ML081820004

Request for Additional Information Related to Response to NRC Bulletin 2007-01, Security Officer Attentiveness

ML081820004
Person / Time
Site:	Wolf Creek
Issue date:	07/02/2008
From:	Balwant Singal NRC/NRR/ADRO/DORL/LPLIV
To:	Muench R Wolf Creek
Singal, Balwant, 415-3016, NRR/DORL/LPL4
References
BL-07-001, TAC MD7669
Download: ML081820004 (7)

Text

July 2, 2008 Mr. Rick A. Muench President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION - REQUEST FOR ADDITIONAL INFORMATION RELATED TO RESPONSE TO NRC BULLETIN 2007-01, SECURITY OFFICER ATTENTIVENESS (TAC NO. MD7669)

Dear Mr. Muench:

By letter dated February 8, 2008, Wolf Creek Nuclear Operating Corporation (the licensee) submitted the required written response to U.S. Nuclear Regulatory Commission (NRC) Bulletin 2007-01, Security Officer Attentiveness, for Wolf Creek Generating 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 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 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.

R. Muench If you have any questions, please contact me at 301-415-3016.

Sincerely,

/RA/

Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482

Enclosure:

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

ML081820004 NSIR e-mail stored under package ML081820158 OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NRR/LPL4/PM NAME BSingal JBurkhardt THiltz BSingal DATE 7/1/08 6/30/08 7/2/08 7/2/08 Wolf Creek Generating Station (6/10/2008) cc:

Jay Silberg, Esq. County Clerk Pillsbury Winthrop Shaw Pittman LLP Coffey County Courthouse 2300 N Street, NW 110 South 6th Street Washington, D.C. 20037 Burlington, KS 66839 Regional Administrator, Region IV Chief, Radiation and Asbestos Control U.S. Nuclear Regulatory Commission Section 612 E. Lamar Blvd., Suite 400 Kansas Department of Health Arlington, TX 76011-4125 and Environment Bureau of Air and Radiation Senior Resident Inspector 1000 SW Jackson, Suite 310 U.S. Nuclear Regulatory Commission Topeka, KS 66612-1366 P.O. Box 311 Burlington, KS 66839 Vice President Operations/Plant Manager Wolf Creek Nuclear Operating Corporation Chief Engineer, Utilities Division P.O. Box 411 Kansas Corporation Commission Burlington, KS 66839 1500 SW Arrowhead Road Topeka, KS 66604-4027 Supervisor Licensing Wolf Creek Nuclear Operating Corporation Office of the Governor P.O. Box 411 State of Kansas Burlington, KS 66839 Topeka, KS 66612 U.S. Nuclear Regulatory Commission Attorney General Resident Inspectors Office/Callaway Plant 120 S.W. 10th Avenue, 2nd Floor 8201 NRC Road Topeka, KS 66612-1597 Steedman, MO 65077-1032

REQUEST FOR ADDITIONAL INFORMATION RELATED TO RESPONSE TO NRC BULLETIN 2007-01, SECURITY OFFICER ATTENTIVENESS WOLF CREEK GENERATING STATION DOCKET NO. 50-482 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 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.

ENCLOSURE

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

3. 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?

4. 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:

5. 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?

6. 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:

7. 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.

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) 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.