ML081910532

Request for Additional Information - Bulletin 2007-001, Security Officer Attentiveness (Tac No. MD7639 & MD7640)

ML081910532
Person / Time
Site:	Prairie Island
Issue date:	07/11/2008
From:	Mahesh Chawla NRC/NRR/ADRO/DORL/LPLIII-1
To:	Wadley M Nuclear Management Co
chawla M, ADRO/DORL, 415-8371
References
BL-07-001, TAC MD7639, TAC MD7640
Download: ML081910532 (7)

Text

July 11, 2008 Mr. Michael D. Wadley Site Vice President Prairie Island Nuclear Generating Plant Nuclear Management Company, LLC 1717 Wakonade Drive East Welch, MN 55089

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 -

REQUEST FOR ADDITIONAL INFORMATION RE: BULLETIN 2007-01 SECURITY OFFICER ATTENTIVENESS (TAC NOS. MD7639 AND MD7640)

Dear Mr. Wadley:

By letter dated February 11, 2008, Nuclear Management Company, LLC (the licensee) submitted the required written response to Security Bulletin 2007-01 Security Officer Attentiveness for the Prairie Island Nuclear Generating Plant, Units 1 and 2. The response was submitted to the Nuclear Regulatory Commission (NRC) in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(f) and 10 CFR 70.22(d).

The NRC staff has reviewed your submittal and has determined that additional information is needed to complete the final staff assessment of the licensee response to the Security Bulletin.

Security Bulletin 2007-01 requested licensees to provide information regarding administrative and managerial programs and controls established to prevent, identify and correct security personnel inattentiveness, complicity, and failures to implement the behavioral observation program by individuals among licensee security personnel including security contractors and subcontractors. The staff will use the additional information received to inform the Commission and to determine if further regulatory action is warranted or if additional assessment of the licensee program implementation is needed.

M. Wadley The specific information requested is addressed in the enclosure to this letter. Responses are requested within 35 days of the issuance of this letter. Before submitting responses to the NRC, licensees must evaluate them for proprietary, sensitive, safeguards, or classified information and mark such information appropriately.

If you have any question, please contact me at 301-415-8371.

Sincerely,

/RA/

Mahesh L. Chawla, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-282 and 50-306

Enclosure:

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

M. Wadley The specific information requested is addressed in the enclosure to this letter. Responses are requested within 35 days of the issuance of this letter. Before submitting responses to the NRC, licensees must evaluate them for proprietary, sensitive, safeguards, or classified information and mark such information appropriately.

If you have any question, please contact me at 301-415-8371.

Sincerely,

/RA/

Mahesh L. Chawla, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-282 and 50-306

Enclosure:

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

PUBLIC LPL3-1 r/f RidsNrrDorlLpl3-1 RidsNrrPMMChawla RidsNrrLATHarris RidsOgcRp RidsAcrsAcnw&mMailCenter RidsNrrDirsltsb RidsRgn3MailCenter RidsNrrDorlDpr LRegner, NRR/DORL MBanic, NRR/DPR FPeduzzi, NSIR RCorreia, NSIR RidsNrrLABTully ADAMS Accession Number: ML081910532

• E-mail transmitting NSIR RAIs - ADAMS Accession Number ML081890364 OFFICE LPL3-1/PM LPL3-1/LA NSIR/BC LPL3-1/BC MChawla BTully

• LJames NAME DATE 7/10/08 7/10/08 06/25/08 7/11/08 OFFICIAL RECORD COPY

Prairie Island Nuclear Generating Plant, Units 1 and 2 cc:

Peter M. Glass Commissioner Assistant General Counsel Minnesota Department of Commerce Xcel Energy Services, Inc. 85 7th Place East, Suite 500 414 Nicollet Mall (MP4) St. Paul, MN 55101-2198 Minneapolis, MN 55401 Tribal Council Manager, Regulatory Affairs Prairie Island Indian Community Prairie Island Nuclear Generating Plant ATTN: Environmental Department Nuclear Management Company, LLC 5636 Sturgeon Lake Road 1717 Wakonade Drive East Welch, MN 55089 Welch, MN 55089 Nuclear Asset Manager Manager - Environmental Protection Division Xcel Energy, Inc.

Minnesota Attorney General=s Office 414 Nicollet Mall (MP4) 445 Minnesota St., Suite 900 Minneapolis, MN 55401 St. Paul, MN 55101-2127 Dennis L. Koehl U.S. Nuclear Regulatory Commission Chief Nuclear Officer Resident Inspector's Office Nuclear Management Company, LLC 1719 Wakonade Drive East 414 Nicollet Mall (MP4)

Welch, MN 55089-9642 Minneapolis, MN 55401 Administrator Joel P. Sorenson Goodhue County Courthouse Director, Site Operations Box 408 Prairie Island Nuclear Generating Plant Red Wing, MN 55066-0408 Nuclear Management Company, LLC 1717 Wakonade Drive East Welch, MN 55089 July 2006

REQUEST FOR ADDITIONAL INFORMATION REVIEW OF SECURITY BULLETIN RESPONSES SUBMITTED IN RESPONSE TO SECURITY BULLETIN 2007-01 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NO. 50-282 AND 50-306 In responding to each of the following questions, licensee should provide information that addresses measures that are currently in place, and any additional planned actions with expected completion dates:

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

1. Describe the process for security post rotations including the rotation process for isolated positions.

Include the following information in your response:

A description of the security post rotation process including, but not limited to: (1) a discussion of the types of posts a typical security officer would rotate through during a normal shift; (2) a discussion on whether the type of activity (i.e., roving or foot patrol or stationary in a Bullet Resisting Enclosure [BRE]) performed at each individual post is taken into consideration when a security officer moves from post to post throughout the shift; and, (3) the length of time at each post. When responding, particular emphasis should be placed on whether the licensee takes into consideration the activities associated with each post assignment when formulating their post rotation schedules for each shift (i.e., rotating from foot patrol to BRE to Vital Area patrol or rotating from BRE to ready room to BRE etc.).

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

2. 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:

Enclosure

A description of any processes in place for the licensee and/or contract management, who work day to day at the site or visit the site on a routine basis from a corporate office or other applicable offsite location, for conducting behavior observations of security personnel while on duty at their assigned posts. Examples should include, but are not limited to, a discussion of random or scheduled observations conducted by the licensee and/or contract management such as the Plant Operations Shift Managers or other Plant Operations Shift Supervisors, Plant Maintenance Supervisors (licensee and contractor), or Quality Assurance Supervisors etc. The discussion should include whether these random or scheduled observations are proceduralized and the required or recommended level of licensee and/or contract management involvement.

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

3. Are security personnel provided opportunities to participate in any personnel surveys regarding the work environment? If so, what is the frequency of the surveys, the average participation rate of security personnel as compared to the general site average, and the process for providing feedback and addressing the results from the survey?

4. How is the licensees policy regarding site employee attentiveness and/or inattentiveness communicated to personnel, both licensee and contractor, and at what frequency?

The NRC staff reviewed your response to Question 2 and requests the following additional information:

5. Describe the process for employees to file reports through the site corrective action program (CAP). Can employees file CAP reports without prior supervisory/management review or approval?

Include the following information in your response:

Describe the process for employees to file reports through the CAP. Discuss the supervisor/management review and/or approval process including, but not limited to: (1) does a supervisor/manager have the authority to reject a report before entering it into the corrective action program without additional management review and approval; and, (2) does a supervisor/manager have the authority to modify the report before such report has been entered into the CAP.

6. Can the employees view the status and disposition of reports directly, or must this information be requested? If yes, please describe the process.

The NRC staff reviewed your response to Question 5 and requests the following additional information:

7. How do you assess the effectiveness of your oversight of contractors and subcontractors?

Include the following information in your response:

Describe the licensees program for oversight of contractors and subcontractors including, but not limited to: (1) a brief overview and description of licensees procedures that describe the oversight process; (2) include a detailed list (bulleted is preferred) of assigned duties for the licensee supervisor(s) or manager(s) responsible for overseeing contractors and subcontractors at the site; (3) include a detailed list (bulleted is preferred) of the assigned duties for the contractor and subcontractor supervisor(s) or manager(s) responsible for overseeing the contractor and subcontractor staff at the site; and, (4) a brief discussion of the corporate (management) involvement with the oversight of contractors and subcontractors at the site.