evaluation checks of officers held over are insufficient and have not been thorough enough to adequately determine if an officer was fit-for-duty. Officers have been required to work when they were tired and may not have been attentive to duty.
WPSC RESPONSE WPSC initiated an investigation of these concerns to determine their validity. In order to ensure a complete review, the scope of this investigation was expanded to include all a
security force personnel overtime hours and not only security officer overtime.
Additionally, the investigation included a review for both 16 consecutive hours of work within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> work period and 16 non-consecutive hours of work within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> work period. Furthermore, if the concern was valid the investigation was to determine the bases or cause for the overtime, whether the overtime was mandatory, and finally what guidance exists to govern overtime and was this guidance followed.
Response to Concern i The investigation which was conducted included a records review for the period of January 1,1991 through July 31,1991. The applicable records reviewed were:
- 1. Payroll records.
- 2. Daily shift status reports compiled by the Operation Shift Captain their respective line supervisors, or bott
- 3. Time card cross refere. e for clarification of those times when 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> may have been recorded within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> work period and the payroll report or shift status report did not clearly indicate if the 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> were consecutive or otherwise.
- 4. Burns Security Consolidated and Rev; sed Fitness For Duty Policy.
- 5. Security Force Collective Bargaining agreement.
l Document Control Desk November 21,1991 Page 2
-1 The results of the investigation revealed that for the period of January 1,1991 through July 31,1991 there was only one occasion, (July 20,1991) in which any member of the security force worked 16 consecutive hours. The reasons associated with this event include:
- 1. The individual worked a normal eight hour shift.
- 2. There was a sick leave call-off from the oncoming shift.
- 3. There were no voluntects on shift to cover the call-off.
- 4. The individual was the lowest person on-shift in equalized overtime.
- 5. In accordance with the bargaining unit agreement the individual was mandatorily
. held over an additional 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
- 6. On-shift supervision attempted to contact additional security force personnel for early relief of the individual. All attempted contacts were unsuccessful.
- 7. In accordance with the bargaining unit agreement, the individual was unable to be relieved and therefore was required to remain another 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
- 8. The on-shift Operations Captain performed a fitness-for-duty evaluation of the individual .within the thirteenth hour of work, in accordance with the Burns Security Consolidated and Revised Fitness-For-Duty Policy.
- 9. The individual was determined to be fit to continue his duties and the evaluation and determination were documented on a Burns Security Routine Report Form.
- 10. After the twelfth hour the individual was assigned to posts and activities, (over 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> in the Security Building), in which other members of the Security Force were capable of observing him.
The evaluation period of January 1,1991 through July 31,1991 consists of 212 working days for security and is equivalent to a time frame of greater than 71,000 man hours.
The second part of the investigation was to determine whether security officers were requitec' to work 16 non-consecutive hours within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> work period. The investigation determined that in addition to the one occasion on July 20,1991, there were 14 additional occasions in which security force personnel worked 16 non-consecutive hours within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> work period. llowever, on all 14 occasions the individual volunteered for the overtime. On each of these occasions the individual had 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> off '
after working a maximum of 12 consecutive hours and prior to accumulating the 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. The reasons for the overtime on these 14 occasions included refueling outage support, training needs, vacations by other security officers, and the creation of two new positions and subsequent promotion of personnel into these positions.
WPSC has reviewed the guidance used by the Security Contractor to govern overtime of l
Security Officers. The guidance is the Burns Security Consolidated and Revised Fitness
Document Control Desk November 21,1991
. Page 3 For Duty Policy which states:
No employee shall work more than 16 continuous hours in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period of time, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period of time, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7 day work period.
This Policy dictates the maximum overtime allowable (excluding emergency or major maintenance situations), for security personnel at the Kewaunce site. In addition, more restrictive guidance is found within the Security Force Collective Bargaining Agicement (Article XXVI) which sets the 7 day maximum at 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />. For consistency and uniformity the bargaining unit agreei..ent of 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> is used to the greatest extent practical in governing overtime hours for the entire security force.
Finally, the investigation into whether the guidance was followed for the July 20,1991 event will be included in response to concern 2.
In conclusion, this investigation determined that no violation of the Burns Fitness For Duty Program occurred and that the Burns program does meet the NRC guidance on overtime. The investigation also confirmed that a security officer was required to work 16 consecutive hours on only one occasion. The reasons associated with this occurrence were previously provided. On 14 different occasions security officers worked 16 non-consecutive hours within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, on all 14 occasions the individual voluntarily requested the overtime, and had 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> off after working a maximum of 12 consecutive hours and prior to accumulating the 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. Since the individuals involved on all 14 occasions did not exceed 12 consecutive hours of work, a documented Fitness _
For Duty evaluation was not performed. However, the continuous supervisory evaluation was in effect. The documentation resulting from this investigation is on file at the KNPP.
l 1
. L- l Document Control Desk i
__ November 21,1991 Page 4 -
Response to Concern 2 The investigation into this concern included a review of the Fitness For Duty Training provided to Security Ofncers and Security Supervisors, documentation indicating Security Officer's have requested relief or reassignment of duties due to fatigue, and finally the adequacy of the evaluation performed on the Security Officer who worked 16 consecutive hours on July 20,1991.
In accordance with the requirements of 10 CFR Part 26, the KNPP developed a continuous behavior observation program (CBOP)/ fitness for duty pror .u. This program established that all individuals badged for access to the KNPP shoma be trained and knowledgeable to the supervisory level and ability. The CBO program (as emphasized in training), specifically identifies the employee's responsibility to report any actual Fitness For Duty concern they may be experiencing or observe in others.
As part ofinitial indoctrination training, all security force personnel are provided a copy of the Burns Security Consolidated and Revised Fitness For Duty Policy. All security force personnel also receive revisions to this policy as they are implemented. This policy identifies the responsibility for each member of the security force on criteria and issues associated with Fitness For Duty, and the ten primary factors which form the minimum bases for a Fitness For Duty Evaluation. Through observations, questions and answers, relevant to these ten factors a supervisor is capable of making a reasonable determination of an individual's Fitness For Duty.
As part of the investigation an evaluation was made of the security force indoctrination and CBO training programs provided during the investigation period. It was verified that these programs provide training to specifically address individual fatigue and stress. The training also addresses the responsibility of all badged personnel at the Kewaunee site to report any situations they observe or are personally involved in which may have an impact on Fitness For Duty _. It was determined that sufficient training is incorporated into these programs.
Since all security force personnel are trained and provided with written guidance on behavioral observation, a records review was performed to determine the number of reports submitted relative to security force personnel being fatigued. There was no documentation found which indicated a security force personnel reported being fatigued or that any fatigue was observed in others.
Finally, a review of the available information was performed to determine whether an adequate evaluation was performed of the July 20,1991 event involving the individual s who worked 16 consecutive hours. This review included conducting interviews with
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-bocument Control Desk November 21,1991 Fage 5 management and supervisory personnel, and reviewing the Fitness For Duty evaluation performed for the individual and documented on a Burns Security Routine Report Form.
This review concluded that no evidence could be found to substantiate that the July 20, 1991 Fitness For Duty evaluation was inadequate. However, during the interviews which were conducted as part of this review a potential weakness was identified involving inconsistent and non-uniform applications of the listed factors between supervisors required to evaluate future Fitness For Duty events.
Based upon the potential for future non uniformity or inconsistent applications of Fitness For Duty evaluations, it was decided to formalize the evaluation process into a separate procedure. This new procedure will require documentation of the evaluation factors utilized, a review and acknowledgment by the evaluated individual, a review of the past and projected work schedules for the individual including the posting from the current shift, and lastly will provide a summary report of the evaluation.
In summary, this investigation has determined that sufficient training is being provided to the security force personnel on the criteria and issues associated with Fitness For Duty. In addition, the training specifically addresses concerns involving -individual fatigue and stress. A review of the information concerning the July 20,1991_ event involving ~the individual who worked 16 consecutive hours was determined to be adequate. ' A potential weakness involving non-uniform or inconsistent applications of Fitness For Duty evaluations was identified and is being addressed with appropriate procedure changes. This procedure should be issued prior to the end of December, 1991.
Finally, a program has been developed which will provide a mechanism in which empivye,a c.c express their concerns about any issue. This program is intended to open avenues for quick reviews by personnel empowered to create changes. It is hoped that these type of issues can be resolved through the use of this program.
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