ML043010255
| ML043010255 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/25/2004 |
| From: | Balduzzi M Entergy Nuclear Operations |
| To: | Dyer J Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML043010255 (3) | |
Text
Entergy Nuclear Operations, Inc.
EntombPilgnim Nuclear Power Station rEn 600 Rocky Hill Road Plymouth, MA 02360 October 25, 2004 Michael A. Balduzzi Octobr 25,2004Site Vice President Via Overnight Delivery Mr. James E. Dyer Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Entergy Nuclear Operations, Inc Pilgrim Nuclear Power Station Docket No.: 50-293 License No.: DPR-35 Supplemental Response to the April 29, 2003, Orders to Pilgrim Nuclear Power Station LETTER NUMBER: 2.04.106 Dear Sir or Madam; 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 Pilgrim Nuclear Power Station.
Order EA-03-086 imposed 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 required 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 required licensees to revise their 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, Entergy Nuclear Operations Inc. (ENO),
submitted a supplemental response for the Pilgrim Nuclear Power Station (PNPS) on April 29, 2004. Our activities were scheduled to be implemented by October 29, 2004, as required by the Order. However, in developing and implementing the detailed plans required by the Orders, ENO has determined that it cannot complete the implementation of all of the elements of its plans at PNPS by the required October 29, 2004, date. to this letter contains Safeguards Information. It includes the specific provision(s) of the Order for which implementation cannot be completed by October 29, 2004; the manner in K W which ENO had intended to meet those requirements at PNPS; the reasons why all elements of the plans will not be able to be implemented by that date; and the steps that will be taken to NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS *SAFEGUARDS INFORMATIONW AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LETTER AND ATTACHMENT 2 ARE 'DECONTROLLED.-
'Entergy Nuclear Operations, Inc.
Letter Number: 2.04.106 Pilgrim Station Page 2 of 3 provide a high degree of assurance that the defensive strategy employed by ENO at PNPS will meet the intent of that requirement of the Order until implementation is complete.
That information will be provided in the following format for each requirement that PNPS does not expect to be able to meet by October 29, 2004:
I.
Order requirement; II. Original plan commitment to meet that requirement:
Ill. Reasons for all elements of the plan not being able to be implemented by October 29, 2004; IV. Steps that PNPS took to minimize the delay in implementing the pertinent provisions of the PNPS plan; V. Current implementation schedule:
VI. Measures to be taken until implementation is complete:.
As a result, ENO requests that the Commission grant an extension until November 30, 2004, for completion of implementation of the remaining elements of PNPS's plan detailed in Attachment I. Further, because the Commission concluded 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, ENO requests that enforcement discretion be exercised during the period from this request until implementation of the steps necessary to meet the requirement that is the subject of this request is complete. At that time, the revised plans will be fully implemented and the exercise of enforcement discretion will no longer be necessary.
This letter contains a new commitment listed in Attachment 2. If you have any questions or require additional information, please contact Mr. Bryan Ford at (508) 830-8403.
I declare under penalty of perjury that the foregoing is true and correct. Executed on thegMyth day of October 2004.
Very truly yours, Michael A. Balduzzi Site Vice President MJG/dm Attachments:
- 1. Order EA-03-086 Requirements That Will Not Be Met 10/29/04
- 2. List of Regulatory Commitments NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION' AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LE1TER AND ATTACHMENT 2 ARE -DECONTROLLED."
'Entergy Nuclear Operations, Inc.
Pilgrim Station Cc:
with attachments Mr. Bhalchandra K. Viadya, Project Manager Security Plan Review Team Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Cc:
all wlo attachments Samuel Collins Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 J. Herron G. Taylor Letter Number: 2.04.106 Page 3 of 3 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Resident Inspector's Office M. Kansler R. Goodrich J. McCann NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION' AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LETTER AND ATTACHMENT 2 ARE DECONTROLLED.'