ML081850030

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

ML081850030
Person / Time
Site:	Diablo Canyon
Issue date:	07/10/2008
From:	Wang A B NRC/NRR/ADRO/DORL/LPLIV
To:	Conway J Pacific Gas & Electric Co
Wang, A B, NRR/DORL/LPLIV, 415-1445
References
BL-07-001, TAC MD7593, TAC MD7594
Download: ML081850030 (7)

Text

July 10, 2008 Mr. John Conway Senior Vice President - Station Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 770000 San Francisco, CA 94177-0001

SUBJECT:

DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO NRC BULLETIN 2007-01, "SECURITY OFFICER ATTENTIVENESS" (TAC NOS. MD7593 AND MD7594)

Dear Mr. Conway,

By letter dated February 11, 2008, Pacific Gas and Electric Company (PG&E, the licensee) submitted the required written response to U.S. Nuclear Regulatory Commission (NRC)Bulletin 2007-01 "Security Officer Attentiveness" for the Diablo Canyon Power Plant, Unit Nos. 1 and 2.

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 NRC 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

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 NRC 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.

J. Conway

If you have any question, please contact me at 301-415-1445.

Sincerely,

/RA Jack Donohew for/

Alan Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos. 50-275 and 50-323

Enclosure:

Request for Additional Information

cc w/encl: see next page J. Conway

If you have any question, please contact me at 301-415-1445.

Sincerely,

/RA Jack Donohew for/

Alan Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos. 50-275 and 50-323

Enclosure:

Request for Additional Information

cc w/encl: See next page

DISTRIBUTION:

PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrLAGLappert Resource RidsNrrPMAWang Resource RidsOgcRp Resource RidsRgn4MailCenter Resource LRegner, NRR/DORL/TA MBanic, NRR/DPR/PGCB FPeduzzi, NSIR/DSO RCorreia, NSIR/DSO GWest, NSIR/DSO DHuyck, NSIR/DSP

ADAMS Accession Number: ML081850030 NSIR e-mail Package ML081820158 OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC (A)

NRR/LPL4/PM

NAME AWang GLappert BSingal AWang JNW for DATE 7/9/08 7/8/08 7/10/08 7/10/08 OFFICIAL RECORD COPY Diablo Canyon Power Plant, Units 1 and 2 (3/10/2008 2007)

cc:

NRC Resident Inspector Diablo Canyon Power Plant c/o U.S. Nuclear Regulatory Commission P.O. Box 369 Avila Beach, CA 93424

Sierra Club San Lucia Chapter ATTN: Andrew Christie P.O. Box 15755 San Luis Obispo, CA 93406

Ms. Nancy Culver San Luis Obispo Mothers for Peace P.O. Box 164 Pismo Beach, CA 93448

Chairman San Luis Obispo County Board of Supervisors 1055 Monterey Street, Suite D430 San Luis Obispo, CA 93408

Mr. Truman Burns Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, CA 94102

Diablo Canyon Independent Safety Committee Attn: Robert R. Wellington, Esq.

Legal Counsel 857 Cass Street, Suite D Monterey, CA 93940 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 612 E.Lamar Blvd., Suite 400 Arlington, TX 76011-41254

Jennifer Post, Esq.

Pacific Gas & Electric Company P.O. Box 7442 San Francisco, CA 94120

City Editor The Tribune 3825 South Higuera Street P.O. Box 112 San Luis, Obispo, CA 94306-0112

Director, Radiologic Health Branch State Department of Health Services P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414

Mr. James Boyd, Commissioner California Energy Commission 1516 Ninth Street MS (31)

Sacramento, CA 95831

Mr. James R. Becker Site Vice President Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424

Jennifer Tang Field Representative United States Senator Barbara Boxer 1700 Montgomery Street, Suite 240 San Francisco, CA 94111

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION RELATED TO NRC BULLETIN 2007-01, "SECURITY OFFICER ATTENTIVENESS" PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-275 AND 50-323

By letter dated February 11, 2008, Pacific Gas and Electric Company (PG&E, the licensee) submitted the required written response to Security Bulletin 2007-01 "Security Officer Attentiveness" for the Diablo Canyon Power Plants, Unit Nos. 1 and 2. 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. 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 U.S. Nuclear Regulatory Commission (NRC) staff reviewed your response to Question 1 and requests the following additional information:

1. How is the licensee's 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 1a and requests the following additional information:

2. 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:

3. 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.

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

4. 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 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 4 and requests the following additional information:

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 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) trai ning opportunities for staff to read and understand the policy.

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

8. 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 licensee's 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.