ML081820272

Request for Additional Information Bulletin 2007-01 Security Officer Attentiveness

ML081820272
Person / Time
Site:	Susquehanna
Issue date:	07/08/2008
From:	Bhalchandra Vaidya NRC/NRR/ADRO/DORL/LPLI-1
To:	Mckinney B Susquehanna
vaidya B, NRR/Dorl/lpl1-1, 415-3308
References
TAC MD7659, TAC MD7660
Download: ML081820272 (7)

Text

July 8, 2008 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RE: BULLETIN 2007-01 SECURITY OFFICER ATTENTIVENESS (TAC NOS. MD7659 AND MD7660)

Dear Mr. McKinney:

By letter dated February 11, 2008, PPL Susquehanna, LLC (the licensee) submitted the required written response to Security Bulletin 2007-01 Security Officer Attentiveness for the Susquehanna Steam Electric Station. 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 licensee program implementation is needed.

B. McKinney 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 regarding this letter, please feel free to contact me at (301) 415-3308.

Sincerely,

/RA/

Bhalchandra K. Vaidya, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosure:

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

B. McKinney 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 regarding this letter, please feel free to contact me at (301) 415-3308.

Sincerely,

/RA/

Bhalchandra K. Vaidya, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosure:

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

PUBLIC PDI-1 RF RidsNrrDorlLPL1-1 RidsAcrsAcnwmailcenter RidsNrrPMBVaidya LRegner, NRR/DORL RidsRgn1MailCenter RidsNrrLaSLittle MBanic, NRR/DPR RidsOGCRp RCorreia, NSIR FPeduzzi, NSIR ADAMS Accession Number: ML081820272 NRR-106 OFFICE LPLI-1/PM LPLI-1/LA NSIR/BC LPLI-1/BC NAME BVaidya SLittle ( MKowal DATE 7/08/08 7/02/08 6/25/08 7/08/08 OFFICIAL RECORD COPY

Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:

Cornelius J. Gannon Bryan A. Snapp, Esq Vice President - Nuclear Operations Assoc. General Counsel PPL Susquehanna, LLC PPL Services Corporation 769 Salem Blvd., NUCSB3 Two North Ninth Street, GENTW20 Berwick, PA 18603-0467 Allentown, PA 18101-1179 Robert M. Paley Document Control Services General Manager - Plant Support PPL Susquehanna, LLC PPL Susquehanna, LLC Two North Ninth Street, GENPL4 769 Salem Blvd., NUCSB2 Allentown, PA 18101-1179 Berwick, PA 18603-0467 Richard W. Osborne Michael H. Crowthers Allegheny Electric Cooperative, Inc.

Manager - Nuclear Regulatory Affairs 212 Locust Street PPL Susquehanna, LLC P.O. Box 1266 Two North Ninth Street, GENPL4 Harrisburg, PA 17108-1266 Allentown, PA 18101-1179 Director, Bureau of Radiation Protection Dayne R. Brophy- Pennsylvania Department of Nuclear Regulatory Affairs Environmental Protection PPL Susquehanna, LLC Rachel Carson State Office Building 769 Salem Blvd., NUCSA4 P.O. Box 8469 Berwick, PA 18603-0467 Harrisburg, PA 17105-8469 Ronald E. Smith Senior Resident Inspector General Manager - Site Preparedness U.S. Nuclear Regulatory Commission and Services P.O. Box 35, NUCSA4 PPL Susquehanna, LLC Berwick, PA 18603-0035 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission Michael H. Rose 475 Allendale Road Manager - Quality Assurance King of Prussia, PA 19406 PPL Susquehanna, LLC 769 Salem Blvd., NUCSB2 Board of Supervisors Berwick, PA 18603-0467 Salem Township P.O. Box 405 Joseph J. Scopelliti Berwick, PA 18603-0035 Community Relations Manager, Susquehanna Dr. Judith Johnsrud PPL Susquehanna, LLC National Energy Committee 634 Salem Blvd., SSO Sierra Club Berwick, PA 18603-0467 443 Orlando Avenue State College, PA 16803

REQUEST FOR ADDITIONAL INFORMATION REVIEW OF SECURITY BULLETIN RESPONSES SUBMITTED IN RESPONSE TO SECURITY BULLETIN 2007-01 SUSQUEHANNA STEAM ELECTRIC STATION DOCKET NOS. 50-387 AND 50-388 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 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 the licensee conducts random or scheduled observations and they are proceduralized. The discussion should also include 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. 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?

5. 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:

6. 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.

7. 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:

8. 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.

9. 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:

10. 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.