View source for RA-08-068, Amergen Energy Company, LLC, Response to the Request for Additional Information Regarding Resolution of NRC Bulletin 2007-01, Security Officer Attentiveness.

{{Adams
| number = ML082140867
| issue date = 08/01/2008
| title = Amergen Energy Company, LLC, Response to the Request for Additional Information Regarding Resolution of NRC Bulletin 2007-01, Security Officer Attentiveness.
| author name = Jury K
| author affiliation = AmerGen Energy Co, LLC, Exelon Generation Co, LLC, Exelon Nuclear
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000219, 05000237, 05000249, 05000254, 05000265, 05000277, 05000278, 05000289, 05000352, 05000353, 05000373, 05000374, 05000454, 05000455, 05000456, 05000457, 05000461
| license number = DPR-016, DPR-019, DPR-025, DPR-029, DPR-030, DPR-044, DPR-050, DPR-056, NPF-011, NPF-018, NPF-037, NPF-039, NPF-062, NPF-066, NPF-072, NPF-077, NPF-085
| contact person = 
| case reference number = 5928-08-20146, BL-07-001, RA-08-068, RS-08-089, TAC MD7570, TAC MD7571, TAC MD7577, TAC MD7578, TAC MD7584, TAC MD7595, TAC MD7596, TAC MD7612, TAC MD7613, TAC MD7614, TAC MD7615, TAC MD7628, TAC MD7633, TAC MD7634, TAC MD7641, TAC MD7642, TAC MD7661
| document type = Letter type:RA
| page count = 16
| project = TAC:MD7570, TAC:MD7571, TAC:MD7577, TAC:MD7578, TAC:MD7584, TAC:MD7595, TAC:MD7596, TAC:MD7612, TAC:MD7613, TAC:MD7614, TAC:MD7615, TAC:MD7628, TAC:MD7633, TAC:MD7634, TAC:MD7641, TAC:MD7642, TAC:MD7661
| stage = Request
}}

=Text=
{{#Wiki_filter:An Exelon Company erG                   .                                     Exelt5n..
Nuclear wwwexeloncorp .com AmerGen Energy Company, LLC 4300 VVinfleld Road                                                                   Exelon Generation Warrenville, I!_ 60555                                                               4300 W9nfield Road Warrenviile, IL 6o555 10 CFR 50 .54(f)
RS-08-089 RA-08-068 5928-08-20146 August 1, 2008 U . S. Nuclear Regulatory Commission ATTN : Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos_ TN 50-454 and STN 50-455 Clinton Power Station, Unit 1 Facility Operating License No . NPF-62 NRC Docket No_ 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos . 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Facility Operating License Nos . NPF-11 and NPF-18 NRC Docket Nos STN 50-373 and STN 50-374 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos 50-352 and 50-35.3 Oyster Creek Nuclear Generating Station Facility Operating License No . DPR-16 NRC Docket No . 50-219

U. S. Nuclear Regulatory Commission August 1, 2008 Page 2 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos . DPR-44 and DPR-56 NRC Docket Nos . 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos . DPR-29 and DPR-30 NRC Docket Nos 50-254 and 50-265 Three Mile Island Nuclear Station, Unit 1 Facility Operating License No. DPR-50 NRC Docket No-50-289

==Subject:==
Response to the Request for Additional Information Regarding Resolution of NRC Bulletin 2007-01, "Security Officer Attentiveness"

==References:==
1 . NRC Bulletin 2007-01, "Security Officer Attentiveness," dated December 12, 2007 2 . Letter from Charles G. Pardee (Exelon Generation Company, LLC/AmerGen Energy Company, LLC) to U. S. NRC, "Exelon Generation Company, LLC/AmerGen Energy Company, LLC, 60-Day Response to NRC Bulletin 2007-01, 'Security Officer Attentiveness,"' dated February 11, 2008
: 3. Letter from C. Gratton (U .S . NRC) to Addressees : Request for Additional Information RE: (TAC NOS. MD7570, MD 7571, MD7577, MD7578, MD7584, MD7595, MD7596, MD7612, MD7613, MD7614, MD7615, MD7628, MD7633, MD7634, MD7641, MD7642, and MD7661), dated June 27, 2008 On December 12, 2007, the NRC issued Bulletin 2007-01, "Security Officer Attentiveness,"
(Reference 1) . The Bulletin requested that all holders of operating licenses submit a written response within 60 days in accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (f). The Bulletin requested information to determine the status of licensee programs regarding the adequate and consistent implementation of their security programs in light of recent security-based incidents at certain sites.
Reference 2 provided the Exelon Generation Company, LLC (Exelon) and AmerGen Energy Company, LLC (AmerGen) 60-day response to the requested information for Braidwood Station, Byron Station, Clinton Power Station, Dresden Nuclear Power Station, LaSalle County Station, Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, Quad Cities Nuclear Power Station, and Three Mile Island Nuclear Station Unit 1 .
In Reference 3, the NRC requested additional information to complete its review of the Exelon/AmerGen response to NRC Bulletin 2007-01 .

U. S. Nuclear Regulatory Commission August 1, 2008 Page 3 The enclosure to this letter provides the Exelon/AmerGen 35-day response to the requested information .
There are no regulatory commitments contained in this letter . Should you have any questions concerning this letter, please contact Mr. Frank Mascitelli at (610) 765-5512 .
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1 St day of August, 2008 .
Respectfully, Keith R. Jury Vice President, Licensing and Regulatory Affairs Exelon Generation Company, LLC AmerGen Energy Company, LLC Enclosure :    35-Day Response to NRC Bulletin 2007-01 RAI-Braidwood Station, Byron Station, Clinton Power Station, Dresden Nuclear Power Station, LaSalle County Station, Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, Quad Cities Nuclear Power Station, and Three Mile Island Nuclear Station, Unit 1 .
cc:     Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Braidwood Station NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station

U. S. Nuclear Regulatory Commission August 1, 2008 Page 4 cc (cont'd) :
NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 TMI File No. 08011 Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA Mayor of Lacey Township, Forked River, NJ S . T. Gray, State of Maryland R. R. Janati, Commonwealth of Pennsylvania

Response to Request for Additional Information                                              Enclosure Re: NRC Bulletin 2007-01                                                                  Page 1 of 12 August 1, 2008 C11 RTION 1 The NRC staff reviewed your response to Question 1 a and requests the following additional information:
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.) .
RF~E Exelon Generation Company, LLC (Exelon) and AmerGen Energy Company, LLC (AmerGen) have procedural guidance associated with watch-standing practices, which define various types of security posts and post rotation periodicity requirements . Security Officers assume a variety of posts during a normal shift including: fixed posts, non-fixed posts, staging area posts, as well as compensatory posts, if warranted. Security Officers routinely rotate between fixed and non-fixed posts, staging areas, and high-risk post locations as part of their normal daily assigned duties .
A fixed post is defined as a defensive post used by Security and integrated into the station security contingency plan . Fixed posts include Bullet Resistant Enclosures (BREs), some rooftop positions, and posts with specific special functions. Non-fixed posts are posts that are not continuously manned or are mobile and integrated into the station security contingency plan . A non-fixed post includes Bullet Resistant Canisters (BRCs), improved fighting positions, and vehicular and roving patrols. Staging area posts are designated areas (e.g ., ready rooms, as applicable), from which Security Officers respond in the event of a contingency response to a non-fixed post, which may include a BRC, improved fighting position, or roof-top position.
Compensatory posts are planned or unplanned and are created to ensure the effectiveness of the physical security system remains equal to, or greater than, the level prior to a loss or degradation of a physical security system.
Procedure requirements are also in place that address posts that pose a high risk for inattentiveness, such as the Vehicle Barrier System (VBS) Check-point, VBS Check-point Over-Watch and Protected Area Access posts during low periods of activity and any isolated low activity security posts. Planned or unplanned compensatory measures are also identified as high-risk posts .

Response to Request for Additional Information                                               Enclosure Re: NRC Bulletin 2007-01                                                                   Page 2 of 12 August 1, 2008 Exelon/AmerGen takes into consideration the types of posts that Security Officers are rotated through when establishing the original post rotation schedules. Consideration for types of posts is factored into developing post rotational assignments. Frequent post rotations allow for the Security Officers to be exposed to a variety of external stimuli and promote attentiveness.
Every effort is made to ensure Security Officers are rotated to a different position at the required periodicity.
Security Supervision is required in accordance with Exelon/AmerGen procedure SY-AA-1016, "Watch-Standing Practices and Communications," to rotate personnel at posts where there is a high risk for inattentiveness about every hour and at other posts about every two hours. The high-risk security posts are defined above .
Security Supervision also has post rotation periodicity requirements . Security Supervisors typically rotate among the following post locations as part of their normal daily assigned duties :
Central Alarm Station (CAS), Secondary Alarm Station (SAS), and Field Supervisor or Response Team Leader (RTL) positions. Security Supervision is procedurally required in accordance with Exelon/AmerGen procedure SY-AA-1020, "Supervisor Post Checks and Post Orders," to rotate among the above-mentioned security supervisory positions at a nominal frequency of once every six hours .
Deviations of rotation frequency must be approved by the Manager-Site Security, or designee.
For short-term issues, deviations will be approved on a case-by-case basis . For long-term issues (e.g ., site layout, or conflicting site-specific strategy) deviations will be approved in a station-specific written communication . Any deviation to recommended frequency rotations also needs to be accompanied by an analysis of additional actions to be taken (if any) to restore the attentiveness margin .
OLESTION 2 The NRC staff reviewed your response to Question 1b and requests the following additional information :
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 responses:
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 .

Response to Request for Additional Information                                          Enclosure Re: NRC Bulletin 2007-01                                                              Page 3 of 12 August 1, 2008 R SPONS Security equipment issues are procedurally required to be identified in the Corrective Action Program (CAP) and prioritized through the normal work management and maintenance processes . Site personnel (including Security personnel) are encouraged to initiate and document security issues in the CAP in accordance with Exelon/AmerGen procedures LS-AA-120, "Issue Identification and Screening Process," and LS-AA-125, "Corrective Action Program (CAP) Procedure ." Issues requiring physical repair work are prioritized in accordance with Exelon/AmerGen procedure WC-AA-106,"Work Screening and Processing ." If the issue is classified as facility and minor maintenance, the repair is performed in accordance with Exelon/AmerGen procedures, MA-AA-716-002, "Facilities Maintenance Process," and MA-AA-716-003, "Tool Pouch/Minor Maintenance," or contractor procedures and processes .
Originators of issues can track the resolution and progress of follow-up corrective actions by inputting the CAP issue report number into the CAP computer program . The program identifies descriptions of corrective actions and their respective status .
Security equipment issues, including Heating, Ventilation and Air Conditioning (HVAC), are identified by Security Supervisors and/or Officers during routine post inspections performed in accordance with Exelon/AmerGen procedure SY-AA-1020, "Supervisor Post Checks and Post Orders ." Security post equipment deficiencies identified by Security Supervisors, as well as by Security Officers during performance of routine post inspections (Exelon/AmerGen procedure SY-AA-1020-F-01/04), BRE quarterly material condition checklist (Exelon/AmerGen procedure SY-AA-1020-F-03), and ready room material condition checklist (Exelon/AmerGen procedure SY-AA-1020-F-05), are documented in CAP, as necessary.
Selected security equipment has been entered into the Preventive Maintenance (PM) program.
PM templates have been developed for ten equipment groups, one of which is for BREs .
Typical PM activities range from cleaning of HVAC intake grill and air filters to BRE tower weld inspections.
Security equipment repairs receive the appropriate priority and timely repair schedule commensurate with the criticality of implementing the Security Plan . Issues that require physical repair work are entered into the work management system. As part of the process, the Work Management Screening Committee performs a daily review of emergent security, fire protection and safety Work Requests/Action Requests with the assistance of the Site Security representative, Fire Protection representative, and Industrial Safety representative to ensure the integrated impact of current outstanding work does not compromise site security, fire protection, or industrial safety (including OSHA compliance review) . Work is prioritized as needed to bring equipment status up to a level acceptable to the Site Security representative and the Engineering representative for Fire Protection systems/Fire Marshal.
Corrective maintenance of climate-controlled areas (BREs, guard enclosures, etc.) is performed by various maintenance groups depending on the complexity of the required maintenance task.
Maintenance has Instrument & Controls personnel specifically trained to perform maintenance on selected security equipment and systems. The Maintenance Department's Fix-It-Now (FIN) team performs some maintenance depending on the nature and urgency of work . In addition to the normal maintenance and work management process initiated through the CAP process,

Response to Request for Additional Information                                             Enclosure Re: NRC Bulletin 2007-01                                                                 Page 4 of 12 August 1, 2008 maintenance may be performed on BREs by Facilities Maintenance personnel and EMCOR personnel (i .e., facility maintenance contractor) . The BREs are cleaned and maintained by Facilities Maintenance personnel.
Preventive maintenance is performed on selected security equipment. There is a preventive maintenance program for climate-controlled areas (e.g., BREs). There is a condition-monitoring task to assess habitability of the BREs that is scheduled to occur on a routine basis .
There are several BRE time-directed tasks including: cleaning HVAC intake grill/filters ;
Uninterruptible Power Supply battery checks; access door, gun port and floor hatch hinge and lock inspections; HVAC annual service; and tower/BRE weld inspections.
Security corrective and preventive maintenance is normally scheduled and worked the same as routine and emergent plant maintenance with the exception of work that requires specific qualifications to repair . Security equipment maintenance is prioritized in accordance with Exelon/AmerGen procedure WC-AA-106 or contractor procedures and processes as applicable .
In addition, a Security Plan-of-the-Day (POD) report is presented on a monthly basis, in a POD meeting attended by senior site management . The report contains a status of the following:
total equipment issues, security system deficiencies requiring compensatory measures, security equipment in degraded status, CAS/SAS distractions/inoperative alarms, security officer workarounds/challenges, and security top priorities . This ensures proper management attention and timely resolution of security equipment issues .
O 1 STION 2 The NRC staff reviewed your response to Question 1c and requests the following additional information :
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.

===RESPONSE===
As a requirement for individuals with Unescorted Access Authorization (UAA), a behavioral observation program is outlined in Exelon/AmerGen procedure SY-AA-103-513, "Behavior

Response to Request for Additional Information                                             Enclosure Re: NRC Bulletin 2007-01                                                                  Page 5 of 12 August 1, 2008 Observation Program." This program provides information and guidance for individuals who are required to participate in a Behavioral Observation Program (BOP) . The BOP is the primary means for determining continued trustworthiness and reliability of individuals with UAA. The objective of the BOP is to detect illegal drug use, alcohol/legal drug abuse and other behaviors such as fatigue and physical or mental illness that may constitute an unreasonable risk to the health and safety of the public, including a potential threat to commit radiological sabotage .
This program is applicable to individuals with UAA and individuals granted Unescorted Access (UA) to Exelon/AmerGen Power Stations . Individuals are responsible for reporting any observed behavior indicating degradation in performance, impairment or change in behavior to a supervisor .
Supervisory personnel are responsible for familiarizing themselves with each employee's behavior patterns in order to enable the supervisor to recognize when an employee is exhibiting unusual or aberrant behavioral traits and patterns that may reflect adversely on their trustworthiness or reliability and constitute an unreasonable risk to the health and safety of the public .
Management personnel are responsible for observing personnel for behavior traits and patterns that may reflect adversely on their trustworthiness or reliability, being aware of behaviors that might be adverse to safe operation, and reporting those observations to the cognizant Department Head and Security . These requirements are also provided and tested in initial and annual Nuclear General Employee Training (NGET) .
Exelon/AmerGen management personnel, who do not have direct responsibility for the security program, are involved in conducting behavior observations of security personnel . The number, frequency and randomness of observations are not procedurally controlled, but are driven by site senior management expectations .
The fleet-wide response (i .e., Nuclear Event Report NC-07-034) to the Peach Bottom Atomic Power Station Security Inattentiveness issue included the following non-security management observations :
Exelon management conducted a once per week backshift visit to ready rooms and daily visits (i.e., during the work week and when on site during the weekend) to ready rooms . If no ready rooms were on site, then high-risk posts were visited randomly. Each of these visits was recorded .
The site Plant Manager and Site Vice President visited the SAS and CAS once per month . Each of these visits was recorded and given to the Manager-Site Security .
Also, the site Plant Manager and Site Vice President visited one security turnover briefing per month .
Each security member listed by title on the duty team as defined in Exelon/AmerGen procedure SY-AA-101-126, "Duties and Responsibilities of the Station Security Organization," performed two paired observations with site operations (i.e., Senior

Response to Request for Additional Information                                              Enclosure Re: NRC Bulletin 2007-01                                                                  Page 6 of 12 August 1, 2008 Reactor Operator or above) focusing on site operations standards. Any members of the duty team who were previously in operations in the last two years were excluded from this action .
Typically, site management observations of security are made and documented (e.g., via Exelon/AmerGen procedure SY-AA-1020-F-04) and include assessing Security Officers to ensure they are Fit-For-Duty (e.g ., alert, attentive) . Typically, the observations include, but are not limited to, the following attributes : assessing use of authorized attentiveness aids, assessing proper weapons controls, soliciting insights from Security Officers with regard to Safety Conscious Work Environment, knowledge of external organizations to raise concerns, and use of the CAP.
In addition to management observations, two organizations, Nuclear Oversight (NOS) and the Nuclear Safety Review Board (NSRB), provide additional oversight and observations of the security organization . Descriptions of the types of observations and assessments performed by NOS and NSRB are provided in response to Question 6 below.
0 1 STION 4 The NRC staff reviewed your response to Question 1 and requests the following additional information :
How is the licensee's policy regarding site employee attentiveness and/or inattentiveness communicated to personnel, both licensee and contractor, and at what frequency?
R SPONS The Exelon/AmerGen policy regarding site employee attentiveness and/or inattentiveness is communicated and contained within the publication titled "Employee Standards of Conduct." In addition, the "Employee Standards of Conduct" is issued to Security Officers upon date of hire .
Security Officers were issued the code of conduct as part of the Wackenhut to Exelon/AmerGen employee transition. With regard to attentiveness, the code of conduct details the requisite disciplinary action associated with "sleeping during work time or giving the appearance of sleeping during work time," as warranted .
For contractors, the Exelon/AmerGen policy regarding attentiveness and/or inattentiveness is communicated during NGET, which is required for contractors who are granted unescorted access authorization.
Exelon/AmerGen communicates and reinforces expectations on being attentive to duty through a number of other methods. Ongoing communication with regard to remaining Fit-For-Duty and maintaining attentiveness is reinforced during each Security Officer's assigned duty shift per Exelon/AmerGen standards for watch-standing practices, which are contained within existing security procedures . Additionally, observations of Security Officers throughout their normal duty shift are also performed by security supervision and are institutionalized within Exelon/AmerGen procedures .

Response to Request for Additional Information                                                  Enclosure Re: NRC Bulletin 2007-01                                                                      Page 7 of 12 August 1, 2008 Security Supervision ensures Security Officers are Fit-For-Duty, including being attentive at the onset of each duty shift. Exelon/AmerGen procedure SY-AA-101-126-1001-F-02, "Nuclear Security Shift Turnover," provides the basis for making this determination . Questions pertaining to whether a Security Officer is taking prescription medications or over-the-counter medications, or has been under the influence of alcohol within the past five hours are asked of each individual . Security Officers are also questioned as to whether they were involved in any illegal activities that need to be reported to supervision. Security Officers are given the opportunity to self-declare fatigue, with no adverse impact, if they feel that during the conduct of shift duties, they are in danger of becoming less than alert. If a self-declaration is made, Security Supervision is notified, actions are taken to provide relief, and an assessment is conducted to determine further actions required .
Additionally, each Security Officer is required to follow Exelon/AmerGen procedure SY-AA-101-126-1001-F-01, "Requirements for Assuming Duty." Each individual must assert the following prior to assuming duty :
              "I am fit-for-duty and will report to my supervisor if I begin to feel unfit for duty .
My qualifications are current for the duty period for which I am about to perform .
I am not the subject of any legal process that might affect my ability to carry a weapon (e.g ., misdemeanor crime of domestic violence or under domestic restraining order) .
I have reported all arrests, criminal charges, convictions, or legal proceedings.
Since my last company physical, I have had no unevaluated change in medical, including eyesight .
I have a valid driver's license.
I have in my possession all valid licenses required for my state.
I have in my possession a second pair of eyeglasses (if required) ."
These requirements are also displayed for each Security Officer to read and understand during shift turnover activities .
Communication on maintaining attentiveness with Security Officers is exhibited during Supervisor observations performed during post inspections. Exelon/AmerGen procedure SY-AA-1020, "Supervisor Post Checks and Post Orders," defines the required periodicity of post rotations and the guidelines for conducting post inspections.
On-shift or staff Security Supervisors are required to perform post inspections at least two times per shift for non-compensatory and compensatory posts. Exelon/AmerGen procedure SY-AA-1020-F-04, "Post Inspection Form," is used to document these inspections. As part of these routine inspections, Security Supervisors monitor each Security Officer for signs of fatigue or other signs of inattentiveness . Security Supervisors reinforce post requirements including maintaining attentiveness at all times. Security Supervisors also monitor and assess the environmental conditions of the post during post inspections (e.g ., heat, lighting, ventilation, noise) as well as human factors (e .g., distractions, breaks, supervisor interface) . If deemed necessary, Security Supervision will initiate appropriate corrective actions (e.g ., increased post rotation frequency, increased radio check frequency, increased break frequency, etc.), to ensure Security Officers remain attentive to duty.

Response to Request for Additional Information                                              Enclosure Re: NRC Bulletin 2007-01                                                                  Page 8 of 12 August 1, 2008 Security Supervision also performs routine communication checks to verify each Security Officer's alertness and attentiveness . These random communication checks are at a frequency not to exceed a nominal hourly rate during periods of high traffic (e.g., day shift or outage) and at a nominal 30-minute rate during periods of low activity (e .g., night shifts or weekends) .
Exelon/AmerGen has also conducted an evaluation of post assignments and has established a list of authorized attentiveness aids as identified in procedure SY-AA-1016, "Watch-Standing Practices and Communications ." The use of these authorized attentiveness aids is continually reinforced with Security Officers as another means of maintaining alertness in performance of assigned duties .
QUESTION 5 The NRC staff reviewed your response to Question 2 and requests the following additional information:
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 responses :
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 the report 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.

===RESPONSE===
Employees can file CAP reports without prior supervisory/management review or approval .
Supervisors/Managers do not have the authority to reject a report before the report is entered into the corrective action program . Exelon/AmerGen personnel and contractors at Exelon/AmerGen facilities are expected to identify and document equipment issues per procedure LS-AA-120, "Issue Identification and Screening Process," into the CAP as Issue Reports (IRs) . The originators of IRs are expected to identify conditions that have or could have an undesirable effect on performance of equipment, programs, or organizations and ensure that necessary immediate actions to place the situation in a safe and stable condition are completed or initiated as appropriate. The originators are expected to verbally communicate the condition to a supervisor, or the Control Room, when appropriate, including communication of immediate corrective actions taken . When entering an issue into the CAP computer program (i .e ., Passport) originators are expected to ensure that the issue is properly documented, with required information and fields populated in Passport. The originator is expected to identify opportunities for improvement and commendable behaviors. If the originator does not have immediate access to a computer terminal, a hardcopy form can be initiated and given to their supervisor or any individual with a user identification . The supervisor

Response to Request for Additional Information                                              Enclosure Re: NRC Bulletin 2007-01                                                                  Page 9 of 12 August 1, 2008 or individual with a user identification are expected to ensure the data is appropriately entered into CAP.
As part of the security transition from Wackenhut contractors to Exelon/AmerGen employees, security employees are being given a unique user identification to enable security employees to access available computers for directly inputting issues into the CAP via the Passport computer program. Individuals with a user identification can directly input issues into CAP, without any supervisor input, by accessing the Exelon/AmerGen issues Initiation Website and inputting their user identification and affected facility . However, one of the required computer fields necessary for an IR to be electronically generated is for the originator to fill in the name of the supervisor that was verbally contacted. Once the computer program electronically generates the IR, the issue description cannot be revised by the originator or their supervisor .
011ESTION 6 The NRC staff reviewed your response to Question 4 and requests the following additional information:
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.

===RESPONSE===
Exelon/AmerGen conducts independent audits of the security program in accordance with the Exelon/AmerGen Quality Assurance Topical Report . These audits are performed by NOS on an annual basis. NOS is organizationally independent from site management and reports to the corporate organization . These audits are performed at times (as needed) with the assistance of non-Exelon security technical specialists. The audits are conducted at each Exelon/AmerGen site and at the corporate facilities, typically over a four-week period during the first quarter of every year . There are three audit teams, each comprised of nominally five members, some with an additional technical security specialist .
The core groups of auditors are experienced in auditing physical security, including Design Basis Threat strategies, Fitness-for-Duty (FFD), Access Authorization (AA), Personnel Access Data System (PADS), and handling of Safeguards Information (SGI) programs . Each audit is conducted using approximately 25 audit templates to ensure regulatory compliance to 10 CFR and NRC Orders, as well as other requirements . The audit scope includes such topics as :
organization, training and qualifications, compensatory measures, detection and response, PADS, AA, FFD, Protected and Owner Controlled Area controls, drills and exercises, equipment material condition and testing, local law enforcement interface, procedure use and adherence, SGI control, document control, corrective actions, and quality assurance records. NOS, corporate personnel, and station personnel are requested to provide input to the audit scope .
Internal and external operating experience are also reviewed to provide input to the audit scope .

Response to Request for Additional Information                                             Enclosure Re: NRC Bulletin 2007-01                                                                Page 1 0 of 12 August 1, 2008 The audits are also performance based to include observing classroom, firearms range, and force-on-force training ; observing personnel and vehicle searches ; observing vehicle barrier system operations, Security Officer patrol rounds, CAS and SAS command and control, shift turnovers, and arming and disarming activities .
Audit entrance and exit meetings are attended by senior team members of the site (e .g., Site Vice President, Plant Manger, Manager-Site Security, Security Supervision, NOS Manager, and other department representatives as required) or the corporate office being audited . NOS-identified significant issues (i .e., findings), deficiencies, and enhancements are entered into the CAP. Each successive annual audit team reviews the responses to the NOS issues from the previous audit. Certified lead auditors follow up on NOS findings prior to the next audit.
Additionally, the site NOS performance assessment organizations observe security related activities throughout the year and report out to station and NOS senior management semi-annually on the status and performance of the security organizations at each site . NOS issues from the assessment group are entered into the CAP, similar to the audit organization .
Certified lead assessors follow up on NOS findings .
The NSRB also performs independent assessments of the security program . The security organization is assessed by the NSRB Regulatory and Nuclear Oversight Sub-Committee. In addition to the NSRB Sub-Committee Chairperson, who is typically an external consultant, the Regulatory and Nuclear Oversight Sub-Committee typically consists of a peer Regulatory Assurance Manager, peer NOS Manager, and Corporate NOS representative along with the representative site Regulatory Assurance and NOS Managers.
The NSRB members conduct observations of the security program at each site typically three times per year . As part of the assessment process, NSRB members conduct plant walkdowns of select security locations (e.g., staging areas, alarm stations) . Additionally, NSRB members also conduct interviews with Security Officers and members of security management to gain a better understanding of the current status and performance level of the organization, as well as to ascertain any insights or concerns that would warrant management's attention.
The NSRB Sub-Committee also typically reviews security performance indicators and metrics, fleet rankings, human performance issues, safety events, material and equipment condition, implementation of fleet directed actions, status of NRC Orders, and Force-on-Force readiness .
After each assessment, NSRB members conduct detailed debrief meetings with the site senior management team, as well as corporate and executive management . The NSRB draws conclusions based on their observations and insights of the overall program health and effectiveness. Formal meeting minutes document the conclusions of the NSRB. The NSRB-identified significant issues are entered into the CAP for appropriate evaluation and disposition, as warranted .

Response to Request for Additional Information                                               Enclosure Re: NRC Bulletin 2007-01                                                                 Page 11 of 12 August 1, 2008 0tIESTInN 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 responses:
Describe the policy 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 .
RRF~PQNSE Security performs self-assessments in accordance with Exelon/AmerGen procedure LS-AA-126, "Self-Assessment Program ." The assessments consist of either a Focused Area Self-Assessment (FASA) or Check-in Assessment. These assessments are used to assess standards compliance, resolution of performance gaps, industry excellence and change management effectiveness . Corporate and site security develop an assessment schedule which is then approved by senior management and documented in the Passport database .
Security performs approximately five assessments per year.
Security Assessment Team Leaders are selected and receive appropriate orientation from the site/department Self-Assessment Coordinator . The department individual for Security is either the corporate Security Learning Programs Analyst or the site Security Program Lead. The Team Leader develops the assessment plan, which is reviewed and approved by the department management . In addition, the plant Management Review Committee or Self-Assessment Review Board approves pre-NRC/INPO inspection FASA plans.
Upon receiving approval, the assessment is executed per the plan and schedule . After the data collection is completed, the Team Leader prepares the assessment report . Actions associated with the identified standards deficiencies, performance improvement recommendations, and strengths are documented and tracked per Exelon/AmerGen procedures LS-AA-126-1001, "Focused Area Self-Assessments," or LS-AA-126-1005, "Check-In Self-Assessments," as appropriate . There is no formal procedural requirement to communicate all self-assessment results to all members of the assessed department ; however, the FASA and Check-in results are communicated, as appropriate, to senior management, the functional area, the functional area peer group, and others who may benefit from the assessment . FASA and Check-in self-assessment schedules, plans, and reports are tracked, documented and made available through the Passport Action Tracking system .
Nuclear Security follows the procedural requirements of Exelon/AmerGen procedure LS-AA-115, "Operating Experience ." LS-AA-115 provides the process for reviewing and documenting Operating Experience (OE) from both internal and external sources. As identified in LS-AA-115, there is an assigned Exelon/AmerGen fleet OE Coordinator who is the central input for operating experience and vendor technical information. The fleet OE Coordinator is

Response to Request for Additional Information                                           Enclosure Re: NRC Bulletin 2007-01                                                             Page 12 of 12 August 1, 2008 responsible for classification and distribution of incoming OE documents to the Corporate Functional Area Managers and subject matter experts, screening potential Nuclear Event Reports, reviewing completed responses to formal OE reviews, and coordinating the effectiveness assessments and self-assessments of the OE program at each Exelon/AmerGen site.
When an OE item is received within the security organization, it is reviewed for applicability by the appropriate security subject matter expert, who determines whether a corporate security review or single site review is required . This determination is based on the number of sites affected by the OE item . Once the OE item has been determined to be applicable, an OE Action Tracking Item is generated in the Passport computer program to track and document the review. Additional actions are created based on the results of the review .
Security also uses the Homeland Security Information Network (HSIN) for OE items . The HSIN database provides a means for Security throughout the nuclear industry to share OE items .
Users of the database are designated as either "read only" or "data entry." The read only users have access to HSIN, but are unable to enter data . Exelon/AmerGen has two data entry individuals at the corporate level . One individual is the primary and the other a backup . The process for entering data into HSIN is as follows:
The respective site Security subject matter expert provides the write-up on the event to the corporate Security Learning Programs Analyst . The document is then reviewed for accuracy and placed onto the HSIN database .
Periodically, a review of HSIN is performed to obtain OE items from other utilities . The periodicity is nominally once per business day, with a minimum of once per week . OE items identified on HSIN are placed through the process as described in Exelon/AmerGen procedure LS-AA-115 . In addition, reviews of HSIN are completed to obtain relevant OE items for analysis during an investigation such as a Root Cause, Apparent Cause Evaluation, or Common Cause Analysis .
The OE is routinely communicated during security shift briefings and, on occasion, through e-mails and required read-and-sign activities . Exelon/AmerGen procedure SY-AA-101-126-1001-F-02, "Nuclear Security Shift Turnover," requires the appropriate Security Supervisor performing the turnover to discuss any issued OE item and how the lessons learned can be applied to the organization .
The OE items are also incorporated into Security pre-job briefs as required per Exelon/AmerGen procedure HU-AA-1211, "Briefings - Pre-Job, Heightened Level of Awareness, Infrequent Plant Activity and Post-Job Briefings." OE items used in pre-job briefings are communicated to security personnel, including how similar events or causes of similar events and near misses will be prevented during performance of the applicable activity.}}

=Text=
{{#Wiki_filter:An Exelon Company erG                   .                                     Exelt5n..
Nuclear wwwexeloncorp .com AmerGen Energy Company, LLC 4300 VVinfleld Road                                                                   Exelon Generation Warrenville, I!_ 60555                                                               4300 W9nfield Road Warrenviile, IL 6o555 10 CFR 50 .54(f)
RS-08-089 RA-08-068 5928-08-20146 August 1, 2008 U . S. Nuclear Regulatory Commission ATTN : Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos_ TN 50-454 and STN 50-455 Clinton Power Station, Unit 1 Facility Operating License No . NPF-62 NRC Docket No_ 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos . 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Facility Operating License Nos . NPF-11 and NPF-18 NRC Docket Nos STN 50-373 and STN 50-374 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos 50-352 and 50-35.3 Oyster Creek Nuclear Generating Station Facility Operating License No . DPR-16 NRC Docket No . 50-219

U. S. Nuclear Regulatory Commission August 1, 2008 Page 2 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos . DPR-44 and DPR-56 NRC Docket Nos . 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos . DPR-29 and DPR-30 NRC Docket Nos 50-254 and 50-265 Three Mile Island Nuclear Station, Unit 1 Facility Operating License No. DPR-50 NRC Docket No-50-289

==Subject:==
Response to the Request for Additional Information Regarding Resolution of NRC Bulletin 2007-01, "Security Officer Attentiveness"

==References:==
1 . NRC Bulletin 2007-01, "Security Officer Attentiveness," dated December 12, 2007 2 . Letter from Charles G. Pardee (Exelon Generation Company, LLC/AmerGen Energy Company, LLC) to U. S. NRC, "Exelon Generation Company, LLC/AmerGen Energy Company, LLC, 60-Day Response to NRC Bulletin 2007-01, 'Security Officer Attentiveness,"' dated February 11, 2008
: 3. Letter from C. Gratton (U .S . NRC) to Addressees : Request for Additional Information RE: (TAC NOS. MD7570, MD 7571, MD7577, MD7578, MD7584, MD7595, MD7596, MD7612, MD7613, MD7614, MD7615, MD7628, MD7633, MD7634, MD7641, MD7642, and MD7661), dated June 27, 2008 On December 12, 2007, the NRC issued Bulletin 2007-01, "Security Officer Attentiveness,"
(Reference 1) . The Bulletin requested that all holders of operating licenses submit a written response within 60 days in accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (f). The Bulletin requested information to determine the status of licensee programs regarding the adequate and consistent implementation of their security programs in light of recent security-based incidents at certain sites.
Reference 2 provided the Exelon Generation Company, LLC (Exelon) and AmerGen Energy Company, LLC (AmerGen) 60-day response to the requested information for Braidwood Station, Byron Station, Clinton Power Station, Dresden Nuclear Power Station, LaSalle County Station, Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, Quad Cities Nuclear Power Station, and Three Mile Island Nuclear Station Unit 1 .
In Reference 3, the NRC requested additional information to complete its review of the Exelon/AmerGen response to NRC Bulletin 2007-01 .

U. S. Nuclear Regulatory Commission August 1, 2008 Page 3 The enclosure to this letter provides the Exelon/AmerGen 35-day response to the requested information .
There are no regulatory commitments contained in this letter . Should you have any questions concerning this letter, please contact Mr. Frank Mascitelli at (610) 765-5512 .
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1 St day of August, 2008 .
Respectfully, Keith R. Jury Vice President, Licensing and Regulatory Affairs Exelon Generation Company, LLC AmerGen Energy Company, LLC Enclosure :    35-Day Response to NRC Bulletin 2007-01 RAI-Braidwood Station, Byron Station, Clinton Power Station, Dresden Nuclear Power Station, LaSalle County Station, Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, Quad Cities Nuclear Power Station, and Three Mile Island Nuclear Station, Unit 1 .
cc:     Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Braidwood Station NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station

U. S. Nuclear Regulatory Commission August 1, 2008 Page 4 cc (cont'd) :
NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 TMI File No. 08011 Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA Mayor of Lacey Township, Forked River, NJ S . T. Gray, State of Maryland R. R. Janati, Commonwealth of Pennsylvania

Response to Request for Additional Information                                              Enclosure Re: NRC Bulletin 2007-01                                                                  Page 1 of 12 August 1, 2008 C11 RTION 1 The NRC staff reviewed your response to Question 1 a and requests the following additional information:
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.) .
RF~E Exelon Generation Company, LLC (Exelon) and AmerGen Energy Company, LLC (AmerGen) have procedural guidance associated with watch-standing practices, which define various types of security posts and post rotation periodicity requirements . Security Officers assume a variety of posts during a normal shift including: fixed posts, non-fixed posts, staging area posts, as well as compensatory posts, if warranted. Security Officers routinely rotate between fixed and non-fixed posts, staging areas, and high-risk post locations as part of their normal daily assigned duties .
A fixed post is defined as a defensive post used by Security and integrated into the station security contingency plan . Fixed posts include Bullet Resistant Enclosures (BREs), some rooftop positions, and posts with specific special functions. Non-fixed posts are posts that are not continuously manned or are mobile and integrated into the station security contingency plan . A non-fixed post includes Bullet Resistant Canisters (BRCs), improved fighting positions, and vehicular and roving patrols. Staging area posts are designated areas (e.g ., ready rooms, as applicable), from which Security Officers respond in the event of a contingency response to a non-fixed post, which may include a BRC, improved fighting position, or roof-top position.
Compensatory posts are planned or unplanned and are created to ensure the effectiveness of the physical security system remains equal to, or greater than, the level prior to a loss or degradation of a physical security system.
Procedure requirements are also in place that address posts that pose a high risk for inattentiveness, such as the Vehicle Barrier System (VBS) Check-point, VBS Check-point Over-Watch and Protected Area Access posts during low periods of activity and any isolated low activity security posts. Planned or unplanned compensatory measures are also identified as high-risk posts .

Response to Request for Additional Information                                               Enclosure Re: NRC Bulletin 2007-01                                                                   Page 2 of 12 August 1, 2008 Exelon/AmerGen takes into consideration the types of posts that Security Officers are rotated through when establishing the original post rotation schedules. Consideration for types of posts is factored into developing post rotational assignments. Frequent post rotations allow for the Security Officers to be exposed to a variety of external stimuli and promote attentiveness.
Every effort is made to ensure Security Officers are rotated to a different position at the required periodicity.
Security Supervision is required in accordance with Exelon/AmerGen procedure SY-AA-1016, "Watch-Standing Practices and Communications," to rotate personnel at posts where there is a high risk for inattentiveness about every hour and at other posts about every two hours. The high-risk security posts are defined above .
Security Supervision also has post rotation periodicity requirements . Security Supervisors typically rotate among the following post locations as part of their normal daily assigned duties :
Central Alarm Station (CAS), Secondary Alarm Station (SAS), and Field Supervisor or Response Team Leader (RTL) positions. Security Supervision is procedurally required in accordance with Exelon/AmerGen procedure SY-AA-1020, "Supervisor Post Checks and Post Orders," to rotate among the above-mentioned security supervisory positions at a nominal frequency of once every six hours .
Deviations of rotation frequency must be approved by the Manager-Site Security, or designee.
For short-term issues, deviations will be approved on a case-by-case basis . For long-term issues (e.g ., site layout, or conflicting site-specific strategy) deviations will be approved in a station-specific written communication . Any deviation to recommended frequency rotations also needs to be accompanied by an analysis of additional actions to be taken (if any) to restore the attentiveness margin .
OLESTION 2 The NRC staff reviewed your response to Question 1b and requests the following additional information :
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 responses:
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 .

Response to Request for Additional Information                                          Enclosure Re: NRC Bulletin 2007-01                                                              Page 3 of 12 August 1, 2008 R SPONS Security equipment issues are procedurally required to be identified in the Corrective Action Program (CAP) and prioritized through the normal work management and maintenance processes . Site personnel (including Security personnel) are encouraged to initiate and document security issues in the CAP in accordance with Exelon/AmerGen procedures LS-AA-120, "Issue Identification and Screening Process," and LS-AA-125, "Corrective Action Program (CAP) Procedure ." Issues requiring physical repair work are prioritized in accordance with Exelon/AmerGen procedure WC-AA-106,"Work Screening and Processing ." If the issue is classified as facility and minor maintenance, the repair is performed in accordance with Exelon/AmerGen procedures, MA-AA-716-002, "Facilities Maintenance Process," and MA-AA-716-003, "Tool Pouch/Minor Maintenance," or contractor procedures and processes .
Originators of issues can track the resolution and progress of follow-up corrective actions by inputting the CAP issue report number into the CAP computer program . The program identifies descriptions of corrective actions and their respective status .
Security equipment issues, including Heating, Ventilation and Air Conditioning (HVAC), are identified by Security Supervisors and/or Officers during routine post inspections performed in accordance with Exelon/AmerGen procedure SY-AA-1020, "Supervisor Post Checks and Post Orders ." Security post equipment deficiencies identified by Security Supervisors, as well as by Security Officers during performance of routine post inspections (Exelon/AmerGen procedure SY-AA-1020-F-01/04), BRE quarterly material condition checklist (Exelon/AmerGen procedure SY-AA-1020-F-03), and ready room material condition checklist (Exelon/AmerGen procedure SY-AA-1020-F-05), are documented in CAP, as necessary.
Selected security equipment has been entered into the Preventive Maintenance (PM) program.
PM templates have been developed for ten equipment groups, one of which is for BREs .
Typical PM activities range from cleaning of HVAC intake grill and air filters to BRE tower weld inspections.
Security equipment repairs receive the appropriate priority and timely repair schedule commensurate with the criticality of implementing the Security Plan . Issues that require physical repair work are entered into the work management system. As part of the process, the Work Management Screening Committee performs a daily review of emergent security, fire protection and safety Work Requests/Action Requests with the assistance of the Site Security representative, Fire Protection representative, and Industrial Safety representative to ensure the integrated impact of current outstanding work does not compromise site security, fire protection, or industrial safety (including OSHA compliance review) . Work is prioritized as needed to bring equipment status up to a level acceptable to the Site Security representative and the Engineering representative for Fire Protection systems/Fire Marshal.
Corrective maintenance of climate-controlled areas (BREs, guard enclosures, etc.) is performed by various maintenance groups depending on the complexity of the required maintenance task.
Maintenance has Instrument & Controls personnel specifically trained to perform maintenance on selected security equipment and systems. The Maintenance Department's Fix-It-Now (FIN) team performs some maintenance depending on the nature and urgency of work . In addition to the normal maintenance and work management process initiated through the CAP process,

Response to Request for Additional Information                                             Enclosure Re: NRC Bulletin 2007-01                                                                 Page 4 of 12 August 1, 2008 maintenance may be performed on BREs by Facilities Maintenance personnel and EMCOR personnel (i .e., facility maintenance contractor) . The BREs are cleaned and maintained by Facilities Maintenance personnel.
Preventive maintenance is performed on selected security equipment. There is a preventive maintenance program for climate-controlled areas (e.g., BREs). There is a condition-monitoring task to assess habitability of the BREs that is scheduled to occur on a routine basis .
There are several BRE time-directed tasks including: cleaning HVAC intake grill/filters ;
Uninterruptible Power Supply battery checks; access door, gun port and floor hatch hinge and lock inspections; HVAC annual service; and tower/BRE weld inspections.
Security corrective and preventive maintenance is normally scheduled and worked the same as routine and emergent plant maintenance with the exception of work that requires specific qualifications to repair . Security equipment maintenance is prioritized in accordance with Exelon/AmerGen procedure WC-AA-106 or contractor procedures and processes as applicable .
In addition, a Security Plan-of-the-Day (POD) report is presented on a monthly basis, in a POD meeting attended by senior site management . The report contains a status of the following:
total equipment issues, security system deficiencies requiring compensatory measures, security equipment in degraded status, CAS/SAS distractions/inoperative alarms, security officer workarounds/challenges, and security top priorities . This ensures proper management attention and timely resolution of security equipment issues .
O 1 STION 2 The NRC staff reviewed your response to Question 1c and requests the following additional information :
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.

===RESPONSE===
As a requirement for individuals with Unescorted Access Authorization (UAA), a behavioral observation program is outlined in Exelon/AmerGen procedure SY-AA-103-513, "Behavior

Response to Request for Additional Information                                             Enclosure Re: NRC Bulletin 2007-01                                                                  Page 5 of 12 August 1, 2008 Observation Program." This program provides information and guidance for individuals who are required to participate in a Behavioral Observation Program (BOP) . The BOP is the primary means for determining continued trustworthiness and reliability of individuals with UAA. The objective of the BOP is to detect illegal drug use, alcohol/legal drug abuse and other behaviors such as fatigue and physical or mental illness that may constitute an unreasonable risk to the health and safety of the public, including a potential threat to commit radiological sabotage .
This program is applicable to individuals with UAA and individuals granted Unescorted Access (UA) to Exelon/AmerGen Power Stations . Individuals are responsible for reporting any observed behavior indicating degradation in performance, impairment or change in behavior to a supervisor .
Supervisory personnel are responsible for familiarizing themselves with each employee's behavior patterns in order to enable the supervisor to recognize when an employee is exhibiting unusual or aberrant behavioral traits and patterns that may reflect adversely on their trustworthiness or reliability and constitute an unreasonable risk to the health and safety of the public .
Management personnel are responsible for observing personnel for behavior traits and patterns that may reflect adversely on their trustworthiness or reliability, being aware of behaviors that might be adverse to safe operation, and reporting those observations to the cognizant Department Head and Security . These requirements are also provided and tested in initial and annual Nuclear General Employee Training (NGET) .
Exelon/AmerGen management personnel, who do not have direct responsibility for the security program, are involved in conducting behavior observations of security personnel . The number, frequency and randomness of observations are not procedurally controlled, but are driven by site senior management expectations .
The fleet-wide response (i .e., Nuclear Event Report NC-07-034) to the Peach Bottom Atomic Power Station Security Inattentiveness issue included the following non-security management observations :
Exelon management conducted a once per week backshift visit to ready rooms and daily visits (i.e., during the work week and when on site during the weekend) to ready rooms . If no ready rooms were on site, then high-risk posts were visited randomly. Each of these visits was recorded .
The site Plant Manager and Site Vice President visited the SAS and CAS once per month . Each of these visits was recorded and given to the Manager-Site Security .
Also, the site Plant Manager and Site Vice President visited one security turnover briefing per month .
Each security member listed by title on the duty team as defined in Exelon/AmerGen procedure SY-AA-101-126, "Duties and Responsibilities of the Station Security Organization," performed two paired observations with site operations (i.e., Senior

Response to Request for Additional Information                                              Enclosure Re: NRC Bulletin 2007-01                                                                  Page 6 of 12 August 1, 2008 Reactor Operator or above) focusing on site operations standards. Any members of the duty team who were previously in operations in the last two years were excluded from this action .
Typically, site management observations of security are made and documented (e.g., via Exelon/AmerGen procedure SY-AA-1020-F-04) and include assessing Security Officers to ensure they are Fit-For-Duty (e.g ., alert, attentive) . Typically, the observations include, but are not limited to, the following attributes : assessing use of authorized attentiveness aids, assessing proper weapons controls, soliciting insights from Security Officers with regard to Safety Conscious Work Environment, knowledge of external organizations to raise concerns, and use of the CAP.
In addition to management observations, two organizations, Nuclear Oversight (NOS) and the Nuclear Safety Review Board (NSRB), provide additional oversight and observations of the security organization . Descriptions of the types of observations and assessments performed by NOS and NSRB are provided in response to Question 6 below.
0 1 STION 4 The NRC staff reviewed your response to Question 1 and requests the following additional information :
How is the licensee's policy regarding site employee attentiveness and/or inattentiveness communicated to personnel, both licensee and contractor, and at what frequency?
R SPONS The Exelon/AmerGen policy regarding site employee attentiveness and/or inattentiveness is communicated and contained within the publication titled "Employee Standards of Conduct." In addition, the "Employee Standards of Conduct" is issued to Security Officers upon date of hire .
Security Officers were issued the code of conduct as part of the Wackenhut to Exelon/AmerGen employee transition. With regard to attentiveness, the code of conduct details the requisite disciplinary action associated with "sleeping during work time or giving the appearance of sleeping during work time," as warranted .
For contractors, the Exelon/AmerGen policy regarding attentiveness and/or inattentiveness is communicated during NGET, which is required for contractors who are granted unescorted access authorization.
Exelon/AmerGen communicates and reinforces expectations on being attentive to duty through a number of other methods. Ongoing communication with regard to remaining Fit-For-Duty and maintaining attentiveness is reinforced during each Security Officer's assigned duty shift per Exelon/AmerGen standards for watch-standing practices, which are contained within existing security procedures . Additionally, observations of Security Officers throughout their normal duty shift are also performed by security supervision and are institutionalized within Exelon/AmerGen procedures .

Response to Request for Additional Information                                                  Enclosure Re: NRC Bulletin 2007-01                                                                      Page 7 of 12 August 1, 2008 Security Supervision ensures Security Officers are Fit-For-Duty, including being attentive at the onset of each duty shift. Exelon/AmerGen procedure SY-AA-101-126-1001-F-02, "Nuclear Security Shift Turnover," provides the basis for making this determination . Questions pertaining to whether a Security Officer is taking prescription medications or over-the-counter medications, or has been under the influence of alcohol within the past five hours are asked of each individual . Security Officers are also questioned as to whether they were involved in any illegal activities that need to be reported to supervision. Security Officers are given the opportunity to self-declare fatigue, with no adverse impact, if they feel that during the conduct of shift duties, they are in danger of becoming less than alert. If a self-declaration is made, Security Supervision is notified, actions are taken to provide relief, and an assessment is conducted to determine further actions required .
Additionally, each Security Officer is required to follow Exelon/AmerGen procedure SY-AA-101-126-1001-F-01, "Requirements for Assuming Duty." Each individual must assert the following prior to assuming duty :
              "I am fit-for-duty and will report to my supervisor if I begin to feel unfit for duty .
My qualifications are current for the duty period for which I am about to perform .
I am not the subject of any legal process that might affect my ability to carry a weapon (e.g ., misdemeanor crime of domestic violence or under domestic restraining order) .
I have reported all arrests, criminal charges, convictions, or legal proceedings.
Since my last company physical, I have had no unevaluated change in medical, including eyesight .
I have a valid driver's license.
I have in my possession all valid licenses required for my state.
I have in my possession a second pair of eyeglasses (if required) ."
These requirements are also displayed for each Security Officer to read and understand during shift turnover activities .
Communication on maintaining attentiveness with Security Officers is exhibited during Supervisor observations performed during post inspections. Exelon/AmerGen procedure SY-AA-1020, "Supervisor Post Checks and Post Orders," defines the required periodicity of post rotations and the guidelines for conducting post inspections.
On-shift or staff Security Supervisors are required to perform post inspections at least two times per shift for non-compensatory and compensatory posts. Exelon/AmerGen procedure SY-AA-1020-F-04, "Post Inspection Form," is used to document these inspections. As part of these routine inspections, Security Supervisors monitor each Security Officer for signs of fatigue or other signs of inattentiveness . Security Supervisors reinforce post requirements including maintaining attentiveness at all times. Security Supervisors also monitor and assess the environmental conditions of the post during post inspections (e.g ., heat, lighting, ventilation, noise) as well as human factors (e .g., distractions, breaks, supervisor interface) . If deemed necessary, Security Supervision will initiate appropriate corrective actions (e.g ., increased post rotation frequency, increased radio check frequency, increased break frequency, etc.), to ensure Security Officers remain attentive to duty.

Response to Request for Additional Information                                              Enclosure Re: NRC Bulletin 2007-01                                                                  Page 8 of 12 August 1, 2008 Security Supervision also performs routine communication checks to verify each Security Officer's alertness and attentiveness . These random communication checks are at a frequency not to exceed a nominal hourly rate during periods of high traffic (e.g., day shift or outage) and at a nominal 30-minute rate during periods of low activity (e .g., night shifts or weekends) .
Exelon/AmerGen has also conducted an evaluation of post assignments and has established a list of authorized attentiveness aids as identified in procedure SY-AA-1016, "Watch-Standing Practices and Communications ." The use of these authorized attentiveness aids is continually reinforced with Security Officers as another means of maintaining alertness in performance of assigned duties .
QUESTION 5 The NRC staff reviewed your response to Question 2 and requests the following additional information:
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 responses :
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 the report 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.

===RESPONSE===
Employees can file CAP reports without prior supervisory/management review or approval .
Supervisors/Managers do not have the authority to reject a report before the report is entered into the corrective action program . Exelon/AmerGen personnel and contractors at Exelon/AmerGen facilities are expected to identify and document equipment issues per procedure LS-AA-120, "Issue Identification and Screening Process," into the CAP as Issue Reports (IRs) . The originators of IRs are expected to identify conditions that have or could have an undesirable effect on performance of equipment, programs, or organizations and ensure that necessary immediate actions to place the situation in a safe and stable condition are completed or initiated as appropriate. The originators are expected to verbally communicate the condition to a supervisor, or the Control Room, when appropriate, including communication of immediate corrective actions taken . When entering an issue into the CAP computer program (i .e ., Passport) originators are expected to ensure that the issue is properly documented, with required information and fields populated in Passport. The originator is expected to identify opportunities for improvement and commendable behaviors. If the originator does not have immediate access to a computer terminal, a hardcopy form can be initiated and given to their supervisor or any individual with a user identification . The supervisor

Response to Request for Additional Information                                              Enclosure Re: NRC Bulletin 2007-01                                                                  Page 9 of 12 August 1, 2008 or individual with a user identification are expected to ensure the data is appropriately entered into CAP.
As part of the security transition from Wackenhut contractors to Exelon/AmerGen employees, security employees are being given a unique user identification to enable security employees to access available computers for directly inputting issues into the CAP via the Passport computer program. Individuals with a user identification can directly input issues into CAP, without any supervisor input, by accessing the Exelon/AmerGen issues Initiation Website and inputting their user identification and affected facility . However, one of the required computer fields necessary for an IR to be electronically generated is for the originator to fill in the name of the supervisor that was verbally contacted. Once the computer program electronically generates the IR, the issue description cannot be revised by the originator or their supervisor .
011ESTION 6 The NRC staff reviewed your response to Question 4 and requests the following additional information:
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.

===RESPONSE===
Exelon/AmerGen conducts independent audits of the security program in accordance with the Exelon/AmerGen Quality Assurance Topical Report . These audits are performed by NOS on an annual basis. NOS is organizationally independent from site management and reports to the corporate organization . These audits are performed at times (as needed) with the assistance of non-Exelon security technical specialists. The audits are conducted at each Exelon/AmerGen site and at the corporate facilities, typically over a four-week period during the first quarter of every year . There are three audit teams, each comprised of nominally five members, some with an additional technical security specialist .
The core groups of auditors are experienced in auditing physical security, including Design Basis Threat strategies, Fitness-for-Duty (FFD), Access Authorization (AA), Personnel Access Data System (PADS), and handling of Safeguards Information (SGI) programs . Each audit is conducted using approximately 25 audit templates to ensure regulatory compliance to 10 CFR and NRC Orders, as well as other requirements . The audit scope includes such topics as :
organization, training and qualifications, compensatory measures, detection and response, PADS, AA, FFD, Protected and Owner Controlled Area controls, drills and exercises, equipment material condition and testing, local law enforcement interface, procedure use and adherence, SGI control, document control, corrective actions, and quality assurance records. NOS, corporate personnel, and station personnel are requested to provide input to the audit scope .
Internal and external operating experience are also reviewed to provide input to the audit scope .

Response to Request for Additional Information                                             Enclosure Re: NRC Bulletin 2007-01                                                                Page 1 0 of 12 August 1, 2008 The audits are also performance based to include observing classroom, firearms range, and force-on-force training ; observing personnel and vehicle searches ; observing vehicle barrier system operations, Security Officer patrol rounds, CAS and SAS command and control, shift turnovers, and arming and disarming activities .
Audit entrance and exit meetings are attended by senior team members of the site (e .g., Site Vice President, Plant Manger, Manager-Site Security, Security Supervision, NOS Manager, and other department representatives as required) or the corporate office being audited . NOS-identified significant issues (i .e., findings), deficiencies, and enhancements are entered into the CAP. Each successive annual audit team reviews the responses to the NOS issues from the previous audit. Certified lead auditors follow up on NOS findings prior to the next audit.
Additionally, the site NOS performance assessment organizations observe security related activities throughout the year and report out to station and NOS senior management semi-annually on the status and performance of the security organizations at each site . NOS issues from the assessment group are entered into the CAP, similar to the audit organization .
Certified lead assessors follow up on NOS findings .
The NSRB also performs independent assessments of the security program . The security organization is assessed by the NSRB Regulatory and Nuclear Oversight Sub-Committee. In addition to the NSRB Sub-Committee Chairperson, who is typically an external consultant, the Regulatory and Nuclear Oversight Sub-Committee typically consists of a peer Regulatory Assurance Manager, peer NOS Manager, and Corporate NOS representative along with the representative site Regulatory Assurance and NOS Managers.
The NSRB members conduct observations of the security program at each site typically three times per year . As part of the assessment process, NSRB members conduct plant walkdowns of select security locations (e.g., staging areas, alarm stations) . Additionally, NSRB members also conduct interviews with Security Officers and members of security management to gain a better understanding of the current status and performance level of the organization, as well as to ascertain any insights or concerns that would warrant management's attention.
The NSRB Sub-Committee also typically reviews security performance indicators and metrics, fleet rankings, human performance issues, safety events, material and equipment condition, implementation of fleet directed actions, status of NRC Orders, and Force-on-Force readiness .
After each assessment, NSRB members conduct detailed debrief meetings with the site senior management team, as well as corporate and executive management . The NSRB draws conclusions based on their observations and insights of the overall program health and effectiveness. Formal meeting minutes document the conclusions of the NSRB. The NSRB-identified significant issues are entered into the CAP for appropriate evaluation and disposition, as warranted .

Response to Request for Additional Information                                               Enclosure Re: NRC Bulletin 2007-01                                                                 Page 11 of 12 August 1, 2008 0tIESTInN 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 responses:
Describe the policy 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 .
RRF~PQNSE Security performs self-assessments in accordance with Exelon/AmerGen procedure LS-AA-126, "Self-Assessment Program ." The assessments consist of either a Focused Area Self-Assessment (FASA) or Check-in Assessment. These assessments are used to assess standards compliance, resolution of performance gaps, industry excellence and change management effectiveness . Corporate and site security develop an assessment schedule which is then approved by senior management and documented in the Passport database .
Security performs approximately five assessments per year.
Security Assessment Team Leaders are selected and receive appropriate orientation from the site/department Self-Assessment Coordinator . The department individual for Security is either the corporate Security Learning Programs Analyst or the site Security Program Lead. The Team Leader develops the assessment plan, which is reviewed and approved by the department management . In addition, the plant Management Review Committee or Self-Assessment Review Board approves pre-NRC/INPO inspection FASA plans.
Upon receiving approval, the assessment is executed per the plan and schedule . After the data collection is completed, the Team Leader prepares the assessment report . Actions associated with the identified standards deficiencies, performance improvement recommendations, and strengths are documented and tracked per Exelon/AmerGen procedures LS-AA-126-1001, "Focused Area Self-Assessments," or LS-AA-126-1005, "Check-In Self-Assessments," as appropriate . There is no formal procedural requirement to communicate all self-assessment results to all members of the assessed department ; however, the FASA and Check-in results are communicated, as appropriate, to senior management, the functional area, the functional area peer group, and others who may benefit from the assessment . FASA and Check-in self-assessment schedules, plans, and reports are tracked, documented and made available through the Passport Action Tracking system .
Nuclear Security follows the procedural requirements of Exelon/AmerGen procedure LS-AA-115, "Operating Experience ." LS-AA-115 provides the process for reviewing and documenting Operating Experience (OE) from both internal and external sources. As identified in LS-AA-115, there is an assigned Exelon/AmerGen fleet OE Coordinator who is the central input for operating experience and vendor technical information. The fleet OE Coordinator is

Response to Request for Additional Information                                           Enclosure Re: NRC Bulletin 2007-01                                                             Page 12 of 12 August 1, 2008 responsible for classification and distribution of incoming OE documents to the Corporate Functional Area Managers and subject matter experts, screening potential Nuclear Event Reports, reviewing completed responses to formal OE reviews, and coordinating the effectiveness assessments and self-assessments of the OE program at each Exelon/AmerGen site.
When an OE item is received within the security organization, it is reviewed for applicability by the appropriate security subject matter expert, who determines whether a corporate security review or single site review is required . This determination is based on the number of sites affected by the OE item . Once the OE item has been determined to be applicable, an OE Action Tracking Item is generated in the Passport computer program to track and document the review. Additional actions are created based on the results of the review .
Security also uses the Homeland Security Information Network (HSIN) for OE items . The HSIN database provides a means for Security throughout the nuclear industry to share OE items .
Users of the database are designated as either "read only" or "data entry." The read only users have access to HSIN, but are unable to enter data . Exelon/AmerGen has two data entry individuals at the corporate level . One individual is the primary and the other a backup . The process for entering data into HSIN is as follows:
The respective site Security subject matter expert provides the write-up on the event to the corporate Security Learning Programs Analyst . The document is then reviewed for accuracy and placed onto the HSIN database .
Periodically, a review of HSIN is performed to obtain OE items from other utilities . The periodicity is nominally once per business day, with a minimum of once per week . OE items identified on HSIN are placed through the process as described in Exelon/AmerGen procedure LS-AA-115 . In addition, reviews of HSIN are completed to obtain relevant OE items for analysis during an investigation such as a Root Cause, Apparent Cause Evaluation, or Common Cause Analysis .
The OE is routinely communicated during security shift briefings and, on occasion, through e-mails and required read-and-sign activities . Exelon/AmerGen procedure SY-AA-101-126-1001-F-02, "Nuclear Security Shift Turnover," requires the appropriate Security Supervisor performing the turnover to discuss any issued OE item and how the lessons learned can be applied to the organization .
The OE items are also incorporated into Security pre-job briefs as required per Exelon/AmerGen procedure HU-AA-1211, "Briefings - Pre-Job, Heightened Level of Awareness, Infrequent Plant Activity and Post-Job Briefings." OE items used in pre-job briefings are communicated to security personnel, including how similar events or causes of similar events and near misses will be prevented during performance of the applicable activity.}}