ML052340025

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30-Day Response to NRC Bulletin 2005-02, Emergency Preparedness and Response Actions for Security-Based Events
ML052340025
Person / Time
Site: Calvert Cliffs, Nine Mile Point, Ginna  Constellation icon.png
Issue date: 08/17/2005
From: Heffley J
Constellation Energy Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-05-002
Download: ML052340025 (25)
v • d • e


Text

J. M. Heffley Chief Nuclear Officer Constellation Energy' Generation Group, LLC Constellation Generation Group 1997 Annapolis Exchange Parkway Suite 310 Annapolis, MD 21401 410-897-5020 August 17, 2005 U. S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 ATTENTION:

SUBJECT:

Document Control Desk Calvert Cliffs Nuclear Power Plant, Inc.

Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 Nine Mile Point Nuclear Station, LLC Unit Nos. 1 & 2; Docket Nos. 50-220 & 50-410 R.E. Ginna Nuclear Power Plant, LLC Docket No. 50-244 30-Day Response to NRC Bulletin 2005-02, "Emergency Preparedness and Response Actions for Security-Based Events"

Reference:

(a)

NRC Bulletin 2005-02, "Emergency Preparedness and Response Actions for Security-Based Events," dated July 18, 2005 By letter dated July 18, 2005, the Nuclear Regulatory Commission (NRC) transmitted Bulletin 2005-02 (Reference a). The bulletin was issued to:

1. Notify addressees about NRC staffs need for information associated with emergency preparedness (EP) for security-based events at a nuclear power plant;
2. Request addressees provide information within 30 days of the date of the bulletin (i.e., August 17, 2005) regarding actions taken or planned to be taken with respect to:
a. Security-based emergency classification levels and emergency action levels (EALs),

emergency response organization augmentation for security-based events, and a security-based emergency preparedness drill and exercise program,

b. Accelerated NRC notifications and onsite protective measures;
3. If actions regarding the topics covered in the bulletin have not been taken, request addressees to provide a schedule detailing expected completion dates for all pending activities; and 90O1

Document Control Desk August 17,2005 Page 2

4. Require addressees to provide a written response to the NRC in accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (f).

Attachments I through 3 provide the three 30-day responses to NRC Bulletin 2005-02 for the Facility Operating Licenses listed above. Preliminary review of these actions, when taken to revise the Emergency Plan, are expected to not pose a decrease in effectiveness to the respective Emergency Plans and therefore are not expected to require NRC approval. Decrease in the effectiveness reviews will be completed in accordance with site processes as changes identified in this document are implemented.

Document Control Desk August 17, 2005 Page 3 If you have any questions about this letter, please contact Mr. Gary L. Detter at 410-897-5126 or email at Gary.Detter(constellation.com.

Respectfully submitted, Coselation eneratirot ohM. Heffley, XY (4d Chief Nuclear Officer STATE OF MARYLAND T

TO WIT:

COUNTY OF ANNE ARUNDEL I, John M. Heffley, Jr., being duly sworn, state that I am the Chief Nuclear Officer -

Constellation Generation Group, LLC (CGG), and that I am duly authorized to execute and file this response on behalf of Calvert Cliffs Nuclear Power Plant, Inc., Nine Mile Point Nuclear Station, LLC, and R.E. Ginna Nuclear Power Plant, LLC. 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 knowledge, they are based upon information provided by other CGG employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Pubic in and for the State of Maryland and County of By

,this Ilt£ day of 2005.

WITNESS my Hand and Notarial Seal:

Public Notary Public ;

My Commission Expires:

acio Date Executed on co

Document Control Desk August 17, 2005 Page 4 Attachments: 1. NRC Bulletin 2005-02 Responses for Calvert Cliffs Nuclear Power Plant, Units I and 2

2.

NRC Bulletin 2005-02 Responses for Nine Mile Point Nuclear Power Station, Units 1 and 2

3.

NRC Bulletin 2005-02 Responses for R.E. Ginna Nuclear Power Plant cc:

P. D. Milano, NRC S. J. Collins, NRC T. G. Colburn, NRC Resident Inspector, NRC (Calvert Cliffs)

Resident Inspector, NRC (Ginna)

Resident Inspector, NRC (Nine Mile Point)

R. I. McLean, Maryland DNR J. P. Spath, NYSERDA

ATTACHMENT I NRC Bulletin 2005-02 Responses for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Constellation Generation Group August 17, 2005 NRC Bulletin 2005-02 Responses for Calvert Cliffs Nuclear Power Plant, Units I and 2 V

V I

Response Area

1) Do you have provisions in place regarding the information provided in the bulletin?
2) If you do not have provisions in place, do you plan to make changes to address the information?
3) If you are making changes to your program, when will you complete those changes?
4) Provide a summary discussion of provisions in place, planned, or if different from the provisions described in this bulletin, a description of how the provisions selected by the licensee differ from those described in the bulletin, and how they adequately address the areas covered by the bulletin.

A. Security-based No Yes 1/20/2006 See Section A Emergency Classification Levels and Emergency Action Levels 1

Attachment I NRC Bulletin 2005-02 Responses for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Response Area

1) Do you have provisions in place regarding the information provided in the bulletin?
2) If you do not have provisions in place, do you plan to make changes to address the information?
3) If you arc making changes to your program, when will you complete those changes?
4) Provide a summary discussion of provisions in place, planned, or if different from the provisions described in this bulletin, a description of how the provisions selected by the licensee differ from those described in the bulletin, and how they adequately address the areas covered by the bulletin.

+

t I

B. NRC Notifications I No Yes 9/30/2005 3a) Is specific discussion of the capability to notify the NRC within 15 minutes of the discovery of a threat or attack in your notification procedures?

No See Section B 3b) If not, will you voluntarily incorporate the 15 minute notification to the NRC into your notification procedures?

Yes 2

NRC Bulletin 2005-02 Responses for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Response Area

1) Do you have provisions in place regarding the information provided in the bulletin? -
2) If you do not have provisions in place, do you.

plan to make changes to address the information?

3) If you are making changes to your program, when will you complete those changes?
4) Provide a summary discussion of provisions in place, planned, or if different from the provisions described in this bulletin, a description of how the provisions selected by the licensee differ from those described in the bulletin, and how they adequately address the areas covered by the bulletin.

C. Onsite Protective Partially Yes 1/20/2006 See Section C Actions D. Emergency Yes N/A N/A See Section D

Response

Organization Augmentation E. Drill and Exercise No Yes Not later than the first See Section E Program drill/exercise scheduled after January 1, 2008 3

Attachment I NRC Bulletin 2005-02 Responses for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 A. Security-Based Emergency Classification Levels and Emergency Action Levels -

Summary Discussion Security-based emergency classification levels and emergency action levels (EALs)

,consistent with NUMARC/NESP-007 and the 2002 Security Order are in place. The Calvert Cliffs Emergency Plan and the EAL set will be updated to reflect the NEI 99-01 EAL scheme and the information provided in Bulletin 2005-02, specifically:

  • NEI 99-01 Guidance in Bulletin 2005-02, Attachment 2, Page 18 Also, acts of civil disobedience or felonious acts that are not part of a concerted attack on the station are addressed by non-terrorism-based EALs and EALs addressing other hazards to station operation continue to apply. Other modifications to the EAL set may be made to maintain internal consistency, e.g., EALs for classification based on judgment.

B. NRC Notifications - Summary Discussion Procedural guidance will be developed to establish an accelerated call to the NRC following discovery of an imminent threat or attack against the station. Note that during a plant transient or an imminent threat situation requiring physical security response, plant personnel are primarily responsible for'stabilizing the plant and keeping it safe. This accelerated call will not be allowed to interfere with plant safety or physical security response. The call will be made after or concurrent with notification of local law enforcement agencies. The goal will be to initiate the accelerated call within about 15 minutes of discovery of an imminent threat or attack against the station. The information in the accelerated call provided will be limited to the following:

  • Site name
  • Emergency classification, in the 'unlikely event it is determined prior to the accelerated call
  • Nature of the threat (briefly described, if known), including the type of attack (e.g.,

armed assault by land, water, or aircraft) and the attack status (i.e., imminent, in progress, or repelled)

The purpose of this notification is to allow the NRC to warn other licensees and initiate federal response in accordance with the National Response Plan. It is expected that additional information will be provided. to the NRC in accordance with the reporting requirements of 10 CFR 50.72(c), after the initial notification is made per 10 CFR 50.72(a)(1 )(i).

C. Onsite Protective Actions - Summary Discussion Calvert Cliffs has,implemented on-site protective measures based on various NRC communications since the September 11, 2001 terrorist attacks.

As a result, Calvert Cliffs' procedures contain many of the attributes listed in Bulletin 2005-02, Attachment 4

Attachment I NRC Bulletin 2005-02 Responses for Calvert Cliffs Nuclear Power Plant, Units 1 and 2

4. However, to ensure completeness, on-site protective measure changes currently in effect will be evaluated against the following considerations and revised as appropriate:
  • Evacuation of personnel from target buildings (including security personnel)
  • Protected Area evacuation by opening'(while continuing to defend) security gates
  • Dispersal of licensed operators
  • Sheltering of personnel in structures away from potential site targets
  • Arrangements for accounting for personnel after the attack In addition, we will consider development of an onsite protective-measure tool to refine rapid decision making with regard to site evacuation route(s), locations for sheltering and buildings to be evacuated. Such a tool might include considering the following circumstances relative to the time available for action:
  • Normal working hours
  • Off-normal hours
  • Weekends
  • Outages
  • Adverse weather As appropriate, consideration will be given to modifying procedures to ensure that plant page announcements accomplish the onsite protective measures.

D. Emergency Response Organization Augmentation - Summary Discussion In the event that site access is hazardous, as in a security event, Calvert Cliffs Emergency Responders for on-site emergency facilities are directed to report to the two local volunteer fire departments within a ten (10) minute driving distance of the facility. The Emergency Operations Facility, (EOF) is approximately seventeen (17) miles from the site. The EOF contains the necessary resources to plan mitigating actions (drawings, system information, procedures,' and access to plant electronic information sources), and to communicate with on-site and off-site organizations using a wide array of methods (phone lines, radios, satellite phones, and the internet). If access to the site is delayed significantly or the EOF requires additional personnel to plan aspects of the emergency response, the personnel at the mustering points can be directed to the EOF.

E. Drill and Exercise Program-Summary Discussion The Calvert Cliffs Nuclear Powver' Plant Emergency Plan implementing documents will be revised to include provisions' for drills and exercises using terrorist-based-events.

Based on current schedule estimates, Calvert Cliffs expects to start using terrorist-based-events not later than the first graded drill/exercise scheduled after January 1, 2008. We will perform demonstration of an emergency response to a terrorist event at least once during the 6-year exercise cycle'thereafter.

5

Attachment I NRC Bulletin 2005-02 Responses for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 This schedule is contingent on several milestones, including:

  • Development of draft industry guidelines by the end of 2005
  • Conduct of industry tabletop drill
  • Conduct of an integrated drill at each site during an off-year exercise
  • FEMA and NRC review and acceptance of terrorist-based-event exercises as meeting the requirements of their evaluated exercise program.

6

ATTACHMENT 2 NRC Bulletin 2005-02 Responses for Nine Mile Point Nuclear Power Station, Units 1 and 2 Constellation Generation Group August 17, 2005 NRC Bulletin 2005-02 Responses for Nine Mile Point Nuclear Station, Units 1 and 2 Response Area

1) Do you have provisions in place regarding the information provided in the bulletin?
2) If you do not have provisions in place, do you plan to make changes to address the information?
3) If you are making changes to your program, when will you complete those changes?
4) Provide a summary discussion of provisions in place, planned, or if different from the provisions described in this bulletin, a description of how the provisions selected by the licensee differ from those described in the bulletin, and how they adequately address the areas covered by the bulletin.

A. Security-based No -

Yes 1/20/2006 See Section A Emergency Classification Levels and Emergency Action Levels I

NRC Bulletin 2005-02 Responses for Nine Mile Point Nuclear Station, Units 1 and 2 Response Area

1) Do you have provisions in place regarding the information provided in the bulletin?
2) If you do not have provisions in place, do you plan to make changes to address the information?
3) If you are making changes to your program, when will you complete those changes?
4) Provide a summary discussion of provisions in place, planned, or if different from the provisions described in this bulletin, a description of how the provisions selected by the licensee differ from those described in the bulletin, and how they adequately address the areas covered by the bulletin.

+

t B. NRC Notifications No Yes 9/30/2005 3a) Is specific discussion of the capability to notify the NRC within 15 minutes of the discovery of a threat or attack in your notification procedures?

No See Section B 3b) If not, will you voluntarily incorporate the 15 minute notification to the NRC into your notification procedures?

Yes 2

NRC Bulletin 2005-02 Responses for Nine Mile Point Nuclear Station, Units 1 and 2 Response Area

1) Do you have provisions in place regarding the information provided in the bulletin?
2) If you do not.

have provisions in place, do you plan to make changes to address the information?

3) If you are making changes to your program, when will you complete those changes?
4) Provide a summary discussion of provisions in place, planned, or if different from the provisions described in this bulletin, a description of how the provisions selected by the licensee differ from those described in the bulletin, and how they adequately address the areas covered by the bulletin.

C. Onsite Protective Partially Yes 1/20/2006 See Section C Actions' D. Emergency Yes N/A N/A See. Section D Response..

Organization Augmentation._._.

E. Drill and Exercise No Yes Not later than the first See Section E Program drill/exercise scheduled after January 1, 2008 3

NRC Bulletin 2005-02 Responses for Nine Mile Point Nuclear Station, Units 1 and 2 A. Security-Based Emergency Classification Levels and Emergency Action Levels -

Summary Discussion Security-based emergency classification levels and emergency action levels (EALs) consistent with NUMARC/NESP-007 and the 2002 Security Order are in place. The Nine Mile Point Emergency Plan and the EAL set will be updated to reflect the information provided in Bulletin 2005-02, specifically:

  • NUMARC/NESP-007 Guidance in Bulletin 2005-02, Attachment 2, Page 6 Also, acts of civil disobedience or felonious acts that are not part of a concerted attack on the station may be addressed by non-hostile action-based EALs and EALs addressing other hazards to station operation continue to apply. Other modifications to the EAL set may be made to maintain internal consistency, e.g., EALs for classification based on judgment.

B. NRC Notifications - Summary Discussion Procedural guidance will be developed to establish an accelerated call to the NRC following discovery of an imminent threat or attack against the station. Note that during a plant transient or an imminent threat situation requiring physical security response, plant personnel are primarily responsible for stabilizing the plant and keeping it safe. This accelerated call will not be allowed to interfere with plant safety, personnel safety or physical security response. The call will be made after or concurrent with notification of local law enforcement agencies. The goal will be to initiate the accelerated call within about 15 minutes of discovery of an imminent threat or attack against the station. The information provided in the accelerated call will be limited to the following:

  • Site name
  • Emergency classification, in the unlikely event it is determined prior to the accelerated call
  • Nature of the threat (briefly described, if known), including the type of attack (e.g.,

armed assault by land, water, or'aircraft) and the attack status (i.e., imminent, in progress, or repelled)

The purpose of this notification is to allow the NRC to warn other licensees and initiate federal response in accordance with the National Response Plan. It is expected that additional information will be 'provided to the' NRC in accordance with the reporting requirements of 10 CFR 50.72(c) after the' initial notification is made per 10 CFR 50.72(a)(1)(i).

C. Onsite Protective Actions-Summary Discussion Nine Mile Point has implemented on-site protective measures based on various NRC communications since the September 11, 2001 terrorist attacks. As a result, Nine Mile Point's procedures contain many of the attributes listed in Bulletin 2005-02, Attachment 4

NRC Bulletin 2005-02 Responses for Nine Mile Point Nuclear Station, Units I and 2

4. However, to ensure completeness, on-site protective measure changes currently in effect will be evaluated against the following considerations and revised as appropriate:
  • Evacuation of personnel from target buildings (including security personnel)
  • Protected Area evacuation by. opening (while continuing to defend) security gates
  • Dispersal of licensed operators
  • Sheltering of personnel in structures away from potential site targets
  • Arrangements for accounting for personnel after the attack In addition, we will consider development of an onsite protective-measure tool to refine rapid decision making with regard to site evacuation route(s), locations for sheltering and buildings to be evacuated.

Such a tool might include considering the following circumstances relative to the time available for action:

Normal working hours

  • Off-normal hours
  • Weekends
  • Outages
  • Adverse weather As appropriate, consideration will be given to modifying procedures to ensure that plant page announcements accomplish the onsite protective measures.

D. Emergency Response Organization Augmentation - Summary Discussion In the event that site access is hazardous, as in a security event, Nine Mile Point Emergency Responders for on-site emergency facilities are directed to report to a mustering point less than one mile from the site Emergency Operations Facility (EOF),

which is approximately twelve (12) miles from the site. If access to the site is expected to be delayed significantly, some of these personnel can be directed to the EOF. The EOF contains the necessary resources to' plan mitigating actions (drawings, system information, procedures, and access to plant electronic information sources), and to communicate with on-site and off-site organizations using a wide array of methods (phone lines, radios, satellite phones, and the internet).

E. Drill and Exercise Program-Summary Discussion The Nine Mile Point Emergency Plan will be revised to include provisions for drills and exercises using terrorist-based-events. Based on current schedule estimates, Nine Mile Point expects to start using terrorist-based events not later than as part of the first graded drill/exercise scheduled after January 1, 2008. We will perform demonstration of an emergency response to a terrorist event at least once during the 6-year exercise cycle thereafter.

This schedule is based on the several rmilestones, including:

5

I V NRC Bulletin 2005-02 Responses for Nine Mile Point Nuclear Station, Units 1 and 2

  • Development of draft industry guidelines by the end of 2005
  • Conduct of industry tabletop drill
  • Conduct of an integrated drill at each site during an off-year exercise
  • FEMA and NRC review and acceptance of terrorist-based-event exercises as meeting the requirements of their evaluated exercise program 6

ATTACHMENT 3 NRC Bulletin 2005-02 Responses for R.E. Ginna Nuclear Power Plant Constellation Generation Group August 17, 2005 NRC Bulletin 2005-02 Responses for R.E. Ginna Nuclear Power Plant Response Area

1) Do you have provisions in place regarding the information

- provided in the bulletin?

2) If you do not have provisions in place, do you plan to make changes to address the information?
3) If you are making changes to your program, when will you complete those changes?
4) Provide a summary discussion of provisions in place, planned, or if different from the provisions described in this bulletin, a description of how the provisions selected by the licensee differ from those described in the bulletin, and how they adequately address the areas covered by the bulletin.

A. Security-based No Yes 1/20/2006 See Section A Emergency Classification -

Levels and Emergency Action Levels I

NRC Bulletin 2005-02 Responses for R.E. Ginna Nuclear Power Plant Response Area

1) Do'you have provisions in place regarding the information provided in the bulletin?
2) If you do not have provisions in place, do you plan to make changes to address the information?
3) If you are making changes to your program, when will you complete those changes?
4) Provide a summary discussion of provisions in place, planned, or if different from the provisions described in this bulletin, a description of how the provisions selected by the licensee differ from those described in the bulletin, and how they adequately address the areas covered by the bulletin.

B. NRC Notifications No Yes 9/30/2005 3a) Is specific discussion of the capability to'notify the NRC within 15 minutes of the discovery of a threat or attack in your notification procedures?

No 3b) If not, will you voluntarily incorporate the 15 minute notification to the NRC into your notification procedures?

Yes See Section B 2

NRC Bulletin 2005-02 Responses for R.E. Ginna Nuclear Power Plant Response Area

1) Do you have provisions in place regarding the information provided in the bulletin?
2) If you do not have provisions in place, do you plan to make changes to address the information?
3) If you are making

-changes to your program,

- when will you complete those changes?

4) Provide a summary discussion of provisions in place, planned, or if different from the provisions described in this bulletin, a description of how the provisions selected by the licensee differ from those described in the bulletin, and how they adequately address the areas covered by the bulletin.

C. Onsite Protective Partially Yes 1/20/2006 See Section C Actions D. Emergency Yes N/A N/A See Section D

Response

Organization Augmentation E. Drill and Exercise No Yes Not later than the first See Section E Program drill/exercise scheduled after January 1, 2008 3

NRC Bulletin 2005-02 Responses for R.E. Ginna Nuclear Power Plant A. Security-Based Emergency Classification Levels and Emergency Action Levels Summary Discussion Security-based emergency classification levels and emergency action levels (EALs) consistent with NUMARC/NESP-007 and the 2002 Security Order are in place. The R.E.

Ginna Emergency Plan and the EAL set will be updated to reflect the information provided in Bulletin 2005-02, specifically:

  • NUMARC/NESP-007 Guidance in'Bulletin 2005-02, Attachment 2, Page 6 Also, acts of civil disobedience or felonious'acts that are not part of a concerted attack on the station may be addressed by non-hostile action-based EALs and EALs addressing other hazards to station operation continue to apply. Other modifications to the EAL set may be made to maintain internal consistency, e.g., EALs for classification based on judgment.

B. NRC Notifications - Summary Discussion Procedural guidance will be developed to establish an accelerated call to the NRC following discovery of an imminent threat or attack against the station. Note that during a plant transient or an imminent threat'situation requiring physical security response, plant personnel are primarily responsible for stabilizing the plant and keeping it safe.'This accelerated call will not be allowed to interfere with plant safety or physical security response. The call will be made after or concurrent with notification of local law enforcement agencies. The goal will be to initiate the accelerated call within about 15 minutes of discovery of an imminent threat or attack against the station. The information in the accelerated call provided will be limited to the following:

  • Site name
  • Emergency classification, in the unlikely event it is determined prior to the accelerated call
  • Nature of the threat (briefly described, if known), including the type of attack (e.g.,

armed assault by land, water, or aircraft) and the attack status (i.e., imminent, in progress, or repelled)

The purpose of this notification is to allow the NRC to warn other licensees and initiate federal response in accordance-with the National Response Plan. It is expected that additional information will be provided to the NRC in accordance with the reporting requirements of 10 CFR 50.72(c) after 'the initial notification is made per 10 CFR 50.72(a)(1)(i).

C. Onsite Protective Actions - Summary Discussion R.E. Ginna Nuclear Power Plant, LLC has implemented on-site protective measures based on various NRC communications since the September 11, 2001 terrorist attacks.

NRC Bulletin 2005-02 Responses for R.E. Ginna Nuclear Power Plant As a result, Ginna's procedures contain many of the attributes listed in Bulletin 2005-02,. However, to ensure completeness, on-site protective measure changes currently in effect will be evaluated against the following considerations and revised as appropriate:

  • Evacuation of personnel from target buildings (including security personnel)
  • Protected area evacuation by opening (while continuing to defend) security gates
  • Dispersal of licensed operators
  • Sheltering of personnel in structures away from potential site targets
  • Arrangements for accounting for personnel after the attack In addition, we will consider development of an onsite protective-measure tool to refine rapid decision making with regard to site evacuation route(s), locations for sheltering and buildings to be evacuated.

Such a tool might include considering the the following circumstances relative to the time available for action:

  • Normal working hours
  • Off-normal hours
  • Weekends
  • Outages
  • Adverse weather As appropriate, consideration will be given to modifying procedures to ensure that plant page announcements accomplish the onsite protective measures.

D. Emergency Response Organization Augmentation - Summary Discussion In the event that site access is hazardous, as in a security event, Ginna Emergency Responders are directed to report to the Emergency Operations Facility (EOF). The EOF is located approximately twelve (12) miles from the site.

It contains the necessary resources to plan mitigating actions (drawings, system information, procedures, and access to plant electronic information sources), and to communicate with on-site and off-site organizations using a wide array of methods (phone lines, radios, satellite phones, and the internet).

E. Drill and Exercise Program - Summary Discussion The Ginna Emergency Plan will be revised to include provisions for drills and exercises using terrorist-based events. Based on current schedule estimates, Ginna expects to start using terrorist-based events not later than the first graded drill/exercise scheduled after January 1, 2008. We will perform demonstration of an emergency response to a terrorist event at least once during the 6-year exercise cycle thereafter.

This schedule is based on the several milestones, including:

5

'Attachment 3 NRC Bulletin 2005-02 Responses for R.E. Ginna Nuclear Power Plant

  • Development of draft industry guidelines by the end of 2005 Conduct of industry tabletop drill Conduct of an integrated drill at each site during an off-year exercise
  • FEMA and NRC review and acceptance of terrorist-based-event exercises as meeting the requirements of their evaluated exercise program i

6

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