ML081790171

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Request for Additional Information Regarding Bulletin 2007-01, Security Officer Attentiveness
ML081790171
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 07/08/2008
From: Martin R
NRC/NRR/ADRO/DORL/LPLII-1
To: Archie J
South Carolina Electric & Gas Co
Martin R, NRR/DORL, 415-1493
References
TAC MD7656
Download: ML081790171 (7)


Text

July 8, 2008 Mr. Jeffery B. Archie Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88 Jenkinsville, SC 29065

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, REQUEST FOR ADDITIONAL INFORMATION RE: NRC BULLETIN 2007-01 SECURITY OFFICER ATTENTIVENESS (TAC NO. MD7656)

Dear Mr. Mr. Archie:

By letter dated February 11, 2008, South Carolina Electric and Gas Company (the licensee) submitted the required written response to U.S. Nuclear Regulatory Commission (NRC)

Bulletin 2007-01, Security Officer Attentiveness for the Virgil C. Summer Nuclear Station. 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 needed to complete the final NRC 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 NRC 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.

J. Archie If you have any question, please contact me at 301-415-1493.

Sincerely,

/RA/

Robert E. Martin, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosure:

Request for Additional Information cc w/encl: see next page

J. Archie If you have any question, please contact me at 301-415-1493.

Sincerely,

/RA/

Robert E. Martin, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosure:

Request for Additional Information cc w/encl: see next page DISTRIBUTION:

Public RidsAcrsAcnw_MailCenter RidsOgcRpResource LPL2-1 R/F RPedersen, NRR RCorreia, NSIR RidsNrrDorlLp2-1Resource RidsRgn2MailCenterResource FPeduzzi, NSIR RidsNrrPMRMartinResource RidsNrrGLappertResource MBanic, NRR/DPR LRegner, NRR ADAMS Accession Number: ML081790171 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/LPL2-1/BC NAME RMartin GLappert MWong DATE 7/8/08 7/8/08 7/8/08 OFFICIAL RECORD COPY

Enclosure OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REVIEW OF SECURITY BULLETIN RESPONSES SUBMITTED IN RESPONSE TO NRC BULLETIN 2007-01 VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50-395 In responding to each of the following questions, licensee should provide information that addresses measures that are currently in place, and any additional planned actions with expected completion dates:

The NRC staff reviewed your response to Question 1c. and requests the following additional information:

1.

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:

2.

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.

3.

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:

4.

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.

5.

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:

6.

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.

7.

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:

8.

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) include 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) include 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.

Virgil C. Summer Nuclear Station cc:

Mr. R. J. White Nuclear CoordinatorS.C. Public Service Authority c/o Virgil C. Summer Nuclear StationPost Office Box 88, Mail Code 802 Jenkinsville, SC 29065 Resident Inspector/Summer NPS c/o U.S. Nuclear Regulatory Commission 576 Stairway Road Jenkinsville, SC 29065 Chairman, Fairfield County Council Drawer 60 Winnsboro, SC 29180 Ms. Susan E. Jenkins, Manager Division of Waste Management Bureau of Land & Waste Management Dept. of Health & Environmental Control 2600 Bull Street Columbia, SC 29201 Mr. Thomas D. Gatlin, General Manager Nuclear Plant Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 300 Jenkinsville, SC 29065 Mr. Bruce L. Thompson, Manager Nuclear Licensing South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 830 Jenkinsville, SC 29065 Ms. Kathryn M. Sutton Morgan, Lewis & Bockius LLP 111 Pennsylvania Avenue, NW.

Washington, DC 20004