ML080290051
| ML080290051 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/25/2008 |
| From: | Barkley R Region 1 Administrator |
| To: | Epstein E - No Known Affiliation |
| References | |
| Download: ML080290051 (4) | |
Text
January 25, 2008 Eric J. Epstein 4100 Hillsdale Road Harrisburg, PA 17112
Dear Eric:
It was good seeing you again on December 3, 2007, at the Peach Bottom Augmented Team Inspection (AIT) Follow-up exit meeting. During the public question and answer session that followed the meeting, you asked that the NRC reply to you with the definition of several terms used frequently during that meeting. Below is a listing of each term and our understanding of its meaning as promised.
Appropriate -- This term is defined in the dictionary as fitting; especially suitable or compatible.
This term was used by the Region I staff to describe the corrective actions taken by Exelon to address the security force performance issues noted at Peach Bottom in September. It was used during the December 3rd meeting to convey the opinion of NRC management and the experienced inspectors that reviewed Exelons corrective actions following notification by the NRC in September 2007 of potential security officer inattentiveness.
Attentiveness -- This term is defined in the dictionary as giving heed; watchful. Its antonym, inattentiveness, as referenced in the September 27, 2007, security advisory issued by the NRC and recently issued Bulletin 2007-01, is used to describe behavior (e.g., sleeping, eyes closed and consciousness partially lost) that may prevent a security force member from being able to promptly respond as required if called upon. While a guard who is sleeping is clearly not attentive, the term inattentiveness is also used to describe behaviors other than sleeping that could distract a security force member to the point that performance of a key job attribute is less than acceptable. The term inattentive is not defined in the NRCs nuclear plant security regulations 10 CFR Part 73; however, Part 73.46 requires that specific security force members be capable of maintaining continuous communications with an individual in each continuously manned alarm station. Security force members who are not attentive are considered in violation of this NRC requirement and/or other applicable procedures required by the NRC approved security plan for the station.
Enhanced Leadership -- This term was used exclusively by Exelon management and is not one referenced by the NRC when describing licensee management performance. Thus I will defer on formally defining this term; however, I believe that Exelon provided clear examples during the December 3rd meeting which conveyed where it felt enhanced leadership was necessary in the handling of the inattentive security guards at Peach Bottom prior to mid-September 2007.
Independence -- This term is defined in the dictionary as the capacity to manage one's own affairs and make one's own judgments. In the context of the subject of the December 3rd meeting, the staff was discussing the ability of the NRC, as well as other parties who conducted reviews of this matter, to review performance issues critically and to make difficult
E. Epstein 2
pronouncements regarding these matters separate and distinct from any conclusions drawn by Exelon. As the NRC reports to Congress, which authorizes our budget and approves the five Commissioners, we consider the agency to be an independent body. Regarding the internal reviews conducted for Exelon, those reviews were performed by individuals who did not report to the Peach Bottom management team, which provided a measure of independence to those efforts.
Independent Contractor -- As defined in Blacks Law Dictionary, an independent contractor is one who contracts to do a piece of work according to his own methods and is subject to his employers control only as to end product or final result of his work. In the case of Wackenhut at Peach Bottom, the company had their own management structure onsite who hired, fired and directly supervised the security force members, but was subject to Exelon oversight. In contrast, the new security organization will have supervisors and security force members who are employed by Exelon.
Safety Conscious -- This term is typically used by the NRC to describe the work environment at a licensee. A Safety Conscious Work Environment (SCWE) is an attribute of safety culture and is formally defined by the NRC in Inspection Manual Chapter 0305 as an environment where employees are encouraged to raise safety concerns without fear of retaliation and where concerns are promptly reviewed, given the proper priority based on their potential safety significance, and appropriately resolved with timely feedback to the originator of the concerns and other employees. The SCWE in the Peach Bottom security organization prior to mid-September 2007 was elaborated in detail during the question and answer session of the December 3rd meeting, and is also described in both our AIT inspection and AIT follow-up inspection reports.
I trust these definitions provide sufficient elaboration on this terminology to ensure that we fully conveyed to you our assessment of this event and Exelons subsequent response. Feel free to give me a call (610-337-5065) if you have further questions.
Sincerely,
/RA/
Richard S. Barkley, PE Technical Communications Assistant
E. Epstein 2
pronouncements regarding these matters separate and distinct from any conclusions drawn by Exelon. As the NRC reports to Congress, which authorizes our budget and approves the five Commissioners, we consider the agency to be an independent body. Regarding the internal reviews conducted for Exelon, those reviews were performed by individuals who did not report to the Peach Bottom management team, which provided a measure of independence to those efforts.
Independent Contractor -- As defined in Blacks Law Dictionary, an independent contractor is one who contracts to do a piece of work according to his own methods and is subject to his employers control only as to end product or final result of his work. In the case of Wackenhut at Peach Bottom, the company had their own management structure onsite who hired, fired and directly supervised the security force members, but was subject to Exelon oversight. In contrast, the new security organization will have supervisors and security force members who are employed by Exelon.
Safety Conscious -- This term is typically used by the NRC to describe the work environment at a licensee. A Safety Conscious Work Environment (SCWE) is an attribute of safety culture and is formally defined by the NRC in Inspection Manual Chapter 0305 as an environment where employees are encouraged to raise safety concerns without fear of retaliation and where concerns are promptly reviewed, given the proper priority based on their potential safety significance, and appropriately resolved with timely feedback to the originator of the concerns and other employees. The SCWE in the Peach Bottom security organization prior to mid-September 2007 was elaborated in detail during the question and answer session of the December 3rd meeting, and is also described in both our AIT inspection and AIT follow-up inspection reports.
I trust these definitions provide sufficient elaboration on this terminology to ensure that we fully conveyed to you our assessment of this event and Exelons subsequent response. Feel free to give me a call (610-337-5065) if you have further questions.
Sincerely,
/RA/
Richard S. Barkley, PE Technical Communications Assistant ADAMS Assession: ML080290051 SUNSI Review Complete: rsb1 (Reviewer=s Initials)
DOCUMENT NAME: G:\\ORA\\Barkley\\Eric Epstein's Definition Request - RV7.doc After declaring this document AAn Official Agency Record@ it will/will not be released to the Public.
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RI/ORA RI/DRS RI/DRS RI/RC NAME RBarkley JTrapp Gamberoni Farrar DATE 01/17/08 01/22/08 01/25/08 01/23/08 OFFICIAL RECORD COPY *See previous concurrence page
E. Epstein 2
Distribution:
RZimmerman, NSIR DScrenci, ORA NSheehan, ORA EBrenner, OPA SCollins, RA KFarrar, RC MGamberoni, DRS JTrapp, DRS PKrohn, DRP