NL-08-029, Transmittal of Indian Point, Unit 1, 2 and 3, Response to NRC Bulletin 2007-01, Security Officer Attentiveness.

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Transmittal of Indian Point, Unit 1, 2 and 3, Response to NRC Bulletin 2007-01, Security Officer Attentiveness.
ML080510585
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 02/11/2008
From: Joseph E Pollock
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-07-001, NL-08-029
Download: ML080510585 (2)


Text

WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Enf01 Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 J.E. Pollock Site Vice President Administration February 11, 2008 Indian Point Units 1, 2 and 3 Docket Nos. 50-3, 50-247, and 50-286 NL-08-029 U. S. Nuclear Regulatory Commission Attn: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

Response to NRC Bulletin 2007-01, Security Officer Attentiveness

Dear Sir or Madam:

On December 12, 2007, the NRC issued Bulletin 2007-01, Security Officer Attentiveness, and requested a response within 60 days. Attached is Entergy Nuclear Operations, Inc. (Entergy) response for Indian Point Entergy Center (IPEC) to NRC Bulletin 2007-01 which requested information about security program administrative and managerial controls established to prevent, identify, and correct security personnel inattentiveness, complicity, and failures of individuals to implement the Behavioral Observation Program (BOP). Attachment 1 to this letter provides the response to the questions included in the bulletin.

Entergy appreciates the staff's recognition that most sites have not had occurrences of the examples cited in the bulletin of inappropriate security conduct or complicity.

However, the existence of multiple, overlapping, and complementary reporting, self-reporting, and oversight programs does not and cannot guarantee such human events would never happen in the future. In the post-September 11, 2001, security environment, significant increases in security force membership and deployment to increased numbers of fixed security posts statistically increased the potential and probability for inattentiveness. The limited number of occurrences demonstrates that the required high assurance of adequate protection of public safety is still provided.

Although the increase in occurrences across the nation in the post-September 11, 2001, environment, when taken holistically, may indicate a negative trend, it presents an opportunity to proactively strengthen administrative and managerial controls in order to WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Attachment 1 contains Security Related Information withheld from public disclosure under 10 CFR 2.390. When separated from this Attachment, this letter becomes decontrolled.

WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Docket Nos. 50-3, 50-247, and 50-286 NL-08-029 Page 2 of 2 minimize the potential for future occurrences. Where problems are identified through industry experience, they are evaluated, and actions are taken to prevent recurrence, not only at the sites where they are discovered, but also proactively at other sites (within a fleet and/or throughout the industry) when they are applicable.

Station management remains vigilant to reinforce expectations for procedural compliance and reporting in order to deter and detect hidden deliberate misconduct and complicity.

Because this response contains security-related information, Entergy requests that the attachment to this letter be withheld from public disclosure in accordance with 10CFR2.390. There are no new commitments identified in this submittal. If you have any questions or require additional information, please contact Mr. R Walpole at (914) 734-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February IL_, 2008.

Sincerely, J. E. Pollock Site Vice President Indian Point Energy Center

Attachment:

1. IPEC RESPONSE TO SPECIFIC QUESTIONS IN NRC BULLETIN 2007-01:

SECURITY OFFICER ATTENTIVENESS cc: Mr. Samuel J. Collins, Regional Administrator, Region I Mr. John Boska, NRR Senior Project Manager IPEC NRC Resident Inspector's Office WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Attachment 1 contains Security Related Information withheld from public disclosure under 10 CFR 2.390. When separated from this Attachment, this letter becomes decontrolled.

Text

WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Enf01 Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 J.E. Pollock Site Vice President Administration February 11, 2008 Indian Point Units 1, 2 and 3 Docket Nos. 50-3, 50-247, and 50-286 NL-08-029 U. S. Nuclear Regulatory Commission Attn: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

Response to NRC Bulletin 2007-01, Security Officer Attentiveness

Dear Sir or Madam:

On December 12, 2007, the NRC issued Bulletin 2007-01, Security Officer Attentiveness, and requested a response within 60 days. Attached is Entergy Nuclear Operations, Inc. (Entergy) response for Indian Point Entergy Center (IPEC) to NRC Bulletin 2007-01 which requested information about security program administrative and managerial controls established to prevent, identify, and correct security personnel inattentiveness, complicity, and failures of individuals to implement the Behavioral Observation Program (BOP). Attachment 1 to this letter provides the response to the questions included in the bulletin.

Entergy appreciates the staff's recognition that most sites have not had occurrences of the examples cited in the bulletin of inappropriate security conduct or complicity.

However, the existence of multiple, overlapping, and complementary reporting, self-reporting, and oversight programs does not and cannot guarantee such human events would never happen in the future. In the post-September 11, 2001, security environment, significant increases in security force membership and deployment to increased numbers of fixed security posts statistically increased the potential and probability for inattentiveness. The limited number of occurrences demonstrates that the required high assurance of adequate protection of public safety is still provided.

Although the increase in occurrences across the nation in the post-September 11, 2001, environment, when taken holistically, may indicate a negative trend, it presents an opportunity to proactively strengthen administrative and managerial controls in order to WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Attachment 1 contains Security Related Information withheld from public disclosure under 10 CFR 2.390. When separated from this Attachment, this letter becomes decontrolled.

WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Docket Nos. 50-3, 50-247, and 50-286 NL-08-029 Page 2 of 2 minimize the potential for future occurrences. Where problems are identified through industry experience, they are evaluated, and actions are taken to prevent recurrence, not only at the sites where they are discovered, but also proactively at other sites (within a fleet and/or throughout the industry) when they are applicable.

Station management remains vigilant to reinforce expectations for procedural compliance and reporting in order to deter and detect hidden deliberate misconduct and complicity.

Because this response contains security-related information, Entergy requests that the attachment to this letter be withheld from public disclosure in accordance with 10CFR2.390. There are no new commitments identified in this submittal. If you have any questions or require additional information, please contact Mr. R Walpole at (914) 734-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February IL_, 2008.

Sincerely, J. E. Pollock Site Vice President Indian Point Energy Center

Attachment:

1. IPEC RESPONSE TO SPECIFIC QUESTIONS IN NRC BULLETIN 2007-01:

SECURITY OFFICER ATTENTIVENESS cc: Mr. Samuel J. Collins, Regional Administrator, Region I Mr. John Boska, NRR Senior Project Manager IPEC NRC Resident Inspector's Office WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Attachment 1 contains Security Related Information withheld from public disclosure under 10 CFR 2.390. When separated from this Attachment, this letter becomes decontrolled.