ML081790347

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

ML081790347
Person / Time
Site:	Vermont Yankee
Issue date:	07/02/2008
From:	James Kim NRC/NRR/ADRO/DORL/LPLI-1
To:	Entergy Nuclear Operations
kim J, NRR/ADRO/DORL, 415-4125
References
BL-07-001, TAC MD7664
Download: ML081790347 (9)

Text

July 2, 2008 Vice President, Operations Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION - REQUEST FOR ADDITIONAL INFORMATION RE: BULLETIN 2007-01 SECURITY OFFICE ATTENTIVENESS (TAC NO. MD7664)

Dear Sir or Madam:

By letter dated February 11, 2008, Entergy Nuclear Operations, Inc. (the licensee) submitted the required written response to Security Bulletin 2007-01 Security Officer Attentiveness for the Vermont Yankee Nuclear Power Station. The response was submitted to the NRC in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(f) and 10 CFR 70.22(d).

The NRC staff has reviewed your submittal and has determined that additional information is needed to complete the final 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 licensee program implementation is needed.

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

If you have any questions, please contact me at 301-415-4125.

Sincerely,

/RA/

James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosure:

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

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 questions, please contact me at 301-415-4125.

Sincerely,

/RA/

James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosure:

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

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Vermont Yankee Nuclear Power Station cc:

Regional Administrator, Region I Ms. Carla A. White, RRPT, CHP U. S. Nuclear Regulatory Commission Radiological Health 475 Allendale Road Vermont Department of Health King of Prussia, PA 19406-1415 P.O. Box 70, Drawer #43 108 Cherry Street Mr. David R. Lewis Burlington, VT 05402-0070 Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, N.W. Ms. Charlene D. Faison Washington, DC 20037-1128 Manager, Licensing Entery Nuclear Operations Mr. David O=Brien, Commissioner 440 Hamilton Avenue Vermont Department of Public Service White Plains, NY 10601 112 State Street Montpelier, VT 05620-2601 Resident Inspector Vermont Yankee Nuclear Power Station Mr. James Volz, Chairman U. S. Nuclear Regulatory Commission Public Service Board P.O. Box 176 State of Vermont Vernon, VT 05354 112 State Street Montpelier, VT 05620-2701 Massachusetts Emergency Management Agency Chairman, Board of Selectmen ATTN: John Giarrusso, Town of Vernon Nuclear Preparedness Manager P.O. Box 116 400 Worcester Rd.

Vernon, VT 05354-0116 Framingham, MA 01702-5399 Operating Experience Coordinator Jonathan M. Block, Esq.

Vermont Yankee Nuclear Power Station Main Street P.O. Box 250 P.O. Box 566 Governor Hunt Road Putney, VT 05346-0566 Vernon, VT 05354 G. Dana Bisbee, Esq.

Deputy Attorney General 33 Capitol Street Concord, NH 03301-6937 Chief, Safety Unit Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108

Vermont Yankee Nuclear Power Station cc:

Senior Vice President Vice President Oversight Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

P.O. Box 31955 P.O. Box 31955 Jackson, MS 39286-1995 Jackson, MS 39268-1995 Mr. Oscar Limpias Senior Manager, Nuclear Safety & Licensing Vice President, Engineering Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations P.O. Box 31953 P.O. Box 31955 Jackson, MS 39286-1995 Jackson, MS 39286-1995 Senior Vice President and COO Mr. John A. Ventosa Entergy Nuclear Operations, Inc.

GM, Engineering 440 Hamilton Avenue Entergy Nuclear Operations White Plains, NY 10601 440 Hamilton Avenue White Plains, NY 10601 Assistant General Counsel Entergy Nuclear Operations, Inc.

Mr. Joseph P. DeRoy 440 Hamilton Avenue VP, Operations Support White Plains, NY 10601 Entergy Nuclear Operations, Inc.

P.O. Box 31955 Vice President, Operations Jackson, MS 39286-1995 Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station Mr. John R. Dreyfuss P.O. Box 250 Director, NSA Governor Hunt Road Entergy Nuclear Operations Vernon, VT 05354 Vermont Yankee Nuclear Power Station P.O. Box 250 Mr. James H. Sniezek Governor Hunt Road 5486 Nithsdale Drive Vernon, VT 05354 Salisbury, MD 21801 Manager, Licensing Mr. Garrett D. Edwards Entergy Nuclear Operations, Inc. 814 Waverly Road Vermont Yankee Nuclear Power Station Kennett Square, PA 19348 P.O. Box 250 Governor Hunt Road Vernon, VT 05354

Vermont Yankee Nuclear Power Station cc:

Ms. Stacey M. Lousteau Treasury Department Entergy Services, Inc.

639 Loyola Avenue New Orleans, LA 70113 Mr. Norman L. Rademacher Director, NSA Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernont, VT 05354 Mr. Raymond Shadis New England Coalition Post Office Box 98 Edgecomb, ME 04556 Mr. James P. Matteau Executive Director Windham Regional Commission 139 Main Street, Suite 505 Brattleboro, VT 05301 Uldis Vanags State Nuclear Engineer Vermont Department of Public Service 112 State Street Montpelier, VT 05620-2601 Mr. Michael D. Lyster 5931 Barclay Lane Naples, FL 34110-7306

REQUEST FOR ADDITIONAL INFORMATION REVIEW OF SECURITY BULLETIN RESPONSES SUBMITTED IN RESPONSE TO SECURITY BULLETIN 2007-01 VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271 In responding to each of the following questions, the 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 1b. and requests the following additional information:

2. Describe any licensee processes or programs that are in place to identify problems in climate controlled security areas. What methods are used to track, inspect, and ensure timely repairs are completed?

Include the following information in your response:

A description of how the security areas are maintained including, but not limited to: (1) a discussion of the maintenance and/or preventive maintenance process and programs in place for these security areas including an overview and brief discussion on routine inspection schedules by maintenance personnel; (2) a discussion on the process a security officer can follow to report concerns with the up-keep and maintenance of his or her post; and, (3) a discussion on the timeliness of repairs and any follow-up actions taken by the licensee to ensure the repairs are completed and resolved adequately.

Enclosure

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

3. What is the level of involvement from management who do not have direct responsibility for the security program (including executive and corporate management) in conducting behavior observations of security personnel?

Include the following information in your response:

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

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

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

The NRC staff reviewed your response to Question 4 and requests the following additional information:

6. How are self-assessment findings and relevant operating experience information communicated to the security force? Describe those processes including, but not limited to, information such as the criteria by which such information is identified, the frequency of such communications, the responsible department(s) or position(s) for such communications, and the recipients of such communications.

Include the following information in your response:

Describe the process including, but not limited to: (1) formal or informal communication methods; (2) procedures that ensure availability of the policy to staff; and, (3) training opportunities for staff to read and understand the policy.

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

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.