3F0404-08, Supplemental Response to the April 29, 2003, Order EA-03-086
| ML041240254 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 04/29/2004 |
| From: | Young D Progress Energy Florida |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response |
| References | |
| 3F0404-08, EA-03-086 | |
| Download: ML041240254 (6) | |
Text
Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 SAFEGUARDS INFORMATION Ref. 10 CFR §50.4 10 CFR §2.202 10 CFR §50.54(p)
April 29, 2004 3F0404-08 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Crystal River Unit 3 - Supplemental Response to the April 29, 2003, Order EA-03-086
References:
(1) Progress Energy to NRC letter, PE&RAS-03-068, "Answer, Response And Request For Clarification In Response To April 29, 2003, Order Requiring Compliance With Revised Design Basis Threat For Operating Power Reactors (EA-03-086)," dated June 3, 2003 (2) NRC to Crystal River Nuclear Generating Plant, "Issuance Of Order Requiring Compliance With Revised Design Basis Threat For Operating Power Reactors (EA-03-086)," dated April 29, 2003 Ladies and Gentlemen:
The NRC issued an Order dated April 29, 2003, Requiring Compliance with Revised Design Basis Threat ('Order EA-03-086" or "Order") and other security related Orders (collectively uOrders") for Crystal River Unit 3 (CR-3). This Supplemental Response of Florida Power Corporation, doing business as Progress Energy Florida, Inc. (PEF), to Order EA-03-086, supplements the previous response dated June 3, 2003 (Reference 1), that PEF filed pursuant to 10 CFR §50.4 and Section l1l, B.1 and B.2 of the Order.
Order EA-03-086 imposes license conditions on nuclear power plants licensed pursuant to the Atomic Energy Act of 1954 and Title 10 of the Code of Federal Regulations.Section III.A of the Order requires licensees to revise their physical security plans and safeguards contingency plans to provide protection against the revised design basis threat (DBT) set forth in Attachment 2 to the Order. Section IlI.A also requires licensees to revise the security force training and qualification plan to implement the revised DBT. These revised plans, along with an implementation schedule, were required to be submitted to the Commission for review and approval no later than April 29, 2004.
NOTE: THE ENCLOSURE TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ENCLOSURE, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION Progress Energy Florida, Inc.
Crystal River Nuclear Plant 15760 W. Powerline Street Crystal River, FL 34428
I U.S. Nuclear Regulatory Commission Page 2 of 5 3F0404-08 SAFEGUARDS INFORMATION In accordance with the Order and 10 CFR §50.4, PEF is submitting this Supplemental Response for CR-3. This submittal, on CD-ROM, includes revisions to the CR-3 Physical Security Plan (File # 001), the CR-3 Guard Training and Qualification Plan (File # 002), and the CR-3 Safeguards Contingency Plan (File # 003) as required by Order EA-03-086. These plans contain the integrated commitments to comply with Order EA-03-086, and other security related Orders issued on February 25, 2002, January 7, 2003, and April 29, 2003. As a result, these plans supersede previous PEF submittals in these areas, including those related to the February 25,2002, January 7, 2003, and April 29, 2003, Orders. PEF will continue to implement the provisions of those previous submittals except to the extent that they are superseded by these plans. All changes being implemented as part of these plans are evaluated, prior to implementation, to ensure that the changes do not compromise plant safety.
PEF has developed these plans to be consistent with NEI-03-01 (Revision 1), Nuclear Power Plant Access Authorization Program(April 2004); NEI-03-09 (Revision 2), Security Officer TrainingProgram (April 2004); and, NEI-03-12 (Revision 2 (draft)), Template for the Security Plan, Trainingand Qualification Plan, Safeguards Contingency Plan, [and Independent Spent Fuel Storage Installation Security Program](April 2004). The schedule for completing those actions, which includes the identification of major transactional activities, is provided in the CR-3 Implementation Schedule (File # 004). To facilitate the NRC's review, any provisions that are different from NEI-03-12 are identified and the justification provided in the CR-3 Deviations from NEI-03-12 (File # 005). CR-3 Previous Exemptions to 10 CFR §73 (File # 006), is a listing of any exemptions to 10 CFR §73 previously granted to PEF and an explanation of their status under the plans hereby submitted. CR-3 Justification forAltematives (File # 007), includes the justification for any of the alternatives provided in NEI-03-12 or in "NRC Guidance on Implementation of the April 2003 Revised Design Basis Threat" that PEF has adopted. Further, PEF has chosen to implement Option 2 of Section 9.4.1.2 of NEI-03-12 and the justification for that choice is provided in CR-3 Justification for Vehicle Search Criteria(File # 008).
When the final revision of NEI-03-12 is approved by the NRC, PEF will supplement this response, if necessary, to conform with NEI-03-12 as finally approved. However, with the filing of these plans, PEF will be implementing its revised protection strategy and completing plant modifications and security personnel training pursuant to these plans to ensure that implementation will be completed by October 29, 2004, as required by the Orders. Upon completion of the implementation of these plans, PEF will be in compliance with all applicable security requirements. For the purpose of complying with the requirements of 10 CFR §73 to conduct an annual audit, the date of the letter that will be submitted to the NRC pursuant to Order EA-03-086 certifying that implementation of the plans is complete will be the effective date for determining commencement of the annual audit requirement period.
NOTE: THE ENCLOSURE TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ENCLOSURE, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION
U.S. Nuclear Regulatory Commission Page 3 of 5 3F0404-08 SAFEGUARDS INFORMATION Because of the requirement for these plans to be fully implemented by October 29, 2004; the need to integrate the requirements of the revised DBT Order with the Orders issued February 25, 2002, January 7, 2003, and April 29, 2003; and the Commission's determination that it would be appropriate to exercise enforcement discretion to accommodate any transitional issues which may arise as licensees, in good faith, take reasonable actions to implement the specific requirements of the Orders, PEF requests that enforcement discretion be exercised during the transition period until full implementation of the plans is accomplished and the physical plant modifications and security force training are complete. At that time, the revised plans will be fully implemented and the exercise of enforcement discretion will no longer be necessary.
Please refer questions regarding this submittal to Mr. Scott S. Young, Superintendent -
Security, at (352) 563-4911.
Sincerely,
,42SeL4 Dale E. Young Vice President Crystal River Nuclear Plant DEY/dwh
Enclosure:
CD-ROM entitled "CR-3 Letter 3F0404-08/Supplemental Response to Order EA-03-086" xc: NRR Project Manager (w/o enclosures)
Regional Administrator, Region II (w/o enclosures)
Senior Resident Inspector (w/o enclosures)
NOTE: THE ENCLOSURE TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ENCLOSURE, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION
U.S. Nuclear Regulatory Commission Page 4 of 5 3F0404-08 SAFEGUARDS INFORMATION STATE OF FLORIDA COUNTY OF CITRUS Dale E. Young states that he is the Vice President, Crystal River Nuclear Plant for Florida Power Corporation, doing business as Progress Energy Florida, Inc.; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
Dale E. Young A Vice President Crystal River Nuclear Plant The foregoing document was acknowledged before me this Q4 day of 2004, by Dale E.Young.
Signature of Notary Public
- ~NWrm Rt l 5 d Fbddc State of Florida
- t':_owadn Cabal 249159 hAndNfV_ 1-154 A (fad dJ/S (Print, type, or stamp Commissioned Name of Notary Public)
Personally Produced Known . -OR- Identification NOTE: THE ENCLOSURE TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ENCLOSURE, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION
U.S. Nuclear Regulatory Commission Page 5 of 5 3F0404-08 SAFEGUARDS INFORMATION A total of one (1) CD-ROM is included in this submission. The CD-ROM, labeled "CR-3 Letter 3F0404-08/Supplemental Response to Order EA-03-086," contains the following eight (8) files:
Fi.- Fil Til.File Size File Classification:
001 001 CR-3_PhysSecPlan.pdf 365 KB Safeguards Information 002 OO2CR-3_Grd_TrngQualPlan.pdf 224 KB Safeguards Information 003 003CR-3_Cntngcy-Plan.pdf 372 KB Safeguards Information 004 004CR-3_lmpLSchedule.pdf 37 KB Safeguards Information (Decontrolled) 005 005CR-3_Dev_NEI-03-12.pdf 25 KB Safeguards Information (Decontrolled) 006 006CR-3_PreyExempt.pdf 25 KB Safeguards Information (Decontrolled) 007 OO7CR-3_JustAltern.pdf 25 KB Safeguards Information (Decontrolled) 008 OO8CR-3_JustVeh_SrchCrit.pdf- 24 KB Safeguards Information The files on the enclosed CD-ROM are classified as Safeguards Information and should be withheld from public disclosure in accordance with 10 CFR §73.21.
The contact person for the information provided on the enclosed CD-ROM is provided below:
Contact Name Scott S. Young Mailing Address Progress Energy Florida, Inc.
Crystal River Nuclear Plant (Mail Code NA2S) 15760 W. Powerline Street Crystal River, FL 34428 E-Mail Address scott.young@pgnmail.com Phone Number 352-563-4911 NOTE: THE ENCLOSURE TO THIS LETTER CONTAINS "SAFEGUARDS I
INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ENCLOSURE, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION
SAFEGUARDS INFORMATION PROGRESS ENERGY FLORIDA, INC.
CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 ENCLOSURE CD-ROM ENTITLED "CR-3 Letter 3F0404-08/SUPPLEMENTAL RESPONSE TO ORDER EA-03-086" NOTE: THE ENCLOSURE TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ENCLOSURE, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION