ML081830009

Request for Additional Information, Related to Response to NRC Bulletin 2007-01, Security Officer Attentiveness.

ML081830009
Person / Time
Site:	Grand Gulf
Issue date:	07/09/2008
From:	Donohew J NRC/NRR/ADRO/DORL/LPLIV
To:	Entergy Operations
Donohew J N, NRR/DORL/LPL4, 415-1307
References
BL-07-001, TAC MD7604
Download: ML081830009 (7)

Text

July 9, 2008 Vice President, Operations Entergy Operations, Inc.

Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

GRAND GULF NUCLEAR STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO RESPONSE TO NRC BULLETIN 2007-01, SECURITY OFFICER ATTENTIVENESS (TAC NO. MD7604)

Dear Sir or Madam:

By letter dated February 7, 2008 (GNRO-2008/00017, Agencywide Documents Access and Management System (ADAMS) Accession No. ML080430054), Entergy Operations, Inc. (the licensee), submitted the required written response to U.S. Nuclear Regulatory Commission (NRC)Bulletin 2007-01, Security Officer Attentiveness, for Grand Gulf Nuclear Station, Unit 1.

The response was submitted to the in accordance with Sections 50.54(f) and 70.22(d) in Title 10 of the Code of Federal Regulations (10 CFR 50.54(f) and 10 CFR 70.22(d)).

The NRC staff has reviewed your submittal and has determined that additional information is required to complete the final staff assessment of the licensee response to NRC Bulletin 2007-01. NRC Bulletin 2007-01 requested licensees to provide information regarding administrative and managerial programs and controls established to prevent, identify, and correct 1) security personnel inattentiveness and complicity, and 2) failures to implement the behavioral observation program for 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 301-415-1307 or, through the internet, at jack.donohew@nrc.gov.

Sincerely,

/RA/

Jack N. Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosure:

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

ML081830009` NSIR e-mail Package ML081820158 OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC (A) NRR/LPL4/PM NAME JDonohew JBurkhardt BSingal JDonohew DATE 7/9/08 7/9/08 7/9/08 7/9/08 Grand Gulf Nuclear Station (7/2/2008) cc:

Senior Vice President Office of the Governor Entergy Nuclear Operations State of Mississippi P.O. Box 31995 Jackson, MS 39201 Jackson, MS 39286-1995 Attorney General Vice President, Oversight Department of Justice Entergy Nuclear Operations State of Louisiana P.O. Box 31995 P.O. Box 94005 Jackson, MS 39286-1995 Baton Rouge, LA 70804-9005 Senior Manager, Nuclear Safety President

& Licensing Claiborne County Entergy Nuclear Operations Board of Supervisors P.O. Box 31995 P.O. Box 339 Jackson, MS 39286-1995 Port Gibson, MS 39150 Senior Vice President Richard Penrod, Senior Environmental

& Chief Operating Officer Scientist/State Liaison Officer Entergy Operations, Inc. Office of Environmental Services P.O. Box 31995 Northwestern State University Jackson, MS 39286-1995 Russell Hall, Room 201 Natchitoches, LA 71497 Associate General Counsel Entergy Nuclear Operations Chief, Energy and Transportation Branch P.O. Box 31995 Environmental Compliance and Jackson, MS 39286-1995 Enforcement Division Mississippi Department of Environmental Manager, Licensing Quality Entergy Operations, Inc. P.O. Box 10385 Grand Gulf Nuclear Station Jackson, MS 39289-0385 P.O. Box 756 Port Gibson, MS 39150 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission State Health Officer 612 E. Lamar Blvd., Suite 400 State Health Board Arlington, TX 76011-4125 P.O. Box 1700 Jackson, MS 39215 Senior Resident Inspector U.S. Nuclear Regulatory Commission Attorney General P.O. Box 399 Asst. Attorney General Port Gibson, MS 39150 State of Mississippi P.O. Box 22947 Jackson, MS 39225-2947

REQUEST FOR ADDITIONAL INFORMATION RELATED TO RESPONSE TO NRC BULLETIN 2007-01, SECURITY OFFICER ATTENTIVENESS GRAND GULF NUCLEAR STATION, UNIT 1 DOCKET NO. 50-416 By letter dated February 7, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML080430054), Entergy Operations, Inc. (the licensee), submitted the required written response to U.S. Nuclear Regulatory Commission (NRC)Bulletin 2007-01, Security Officer Attentiveness, for the Grand Gulf Nuclear Station, Unit 1. The NRC staff has reviewed the submittal and determined that additional information is needed to complete the final staff assessment of the licensee's response to NRC Bulletin 2007-01. 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 1b. and requests the following additional information:

1. 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 upkeep 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.

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:

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 ENCLOSURE

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. 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:

4. 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 CAP 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?

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) 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) 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.