ML043120019

Administrative Change to Facility Operating License in Conjunction with the Commission Order EA-03-086 Regarding Revised Design Basis Threat...

ML043120019
Person / Time
Site:	Grand Gulf
Issue date:	10/28/2004
From:	John Nakoski NRC/NRR/DLPM/LPD2
To:	Gerald Williams Entergy Operations
Nakoski J A, NRR/DLPM, 415-1068
References
EA-03-086, TAC MC2924
Download: ML043120019 (8)

Text

SAFEGUARDS INFORMATION October 28, 2004 Mr. George A. Williams Vice President - Operations Entergy Grand Gulf Nuclear Station Waterloo Road P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

GRAND GULF NUCLEAR STATION - ADMINISTRATIVE CHANGE TO FACILITY OPERATING LICENSE IN CONJUNCTION WITH THE COMMISSION ORDER EA-03-086 REGARDING REVISED DESIGN BASIS THREAT (DBT) AND REVISIONS TO PHYSICAL SECURITY PLAN, TRAINING AND QUALIFICATIONS PLAN, AND SAFEGUARDS CONTINGENCY PLAN (TAC NO. MC2924)

Dear Mr. Williams:

By letter dated April 29, 2004, Entergy submitted a supplemental response in accordance with Order EA-03-086, the Order requiring compliance with revised design basis threat, dated April 29, 2003, (DBT Order) for Grand Gulf Nuclear Station.Section III.A of the Order requires licensees to revise their physical security plans (PSPs), training and qualification plans (T&Q Plans), and safeguards contingency plans (SCPs) to provide protection against the revised DBT set forth in Attachment 2 to the DBT Order. These revised plans, along with an implementation schedule, were required to be submitted to the Nuclear Regulatory Commission (NRC or the Commission) for review and approval no later than April 29, 2004.

The NRC staffs review of the PSP, SCP, and T&Q Plans submitted in your letter dated April 29, 2004, as supplemented on July 1, July 19, July 26, August 9, August 17, August 26, September 9, and September 30, 2004, has focused on ensuring the necessary programmatic elements are contained in these plans in order to provide high assurance that activities involving special nuclear material are not inimical to the common defense and security and do not constitute an unreasonable risk to the public health and safety.

NOTICE: Enclosure 2 contains Safeguards Information.

Upon separation from Enclosure 2, this letter and Enclosure 1 are DECONTROLLED.

SAFEGUARDS INFORMATION

Mr. Williams The NRC staff has determined that subject to subsequent inspection and evaluation, these plans contain the necessary programmatic elements that, when effectively implemented, will provide the required high assurance that the Grand Gulf Nuclear Station will be protected against the revised DBT. The NRC staff, therefore, approves the PSP, SCP, and T&Q Plan for Grand Gulf Nuclear Station. However, ultimately, the effectiveness of these plans will be judged on your ability to meet regulatory requirements through facility implementing procedures and site practices. As such, your facility implementing procedures and practices will continue to be subject to future NRC review and inspection, including NRC-conducted force-on-force exercises.

In addition, the NRC staff noted that your PSP included alternatives to certain requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 73.55. In each case, the NRC staff found that the alternative measures provide an equivalent level of protection to that of the associated requirement and meet the high assurance objective of 10 CFR 73.55(a). The NRC staff, therefore, approves the alternatives shown in the table below. The NRC staffs evaluation is discussed further in the enclosed Safety Evaluation (SE).

Approved Alternatives to the Requirements of 10 CFR Part 73 SE Section PSP Section Alternative to 10 CFR Description 3.6.2 6.2 73.55(c)(3) Isolation Zones 3.9.4.3 9.4.3 73.55(d)(4) Protected Area (PA) vehicle search requirements 3.9.4.4 9.4.4 73.55(d)(1) PA personnel search requirements 3.9.5.2 9.5 73.55(d)(4) PA access control requirements 3.10.1 10.1 73.55(c)(5) PA illumination requirements 3.13.1 14.1 73.55(c)(1) Temporary reclassification of Vital Areas 73.55(d)(7)(i)(B) to PA status (devitalization)

Finally, consistent with the DBT Order, conforming administrative changes to Facility Operating Licenses (FOLs) are required to ensure implementation of DBT Order requirements.

Therefore, an administrative license change to FOL No. NPF-29 is being made to incorporate the reference to the revised PSP, SCP, and T&Q Plan required by the DBT Order. This change complies with the standards and requirements of the Atomic Energy Act of 1954, as amended, and the Commission's rules and regulations set forth in 10 CFR Chapter I.

Please replace the enclosed page to your FOL as indicated in Enclosure 1.

Mr. Williams A copy of our SE (designated as Safeguards Information), is also enclosed as Enclosure 2.

Sincerely,

/RA/

John A. Nakoski, Chief Security Plan Review Team Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosures:

1. Administrative Change to FOL No. NPF-29

2. SE Regarding the Security Plans (SAFEGUARDS INFORMATION) cc w/encl 1 only: See Mailing List 1 cc w/encls 1 and 2: Greg D. Brown

Mr. Williams A copy of our SE (designated as Safeguards Information), is also enclosed as Enclosure 2.

Sincerely,

/RA/

John A. Nakoski, Chief Security Plan Review Team Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosures:

1. Nm,Administrative Change to FOL No. NPF-29

2. SE Regarding the Security Plans (SAFEGUARDS INFORMATION) cc w/encl 1 only: See Mailing List 1 cc w/encls 1 and 2: Greg D. Brown DISTRIBUTION (w/o Enclosure 2):

PUBLIC SPRT R/F OGC ACRS DJohnson NKalyanam RGramm HBerkow GHill (2) DLPM DPR TBoyce AHowell, RIV Accession No.: ML043120019 OFFICE SPRT/TL SPRT/PM SPRT/LA SPRT/PL OGC NSIR/SC NRR/SC NAME PPeduzzi MChernoff CHawes JPeralta DCummings SMorris JNakoski DATE 10/12/04 10/11/04 10/11/04 10/12/04 10/23/04 10/28/04 10/28/04 OFFICIAL RECORD COPY

ENTERGY OPERATIONS, INC.

SYSTEM ENERGY RESOURCES, INC.

ENTERGY MISSISSIPPI, INC.

DOCKET NO. 50-416 GRAND GULF NUCLEAR STATION ADMINISTRATIVE LICENSE CHANGE TO FACILITY OPERATING LICENSE License No. NPF-29

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. Consistent with the Order EA-03-086, the Order requiring compliance with revised design basis threat, (DBT Order), issued on April 29, 2003, conforming administrative license changes to Facility Operating Licenses (FOLs) are required to ensure implementation of the DBT Order requirements. Therefore, an administrative license change to FOL No. NPF-29 is being made to incorporate the reference to the revised required by the DBT Order. These changes comply with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this administrative license change can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this administrative license change will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this administrative license change is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the FOL is changed as indicated in the attachment.

3. This administrative license change is effective as of its date of issuance and shall be implemented on or before October 29, 2004.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

John A. Nakoski, Chief Security Plan Review Team Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the FOL Date of Issuance: October 28, 2004

CHANGES TO FACILITY OPERATING LICENSE NO. NPF-29 DOCKET NO. 50-216 Replace the following page of the Facility Operating License NPF-29 with the attached revised page as indicated. The revised page is identified by revision date and contains marginal lines indicating the area of change.

Remove Page Insert Page 16 16

(41) Fire Protection Program Entergy Operations, Inc. shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in Revision 5 to the Updated Final Safety Analysis Report, and as approved in the Safety Evaluation dated August 23, 1991, subject to the following provisions:

The licensee may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

D. The facility required exemptions from certain requirements of Appendices A and J to 10 CFR Part 50 and from certain requirements of 10 CFR Part 100. These include: (a) exemption from General Design Criterion 17 Appendix A until startup following the first refueling outage, for (1) the emergency override of the test mode for the Division 3 diesel engine, (2) the second level undervoltage protection for the Division 3 diesel engine, and (3) the generator ground over current trip function for the Division 1 and 2 diesel generators (Section 8.3.1 of SSER #7) and (b) exemption from the requirements of Paragraph III.D.2(b)(ii) of Appendix J for the containment airlock testing following normal door opening when containment integrity is not required (Section 6.2.6 of SSER

1. 7). These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. In addition, by exemption dated December 20, 1986, the Commission exempted licensees from 10 CFR 100.11(a)(1), insofar as it incorporates the definition of exclusion area in 10 CFR 100.3(a), until April 30, 1987 regarding demonstration of authority to control all activities within the exclusion area (safety evaluation accompanying Amendment No. 27 to License (NPF-29). This exemption is authorized by law, and will not present and undue risk to the public health and safety, and is consistent with the common defense and security. In addition, special circumstances have been found justifying the exemption. Therefore, these exemptions are hereby granted pursuant to 10 CFR 50.12.

With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act and the rules and regulations of the Commission.

E. The licensee shall fully implement and maintain in effect all provision of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: Physical Security, Safeguards Contingency and Training and Qualification Plan, and were submitted to the NRC on September 30, 2004.

16 Amendment No. 65, 82 Revised by letter dated October 28, 2004