ML081840435

Request for Additional Information Bulletin 2007-01 Security Officer Attentiveness

ML081840435
Person / Time
Site:	Pilgrim
Issue date:	07/03/2008
From:	James Kim NRC/NRR/ADRO/DORL/LPLI-1
To:	Entergy Nuclear Operations
kim j
References
TAC MD7636
Download: ML081840435 (10)

Text

July 3, 2008 Vice President, Operations Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508

SUBJECT:

PILGRIM NUCLEAR POWER STATION - REQUEST FOR ADDITIONAL INFORMATION RE: BULLETIN 2007-01 SECURITY OFFICER ATTENTIVENESS (TAC NO. MD7636)

Dear Sir or Madam:

By letter dated February 9, 2008, Entergy Nuclear Operations, Inc. (the licensee) submitted the required written response to Security Bulletin 2007-01 Security Officer Attentiveness for the Pilgrim Nuclear Power Station. 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 your submittal and has determined that additional information is needed to complete the final staff assessment of the licensee response to the Security Bulletin.

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 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.

If you have any questions, please contact me at 301-415-4125.

Sincerely,

/RA/

James S. Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

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

July 3, 2008 Vice President, Operations Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508

SUBJECT:

PILGRIM NUCLEAR POWER STATION - REQUEST FOR ADDITIONAL INFORMATION RE: BULLETIN 2007-01 SECURITY OFFICER ATTENTIVENESS (TAC NO. MD7636)

Dear Sir or Madam:

By letter dated February 9, 2008, Entergy Nuclear Operations, Inc. (the licensee) submitted the required written response to Security Bulletin 2007-01 Security Officer Attentiveness for the Pilgrim Nuclear Power Station. 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 your submittal and has determined that additional information is needed to complete the final staff assessment of the licensee response to the Security Bulletin.

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 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.

If you have any questions, please contact me at 301-415-4125.

Sincerely,

/RA/

James S. Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

Request for Additional Information cc w/encl: See next page ADAMS Accession Number: ML081840435 OFFICE LPL1-1/PM LPL1-1/LA LPL1-1/BC NAME JKim SLittle MKowal DATE 7/3/08 7/03/08 7/03/08 OFFICIAL RECORD COPY

DISTRIBUTION:

PUBLIC RidsNrrDorlLpl1-1 RidsNrrPMJKim RidsOgcMailCenter LPL1-1 RF SWilliams, EDO RI RidsNrrLASLittle RidsAcrsAcnw&mMailCenter RidsNrrDorlDpr RidsRgn1MailCenter RidsNrrAdes RidsNrrOd Peduzzi, NSIR RCorreia, NSIR LRegner BNorris, RI MBanic

Pilgrim Nuclear Power Station cc:

Regional Administrator, Region I Massachusetts Emergency U. S. Nuclear Regulatory Commission Management Agency 475 Allendale Road Attn: John Giarrusso, King of Prussia, PA 19406-1415 Nuclear Preparedness Manager 400 Worcester Road Senior Resident Inspector Framingham, MA 01702-5399 U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Mr. William D. Meinert Post Office Box 867 Nuclear Engineer Plymouth, MA 02360 Massachusetts Municipal Wholesale Electric Company Chairman, Board of Selectmen P.O. Box 426 11 Lincoln Street Ludlow, MA 01056-0426 Plymouth, MA 02360 Site Vice President Chairman Entergy Nuclear Operations Nuclear Matters Committee Pilgrim Nuclear Power Station Town Hall 600 Rocky Hill Road 11 Lincoln Street Plymouth, MA 02360-5508 Plymouth, MA 02360 General Manager, Plant Operations Chairman, Duxbury Board of Selectmen Entergy Nuclear Operations Town Hall Pilgrim Nuclear Power Station 878 Tremont Street 600 Rocky Hill Road Duxbury, MA 02332 Plymouth, MA 02360-5508 Office of the Commissioner Director, Nuclear Safety Assurance Massachusetts Department of Entergy Nuclear Operations Environmental Protection Pilgrim Nuclear Power Station One Winter Street 600 Rocky Hill Road Boston, MA 02108 Plymouth, MA 02360-5508 Office of the Attorney General Manager, Licensing One Ashburton Place Entergy Nuclear Operations 20th Floor Pilgrim Nuclear Power Station Boston, MA 02108 600 Rocky Hill Road Plymouth, MA 02360-5508 MA Department of Public Health Radiation Control Program Schrafft Center, Suite 1M2A 529 Main Street Charlestown, MA 02129

Pilgrim Nuclear Power Station cc:

Senior Vice President Senior Manager, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

P.O. Box 31955 P.O. Box 31955 Jackson, MS 39286-1995 Jackson, MS 39268-1995 Vice President, Oversight Assistant General Counsel Entergy Nuclear Operations, Inc. Entergy Nuclear Operations P.O. Box 31995 440 Hamilton Avenue Jackson, MS 39286-1995 White Plains, NY 10601 Senior Vice President and COO Ms. Stacey Lousteau Entergy Nuclear Operations, Inc. Treasury Department 440 Hamilton Avenue Entergy Services, Inc.

White Plains, NY 10601 639 Loyola Avenue New Orleans, LA 70113 Vice President, Operations Entergy Nuclear Operations, Inc. Mr. James Sniezek Pilgrim Nuclear Power Station 5486 Nithsdale Drive 600 Rocky Hill Road Salisbury, MD 21801-2490 Plymouth, MA 02360-5508 Mr. Michael D. Lyster Mr. Michael Kansler 5931 Barclay Lane President & CEO/CNO Naples, FL 34110-7306 Entergy Nuclear Operations, Inc.

P.O. Box 31955 Mr. Garrett D. Edwards Jackson, MS 39268-1995 814 Waverly Road Kennett Square, PA 19348 Mr. John F. McCann Director, Nuclear Safety & Licensing Mr. John Doering Entergy Nuclear Operations, Inc. P.O. Box 189 440 Hamilton Avenue Parker Ford, PA 19457 White Plains, NY 10601

REQUEST FOR ADDITIONAL INFORMATION REVIEW OF SECURITY BULLETIN RESPONSES SUBMITTED IN RESPONSE TO SECURITY BULLETIN 2007-01 PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293 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 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 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. 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 4 and requests the following additional information:

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.