ML081820168

Request for Additional Information Bulletin 2007-01, Security Officer Attentiveness

ML081820168
Person / Time
Site:	Perry
Issue date:	07/03/2008
From:	Goodwin C NRC/NRR/ADRO/DORL/LPLIII-2
To:	Bezilla M FirstEnergy Nuclear Operating Co
Goodwin C
References
BL-07-001, TAC MD7635
Download: ML081820168 (8)

Text

July 3, 2008 Mr. Mark B. Bezilla Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RE: BULLETIN 2007-01 SECURITY OFFICER ATTENTIVENESS (TAC NO. MD7635)

Dear Mr. Bezilla:

By letter to the Nuclear Regulatory Commission (NRC, the Commission) dated February 11, 2008, the FirstEnergy Nuclear Operating Company (the licensee) submitted the required written response to Security Bulletin 2007-01 Security Officer Attentiveness for Perry Nuclear Power 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 needed to complete the final staff assessment of the licensee response to the Security Bulletin 2007-01. Security Bulletin 2007-01 requested licensees to provide information regarding administrative and managerial programs and controls established to prevent, identify and correct security personnel inattentiveness, complicity, and failures to implement the behavioral observation program by individuals among 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.

M. Bezilla If you have any questions, please contact me at 301-415-3719.

Sincerely,

/RA/

Cameron Goodwin, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

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

ML081820168 NRR-088 OFFICE LPL3-2/PM LPL3-2/LA LPL3-2/BC RGibbs NAME CGoodwin EWhitt (JWiebe for)

DATE 7/3/08 7/3/08 7/3/08 Perry Nuclear Power Plant, Unit No. 1 cc:

David W. Jenkins, Attorney Robert Owen FirstEnergy Corporation Radiological Assistance Section Supervisor Mail Stop A-GO-15 Bureau of Radiation Protection 76 South Main Street Ohio Department of Health Akron, OH 44308 P.O. Box 118 Columbus, OH 43266-0118 Resident Inspector's Office U.S. Nuclear Regulatory Commission Zack A. Clayton P.O. Box 331 DERR Perry, OH 44081-0331 Ohio Environmental Protection Agency ATTN: Mr. Zack A. Clayton Sue Hiatt P.O. Box 1049 OCRE Interim Representative Columbus, OH 43266-0149 8275 Munson Mentor, OH 44060 Chairman Perry Township Board of Trustees Manager, Site Regulatory Compliance 3750 Center Road, Box 65 FirstEnergy Nuclear Operating Company Perry, OH 44081 Perry Nuclear Power Plant Mail Stop A-PY-A200 Daniel Z. Fisher P.O. Box 97, 10 Center Road Transportation Department Perry, OH 44081-0097 Public Utilities Commission 180 East Broad Street Mayor, Village of North Perry Columbus, OH 43215-3793 North Perry Village Hall 4449 Lockwood Road James H. Lash North Perry Village, OH 44081 Senior Vice President of Operations and Chief Operating Officer Dean Jagger, Chief Boiler Inspector FirstEnergy Nuclear Operating Company Ohio Department of Commerce Mail Stop A-GO-14 Division of Industrial Compliance 76 South Main Street Bureau of Operations & Maintenance Akron, OH 44308 6606 Tussing Road P.O. Box 4009 Director, Fleet Regulatory Affairs Reynoldsburg, OH 43068-9009 FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 Carol OClaire, Chief, Radiological Branch 76 South Main Street Ohio Emergency Management Agency Akron, OH 44308 2855 West Dublin Granville Road Columbus, OH 43235-7150 Joseph J. Hagan President and Chief Nuclear Officer Mayor, Village of Perry FirstEnergy Nuclear Operating Company P.O. Box 100 Mail Stop A-GO-19 Perry, OH 44081-0100 76 South Main Street Akron, OH 44308

Perry Nuclear Power Plant, Unit No. 1 cc:

Danny L. Pace Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308 Paul A. Harden Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308

REQUEST FOR ADDITIONAL INFORMATION REVIEW OF SECURITY BULLETIN RESPONSES SUBMITTED IN RESPONSE TO SECURITY BULLETIN 2007-01 PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-440 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 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 up keep and maintenance of his or her post; and (3) a Enclosure

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 corrective action program 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 responses:

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) 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.