CNRO-2003-00002, Response to Issuance of Orders to Modify License for Revised Design Basis Threat and Compensatory Measures Related to Security Force Training and Fitness-for-Duty
| ML031560372 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, Grand Gulf, Pilgrim, Arkansas Nuclear, River Bend, Vermont Yankee, Waterford, FitzPatrick  |
| Issue date: | 06/03/2003 |
| From: | Gabe Taylor Entergy Nuclear Operations, Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BVY-03-52, CNRO-2003-000025, ENO 2.03.080, JPN-03-013, NL-03-096 | |
| Download: ML031560372 (12) | |
Text
Entergy Nuclear
- Entergy P.O. Box 31995 Jackson, MS 39286-1995 CNRO-2003-000025 NL-03-096 BVY-03-52 ENO Ltr. 2.03.080 JPN-03-013 June 3, 2003 Via Overnight Delivery U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 301-415-7000
SUBJECT:
Entergy Operations, Inc., Entergy Nuclear Operations, Inc. - Response to Issuance of Orders to Modify License for Revised Design Basis Threat and Compensatory Measures Related to Security Force Training and Fitness-For-Duty Indian Point 2 and 3 Nuclear Power Vermont Yankee Nuclear Power Plant Station Docket Nos. 50-247 and 50-286 Docket No. 50-271 License Nos. DPR-26, DPR-64 License No. DPR-28 Pilgrim Nuclear Power Station Arkansas Nuclear One Docket No. 50-293 Units 1 and 2 License No. DPR-35 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 James A. FitzPatrick Nuclear Waterford 3 Steam Electric Power Plant Station Docket No. 50-333 Docket No. 50-382 License No.DPR-59 License No. NPF-38 Grand Gulf Nuclear Station River Bend Station Docket No. 50-416 Docket No. 50-458 License No. NPF-29 License No. NPF-47
REFERENCES:
See Below 505
CNRO-2003-000025 NL-03-096 BVY-03-52 ENO Ltr. 2.03.080 JPN-03-013 Page 2 of 5
Dear Sir or Madam:
In response to the events of September 11, 2001, Entergy (Entergy Operations, Inc., or Entergy Nuclear Operations, Inc.) on its own and in response to NRC Advisories, Orders and industry initiatives, promptly initiated and maintained heightened security measures to continue to provide high assurance that activities involving special nuclear material are not inimical to the common defense and security and do not constitute an unreasonable risk to the public health and safety in the current threat environment.
On April 29, 2003, the NRC issued Orders requiring additional compensatory measures as prudent to address the current security threat environment. Pursuant to the requirements of 10 CFR § 50.4, the attachment to this letter contains Entergy's responses to the referenced Orders.
Entergy fully intends to comply with the Orders. Entergy notes the request for clarification of five Design Basis Threat (DBT) issues provided in the safeguards attachment to the letter from Mr. Colvin, President and CEO of the Nuclear Energy Institute, Inc., to Chairman Diaz dated May 16, 2003. Entergy encourages the Commission to respond to this request as soon as possible as the Commission's clarifications may affect the manner of its compliance with the Orders.
Pursuant to the requirements of 10 CFR § 2.202(a)(2), a document relating to the answers to the three Orders is being transmitted to the Secretary of the Commission under separate cover. In addition, Entergy has sent a letter to the Director, Office of Nuclear Reactor Regulation requesting an extension of time in which to submit an answer and request a hearing for one of the orders and for certain relief regarding the two other orders. As required by Condition IIL.C of the DBT Order and Condition III.C.2 of the other two Orders, Entergy will notify the Commission when full compliance with each Order has been achieved.
If you have any questions or require additional information, please contact Mr. L. England at 601-368-5766.
This letter includes new commitments as summarized in Attachment 2.
CNRO-2003-000025 NL-03-096 BVY-03-52 ENO Ltr. 2.03.080 JPN-03-013 Page 3 of 5 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 3rd day of June, 2003.
Sincerely, GaryY.'aylco Chief Executive Officer Entergy Operations, Inc., Entergy Nuclear Operations, Inc.
GJT/LAE/bal Attachments Response to Issuance of Orders List of Commitments REFERENCES NRC Letters from Samuel J. Collins to Holders of Licenses for Operating Power Reactors as listed in Enclosure 2, dated April 29, 2003 Regarding Issuance of Order Requiring Compliance with Revised Design Basis Threat for Operating Power Reactors (EA-03-086), Issuance of Order for Compensatory Measures Related to Training Enhancements on Tactical and Firearms Proficiency and Physical Fitness Applicable to Armed Nuclear Power Plant Security Force Personnel (EA-03-039) and Issuance of Order for Compensatory Measures Related to Fitness-For-Duty Enhancements Applicable to Nuclear Facility Security Force Personnel (EA-03-038)
(RBC-50030,50031 & 50027; GNRI 2003/00045,2003/00041 & 2003/00040; OCNA040310, OCNA040311, & OCNA040312; and ILN 03-0039,03-0040 &
03-0041 respectively) cc: all w/ attachments Mr. C. G. Anderson (N-GSB) Mr. N. S. Reynolds (W&S)
Mr. J. L. Blount (M-ECH-62) Mr. L. J. Smith (Wise Carter)
Mr. W. R. Campbell (M-ECH-38) Mr. J. E. Venable (W-GSB-300)
Mr. W. A. Eaton (M-ECH-579) Mr. M. J. Wetterhahn (W&S)
Mr. P. D. Hinnenkamp (R-GSB-40) Mr. G. A. Williams (G-ESC3-VPO)
Mr. J. R. McGaha (M-ECH-65)
CN RO-2003-000025 NL-03-096 BVY-03-52 ENO Ltr. 2.03.080 JPN-03-013 Page 4 of 5 cc: (Continued)
Mr. T. W. Alexion, P.M., (ANO-2) Mr. P. J. Alter, SRI, RBS w/a Mr. N. Kalyanam, P.M., (W-3) Mr. R. L. Bywater SRI, ANO w/a Mr. J. L. Minns, P.M.,(ANO-1) Mr. M. C. Hay, SRI, W-3 w/a Mr. B. K. Vaidya, P.M., (GGNS) Mr. T. L. Hoeg, SRI, GGNS w/a Mr. M. K. Webb, P.M.,(RBS) (SRIs via Company Mail)
Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 07-D-01 Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission Assistant General Counsel for Materials ATTN: Mr. Samuel J. Collins, Director Litigation and Enforcement Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 05-E-07 Washington, DC 20555-0001 One White Flint North (via facsimile) 11555 Rockville Pike Rockville, MD20852-2738 301-415-7000 (via overnight delivery)
Office of the Secretary Regional Administrator U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission, ATTN: Rulemakings and Adjudications Staff Region IV Washington, DC 20555-0001 611 Ryan Plaza Drive, Suite 400 (via facsimile) Arlington, TX 76011-8064 Mr. Bernard R. Bevill Dr. E. F. Thompson Director Division of Radiation State Health Officer Control and Emergency Management State Board of Health Arkansas Department of Health PO Box 1700 4815 West Markham Street Jackson, MS 39205 Little Rock, AR 72205 Mr. Hubert Miller Mr. Prosanta Chowdhury Regional Administrator, Region I Program Manager - Surveillance Division U.S. Nuclear Regulatory Commission Louisiana Dept of Environmental Quality 475 Allendale Road PO Box 82215 King of Prussia, PA 19406-1415 Baton Rouge, LA 70884-2215
CNRO-2003-000025 NL-03-096 BVY-03-52 ENO Ltr. 2.03.080 JPN-03-013 Page 5 of 5 cc: (Continued)
Mr. Martin J. Virgilio Mr. David O'Brien Director, Office of Nuclear Material Safety Commissioner and Safeguards Department of Public Service U. S. Nuclear Regulatory Commission 120 State Street, Drawer 20 Washington, DC 20555-0001 Montpelier, VT 05602-2601 Mr. Guy S. Vissing, Project Manager Mr. Patrick D. Milano Sr. Project Manager Project Directorate I Project Directorate I Division of Licensing Project Management Division of Licensing Project Management Office of Nuclear Reactor Regulation Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Mail Stop: O-8-C2 Washington, DC 20555-0001 Washington, DC 20555-0001 Senior Resident Inspector Resident Inspector's Office Indian Point Unit 2 Indian Point Unit 3 U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission P. 0. Box 38 P. 0. Box 337 Buchanan, NY 10511-0038 Buchanan, NY 10511-0337 Resident Inspector's Office Resident Inspector James A. FitzPatrick Vermont Yankee Nuclear Power Station U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission P. 0. Box 136 320 Governor Hunt Road Lycoming, NY 13093-0136 P. O. Box 157 Vernon, VT 05354 Mr. Travis Tate, Project Manager Mr. Robert M. Pulsifer, Project Manager Project Directorate I Project Directorate I Division of Licensing Project Management Division of Licensing Project Management Office of Nuclear Reactor Regulation Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Mail Stop 0-8-B-1A Mail Stop 0-8-B-1 Washington, DC 20555-0001 Washington, DC 20555-0001
Attachment 1 CNRO 2003-00025 NL-03-096 BVY-03-52 ENO Ltr. 2.03.080 JPN-03-013 Response to Issuance of Orders to Modify License for Revised Design Basis Threat and Compensatory Measures Related to Security Force Training and Fitness-For-Duty
Page 1 of 3 Compliance with Revised Design Basis Threat (DBT) Order Order EA-03-086 item liI A. 1 All licensees shall, notwithstanding the provisions of any Commission regulation, license, or order to the contrary, revise their physical security plans and safeguards contingency plans, prepared pursuant to 10 C.F.R. §§ 50.34(c) and 50.34(d), to provide protection against the DBT set forth in attachment 2 to the Order. In addition, all licensees shall, notwithstanding the provisions of any Commission regulation, license, or order to the contrary, revise their guard training and qualification plans, required by 10 C.F.R. § 73.55(b)(4)(ii), to implement the DBT set forth in Attachment 2 to Order EA-03-086.
EnterqV Response to Order EA-03-086 item IlIl A.1 Entergy will, subject to the relief requested in the form of clarifications, submit to the Commission for review and approval no later than April 29, 2004 the revised physical security plans, safeguards contingency plans, and guard training and qualification plans, including an implementation schedule, which will describe how the facilities will respond to the design basis threat contained in Attachment 2 to the Order.
Page 2 of 3 Compensatory Measures Related to Security Training Order Order EA-03-039 item III.A.1 All licensees shall, notwithstanding the provisions of any Commission regulation or license to the contrary, comply with the requirements described in Attachment 2 to Order EA-03-039 except to the extent that a more stringent requirement is set forth in the licensee's security plan and training and qualification plan.
Enterqv Response to Order EA-03-039 item IlIl A.1 Entergy is implementing, subject to the relief requested in the form of clarifications, the requirements in Attachment 2 to Order EA-03-039 and shall complete implementation as set forth below, fully training and qualifying all armed security force personnel on the new requirements no later than October 29, 2004.
The requirements of Item C.1.a will be complete by April 29, 2004.
Entergy will be incompliance with the requirements of Item C.1.b by October 29, 2004.
Entergy will be in compliance with the requirements of Item C.1.c by October 29, 2004 following completion of Item C.2.
Entergy will be in compliance with the requirements of Item C.1.d by April 29, 2004 following completion of C.2 and C.4.
Entergy will be in compliance with the requirements of Item C.1.e upon completion of item C.2. on April 29, 2004.
The requirements of Item C.2.a.1 will be complete by April 29, 2004.
The requirements of Item C.2.a.2 will be complete by April 29, 2004.
Entergy is currently in compliance with the requirements with Item C.2.a.3.
The requirements of Item C.2.a.4 will be complete by April 29, 2004.
The requirements of Item C.2.a.5 will be complete by April 29, 2004.
The requirements of Item C.2.a.6 will be complete by April 29, 2004.
For ANO, GGNS, RBS, VY and W3 the requirements of Item C.2.b will be completed by April 29, 2004. Currently IPEC, JAF and PNPS are in compliance.
Entergy will be in compliance with the requirements of Item C.3 by April 29, 2004.
The requirements of Item C.4 will be complete by April 29, 2004.
Page 3 of 3 Compensatory Measures Related to Security Fitness-for-Duty Order Order EA-03-038 item Ill. A All licensees shall, notwithstanding the provisions of any Commission regulation or license to the contrary, comply with the requirements described in Attachment 2 to Order EA-03-038 except to the extent that a more stringent requirement is set forth in the Licensee's security plans.
EnterqV Response to Order EA-03-038 item I A.1 Entergy will immediately start implementation of the requirements in Attachment 2 to Order EA-03-038 and, subject to the relief requested and the possible request for a hearing, will be in compliance by October 29, 2003.
Attachment 2 CNRO 2003-00025 NL-03-096 BVY-03-52 ENO Ltr. 2.03.080 JPN-03-013 List of Regulatory Commitments
Page 1 of 2 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document.
Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE SCHEDULED (Che ck one) COMPLETION ONE-TIME CONTINUING DATE (If COMMITMENT ACTION COMPLIANCE Required)
As required by Condition III.C.2 of the FFD x October 29, Order, Entergy will notify the Commission when 2003 full compliance has been achieved.
As required by Condition I.C.2 of the DBT and x October 29, Training Orders, Entergy will notify the 2004 Commission when full compliance has been achieved.
As required by Condition III.A.1 of the DBT x April 29, 2004 Order submit the revised physical security plans, safeguards contingency plans, and guard training and qualification plans, including an implementation schedule to the Commission for review and approval.
Complete the requirements of Training Order x October 29, EA-03-039 Attachment 2 fully training and 2004 qualifying all armed security force personnel on the new requirements Complete the requirements of Training Order x April 29, 2004 EA-03-039 Attachment 2 Item C.1.a Comply with the requirements of Training Order x October 29, EA-03-039 Attachment 2 Item C.1.b 2004 Comply with the requirements of Training Order x October 29, EA-03-039 Attachment 2 Item C.1.c 2004 Comply with the requirements of Training Order x April 29, 2004 EA-03-039 Attachment 2 Item C.1.d Comply with the requirements of Training Order x April 29, 2004 EA-03-039 Attachment 2 Item C.1.e Complete the requirements of Training Order x April 29, 2004 EA-03-039 Attachment 2 Item C.2.a.1 Complete the requirements of Training Order x April 29, 2004 EA-03-039 Attachment 2 Item C.2.a.2 The requirements of Training Order EA-03-039 x In Compliance Item C.2.a.3 Complete the requirements of Training Order x April 29, 2004 EA-03-039 Attachment 2 Item C.2.a.4 Complete the requirements of Training Order x April 29, 2004 EA-03-039 Attachment 2 Item C.2.a.5 Complete the requirements of Training Order x April 29, 2004 EA-03-039 Attachment 2 Item C.2.a.6 Complete the requirements of Training Order X April 29, 2004 EA-03-039 Attachment 2 Item C.2.b
Page 2 of 2 TYPE SCHEDULED (Ch ck one) COMPLETION ONE-TIME CONTINUING DATE (If COMMITMENT ACTION COMPLIANCE Required)
Complete the requirements of Training Order X April 29, 2004 EA-03-039 Attachment 2 Item C.3 Comply with the requirements of Training Order x April 29, 2004 EA-03-039 Attachment 2 Item C.4 Complete the requirements of FFD Order EA- x October 29,03-038 Attachment 2 Item C.1, C2 & C.4 2003 Provide Answer to FFD Order 35 days from x TBD receipt of NRC decision. I_I_ _