L-2018-067, Units 1 and 2 - Submittal of Joint Plant Access Shared Information Table

Units 1 and 2 - Submittal of Joint Plant Access Shared Information Table

ML18081A687
Person / Time
Site:	Saint Lucie, Point Beach, Seabrook, Turkey Point, Duane Arnold
Issue date:	03/19/2018
From:	Larry Nicholson Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2018-067
Download: ML18081A687 (7)

Text

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March 19, 2018 L-2018-067 Nuclear Regulatory Commission Attn: Document Control Desk

.Washington, DC 20555-0001

• Florida Power & Light Company St. Lucie Units 1 and 2, Docket Nos. 50-335, 50-389 Florida Power & Light Company Turkey Point Units 3 and 4, Docket Nos. 50-250, 50-251 NextEra Energy Seabrook, LLC Seabrook Station, Docket No. 50-443 NextEra Energy Duane Arnold, LLC Duane Arnold Energy Center, Docket No. 50-331 NextEra Energy Point Beach, LLC Point Beach Units 1 and 2, Docket Nos. 50-266, 50-301 NextEra Energy.:.Entergy Joint Plant Access Shared Information Table

Reference:

Entergy letter CNR0-2018-00011, dated March 19, 2018 Florida Power & Light Company, the licensee for the St. Lucie Nuclear Plant, Units 1 and 2, and the Turkey Point Nuclear Plant, Units 3 and 4, and on behalf of NextEra Energy Seabrook, LLC (NextEra Energy Seabrook), the licensee for Seabrook Station*; NextEra Energy Duane Arnold, LLC (NextEra Energy .Duane Arnold), the licensee for Duane Arnold Energy Center; and NextEra Energy Point Beach, LLC (NextEra Energy Point Beach), the licensee for Point Beach Nuclear Plant, Units 1 and 2 (collectively referred to as NextEra Energy) hereby submits the attached information table which describes our compliance with all elements of licensee shared information as described in 10 CFR 73.56, 10 CFR 26, and NEl-03-01 (Nuclear Power Plant Access Authoriz_ation Program). This table shows how the NextEra Energy fle_et. is implementing

• the provisions of NE! 03-01 without having access to the industry system.

T~is letter contains no new regulatory commitments.

Should you have any questions, please contact Larry Nicholson at (561) 304-6224.

Sincerely, '--

6ols~

Nuclear Licensing and Regulatory Compliance Director

Enclosure:

Florida Power & Ught Company 700 Universe Boulevard, Juno Beach, FL 33408 .

• - -----i L-2018-067 P a.g e I2 cc: USNRC Director, Office of Nuclear Security and Incident Response USNRC Regional Administrator, Region I USNRC Regional Administrator, Region 11 USNRC Regional Administrator, Region Ill USNRC Project Manager, Seabrook Station USNRC Project Manager, St. Lucie Nuclear Plant USNRC Project Manager, Turkey Point Nuclear Plant USNRC Project Manager, Duane Arnold Energy Center USNRC Project Manager, Point Beach Nuclear Plant USNRC Senior Resident Inspector, Seabrook Station USNRC Senior Resident Inspector, St. Lucie Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant USN RC Senior Resident Inspector, Duane Arnold Energy Center USNRC Senior Resident Inspector, Point Beach Nuclear Plant

L-2018-067 Enclosure Page 11 NextEra/Entergy alternative process with no Personnel Access Database System (PADS) access

Background

10 CFR 73.56(h)(6) discusses information sharing and that licensees, applicants, and contractors or vendors may rely upon the information.

NEI 03-01 Section 12 provides guidance on how the sharing of information is conducted via the information-sharing mechanism also known as the Personnel Access Data System (PADS) and states that, if the information-sharing mechanism is unavailable, licensees shall take manual actions to ensure information is shared.

1 NextEra and Entergy2 are no longer members of the Nuclear Energy Institute and therefore, as of February 4th, 2018, both fleets are now utilizing manual processes in lieu of PADS to ensure all elements of licensee shared information as described in 10 CFR 73.56, 10 CFR 26, and NEl-03-01 are being maintained.

The following table shows how both fleets are implementing the provisions of NEI 03-01 without having access to the PADS system.

NEI 03-01 Information Mitigation 12(a) The NRC requires that key access authorization and fitness-for- NextEra and Entergy provide a daily spreadsheet to industry duty program information be accessible by other power reactor counterparts via an e-mail identifying if an individual is still licensee. However, this requirement extends to other entities currently badged or has been terminated along with a favorable committed to 10 CFR 73.56, 10 CFR 26, and NEI 03-01 who agree or unfavorable flag. The receiving licensees are responsible for to participate in the industry information-sharing program. The checking the list and requesting any further information or a section defines the minimum elements that must be made transfer of an individual's record.

available by licensees or other entities to meet requirements.

The industry database may require additional information to facilitate data management and audit requirements.

12(c) If the shared information used for determining an individual's On a daily basis, NextEra and Entergy transfer those individuals trustworthiness and reliability changes or new or additional who have been placed in a denial status or have a change in information is developed about the individual, the licensees or status in the follow-up drug testing program to NEI PADS Contractor/Vendors (C/V's) that acquire this information shall Central. PADS central then adds those individuals to the PADS correct or augment the data contained in the information sharing database and provides NextEra and Entergy with a new daily list mechanism. of those currently denied or in a follow-up program.

1 In this paper, NextEra refers to Florida Power & Light Company, NextEra Energy Seabrook, LLC, NextEra Energy Duane Arnold, LLC, and NextEra Energy Point Beach, LLC.

2 In this paper, Entergy or Entergy Nuclear, refers to both Entergy Operations, Inc., the licensee for the Arkansas Nuclear One Units 1 & 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford 3 Steam Electric Station, and to Entergy Nuclear Operations, Inc., the licensee for Indian Point Nuclear Generating Units 2 & 3, Palisades Nuclear Power Plant and Pilgrim Nuclear Power Station.

L-2018-067 Enclosure Page 12 NextEra/Entergy alternative process with no Personnel Access Database System (PADS) access 12(d) If the changed, additional or developed information has In addition to the data provided to PADS Central for the daily implications for adversely affecting and individual's update or the industry e-mailed spreadsheet, separate forms trustworthiness and reliability, the licensee or C/V who were developed for Potentially Disqualifying Information {POI) discovered or obtained the new, additional or changes and 10 CFR Part 26 Follow-up program requirements for information, shall on the day of discovery, inform the reviewing providing the industry information of any change where the official of any licensee access authorization program under which licensee could request a transfer of information.

the individual is maintaining his or her UAA/UA status of the updated information. As some licensees note changes to individuals that may affect their access, the licensees are providing the individual's name to us as notice. Our internal systems are checked to determine whether the individual is or has ever been badged at any of the NextEra or Entergy fleet sites. If currently badged, a transfer of information is requested from the licensee that provided the information to obtain the relevant details in order to make an access determination. If never badged, the licensee supplying the information is informed of such. Other licensees are providing their derogatory information to both NextEra and Entergy to ensure compliance since there is no awareness if the individual is currently badged at our.sites. Our response is a courtesy. _If the individual was badged at some point but is not currently badged, our internal system is annotated with the appropriate flag for resolution upon their return to any fleet site.

L-2018-067.

Enclosure Page 13 NextEra/Entergy alternative process with no Personnel Access Database System (PADS) access 12{f) If the information-sharing mechanism is unavailable and a Because NextEra and Entergy no longer have access to PADS, notification of change or updated information is required, this provision is critical to NextEra's and Entergy's regulatory licensees and C/V's shall take manual actions to ensure that the compliance .. Transfer of information forms were developed by information is shared and update the data in the information- NextEra and Entergy independently of NEI forms and sharing mechanism as soon as reasonably possible. automated for fast turnaround on a licensee request. Similarly when NextEra or Entergy requires information fror:n another licensee, a transfer request is provided to a receiving licensee for their cooperation and.response. Some licensees are not willing to provide any access or FFD information such as dates of access, fingerprinting and drug testing, etc. so alternate measures are taken in lieu of their response such as, conducting a new initial investigation, going back to the last known licensee where information can be validated and re-fingerprinting those individuals. The denial list and the follow-up lists are checked prior to the certifying of Unescorted Access Authorization (UAA) or the* granting of Unescorted Access {UA}.

12{g) Records maintained in the database must be available for NRC Records associated with this proc;ess are available for review by review. the NRC.

12.l{c) c. The most recent data that provides the basis for the current Key UAA/UA elements are made available to the industry via authorization needs to be provided. The information to be the daily spreadsheet identified in 12(a) above. If a licensee shared includes: identifies an individual on the spreadsheet where they would

1. date current UAA/UA granted; require a transfer of information, this information would be

2. employer; provided upon their request.

3. date psychological evaluation completed;

4. date CHRI received (the date the CHRI is reviewed and approved);

5. date of FFD chemical sample collected and reason for test;

6. date Bl and suitable inquiry completed;

7. licensee providing the information;.

8. company holding the supporting records, if not the licensee;

9. whether additional information is held by the licensee;

10. follow-up information; begin date, estimated end date frequency of testing, and number of tests required; and

11. whether the individual is participating in a treatment plan.

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L-2018-067 Enclosure Page 14 NextEra/Entergy alternative process with no Personnel Access Database System (PADS) access 12.l(d) d. For individuals granted UAA/UA after July 7, 2003, the Key UAA/UA elements are made available to the industry via information to be shared includes: the daily spreadsheet identified in 12(a) above. If a licensee

1. date UA granted; identifies an individual on the spreadsheet where they would

2. employer; require a transfer of information, this information would be

3. citizenship; provided upon their request.

4. date psychological evaluation completed;

5. date CHRI received, (the date the CHRI is reviewed and approved);

6. date of FFD chemical sample collected and reason for test;

7. date of completion of Plant Access Training and BOP training and other training as defined in NEI 03-04;

8. date UAA completed;

9. licensee providing the information;

10. company holding the supporting records, if not the licensee;

11. whether additional information is held by the licensee; and

12. follow-up information; begin date, estimated end date frequency of testing, and number of tests required.

12.l(f)&(g) f. Licensees shall ensure the demographic information of any Upon a licensee's identification of an individual on the person formally applying for UAA/UA to a licensee facility, is spreadsheet where they would require a transfer of added to or updated in the method. information, this information would be provided to the

g. Demographic data for individuals granted UA after July 7, 2003 requesting licensee upon their request.

includes:

1. current address;

2. height;

3. weight;

4. eye color;

5. hair color;

6. gender; and

7. Place of birth (city, US state or province, and country if not US).

12.4(a) Licensees shall ensure those persons denied UA since January 1, See 12(a) above 1997, are identifiable by other licensees through the established methods.

12.S(a) Licensees shall include the follow-up information regarding all See 12(c) above persons in a UAA/UA status, including the date the follow-up commenced and the date the follow-up is expected to end.

L-2018-067 Enclosure \

Page IS NextEra/Entergy alternative process with no Personnel Access Database System (PADS) access 12.6(c) UAA/UA Denial Review Process On a daily basis, NextEra and Entergy transfers to NEI PADS (c) If the review finds in favor of the individual, the licensee shall Central the names of those individuals who had been placed in update the releva*nt Jecords to reflect the outcome of th.e review a denial status and. subsequently have had their denial and delete or correct all information the review found to be overturned through the UAA/UA Denial Review Process.

inaccurate.

12.7(a) Except for emergency conditions e.g., ambulance, fire, law See 12(c) above. In addit.ion, the spreadsheet from PADS enforcement response, etc., and NRC employees, all visitors will central is uploaded to a security file share where it is accessed be checked against the industry database to ensure that they are by those performing visitor checks prior to an individual's entry not currently denied access. The check for each visitor will be into the PA.

performed at least once daily (00:01-2400 hours) prior to the worker's first daily entry int.a the protected area.

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