IR 05000313/1999007
| ML20212J109 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/21/1999 |
| From: | Good G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hutchinson C ENTERGY OPERATIONS, INC. |
| References | |
| 50-313-99-07, 50-313-99-7, 50-368-99-07, 50-368-99-7, NUDOCS 9906280366 | |
| Download: ML20212J109 (4) | |
Text
June 21, 1999
SUBJECT:
NRC INSPECTION REPORT NO. 50-313/99-07; 50-368/99-07
Dear Mr. Hutchinson Thank you for your letter (OCAN069901) dated June 14,1999, in response to our NRC Inspection Report 50-313:-368/9907, dated May 14,1999. Your letter documented a requested evaluation of provisions to maintain an adequate level of security response personnel on site.
l As stated in your response, during the 1994 Operational Safeguards Response Evaluation
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(OSRE), you utilized "X" plus 4 (specific number is safeguards information) armed response force personnel per shift, and maintained this shift staffing level prior to and subsequent to the OSRE. This staffing level was verified by NRC during this April 26-31,1999, inspection.
The adequacy of your minimum staffing levels may be reviewed during future inspections.
Sincerely,
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Gail M. Good, Chief Plant Support Branch Division of Reactor Safety Docket Nos.: 50-313 50-368 License Nos.: DPR-51 NPF-G Executive Vice President
& Chief Operating Officer Entergy Operations, Inc.
P.O. Box 31995 Jackson, Mississippl 39286-1995
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e-Vice President Operations Support Entergy Operations, Inc.
P.O. Box 31995 -
Jackson, Mississippi 39286 Manager, Washington Nuclear Operations
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Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 County Judge of Pope County Pope County Courthouse Russellville, Arkansas 72801 Winston & Strawn 1400 L Street, N.W.
Washington, D.C. 20005-3502 David D. Snellings, Jr., Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Mall Slot 30 -
Little Rock, Arkansas 72205-3867 Manager
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Rockville Nuclear Licensing
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Framatome Technologies 1700 Rockville Pike, Suite 525
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DLSIRIBUTION with copy of licensee's letter dated June 14.1999:
DMB(IE53)
Regional Administrator Resident inspector DRP Director MIS System Branch Chiedi(DRP/D)
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Branch Chief (DRS/PSD)
RIV Docket File Elaine Koup (NRR/DRPM/SGB, MS: 012E-11)
NRR Docket File DRS/PSB Security File (99-G-0082)
RITS Coordinator -
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DOCUMENT NAME:' S:\\DRS\\DRSLTRS\\AN907AK.DWS To receive copy of document, indicate in bor: "C' = Copy without enclosures *E' = Copy with enclosures 'N' = No copy RIV:PSB E
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l DWSchaefer:nh J GMGood 06/ / V /99 06/ 6 /99 OFFICIAL RECORD COPY
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Entergy Operations, Inc.
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DMB (IE53)
Regional Administrator Resident inspector DRP Director MIS System Branch Chiedf (DRP/D)
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Branch Chief (DRS/PSB)
RIV Docket File Elaine Koup (NRR/DRPM/SGB, MS: 012E-11)
(NRR Docket Fi!b DRS/PSB Security File (99-G-0082)
RITS Coordinator l
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DOCUMENT NAME: S:\\DRS\\DRSLTRS\\AN907AK.DWS
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To receive copy of document, indicate in box: 'C" = Copy without enclosures *E' = Copy with enclosures *N" = No copy RIV:PSB lE C:DRS\\PSB l l
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06/ / 7 /99 06/ 8 /99 OFFICIAL RECORD COPY
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i Subject:
Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Response to NRC Inspection Report 50-313/99-07; 50-368/99-07 Gentlemen:
NRC Inspection Report 50-313/99-07; 50-368/99-07 (0CNA059908), dated May 14, 1999, requested Arkansas Nuclear One (ANO) to provide an evaluation of provisions to maintain an adequate level of security response personnel on-site. The report identified a concern regarding the difference between the number of armed responders committed to in the approved Industrial Security Plan (ISP) and the additional number of armed response personnel used during the 1994 Operational Safeguards Response Evaluation (OSRE).
Section 1.4.2 of the ANO ISP requires that the security force at ANO be comprised of a minimum of "X" (specific number is safeguards information) armed response officers plus additional armed / unarmed personnel necessary to support routine security activities. The number of armed response personnel available has not changed since Revision 1 to the ISP dated January 11, 1979. This number, "X", was reviewed in the NRC Security Plan Evaluation Report (SPER) dated February 23, 1979, stating that "X" armed responders meets the requirements of 10CFR73.55(h)(3), and is acceptable. The SPER also stated that this number provided a high assurance of protection of the facility based on a number of factors such as the construction of vital areas, the redundancy of security systems, the response capabilities of local law enforcement agencies, and others. These factors are consistent with the guidance !ater published in NUREG-0907, Acceptance Criteria for Determining ArmedResponse Force Si:e at Nuclear Power Plants, dated February,1983.
This NUREG provided a worksheet to establish guidelines for selecting the number of
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armed responders based on 26 factors. ANO evaluated the number of armed responders utilizing the NUREG guidelines and determined that the number of armed responders specified in the ANO ISP met and even exceeded the NUREG requirements.
As allowed during the 1994 OSRE, "X"+4 armed security response personnel per shift
l were utilized. ANO staf5ng levels are driven by 10CFR73.55(g)(1) which requires that
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ANO have ti.e number ofsecurity officers available to compensate for a total failure of the security computer system. These staffing levels have remained greater than the "X"+4 number utilized during the 1994 OSRE and were in place prior to the 1994 OSRE.
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It was not Entergy's understanding when the OSRE was conducted that it was intended to replace current regulations or NUREG-0907 as a means of determining minimum acceptable armed response force size. During the OSRE, ANO was allowed to use existing staffing levels to perform response functions. The OSRE team conducted a review of the ANO ISP and at no time was ANO informed that only personnel identified in the plan could respond to each scenario. The 1994 OSRE report dated December 6, 1994 (OCNA129409), indicated that the OSRE objectives were met and stated that the ANO security force demonstrated an effective contingency response capability.
Entergy is currently involved with the Industry in a Nuclear Energy Institute (NEI)
security task force to follow the regulatory reform effort and promote reform in the area of security. ANO will continue to follow this effort and make changes to procedures and the ISP as appropriate to address identified improvements.
ANO has reviewed the Staff's concerns and has determined that until additional guidance or changes in regulations are issued, ANO remains in full compliance with the requirements of 10CFR73.55(h)(3), and no changes to the ANO ISP are necessary.
Ve trulyyours,
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. Vandergrift Director, Nuclear Safety JDV/SLP I
U. S. NRC
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Mr. Ellis W. Merschoff
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Regional Administrator l
U. S. Nuclear Regulatory Commission Region IV 61I Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC SeniorResident Inspector
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Arkansas Nuclear One P.O. Box 310 London, AR72847 Mr. Nick Hilton NRR Project Manager Region IV/ANO-1 U. S. NuclearRegulatory Commission NRR Mail Stop 13-D-18 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Chris Nolan NRRProject Manager Region IV/ANO-2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-D-18 One White Flint North 11555 Rockville Pike J
Rockville, MD 20852
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