ML043180009
| ML043180009 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/29/2004 |
| From: | John Nakoski NRC/NRR/DLPM/LPD2 |
| To: | Nunn D Southern California Edison Co |
| Nakoski J A, NRR/DLPM, 415-1068 | |
| References | |
| EA-03-086, TAC MC2969, TAC MC2970 | |
| Download: ML043180009 (14) | |
Text
SAFEGUARDS INFORMATION October 29, 2004 Mr. Dwight E. Nunn Vice President c/o Mr. John Todd Southern California Edison Company San Onofre Nuclear Generating Station, Units 2 and 3 P. O. Box 128 San Clemente, CA 92674-0128
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 -
ADMINISTRATIVE CHANGE TO FACILITY OPERATING LICENSES IN CONJUNCTION WITH THE COMMISSION ORDER EA-03-086 REGARDING REVISED DESIGN BASIS THREAT; AND REVISIONS TO PHYSICAL SECURITY PLAN, TRAINING AND QUALIFICATION PLAN, SAFEGUARDS CONTINGENCY PLAN (TAC NOS. MC2969 AND MC2970)
Dear Mr. Nunn:
By letter dated April 28, 2004, Southern California Edison Company submitted a supplemental response in accordance with Order EA-03-086, the Order requiring compliance with the revised design basis threat, dated April 29, 2003, (DBT Order) for the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3.Section III.A of the DBT Order required licensees to revise physical security plans (PSPs), training and qualification plans (T&Q Plans), and safeguards contingency plans (SCPs) in order to provide protection against the revised DBT set forth in 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.
As an attachment to your April 28, 2004, letter, you also submitted Attachment G, Summary of Plans and Bases of Compliance for the Revised Design Basis Threat Security Order. The NRC staff has neither reviewed nor approved Attachment G. Implementing guidance regarding the DBT Order, NRC Guidance on Implementation of the April 2003 Revised Design Basis Threat, dated May 8, 2004, was forwarded to all licensees in a letter dated June 8, 2004.
SAFEGUARDS INFORMATION NOTICE: Enclosure 2 contains Safeguards Information.
Upon separation from Enclosure 2, this letter and is DECONTROLLED.
D. E. Nunn In the revised security plans for SONGS, Units 2 and 3, you included information related to the independent spent fuel storage installation (ISFSI) co-located at the site. The DBT Order did not require this information to be included in the revised security plans for SONGS, Units 2 and 3. However, Order EA-02-104, the Order requiring compensatory measures for dry ISpFSI, dated October 16, 2002, required licensees to comply with the requirements, set forth in an attachment to the Order, that described the compensatory measures necessary to protect the ISFSI as a result of the heightened threat environment following the September 11, 2001, terrorist attacks. On September 10, 2004, the NRC staff requested that you clarify whether the information provided in the revised security plans for SONGS, Units 2 and 3 related to the ISFSI, modified the response you provided to Order EA-02-104.
By letter dated September 21, 2004, you indicated that no modifications or revisions which decrease the effectiveness of the implementation of ISFSI-related security provisions have been made since reporting on October 3, 2003, that full compliance with Order EA-02-104 had been achieved. The effectiveness of these security provisions will continue to be the subject of NRC review and inspection.
The NRC staffs review of the SONGS, Units 2 and 3, PSP, SCP, T&Q Plan submitted in your letter dated April 28, 2004, as supplemented on July 9, July 26, July 30, August 16, September 10, and October 19, 2004, has focused on ensuring the necessary programmatic elements are contained in these plans in order to provide the 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.
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 SONGS, Units 2 and 3, will be protected against the revised DBT. The NRC staff, therefore approves the for SONGS, Units 2 and 3. 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 meets 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) 73.55(d)(7)(i)(B)
Temporary reclassification of Vital Areas to PA status (devitalization)
Also, your application identified the following previously NRC-approved exemption. The NRC staff found that the bases for granting this exemption remain unchanged and, therefore, continues to be in effect and remain part of the licensing basis for SONGS.
Exemption From Requirement(s) of Approval Date PSP Section 10 CFR 73.55(c)(6)
April 26, 1984 3.6.3 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 Nos. NPF-10 and NPF-15 is being made to incorporate the reference to the revised PSP, SCP, and T&Q Plan required by the DBT Order.
These changes comply 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 pages to your FOLs as indicated in Enclosure 1.
A copy of our SE with regard to your security plans (designated as Safeguards Information) is provided in Enclosure 2.
Sincerely,
/RA/
John A. Nakoski, Section Chief Security Plan Review Team Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362
Enclosures:
- 2. Safety Evaluation Regarding the Security Plans (SAFEGUARDS INFORMATION) cc w/encl 1 only: See mailing list 1 cc w/encls 1 and 2: John Todd, Site Security Manager
A copy of our SE with regard to your security plans (designated as Safeguards Information) is provided in Enclosure 2.
Sincerely,
/RA/
John A. Nakoski, Section Chief Security Plan Review Team Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362
Enclosures:
- 2. Safety Evaluation Regarding the Security Plans (SAFEGUARDS INFORMATION) cc w/encl 1 only: See mailing list 1 cc w/encls 1 and 2: John Todd, Site Security Manager DISTRIBUTION w/o Enclosure 2:
PUBLIC SPRT R/F OGC ACRS DBaxley BPham SDembek HBerkow GHill (4)
DLPM DPR TBoyce AHowell, RIV Accession No.:
OFFICE SPRT/TL SPRT/PM SPRT/LA SPRT/PL OGC NSIR/SC NRR/SC NAME JCreed BBenney CRaynor JPeralta SBupp SMorris JNakoski DATE 10/25/04 10/25/04 10/25/04 10/25/04 10/22/04 10/26/04 10/28/04 OFFICIAL RECORD COPY
San Onofre Nuclear Generating Station, Units 2 and 3 cc: w/o encl.:
Mr. Raymond Waldo, Plant Manager Nuclear Generation Southern California Edison Company San Onofre Nuclear Generating Station P. O. Box 128 San Clemente, CA 92674-0128 Mr. Douglas K. Porter Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770 Mr. David Spath, Chief Division of Drinking Water and Environmental Management P. O. Box 942732 Sacramento, CA 94234-7320 Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101 Eileen M. Teichert, Esq.
Supervising Deputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522 Mr. Gary L. Nolff Power Projects/Contracts Manager Riverside Public Utilities 2911 Adams Street Riverside, CA 92504 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mr. Michael Olson San Diego Gas & Electric Company P.O. Box 1831 San Diego, CA 92112-4150 Mr. Ed Bailey, Chief Radiologic Health Branch State Department of Health Services Post Office Box 997414 (MS7610)
Sacramento, CA 95899-7414 Resident Inspector/San Onofre NPS c/o U.S. Nuclear Regulatory Commission Post Office Box 4329 San Clemente, CA 92674 Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672 Mr. Dwight E. Nunn, Vice President Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 31)
Sacramento, CA 95814 Mr. Joseph J. Wambold, Vice President Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92764-0128 Mr. Steve Hsu Department of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899 Mr. Harold B. Ray Executive Vice President Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128, Mail Stop: D-3-F San Clemente, CA 92674-0128
SOUTHERN CALIFORNIA EDISON COMPANY DOCKET NOS. 50-361 SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 2 ADMINISTRATIVE LICENSE CHANGE TO FACILITY OPERATING LICENSE License No. NPF-10 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
Consistent with Order EA-03-086, the Order requiring compliance with the revised design basis threat, (DBT Order) issued on April 29, 2003, 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-10 is being made to incorporate the reference to the revised Physical Security Plan, Safeguards Contingency Plan, and Training and Qualification Plan required by the DBT Order. These changes comply with the standards and requirements of the Atomic Energy Act (the Act) of 1954, as amended 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. 2.
Accordingly, the FOL is changed, as indicated in the attachment.
3.
Except as otherwise noted in the letter dated October 29, 2004, relaxing the requirement of Section III.A.2 of Order EA-03-086, 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, Section 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 29, 2004
CHANGES TO FACILITY OPERATING LICENSE NO. NPF-10 DOCKET NO. 50-361 Replace the following page of the Facility Operating License No. NPF-10 with the attached revised page as indicated. The revised page is identified by a revision date and contains marginal lines indicating the area of change.
Remove Page Insert Page 8
8 E.
SCE shall fully implement and maintain in effect all provisions of the l
Commission-approved physical security, training and qualification, and l
safeguards contingency plans including amendments made pursuant to l
provisions of the Miscellaneous Amendments and Search Requirements l
revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of l
10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain l
Safeguards Information protected under 10 CFR 10 CFR 73.21 is entitled: "San l
Onofre Nuclear Generating Station Security, Training and Qualification, and l
Safeguards Contingency Plan, Revision 0" submitted by letter dated October 19, l
2004.
l F.
This license is subject to the following additional condition for the protection of the environment:
Before engaging in activities that may result in a significant adverse environmental impact that was not evaluated or that is significantly greater than that evaluated in the Final Environmental Statement, SCE shall provide a written notification of such activities to the NRC Office of Nuclear Reactor Regulation and receive written approval from that office before proceeding with such activities.
G.
SCE shall report any violations of the requirements contained in Section 2, items C(1), C(3), and F of this license within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and confirm by telegram, mailgram, or facsimile transmission to the NRC Regional Administrator, Region IV, or his designee, no later than the first working day following the violation, with a written followup report within fourteen (14) days.
H.
SCE shall notify the Commission, as soon as possible but not later than one hour, of any accident at this facility which could result in an unplanned release of quantities of fission products in excess of allowable limits for normal operation established by the Commission.
I.
SCE shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.
On September 29, 1983, the Safeguards Contingency Plan was made a separate, companion document to the Physical Security Plan pursuant to the authority of 10 CFR 50.54.
Amendment No. 185 Revised by letter dated October 29, 2004
SOUTHERN CALIFORNIA EDISON COMPANY DOCKET NO. 50-362 SAN ONOFRE NUCLEAR STATION, UNIT 3 ADMINISTRATIVE LICENSE CHANGE TO FACILITY OPERATING LICENSE License No. NPF-15 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
Consistent with Order EA-03-086, the Order Requiring compliance with the revised design basis threat, (DBT Order) issued on April 29, 2003, 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-15 is being made to incorporate the reference to the revised Physical Security Plan, Safeguards Contingency Plan, and Training and Qualification Plan required by the DBT Order. These changes comply with the standards and requirements of the Atomic Energy Act (the Act) of 1954, as amended 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.
2.
Accordingly, the FOL is changed, as indicated in the attachment.
3.
Except as otherwise noted in the letter dated October 29, 2004, relaxing the requirement of Section III.A.2 of Order EA-03-086, 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, Section 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 29, 2004
CHANGES TO FACILITY OPERATING LICENSE NO. NPF-15 DOCKET NO. 50-362 Replace the following page of the Facility Operating License No. NPF-15 with the attached revised page as indicated. The revised page is identified by a revision date and contains marginal lines indicating the area of change.
Remove Page Insert Page 7
7 E.
SCE shall fully implement and maintain in effect all provisions of the l
Commission-approved physical security, training and qualification, and l
safeguards contingency plans including amendments made pursuant to l
provisions of the Miscellaneous Amendments and Search Requirements l
revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 l
CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain l
Safeguards Information protected under 10 CFR 10 CFR 73.21 is entitled: "San l
Onofre Nuclear Generating Station Security, Training and Qualification, and l
Safeguards Contingency Plan, Revision 0" submitted by letter dated October 19, l
2004.
l F.
This license is subject to the following additional condition for the protection of the environment:
Before engaging in activities that may result in a significant adverse environmental impact that was not evaluated or that is significantly greater than that evaluated in the Final Environmental Statement, SCE shall provide a written notification of such activities to the NRC Office of Nuclear Reactor Regulation and receive written approval from that office before proceeding with such activities.
G.
SCE shall report any violations of the requirements contained in Section 2, items C(1), C(3), and F of this license within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and confirm by telegram, mailgram, or facsimile transmission to the NRC Regional Administrator, Region IV, or his designee, no later than the first working day following the violation, with a written followup report within fourteen (14) days.
H.
SCE shall notify the Commission, as soon as possible but not later than one hour, of any accident at this facility which could result in an unplanned release of quantities of fission products in excess of allowable limits for normal operation established by the Commission.
I.
SCE shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.
J.
This license is effective as of the date of issuance and shall expire at midnight on November 15, 2022.
On September 29, 1983, the Safeguards Contingency Plan was made a separate, companion document to the Physical Security Plan pursuant to the authority of 10 CFR 50.54.
Amendment No. 176 Revised by letter dated October 29, 2004