ML081780333
| ML081780333 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/03/2008 |
| From: | Thadani M NRC/NRR/ADRO/DORL/LPLIV |
| To: | Naslund C Union Electric Co |
| Thadani, M C, NRR/DORL/LPL4, 415-1476 | |
| References | |
| BL-07-001, TAC MD7579 | |
| Download: ML081780333 (9) | |
Text
July 3, 2008 Mr. Charles D. Naslund Senior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251
SUBJECT:
CALLAWAY PLANT, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO RESPONSE TO NRC BULLETIN 2007-01, SECURITY OFFICER ATTENTIVENESS (TAC NO. MD7579)
Dear Mr. Naslund:
By letter dated February 11, 2008, Union Electric Company (the licensee) submitted the required written response to U.S. Nuclear Regulatory Commission (NRC)Bulletin 2007-01, Security Officer Attentiveness, for the Callaway Plant, Unit 1. The response was submitted to the NRC in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(f) and 10 CFR 70.22(d).
The NRC staff has reviewed your submittal and has determined that additional information is required to complete the final staff assessment of the licensee response to NRC Bulletin 2007-01. NRC Bulletin 2007-01 requested licensees to provide information regarding administrative and managerial programs and controls established to prevent, identify, and correct 1) security personnel inattentiveness and complicity, and 2) failures to implement the behavioral observation program for licensee security personnel including security contractors and subcontractors. The staff will use the additional information received to inform the Commission and to determine if further regulatory action is warranted or if additional assessment of licensee program implementation is needed.
The specific information requested is addressed in the enclosure to this letter. Responses are requested within 35 days of the issuance of this letter. Before submitting responses to the NRC, licensees must evaluate them for proprietary, sensitive, safeguards, or classified information and mark such information appropriately.
C. If there are any questions, please contact me at (301) 415-1476, or via e-mail at mohan.thadani@nrc.gov.
Sincerely,
/RA/
Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483
Enclosure:
As stated cc w/encl: See next page
ML081780333 OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NRR/LPL4/PM NAME MThadani JBurkhardt THiltz, MCT for MThadani DATE 7/3/08 6/27/08 7/3/08 7/3/08
Callaway Plant, Unit 1 (6/10/2008) cc:
John ONeill, Esq.
Pillsbury Winthrop Shaw Pittman LLP 2300 N. Street, N.W.
Washington, D.C. 20037 Mr. Tom Elwood, Supervising Engineer Regulatory Affairs and Licensing AmerenUE P.O. Box 620 Fulton, MO 65251 Mr. Les H. Kanuckel, Manager Quality Assurance AmerenUE P.O. Box 620 Fulton, MO 65251 Mr. Luke Graessle, Manager Regulatory Affairs AmerenUE P.O. Box 620 Fulton, MO 65251 Mr. Scott Maglio Assistant Manager, Regulatory Affairs AmerenUE P.O. Box 620 Fulton, MO 65251 U.S. Nuclear Regulatory Commission Resident Inspector Office 8201 NRC Road Steedman, MO 65077-1302 Missouri Public Service Commission Governor Office Building 200 Madison Street P.O. Box 360 Jefferson City, MO 65102-0360 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Mr. H. Floyd Gilzow Deputy Director for Policy Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176 Mr. Rick A. Muench, President and CEO Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KA 66839 Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 Technical Services Branch Chief FEMA Region VII 2323 Grand Boulevard, Suite 900 Kansas City, MO 64108-2670 Kathleen Logan Smith, Executive Director and Kay Drey, Representative, Board of Directors Missouri Coalition for the Environment 6267 Delmar Blvd., Suite 2E St. Louis, City, MO 63130 Mr. Lee Fritz, Presiding Commissioner Callaway County Courthouse 10 East Fifth Street Fulton, MO 65251 Mr. Keith G. Henke, Planner III Division of Community and Public Health Office of Emergency Coordination Missouri Department of Health and Senior Services 930 Wildwood Drive P.O. Box 570 Jefferson City, MO 65102 Mr. Scott Clardy, Director Section for Environmental Public Health Missouri Department of Health and Senior Services 930 Wildwood Drive P.O. Box 570 Jefferson City, MO 65102 Director, Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116
OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION RELATED TO RESPONSE TO NRC BULLETIN 2007-01, SECURITY OFFICER ATTENTIVENESS UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483 In responding to each of the following questions, the licensee should provide information that addresses measures that are currently in place, and any additional planned actions with expected completion dates.
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed your response to Question 1a and requests the following additional information:
- 1.
Describe the process for security post rotations including the rotation process for isolated positions.
Include the following information in your response:
A description of the security post rotation process including, but not limited to: (1) a discussion of the types of posts a typical security officer would rotate through during a normal shift; (2) a discussion on whether the type of activity (i.e., roving or foot patrol or stationary in a Bullet Resisting Enclosure (BRE) performed at each individual post is taken into consideration when a security officer moves from post to post throughout the shift; and (3) the length of time at each post. When responding, particular emphasis should be placed on whether the licensee takes into consideration the activities associated with each post assignment when formulating their post rotation schedules for each shift (i.e., rotating from foot patrol to BRE to Vital Area patrol or rotating from BRE to ready room to BRE, etc.).
The NRC staff reviewed your response to Question 1b. and requests the following additional information:
- 2.
Describe any licensee processes or programs that are in place to identify problems in climate-controlled security areas. What methods are used to track, inspect, and ensure timely repairs are completed?
Include the following information in your response:
A description of how the security areas are maintained including, but not limited to: (1) a discussion of the maintenance and/or preventive maintenance process and programs in place for these security areas including an overview and brief discussion on routine inspection schedules by maintenance personnel; (2) a discussion on the process a security officer can ENCLOSURE
follow to report concerns with the upkeep and maintenance of his or her post; and (3) a discussion on the timeliness of repairs and any follow-up actions taken by the licensee to ensure the repairs are completed and resolved adequately.
The NRC staff reviewed your response to Question 1c. and requests the following additional information:
- 3.
What is the level of involvement from management who do not have direct responsibility for the security program (including executive and corporate management) in conducting behavior observations of security personnel?
Include the following information in your response:
A description of any processes in place for licensee and/or contract management, who work day-to-day at the site or visit the site on a routine basis from a corporate office or other applicable offsite location, for conducting behavior observations of security personnel while on duty at their assigned posts. Examples should include, but are not limited to, a discussion of random or scheduled observations conducted by licensee and/or contract management such as the Plant Operations Shift Managers or other Plant Operations Shift Supervisors, Plant Maintenance Supervisors (licensee and contractor), or Quality Assurance Supervisors, etc. The discussion should include whether these random or scheduled observations are proceduralized and the required or recommended level of licensee and/or contract management involvement.
The NRC staff reviewed your response to Question 1 and requests the following additional information:
- 4.
Are security personnel provided opportunities to participate in any personnel surveys regarding the work environment? If so, what is the frequency of the surveys, the average participation rate of security personnel as compared to the general site average, and the process for providing feedback and addressing the results from the survey?
- 5.
How is the licensees policy regarding site employee attentiveness and/or inattentiveness communicated to personnel, both licensee and contractor, and at what frequency?
The NRC staff reviewed your response to Question 2 and requests the following additional information:
- 6.
Describe the process for employees to file reports through the site corrective action program (CAP). Can employees file CAP reports without prior supervisory/management review or approval?
Include the following information in your response:
Describe the process for employees to file reports through the CAP. Discuss the supervisor/
management review and/or approval process including but not limited to: (1) does a supervisor/manager have the authority to reject a report before entering it into the CAP without
additional management review and approval; and (2) does a supervisor/manager have the authority to modify the report before such report has been entered into the CAP?
- 7.
Can the employees view the status and disposition of reports directly, or must this information be requested? If yes, please describe the process.
The NRC staff reviewed your response to Question 4 and requests the following additional information:
- 8.
Are formal assessments of the security program conducted by organizations/
individuals that do not have direct responsibility for the security program? If so, provide information on the process, including, but not limited to, the organizations and levels of management involved, the frequency of such activities, and any tracking of how findings are resolved.
- 9.
How are self-assessment findings and relevant operating experience information communicated to the security force? Describe those processes including, but not limited to, information such as the criteria by which such information is identified, the frequency of such communications, the responsible department(s) or position(s) for such communications, and the recipients of such communications.
Include the following information in your response:
Describe the process including, but not limited to: (1) formal or informal communication methods; (2) procedures that ensure availability of the policy to staff; and (3) training opportunities for staff to read and understand the policy.
The NRC staff reviewed your response to Question 5 and requests the following additional information:
- 10.
How do you assess the effectiveness of your oversight of contractors and subcontractors?
Include the following information in your response:
Describe the licensees program for oversight of contractors and subcontractors including, but not limited to: (1) a brief overview and description of licensees procedures that describe the oversight process; (2) a detailed list (bulleted is preferred) of assigned duties for the licensee supervisor(s) or manager(s) responsible for overseeing contractors and subcontractors at the site; (3) a detailed list (bulleted is preferred) of the assigned duties for the contractor and subcontractor supervisor(s) or manager(s) responsible for overseeing the contractor and subcontractor staff at the site; and (4) a brief discussion of the corporate (management) involvement with the oversight of contractors and subcontractors at the site.