ML033070129

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Response to Order (EA-03-038) for Compensatory Measures Related to Fitness-for Duty Enhancements Applicable to Browns Ferry, Units 1, 2, and 3, Sequoyah, Units 1 and 2, and Watts Bar, Unit 1
ML033070129
Person / Time
Site: Browns Ferry, Watts Bar, Sequoyah  Tennessee Valley Authority icon.png
Issue date: 10/30/2003
From: Burzynski M
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-03-038
Download: ML033070129 (4)


Text

Tennessee Valley Authority. 1101 Market Street, Chattanooga, Tennessee 37402-2801 October 30, 2003 10 CFR 50.4(b) (4) 10 CFR 2.202 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

In the Matter of

)

Docket Nos. 50-259 50-327 Tennessee Valley Authority

)

50-260 50-328 50-296 50-390 RESPONSE TO ORDER (EA-03-038) FOR COMPENSATORY MEASURES RELATED TO FITNESS-FOR-DUTY ENHANCEMENTS APPLICABLE TO NUCLEAR FACILITY SECURITY PERSONNEL FOR BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3; SEQUOYAH NUCLEAR PLANTS, UNITS 1 AND 2; AND WATTS BAR NUCLEAR PLANT, UNIT 1 On June 3, 2003, in accordance with 10 CFR § 50.4, the Tennessee Valley Authority (TVA) submitted its initial response to the Security Fitness-for-Duty Enhancements Compensatory Measures Order (Order) issued by the Nuclear Regulatory Commission (NRC) on April 29, 2003.

Pursuant to the requirements of 10 CFR § 2.202, TVA's June 3, 2003 response provided TVA's Answer to the Order.

In most respects, the Answer consented to the Order.

In its response, TVA requested an extension of time in which to submit information in response to the Order and to request a hearing.

Additionally, TVA requested that NRC provide information explaining the bases for certain specific limits prescribed in the Order.

Subject to the requests mentioned above, TVA's response included a schedule for achieving compliance with the Compensatory Measures prescribed by the Order.

On July 10, 2003, NRC issued a reply to TVA's response denying TVA's request for an extension, providing the requested information regarding the bases for the specific work hour limits specified in the Order, and requiring a subsequent

U.S. Nuclear Regulatory Commission Page 2 October 30, 2003 response.

On July 25, 2003, TVA provided a supplemental Answer and Response consenting to the Order and stating that it did not request a hearing.

TVA further stated that it had started implementing the Order and would complete implementation by October 29, 2003 as described in detail in the enclosure to TVA's June 3, 2003 response.

In accordance with Part III, Section C.1 of the Order, TVA is providing this final response confirming compliance with the Compensatory Measures described in Attachment 2 to the Order.

As required by Part III, Section A of the Order, full compliance was achieved on or before October 29, 2003.

One point of clarification regarding our implementation is necessary.

TVA has conducted training for available personnel on the provisions of the Order and our procedure and program for compliance.

However, TVA has identified a small population of personnel that require training for Order compliance that are currently unavailable for training due to extended absence (e.g., military leave, extended illness, etc.).

TVA will ensure that these persons receive the needed training upon their return to work and before they assume their duties.

In addition, TVA received an October 23, 2003 reply from NRC granting our request to relax those provisions of the Order which had required inclusion of shift turnover time in Group Work Hour Controls as well as the counting of hours worked in preparation and conduct of force-on-force exercises.

Because these relaxations were only recently granted, we are in the process of making changes in the appropriate procedures and programs as necessary to implement the relaxed provisions.

Until these changes are made, we will comply with the original requirements of the Order.

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct.

Executed on this 30th day of October 2003.

Sincerely, aAn Oark Burzynski Manager Nuclear Licensing cc:

See page 3

U.S. Nuclear Regulatory Commission Page 3 October 30, 2003 cc:

Assistant General Counsel for Materials Litigation and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Ms. Margaret H. Chernoff, Project Manager U.S. Nuclear Regulatory Commission MS 08 G9 One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Mr. J. E. Dyer, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Mr. Kahtan N. Jabbour, Senior Project Manager U.S. Nuclear Regulatory Commission MS 08 G9 One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Mr. Michael L. Marshall, Jr., Project Manager U.S. Nuclear Regulatory Commission MS 08 G9 One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Mr. Luis Reyes, Regional Administrator U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 Secretary Office of the Secretary U.S. Nuclear Regulatory Commission ATTN:

Rulemakings and Adjudications Staff Washington, D.C. 20555-0001 cc:

Continued on page 4

U.S. Nuclear Regulatory Commission Page 4 October 30, 2003 cc: NRC Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 NRC Senior Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379-3624 NRC Senior Resident Inspector Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381