ML041240298
| ML041240298 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/29/2004 |
| From: | Vanderheyden G Constellation Energy Group |
| To: | Document Control Desk, Office of Nuclear Security and Incident Response |
| References | |
| Download: ML041240298 (4) | |
Text
George Vanderheyden SAFEGUARDS INFORMATION 16 50 Calvert Cliffs Parkway Vice President Lusby, Maryland 20657 Calvert Cliffs Nuclear Power Plant 410.495.4455 Constellation Generation Group, LLC 410.495.3500 Fax Constellation Energy April 29, 2004 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Supplemental Response to the April 29, 2003 Orders to Calvert Cliffs Nuclear Power Plant, Inc.
The Nuclear Regulatory Commission ("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 Calvert Cliffs Nuclear Power Plant ("CCNPP"), Units I and 2.
This Supplemental Response of Calvert Cliffs Nuclear Power Plant, Inc. ("CCNPPI"), to Order EA-03-086 supplements the previous response dated June 2, 2003 that CCNPPI filed pursuant to 10 CFR 50.4 and Section III, Conditions A.l, 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 1II.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, CCNPPI is submitting this Supplemental Response for the above-mentioned licensed facilities. This submittal includes, as Attachment A, revisions to the CCNPP Physical Security Plan, Safeguards Contingency Plan, and the Training and Qualification Plan as required by Order 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 CCNPPI in these areas, including those related to the February 25, 2002, January 7, 2003, and April 29, 2003, Orders. Calvert Cliffs Nuclear Power Plant, Inc. will continue to implement the provisions of those previous submittals This cover lettcr is not subject to protective requirements. The enclosure is subject to safeguards information protection according to 10 CFR 73.21. Upon separation from the enclosure, this cover letter is to be considered DECONTROLLED.
SAFEGUARDS INFORMATION
Document Control Desk April 29,2004 Page 2 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.
Calvert Cliffs Nuclear Power Plant, Inc. has developed these plans to be consistent with NEI-03-01 (Revision 1), Nuclear Power PlantAccess Authorization Program(April 2004); NEI-03-09 [Revision 2 (draft)], Security Officer Training Program(April 2004); and NEI-03-12 [Revision 2 (draft)], Template for the Security Plan, Training and QualificationPlan, Safeguards Contingency Plan, [and Independent Spent Fuel Storage Installation Security Program] (April 2004). The schedule for completing major transitional activities necessary for implementation of the plans, is included in Attachment B, Implementation Schedule, 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, Deviationsfrom NEI-03-12, to this submittal. Attachment D, Previous Exemptions to 10 CFR Part 73, is for listing any exemptions to 10 CFR Part 73 previously granted to CCNPPI and an explanation of their status. As CCNPPI is not including any previously granted exemptions in the revised security plans, Attachment D is not applicable and accordingly, not provided. Attachment E, Justificationfor4Alternatives,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 CCNPPI has adopted. Finally, as CCNPPI has not chosen to implement Option I of Section 9.4.1.2 of NEI-03-12, Attachment F, Justificationfor Vehicle Search Criteria,is not applicable and accordingly, not provided. Attachments A, B, C, and E, as well as this cover letter are formatted in pdf on the enclosed CD-ROM.
When the final revision of NEI-03-12 is approved by the NRC, CCNPPI will supplement this response, if necessary, to conform with NEI-03-12 as finally approved. However, with the filing of these plans, CCNPPI 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, CCNPPI 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 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, CCNPPI 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.
Document Control Desk April 29, 2004 Page 3 Should you have questions regarding this matter, we them with you.
STATE OF MARYLAND
- TO WIT:
COUNTY OF CALVERT I, George Vanderheyden, being duly sworn, state that I am Vice President - Calvert Cliffs Nuclear Power Plant, Inc. (CCNPPI), and that I am duly authorized to execute and file this response on behalf of CCNPPI. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal kn wledge, they are based upon information provided by other CCNPPI employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to bqrelipbl Subscribed and sworn before me, a Notary P blic in and for the State of Maryh and and County of
,this af' dayofry E ll 2004.
m, WITNESS my Hand an,d Notarial Seal: / 5 Notary Publi My Commission Expires: g4 dztc/ Date62 97 Dat6 GV/ALS/bjd cc: (Without Enclosure)
J. M. Petro, Esquire Resident Inspector, NRC M. J. Wetterhahn, Esquire R. I. McLean, DNR Director, Project Directorate I-1, NRC J. E. Dyer, NRC G. S. Vissing, NRC R. P. Zimmerman, NRC H. J. Miller, NRC
Document Control Desk April 29, 2004 Page 4
Contact:
Name V. L:*Williams Mailing Address Calvert Cliffs Nuclear Power Plant, Inc.
1650 Calvert Cliffs Parkway Lusby, MD 20657 Email Address vince.l.williams(-aconstellation.com Phone Number 410-495-2484 Contents of Enclosure (CD-ROM):
Cover Letter, Supplemental Response to the April 29, 2003 Orders to CCNPP (001 Cover Letter nrcO4052.pdf; 552KB; publicly available)
Attachments: A Calvert Cliffs Nuclear Power Plant Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, Revision 0 (002 Attachment A.pdf; 334KB; Safeguards Information)
B Implementation Schedule (003 Attachment B.pdf; 8.05KB; Safeguards Information)
C Deviations from NEI-03-12 (004 Attachment C.pdf; 7.90KB; publicly available)
E Justification for Alternatives (005 Attachment E.pdf; 65.3KB; Safeguards Information)