ML080420474

Peach Bottom Lessons Learned - Memo to Mallett, Virgilo, Dyer and Carpenter from Reyes

ML080420474
Person / Time
Site:	Peach Bottom
Issue date:	02/11/2008
From:	Reyes L NRC/EDO
To:	Carpenter C, Dyer J, Mallett B, Virgilio M NRC/EDO, Office of Nuclear Reactor Regulation, NRC/OE
Mallett, Bruce S.
Shared Package
ML080420580	List: ML080420474 ML080420566
References
OEDO-2008-0089
Download: ML080420474 (3)

Text

February 11, 2008 MEMORANDUM TO: Bruce S. Mallett Deputy Executive Director for Reactor and Preparedness Programs Office of the Executive Director for Operations Martin J. Virgilio Deputy Executive Director for Materials, Waste, Research, State, Tribal, and Compliance Programs Office of the Executive Director for Operations James E. Dyer, Director Office of Nuclear Reactor Regulation Cynthia A. Carpenter, Director Office of Enforcement FROM: Luis A. Reyes /RA/

Executive Director for Operations

SUBJECT:

PEACH BOTTOM LESSONS LEARNED In December 2007, Bruce S. Mallett, Deputy Executive Director for Reactor and Emergency Preparedness Programs, tasked a team to evaluate NRC actions associated with the review of allegations and inspection activities related to inattentive security officers at the Peach Bottom nuclear power plant in 2007 and determine lessons learned. This lessons learned review team, led by Marc L. Dapas, Deputy Regional Administrator, Region I, focused on answering three questions: (1) whether the NRCs allegation process was followed; (2) whether the process should be changed to more effectively evaluate and respond to allegations; and (3) whether the guidance for inspection of allegations or for baseline inspections should be changed to more effectively detect inattentive security officers at nuclear facilities. The team completed its review in January and provided a report to Dr. Mallett on February 6, 2008.

I have determined that the review was thorough, addressed the appropriate questions, and included a broad spectrum of input from individuals in Region I, the Office of Enforcement, other regional offices, and the Office of the Executive Director for Operations. The team made recommendations for improvement in the NRCs allegation and inspection programs, which would apply to fuel cycle and other large materials facilities with required security officers, as well as, the nuclear reactor facilities. The teams report wrote these recommendations in the form of areas for further evaluation.

B. Mallett, et al. While I agree with the recommendations and have grouped them into a list of actions to address the lessons learned findings (below), we should not loose sight that this is only one of several activities underway regarding Peach Bottom. Both the Office of the Inspector General and the Office of Investigation are moving forward with investigations of this issue, and I may modify these tasks based on the outcome of the investigations.

Forwarding Allegations and Evaluating Licensee Responses

• Expand the guidance for obtaining additional information from the alleger to adequately scope the problem.

• Modify the allegation review board procedure to document how allegation follow up history, allegation trends, inspection findings, etc. are evaluated in the decision to forward an allegation for licensee follow up.

• Provide direction to include specific, descriptive information and scope of expected review when forwarding an allegation to a licensee.

• Modify the allegation process to include a more formal, structured review of licensee responses to forwarded allegations, including the extent of NRC, independent follow up.

Communications/Interactions with Concerned Individuals

• Change the guidance to require contact with the concerned individual to obtain information to scope the complete concern in all instances.

• Modify the procedure for documenting closure of allegations to include sections on how the licensee followed up on forwarded concerns, the NRC evaluation of the adequacy of the licensee follow up, and how the NRC independently verified the licensees follow up.

NRC Inspection Process for Detecting Inattentiveness

• Modify the inspection procedures to include specific guidance on techniques for maximizing methods to detect inattentiveness. Factor licensee responses to Bulletin 2007-01 into this guidance.

• Expand the inspection procedures to include a review of all open allegations or past allegation trends pertaining to areas to be inspected during preparation for baseline inspections at a facility.

• Modify the allegation review process to include a structured method to inform NRC resident inspectors of all allegation concerns and allegation board direction to follow up for their assigned site.

By this memorandum, I am establishing a senior executive review panel to decide how best to act upon the recommendations and the list of actions in this memorandum (e.g., who should be tasked to implement actions and a schedule to address each recommendation). The panel should also determine if the list of recommendations and actions should be expanded. The panel members should be: Bruce S. Mallett (Chair), Martin J. Virgilio, James E. Dyer, and Cynthia A. Carpenter. The panel should convene and make this determination and provide a response to me within two weeks of the date of this memorandum.

B. Mallett, et al. In parallel, I have directed Bruce S. Mallett to forward the review teams findings, recommendations, and a copy of this memorandum to the Agencys Lessons Learned Oversight Board for review.

A copy of the teams report is attached for your use. If you have any question or desire to discuss, please contact me.

Enclosure:

Review Team Findings with Respect to Inattentive Security Officers at Peach Bottom

ML080420580 OFFICE DEDR EDO NAME B. Mallett L. Reyes DATE 02/11/08 02/11/08