ML040500669
| ML040500669 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/05/2004 |
| From: | Domonique Malone Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML040500669 (12) | |
Text
NCMC Committed to Nuclear Exx Palisades Nuclear Plant Operated by Nuclear Management Company, LLC February 5, 2004 10 CFR 50.54 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Docket 50-255 License No. DPR-20 Palisades Nuclear Plant Suitability, Training and Qualification Plan, Revision 21 Nuclear Management Company, LLC (NMC) is transmitting two enclosures that comprise Revision 21 of the Palisades Nuclear Plant Suitability, Training and Qualification Plan. Enclosure 1 contains a description of, and rationale for, the changes included in Revision 21. Enclosure 2 contains one original and three copies of the revised pages of the Plan.
NMC has determined that the changes contained in Revision 21 do not decrease the safeguards effectiveness of the Palisades Suitability, Training and Qualification Plan.
Accordingly, this revision is submitted under the provisions of 10 CFR 50.54(p)(2).
Summary of Commitments This letter nnew commitments and no revisions to existing commitments.
Daniel J. Mal ne Site Vice President, Palisades Nuclear Plant Nuclear Management Company, LLC Enclosures (2)
CC Administrator, Region ll, USNRC Poject Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC - 53 27780 Blue Star Memorial Highway
- Covert, Michigan 49043-9530 Telephone: 269.764.2000
ENCLOSURE I DESCRIPTION OF, AND RATIONALE FOR, SUITABILITY, TRAINING AND QUALIFICATION PLAN CHANGES REVISION 21 4 Pages Follow
Palisades Security Procedure Change Summary Procedure Palisades Suitability, Training and Qualification Plan Revision Number Revision 21 Summary of Changes A detailed description of and justification for changes made in Suitability, Training and Qualification Plan, Revision 21, are included in the attached review package. Following is a summary of these changes.
The rifle qualification course used by Security personnel has been changed to the NMC Fleet standard.
Comments This revision reflects a change to the rie qualification course. The review package provides justification for that change and explanation for why the change does not lessen Suitability, Training and Qualification Plan effectiveness. These changes do not impact plant operations or safety related equipment.
Procedure Sponsor Date
10CFR50.54(p) SCREENING EVALUATION DocumenVRevision: Palisades Nuclear Plant Security Training and Qualification Plan, Revision 21 Section/Title: Section 4.2 RIFLE PROPOSED CHANGE(S): List of changes attached? Yes L No The rifle qualification course has been revised. The revised plan supersedes Suitability, Training and Qualification Plan, Revision 20. A comprehensive summary of changes made to the superseded plan is provided in ATTACHMENT 1.
IMPACT ON EFFECTIVENESS:
This section asks a series of questions. If the response to each question is "no" and the rationale supports a no" response, the change may be processed using the provisions of 10 CFR 50.54(p) without NRC prior approval. The questions are as follows:
- 1. LI Yes E No Does this change delete or contradict any regulatory requirement?
- 2. D Yes S No Would the change decrease the overall level of security system performance as described in paragraphs (b) through (h) of 10 CFR 73.55 to protect with the objective of high assurance against the design basis threat of radiological sabotage as stated inl 0 CFR 73.1(a)?
Rationale: The rationale to support the answer "NO" for each change is provided in ATTACHMENT 1.
- 3. L Yes E No For any licensee that has NRC-approved security plan commitments as alternatives to one or more of the requirements of 10 CFR 73.55(b) through (h):
Does this change decrease the overall level of security system performance needed to protect with the objective of high assurance against the design basis threat of radiological sabotage as stated in 10 CFR 73.1(a).
Rationale: No changes are being made to the NRC-approved Security Training and Qualification commitments which are alternatives to the requirements of 10CFR73.55(b) through (h).
E Yes 3 No If the response to each question is no" and the rationale supports the response, then the change may be processed under the provisions of 10CFR50.54(p) without prior NRC approval. If any response is yes," then NRC approval is required Prior to implementing the change. Is NRC approval required?
Review and Approval:
Completed By: Date: /-2356eY Reviewed By: < Date: 09- (1-41 Approved By: Date: 2Y&L Page 1 of 3
ATTACHMENT 1: Assessment of Acceptability of 10 CFR Section 50.54(p) Changes to the Palisades Security Training And Qualification Plan
- 1. The following matrix correlates information contained in the applicable sections and paragraphs of the revised plan with the applicable sections and paragraphs of the superseded plan. A description of each change and, where required, the rationale for the "NO" response to question 2 of the 10 CFR Section 50.54(p) evaluation is provided.
- 2. A separate description is provided for changes and the rationale for the change is provided to include its impact on the overall level of security system performance specified in the Physical Security or Safeguards Contingency Plans.
Page 2 of 3
PALISADES SECURITY TRAINING AND QUALIFICATION PLAN CHANGE MATRIX Change Superseded Revised TQP Number TQP Reference Reference Change Description and Rationale Section 4, Section 4, Change: Revised the rifle qualification course.
4.2 4.2 Rationale:
The rifle qualification course has been changed. Nuclear Management Company has adopted a standard course to be used at all NMC sites. The Palisades Security Training and Qualification Plan is being revised to adopt this new qualification course. The course revision contains the following changes.
- The last four courses of fire do not have time restraints. This was changed to evaluate the precision shooting of the individual qualifying.
- The last column of the course was revised to Barricade Shooting Position" from Shooting Position".
- The items in the "Barricade Shooting Position" column had "barricade removed from their description. This description was added to the heading of the column.
Since there will be no change in actual weapons training for Security Officers, there is no decrease in the ability of the onsite physical protection system or security organization to protect with a high assurance against the design basis threat as stated in 10 CFR 73.1 (a)(1).
Page 3 of 3
ENCLOSURE 2 PALISADES NUCLEAR PLANT SUITABILITY, TRAINING AND QUALIFICATION PLAN, REVISION 21 REVISED PAGES 25 Pages Follow
NUCLEAR MANAGEMENT COMPANY PALISADES NUCLEAR PLANT SUITABILITY, TRAINING AND QUALIFICATION PLAN List of Effective Pages Revision 21 Section Page Rev Section Page Rev List of Eff Pages 1 of 1 21 Table of Contents 1 of 2 21 2 of 2 21 Section 4 12 of 14 21 13 of 14 21
NUCLEAR MANAGEMENT COMPANY PALISADES NUCLEAR PLANT SUITABILITY, TRAINING AND QUALIFICATION PLAN Table of Contents Revision 21 Page SCOPE OF SUITABILITY TRAINING AND QUALIFICATION PLAN SCOPE.............................................................................................................1 SECTION 1 - EMPLOYMENT SUITABILITY AND QUALIFICATION 1.0 EMPLOYMENT SUITABILITY AND QUALIFICATION ..................................... 2 1.1 SUITABILITY ........................................... 2 1.1.1 Education Development .......................................... 2 1.1.2 Felony Conviction ........................................... 2 1.1.3 Age...................................................................................................................2 1.2 PHYSICAL AND MENTAL QUALIFICATIONS ........................................... 2 1.2.1 Physical Qualifications........................................... 2 1.2.2 Mental Qualifications ........................................... 4 1.3 PHYSICAL FITNESS QUALIFICATIONS ........................................... 5 1.4 CONTRACT SECURITY PERSONNEL ........................................... 5 1.5 PHYSICAL AND MENTAL ANNUAL REQUALIFICATION ............................... 5 1.6 DOCUMENTATION ...... 6....................
1.7 RECORDS RETENTION .......................................... 6 1.8 CONSTRAINTS ........................................... 6 SECTION 2 -TRAINING AND QUALIFICATIONS 2.0 TRAINING AND QUALIFICATIONS ........................................... 7 2.1 TRAINING REQUIREMENTS ........................................... 7 2.2 QUALIFICATION REQUIREMENTS ........................................... 8 2.2.1 Individual Responsibility Matrix ........................................... 8 2.2.2 Job Analysis .......................................... 8 2.2.3 Duty Qualification .......................................... 8 2.2.4 Individual Qualification Record (IQR) ........................................... 8 2.2.5 Test Materials ........................................... 9 Page 1 of 2
NUCLEAR MANAGEMENT COMPANY PALISADES NUCLEAR PLANT SUITABILITY, TRAINING AND QUALIFICATION PLAN Table of Contents Revision 21 Page 2.3 CONTRACT PERSONNEL .................... 9 2.4 REQUALIFICATION ................... 9 SECTION 3 - WEAPONS TRAINING 3.0 WEAPONS TRAINING .10 SECTION 4 - WEAPONS QUALIFICATION AND REQUALIFICATION PROGRAM 4.0 WEAPONS QUALIFICATION AND REQUALIFICATION PROGRAM . 11 4.1 HANDGUN . 1 4.2 RIFLE .12 4.3 REQUALIFICATION .13 SECTION 5 - GUARD, ARMED RESPONSE AND ARMED ESCORT EQUIPMENT 5.0 GUARD, ARMED RESPONSE AND ARMED ESCORT EQUIPMENT 14 5.1 FIREARMS .14 5.2 AMMUNITION .14 5.3 CONTINGENCY EQUIPMENT .14 APPENDICES Appendix A, "Company Training Program" Appendix B, "Job Analysis" Appendix C, "Individual Responsibility Matrix" Page 2 of 2
l NUCLEAR MANAGEMENT COMPANY Section 5 PALISADES NUCLEAR PLANT Revision 21 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 12 of 14 TITLE: Weapons Qualification and Requalification Program 4.2 RIFLE To qualify in use of the rifle, the individual must successfully complete the following course with a minimum score of 80% (i.e., 39 hits out of a possible 48 within the shaded area):
RANGE NUMBER BARRICADE STAGE DISTANCE OF ROUNDS TIME SHOOTING POSITION 1 50 YARDS 2 5 SECONDS Standing, Strong Side l 2 50 YARDS 2 5 SECONDS Standing, Reaction Side l 3 50 YARDS 2 5 SECONDS Standing, Strong Side l 4 50 YARDS 2 5 SECONDS Standing, Reaction Side Note: The number of "hits" on-target from the 50-yard line should be counted, recorded and covered over before continuing the course from the 25-yard line.
5 25 YARDS 2 5 SECONDS Standing, Strong Side l 6 25 YARDS 2 5 SECONDS Kneeling, Strong Side l 7 25 YARDS 2 5 SECONDS Standing, Strong Side l 8 25 YARDS 2 5 SECONDS Kneeling, Strong Side l 9 25 YARDS 2 5 SECONDS Standing, Strong Side l 10 25 YARDS 2 5 SECONDS Kneeling, Strong Side l 11 25 YARDS 2 5 SECONDS Standing, Strong Side 12 25 YARDS 2 5 SECONDS Kneeling, Strong Side l 13 25 YARDS 2 5 SECONDS Standing, Reaction Side l 14 25 YARDS 2 5 SECONDS Kneeling, Reaction Side l 15 25 YARDS 2 5 SECONDS Standing, Reaction Side l 16 25 YARDS 2 5 SECONDS Kneeling, Reaction Side 17 25 YARDS 2 5 SECONDS Standing, Reaction Side l 18 25 YARDS 2 5 SECONDS Kneeling, Reaction Side l 19 25 YARDS 2 5 SECONDS Standing, Reaction Side l 20 25 YARDS 2 5 SECONDS Kneeling, Reaction Side l 21 25 YARDS 2 NIA Standing, Strong Side
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V NUCLEAR MANAGEMENT COMPANY Section 5 PALISADES NUCLEAR PLANT Revision 21 SUITABILITY, TRAINING AND QUALIFICATION PLAN Page 13 of 14 TITLE: Weapons Qualification and Requalification Program RANGE NUMBER BARRICADE STAGE DISTANCE OF ROUNDS TIME SHOOTING POSITION l 22 25 YARDS 2 N/A Kneeling, Strong Side 23 25 YARDS 2 N/A Standing, Reaction Side l 24 25 YARDS 2 N/A Kneeling, Reaction Side I 4.3 REQUALIFICATION Individuals required to be armed in the performance of their security related duties shall be requalified in the use of their assigned weapons once every 12 months.
This 12 month requalification period may be extended under the following conditions:
- a. the maximum allowable extension shall not exceed 25% (three months) of the 12 month requalification period and
- b. the combined time extension for-any three consecutive 12 month requalification periods shall not exceed 3.25 times the 12 month requalification period. (12 months x 3.25 = 39 months in any three consecutive years).
The requalification will be in accordance with the provisions of Paragraphs 4.0 and 4.2 above the documented in accordance with Section 2, Step 2.2.4, "Individual Qualification (IQR)," and Section 2, Step 2.3, "Contract Personnel."