ML081850030

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

ML081850030
Person / Time
Site:	Diablo Canyon
Issue date:	07/10/2008
From:	Wang A NRC/NRR/ADRO/DORL/LPLIV
To:	Conway J Pacific Gas & Electric Co
Wang, A B, NRR/DORL/LPLIV, 415-1445
References
BL-07-001, TAC MD7593, TAC MD7594
Download: ML081850030 (7)

Text

July 10, 2008 Mr. John Conway Senior Vice President - Station Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 770000 San Francisco, CA 94177-0001

SUBJECT:

DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO NRC BULLETIN 2007-01, SECURITY OFFICER ATTENTIVENESS (TAC NOS. MD7593 AND MD7594)

Dear Mr. Conway,

By letter dated February 11, 2008, Pacific Gas and Electric Company (PG&E, the licensee) submitted the required written response to U.S. Nuclear Regulatory Commission (NRC) Bulletin 2007-01 Security Officer Attentiveness for the Diablo Canyon Power Plant, Unit Nos. 1 and 2.

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 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

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. Conway If you have any question, please contact me at 301-415-1445.

Sincerely,

/RA Jack Donohew for/

Alan Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosure:

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

J. Conway If you have any question, please contact me at 301-415-1445.

Sincerely,

/RA Jack Donohew for/

Alan Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosure:

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

PUBLIC RidsRgn4MailCenter Resource LPLIV Reading LRegner, NRR/DORL/TA RidsAcrsAcnw_MailCTR Resource MBanic, NRR/DPR/PGCB RidsNrrDorlLpl4 Resource FPeduzzi, NSIR/DSO RidsNrrLAGLappert Resource RCorreia, NSIR/DSO RidsNrrPMAWang Resource GWest, NSIR/DSO RidsOgcRp Resource DHuyck, NSIR/DSP ADAMS Accession Number: ML081850030 NSIR e-mail Package ML081820158 OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC (A) NRR/LPL4/PM NAME AWang GLappert BSingal AWang JNW for DATE 7/9/08 7/8/08 7/10/08 7/10/08 OFFICIAL RECORD COPY

Diablo Canyon Power Plant, Units 1 and 2 (3/10/2008 2007) cc:

NRC Resident Inspector Regional Administrator, Region IV Diablo Canyon Power Plant U.S. Nuclear Regulatory Commission c/o U.S. Nuclear Regulatory Commission 612 E.Lamar Blvd., Suite 400 P.O. Box 369 Arlington, TX 76011-41254 Avila Beach, CA 93424 Jennifer Post, Esq.

Sierra Club San Lucia Chapter Pacific Gas & Electric Company ATTN: Andrew Christie P.O. Box 7442 P.O. Box 15755 San Francisco, CA 94120 San Luis Obispo, CA 93406 City Editor Ms. Nancy Culver The Tribune San Luis Obispo 3825 South Higuera Street Mothers for Peace P.O. Box 112 P.O. Box 164 San Luis, Obispo, CA 94306-0112 Pismo Beach, CA 93448 Director, Radiologic Health Branch Chairman State Department of Health Services San Luis Obispo County P.O. Box 997414, MS 7610 Board of Supervisors Sacramento, CA 95899-7414 1055 Monterey Street, Suite D430 San Luis Obispo, CA 93408 Mr. James Boyd, Commissioner California Energy Commission Mr. Truman Burns 1516 Ninth Street MS (31)

Mr. Robert Kinosian Sacramento, CA 95831 California Public Utilities Commission 505 Van Ness, Room 4102 Mr. James R. Becker San Francisco, CA 94102 Site Vice President Diablo Canyon Power Plant Diablo Canyon Independent Safety P.O. Box 56 Committee Avila Beach, CA 93424 Attn: Robert R. Wellington, Esq.

Legal Counsel Jennifer Tang 857 Cass Street, Suite D Field Representative Monterey, CA 93940 United States Senator Barbara Boxer 1700 Montgomery Street, Suite 240 San Francisco, CA 94111

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION RELATED TO NRC BULLETIN 2007-01, SECURITY OFFICER ATTENTIVENESS PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-275 AND 50-323 By letter dated February 11, 2008, Pacific Gas and Electric Company (PG&E, the licensee) submitted the required written response to Security Bulletin 2007-01 Security Officer Attentiveness for the Diablo Canyon Power Plants, Unit Nos. 1 and 2. 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. 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 U.S. Nuclear Regulatory Commission (NRC) staff reviewed your response to Question 1 and requests the following additional information:

1. 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 1a and requests the following additional information:

2. 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:

3. 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.

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

4. 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 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.