ML081900514

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

ML081900514
Person / Time
Site:	Fermi
Issue date:	07/11/2008
From:	Justin Poole NRC/NRR/ADRO/DORL/LPLIII-1
To:	Jennifer Davis Detroit Edison
Justin Poole, LPL3-1, 415-2048
References
TAC MD7600
Download: ML081900514 (7)

Text

July 11, 2008 Mr. Jack M. Davis Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

FERMI 2 - REQUEST FOR ADDITIONAL INFORMATION RE: SECURITY BULLETIN 2007-01 (TAC NO. MD7600)

Dear Mr. Davis,

By letter dated February 11, 2008, Detroit Edison Company (the licensee) submitted the required written response to Security Bulletin 2007-01 Security Officer Attentiveness for the Fermi 2 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 your submittal and has determined that additional information is needed to complete the final NRC staff assessment of the licensees 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 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.

J. M. Davis 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 question, please contact me at 301-415-2048.

Sincerely,

/RA/

Justin Poole, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosure:

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

J. M. Davis 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 question, please contact me at 301-415-2048.

Sincerely,

/RA/

Justin Poole, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosure:

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

PUBLIC LPL3-1 r/f RidsNrrDorlLpl3-1 RidsRgn3MailCenter RidsNrrDorlDpr RidsNrrLABTully MBanic, NRR/DPR RidsNrrPMFermi2 RidsOgcRp LRegner, NRR/DORL FPeduzzi, NSIR RidsAcrsAcnw&mMailCenter RCorreia, NSIR ADAMS Accession Number: ML081900514 *Per email dated June 30, 2008 OFFICE LPL3-1/PM LPL3-1/LA NSIR/DSO LPL3-1/BC GWest for NAME JPoole BTully RCorreia*

LJames DATE 07/10/08 07/10/08 06/30/08 07/11/08 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION REVIEW OF SECURITY BULLETIN RESPONSES SUBMITTED IN RESPONSE TO SECURITY BULLETIN 2007-01 FERMI 2 DOCKET NO. 50-341 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 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 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 the 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 the 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 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:

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.

Fermi 2 cc:

David G. Pettinari Legal Department Mr. Joseph H. Plona 688 WCB Vice President - Nuclear Generation Detroit Edison Company Detroit Edison Company 2000 2nd Avenue Fermi 2 - 210 NOC Detroit, MI 48226-1279 6400 North Dixie Highway Newport, MI 48166 Michigan Department of Environmental Quality Waste and Hazardous Materials Division Radiological Protection Section Radiological Assessment Unit Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741 U.S. Nuclear Regulatory Commission Resident Inspector's Office 6450 N Dixie Highway Newport, MI 48166 Mr. M. V. Yudasz, Jr., Director Monroe County Emergency Management Division 965 South Raisinville Road Monroe, MI 48161 Ronald W. Gaston Manager, Nuclear Licensing Detroit Edison Company Fermi 2 - 200 TAC 6400 North Dixie Highway Newport, MI 48166 Supervisor - Electric Operators Michigan Public Service Commission P.O. Box 30221 June 18, 2008 Lansing, MI 48909 Wayne County Emergency Management Division 10250 Middlebelt Road Detroit, MI 48242