ML081820855

Request for Additional Information Re Bulletin 2007-01, Security Office Attentiveness

ML081820855
Person / Time
Site:	Monticello
Issue date:	07/07/2008
From:	Tam P NRC/NRR/ADRO/DORL/LPLIII-1
To:	O'Connor T Nuclear Management Co
Tam P
References
TAC MD7620
Download: ML081820855 (8)

Text

July 7, 2008 Mr. Timothy J. O=Connor Site Vice President Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT - REQUEST FOR ADDITIONAL INFORMATION RE: SECURITY BULLETIN 2007-01 SECURITY OFFICER ATTENTIVENESS (TAC NO. MD7620)

Dear Mr. OConnor:

By letter dated February 11, 2008, Nuclear Management Company, LLC (NMC) submitted the required written response to Security Bulletin 2007-01 Security Officer Attentiveness Monticello Nuclear Generating Plant. The response was submitted to the Nuclear Regulatory Commission (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 NMCs submittal and has determined that additional information is needed to complete the final assessment of your response. 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. We request your response within 35 days of the date of issuance of this letter. Before submitting your response, you should evaluate it for proprietary, sensitive, safeguards, or classified information and handle such information appropriately. If you have any question, please contact me at 301-415-1451.

Sincerely,

/RA/

Peter S. Tam, Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-263

Enclosure:

As stated cc w/encl: See next page

Mr. Timothy J. O=Connor July 7, 2008 Site Vice President Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT - REQUEST FOR ADDITIONAL INFORMATION RE: SECURITY BULLETIN 2007-01 SECURITY OFFICER ATTENTIVENESS (TAC NO. MD7620)

Dear Mr. OConnor:

By letter dated February 11, 2008, Nuclear Management Company, LLC (NMC) submitted the required written response to Security Bulletin 2007-01 Security Officer Attentiveness Monticello Nuclear Generating Plant. The response was submitted to the Nuclear Regulatory Commission (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 NMCs submittal and has determined that additional information is needed to complete the final assessment of your response. 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. We request your response within 35 days of the date of issuance of this letter. Before submitting your response, you should evaluate it for proprietary, sensitive, safeguards, or classified information and handle such information appropriately. If you have any question, please contact me at 301-415-1451.

Sincerely,

/RA/

Peter S. Tam, Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-263

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION:

PUBLIC LPL3-1 r/f RidsNrrDorlLpl3-1 Resource LRegner, NRR/DORL MBanic, NRR/DPR FPeduzzi, NSIR RCorreia, NSIR RidsNrrLATHarris RidsNrrPMPTam Resource RidsOgcRp Resource RidsAcrsAcnw_MailCTR Resource RidsRgn3MailCenter Resource ADAMS Accession Number: ML081820855 OFFICE LPL3-1/PM LPL3-1/LA NSIR* LPL3-1/BC NAME PTam THarris -- LJames DATE 7/1/08 7/1/08 -- 7/1/08

• See package of e-mails from NSIR (Accession No. ML081820158)

OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION REVIEW OF RESPONSE TO SECURITY BULLETIN 2007-01 MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263 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 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 its 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 1c. and requests the following additional information:

(2) What is the level of involvement from management personnel 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 personnel, 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 personnel 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:

(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 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.

(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 5 and requests the following additional information:

(7) How do you assess the effectiveness of your oversight of contractors and subcontractors? Include the following information in your response:

Describe 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.

Monticello Nuclear Generating Plant cc:

Peter M. Glass Commissioner Assistant General Counsel Minnesota Department of Commerce Xcel Energy Services, Inc. 85 7th Place East, Suite 500 414 Nicollet Mall (MP4) St. Paul, MN 55101-2198 Minneapolis, MN 55401 Manager - Environmental Protection U.S. Nuclear Regulatory Commission Division Resident Inspector's Office Minnesota Attorney General=s Office 2807 W. County Road 75 445 Minnesota St., Suite 900 Monticello, MN 55362 St. Paul, MN 55101-2127 Manager, Nuclear Safety Assessment Nuclear Asset Manager Monticello Nuclear Generating Plant Xcel Energy, Inc.

Nuclear Management Company, LLC 414 Nicollet Mall (MP4) 2807 West County Road 75 Minneapolis, MN 55401 Monticello, MN 55362-9637 Dennis L. Koehl Commissioner Chief Nuclear Officer Minnesota Pollution Control Agency Nuclear Management Company, LLC 520 Lafayette Road 414 Nicollet Mall (MP4)

St. Paul, MN 55155-4194 Minneapolis, MN 55401 Commissioner Minnesota Department of Health 717 Delaware Street, S. E.

Minneapolis, MN 55440 Douglas M. Gruber, Auditor/Treasurer Wright County Government Center 10 NW Second Street Buffalo, MN 55313