DCL-04-054, Supplemental Response to the April 29. 2003. Orders to Pacific Gas & Electric Company
| ML041260204 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/28/2004 |
| From: | Rueger G Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Security and Incident Response |
| References | |
| DCL-04-054, EA-03-086 | |
| Download: ML041260204 (6) | |
Text
I WI Pacific Gas and Electric company-SAFEGUARDS INFORMATION Gregory M. Rueger US MaW:
Senior Vice President-Mail Code 832 Generation and Pacific Gas and Electric Company Chief Nuclear Officer PO Box 770000 April 28, 2004 San Francisco, CA 94177-0001 Overnight Mail.
Mail Code 832 PG&E Letter DCL-04-054 Pacific Gas and Electric Company 77 Beale Street. 32nd Floor San Francisco, CA 94105-1814 U.S. Nuclear Regulatory Commission 415.973.4684 ATTN: Document Control Desk Fax: 415.973.2313 Washington, DC 20555-0001 Diablo Canyon Units 1 and 2 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Supplemental Response to the April 29. 2003. Orders to Pacific Gas & Electric Company. Diablo Canyon Power Plant Units I and 2
Dear Commissioners and Staff:
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 Diablo Canyon Power Plant Units 1 and 2 (DCPP). This Supplemental Response of Pacific Gas and Electric Company (PG&E) to Order EA-03-086 supplements the previous response, PG&E Letter DCL-03-064, dated June 2, 2003, that PG&E filed pursuant to 10 CFR § 50.4 and Section 1II, Conditions A.1, B.1 and B.2.
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 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, PG&E is submitting this Supplemental Response for the above-mentioned licensed facility. This submittal includes, as Attachment A, revisions to the DCPP Physical Security Plan, the Contingency Plan, and the Training and Qualification Plan as required by Order SAFEGUARDS INFORMATION NOTE: THE ATTACHMENTS TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED IN ACCORDANCE WITH 10 CFR 73.21. UPON SEPARATION OF THE ATTACHMENTS, THIS LETTER IS "DECONTROLLED."
U.S. Nuclear Regulatory Commission PG&E Letter DCL-04-054 April 28, 2004 Page 2 EA-03-086. These plans contain the integrated commitments to comply with Order EA-03-086 and the 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 PG&E in these areas, including those related to the February 25, 2002, January 7, 2003, and April 29, 2003, Orders. PG&E will continue to implement the provisions of those previous submittals except to the extent that they are superseded by these plans. All changes that have been or will be made have been evaluated to ensure that they do not compromise plant safety.
PG&E 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 Training Program (April 2004); and NEI-03-12 (Revision 2 (draft)), Template for the Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan. The schedule for completing those actions, which includes the identification of major transitional activities, is provided in Attachment B to this submittal. To facilitate the NRC's review, any provisions that are different from NEI-03-12 are identified and the justification provided in Attachment C, Deviations from'NEI-03-12, to this submittal. Attachment D, Previous Exemptions to 10 CFR Part 73, is a listing of any exemptions to 10 CFR Part 73 previously granted to PG&E and an explanation of their status under the plans hereby submitted. Attachment E, Justification forAlternatives, 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 PG&E has adopted.
When the final revision of NEI-03-12 is approved by the NRC, PG&E will supplement this response, if necessary, to conform with NEI-03-12 as finally approved.
However, with the filing of these plans, PG&E 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, PG&E will be in compliance with all applicable security requirements. For the purpose of complying with the requirements of 10 CFR Part 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 requirement of the revised DBT Order with the Orders issued February 25, 2002, January 7, 2003, and April 29, 2003; and the SAFEGUARDS INFORMATION NOTE: THE ATTACHMENTS TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED IN ACCORDANCE WITH 10 CFR 73.21. UPON SEPARATION OF THE ATTACHMENTS, THIS LETTER IS "DECONTROLLED."
I U.S. Nuclear Regulatory Commission April 28, 2004 Page 3 PG&E Letter DCL-04-054 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, PG&E 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.
This response is hereby submitted to the Commission in accordance with 10 CFR 50.4 and 10 CFR 2.202. If you have any questions, please contact me at (415) 973-4684 or Ronald Todaro at (805) 545-4309.
- jrely, Grbgdry M. Rueger swh/A0582378 Enclosure Attachments cc:
Bruce S. Mallett, Region IV David L. ProuIx, Resident Girija S. Shukla, NRR Office of the Secretary of the Commission (NRC)
Diablo Distribution SAFEGUARDS INFORMATION NOTE: THE ATTACHMENTS TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED IN ACCORDANCE WITH 10 CFR 73.21. UPON SEPARATION OF THE ATTACHMENTS, THIS LETTER IS "DECONTROLLED."
Enclosure PG&E Letter DCL-04-054 SAFEGUARDS INFORMATION Compact Diskette Supplemental Response to the April 29, 2003, Orders to Pacific Gas & Electric Company, Diablo Canyon Power Plant Units I and 2 Compact Diskette Transmittal Form Filename Sensitivity. iFile Site -
Description PSP04272004.pdf SGI 1 Mb Security Plan, Contingency Plan, Training and Qualification Plan DCL04-054 SGI 190 kb Attachments Attachments.pdf Cover Letter.pdf Non-SGI 89.6 kb Cover Letter Contact Name and Phone Number:
Ronald Todaro (805) 545-4309 Special Instructions:
The CD-R media are read-only, 700MB compact diskettes.
All files are in word searchable, PDF format.
SAFEGUARDS INFORMATION NOTE: THE ATTACHMENTS TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED IN ACCORDANCE WITH 10 CFR 73.21. UPON SEPARATION OF THE ATTACHMENTS, THIS LETTER IS "DECONTROLLED."
PG&E Letter DCL04-054 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of PACIFIC GAS AND ELECTRIC COMPANY Diablo Canyon Power Plant Units 1 and 2
)
)
)
)
))
)
Docket No. 50-275 Facility Operating License No. DPR-80 Docket No. 50-323 Facility Operating License No. DPR-82 AFFIDAVIT Gregory M. Rueger, of lawful age, first being duly sworn upon oath says that he is Senior Vice President - Generation and Chief Nuclear Officer of Pacific Gas and Electric Company; that he has executed this response to the NRC Security Order, EA-03-086, dated April 29, 2003, on behalf of said company with full power and authority to do so; that he is familiar with the content thereof; and that the facts stated therein are true and correct to the best of his knowledge, information, and belief.
Grego MI Ruger Senior Vice President - Generation and Chief Nuclear Officer Subscribed and sworn to before me this 28th day of April 2004.
Notary Public County of San Luis Obispo SAon.HERLY State of California i
Commkson # 1425568 NOtarY Pubic - Colltfomja fl;hSon LUIS Obipo qouy I..xphs1 Ju 182007
1
Document:
Access Authorization Order DCL-04-054
Subject:
Supplemental Response to the April 29, 2003, Orders to Pacific Gas &
Electric Company, Diablo Canyon Power Plant Units 1 and 2 File Location S:\\RS\\RA\\SECURITY\\Orders2003\\Security Orders - supplemental response to orders 4-29-04.doc Version:
04/26/2004 FSAR Update Review Utilizing the guidance in X13.1D2, does the FSAR Update need to be revised?
Yes No 1 If fYes' submit an FSAR Update Change Request in accordance with X13.ID2 (or if this is an LAR, process in accordance with WG-9)
Statement of Commitment: None Clarification:
AR or NCR AEorACT Tracking Document:
A0582378 AE 02 NAME ORGANIZATION CODE Assigned To:
SWH2 PTRB FIRM OR TARGET DUE DA TE:
Commitment Type:
F 04/29/2004 YES OR NO IF YES, WHICH? (E.G., 2R9 IRIO. ETC.)
Outage Commitment?
N YES OR NO IF YES, LIST THE IMPLEMENTING DOCUMENTS (IF KNOWN)
PCD Commitment?
N YES OR NO IF YES. LIST PCD NUMBER (e.g'. T35905, etc)
Duplicate of New NCR Commitment in N
PCD?
YES OR NO IF YES, LIST PCD NUMBER, AND CLARIFY TO CLERICAL HOW COMMITMENT TO BE REVISED Old PCD Commitment being N
changed?
I.
S-I- -
.A a-p SAFEGUARDS INFORMATION NOTE: THE ATTACHMENTS TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED IN ACCORDANCE WITH 10 CFR 73.21. UPON SEPARATION OF THE ATTACHMENTS, THIS LETTER IS "DECONTROLLED."