BSEP 04-0026, Supplemental Response to the April 29, 2003, Order EA-03 -086
| ML041240306 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/29/2004 |
| From: | Gannon C Progress Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Security and Incident Response |
| References | |
| 10 CFR 50.4, BSEP 04-0026, EA-03-086 | |
| Download: ML041240306 (5) | |
Text
a SAFEGUARDS INFORMATION Cornelius J. Gannon Brunswick Nuclear Plant Progress Energy Carolinas, Inc.
April 29, 2004 SERIAL: BSEP 04-0026 10 CFR 50.4 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Supplemental Response to the April 29, 2003, Order EA-03 -086 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 "Orders") for the Brunswick Steam Electric Plant (BSEP). This Supplemental Response of Carolina Power & Light Company, doing business as Progress Energy Carolinas, Inc. (PEC), to Order EA-03-086, supplements the previous response dated June 3, 2003 (i.e., Serial: PE&RAS-03-068), that PEC filed pursuant to 10 CFR §50.4 and Section III, B.1 and B.2 of the Order.
Order EA-03-086 imposes license conditions on nuclear power plants licensed pursuant to the Atomic EnergyAct of l954 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 III.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.
In accordance with the Order and 10 CFR §50.4, PEC is submitting this Supplemental Response for BSEP. This submittal, on CD-ROM, includes revisions to the BSEP Physical Security Plan (i.e., File # 001), the BSEP Guard Training and Qualification Plan (i.e.,
File # 002), and the BSEP Safeguards Contingency Plan (i.e., 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 submittals of PEC in these areas, including those related to the February 25, 2002, January 7, 2003, and April 29, 2003, Orders. PEC will continue to implement the provisions of those NOTE: THE ENCLOSURE TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE P.O.
Box 10429 ENCLOSURE, THIS LETTER IS "DECONTROLLED" Southport. NC 28461 T>910.457.3698 SAFEGUARDS INFORMATION F> 910.457.2803
SAFEGUARDS INFORMATION Document Control Desk BSEP 04-0026 / Page 2 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.
PEC has developed these plans to be consistent with NEI-03-01 (Revision 1), Nuclear Pover Plant Access Authorization Program (April 2004); NEI-03-09 (Revision 2),
Security Officer Training Program (April 2004); and NEI-03-12 (Revision 2 (draft)),
Template for the Security Plan, Training and 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 BSEP Implementation Schedule (i.e., 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 BSEP Deviationsfrom NEI-03-12 (i.e.,
File # 005). BSEP Previous Exemptions to 10 CFR §73 (i.e., File # 006), is a listing of any exemptions to 10 CFR §73 previously granted to PEC and an explanation of their status under the plans hereby submitted. BSEP Justification forAlternatives (i.e., 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 PEC has adopted. Further, PEC 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 BSEP Justification for Vehicle Search Criteria (i.e., File # 008).
When the final revision of NEI-03-12 is approved by the NRC, PEC will supplement this response, if necessary, to conform with NEI-03-12 as finally approved. However, with the filing of these plans, PEC 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, PEC 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.
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 NOTE: THE ENCLOSURE TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ENCLOSURE, THIS LETfER IS "DECONTROLLED" SAFEGUARDS INFORMATION
SAFEGUARDS INFORMATION Document Control Desk BSEP 04-0026 / Page 3 accommodate any transitional issues which may arise as licensees, in good faith, take reasonable actions to implement the specific requirements of the Orders, PEC 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. Allen Brittain, Superintendent - Security, at (910) 457-3645.
Sincerely Cornelius J. Gannon William G Noll, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge, and belief; and the sources of his information are officers, employees, and agents of Carolina Power
& Light Company.
Notary (Seal)
My commission expires:
MoCI I'12, 2o8-CRE/cre 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
SAFEGUARDS INFORMATION Document Control Desk BSEP 04-0026 / Page 4
Enclosure:
CD-ROM entitled "BSEP-04-0026/Supl. Response to Order EA-03-086" cc (with enclosure):
U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Luis A. Reyes, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 A total of one (1) CD-ROM is included in this submission. The CD-ROM, labeled "BSEP-04-0026/Supl. Response to Order EA-03-086," contains the following eight (8) files:
001 001_BSEPPhysSecPlan.pdf 332 KB Safeguards Information 002 002_BSEP_GrdTrng.Qual_Plan.pdf 155 KB Safeguards Information 003 003_BSEPSaf_Cntngcy.Plan.pdf 283 KB Safeguards Information 004 004_BSEPjimpl-Schedule.pdf 18 KB Safeguards Information (Decontrolled) 005 005_BSEP_Dev_NEI_03_12.pdf 26 KB Safeguards Information 006 006_BSEP_PrevExempt.pdf 14 KB Safeguards Information (Decontrolled) 007 007_BSEP_JustAltern.pdf 14 KB Safeguards Information (Decontrolled) 008 008_ESEPJustVeh_Srch-Crit.pdf 23 KB Safeguards Information The files on the enclosed CD-ROM are classified as Safeguards Informnation and should be withheld from public disclosure in accordance with 10 CFR §73.21.
NOTE: THE ENCLOSURE TO THIS LEITER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ENCLOSURE, THIS LETTER IS "DECONTROLLED" SAFEGUARDS INFORMATION
r SAFEGUARDS INFORMATION Document Control Desk BSEP 04-0026 / Page 5 The contact person for the information provided on the enclosed CD-ROM is provided below:
Contact Name Mailing Address E-Mail Address Phone Number Allen Brittain Progress Energy Carolinas, Inc.
P.O. Box 10429 Southport, NC 28461-0429 allen.brittain @pgnmail.com 910457-3645 NOTE: THE ENCLOSURE TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ENCLOSURE, THIS LET1ER IS "DECONTROLLED" SAFEGUARDS INFORMATION