ML122290308

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Draft RAI - Oyster Creek Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 12
ML122290308
Person / Time
Site: Oyster Creek
Issue date: 08/16/2012
From: John Lamb
Plant Licensing Branch 1
To: David Helker
Exelon Generation Co LLC
Lamb J
References
Download: ML122290308 (3)


Text

From:

Lamb, John Sent:

Thursday, August 16, 2012 10:32 AM To:

'david.helker@exeloncorp.com' Cc:

'thomas.loomis@exeloncorp.com'; Richard.Gropp@exeloncorp.com; Khanna, Meena; Roundtree, Amy; Wiebe, Joel

Subject:

For Your Review - DRAFT RAI - Oyster Creek Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 12 Importance:

High

Tom, Below, for your review, is a DRAFT Request for Additional Information (RAI) regarding the Oyster Creek Physical Security Plan (PSP), Training and Qualification Plan (T&QP), and Safeguards Contingency Plan (SCP), Revision 12. Please review to ensure that the questions are understandable, the regulatory basis is clear, there is no proprietary information or safeguards information contained in the DRAFT RAI, and to determine if the information was previously docketed. Please also let me know how much time Exelon needs to respond to the RAI.

Thanks.

John DRAFT RAI By letter dated July 13, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12198A298), Exelon Generation Company, LLC (the licensee) submitted the Oyster Creek Nuclear Generating Stations (Oyster Creek) Physical Security Plan (PSP), Training and Qualification Plan (T&QP), and Safeguards Contingency Plan (SCP),

Revision 12. The enclosure to the letter contained Safeguards Information and has been withheld from public disclosure.

The U.S. Nuclear Regulatory Commission (NRC) staff is currently reviewing the submittal to ensure compliance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(p)(2), has determined that additional information is required to complete the review. The specific information requested is below.

DRAFT REQUEST FOR ADDITIONAL INFORMATION

1. In section 11.3 of the PSP, the licensee describes protected area (PA) barriers. The plan describes areas where there is no isolation zone in accordance with 10 CFR 73.55(e)(8)(iv). Describe any other buildings and/or structures do not have an isolation zone. Additionally, the licensee should make appropriate changes during the next revision of the sites PSP to ensure the language clearly describes any building or structures that do not have an isolation zone in accordance with 10 CFR 73.55(c)(3).
2. In section 15.1 of the PSP, the licensee describes illumination at Oyster Creek.

Describe how the use of alternative technology for the assessment of the PA perimeter in no-light or low-light conditions meets the requirements 10 CFR 73.55(e)(7)(i)(C) and 73.55(i)(2). Describe the technology used for assessment of the PA perimeter in no-light or low-light conditions.

3. In section 15.5.1 of the PSP, the licensee describes owner controlled area (OCA) surveillance methods. The second numbered paragraph does not adequately address the language in the bracketed text of NEI 03-12, Revision 7; it solely discusses facility procedures. Describe what equipment and/or personnel are used for OCA surveillance. Also, the licensee should make appropriate changes during the next revision of the sites PSP to ensure the language clearly describes the equipment and/or personnel used for OCA surveillance what technology in accordance with 10 CFR 73.55(c)(3).
4. In section 4.1.2 of the SCP, the licensee describes the security chain of command and delegation of authority. The description of the security chain of command and delegation of authority in Revision 11 of the SCP is different than in Revision 12.

Provide an explanation of the rationale for the change. Describe who is responsible for command and control when the individuals listed are not available. Additionally, the licensee should make appropriate changes during the next revision of the sites SCP to ensure the language clearly describes the security chain of command and delegation of authority in accordance with 10 CFR 73.55(c)(5).

5. In section 5.4 of the SCP, the licensee describes facility operations personnel response. The description of training in Revision 11 of the SCP is different than in Revision 12. This change was not described in the Description of Changes report in Revision 12. Provide an explanation of the change. Was this change evaluated to ensure it complies with 50.54(p)(2)? The licensee should make appropriate changes during the next revision of the sites SCP section 5.4 to ensure the language clearly describes the training related to facility operations personnel response in accordance with 10 CFR 73.55(c)(5).
6. In section 7 of the SCP, the licensee describes their OCA vehicle checkpoint. It is unclear from the language whether the OCA vehicle checkpoint meets the requirements of 10 CFR 73.55(h)(2)(iii) and (h)(2)(v). Describe the OCA vehicle checkpoint and how it meets the requirements of 10 CFR 73.55(h)(2)(iii) and 10 CFR(h)(2)(v). Additionally, the licensee should make appropriate changes during the next revision of the sites SCP to ensure to ensure the language clearly describes the OCA vehicle checkpoint in accordance with 10 CFR 73.55(c)(5).
7. In section 7 of the SCP, the licensee describes assessment capabilities of the security officers in the bullet-resistant enclosures (BREs). Are these assessment capabilities separate and distinct from meeting the requirements of 10 CFR

73.55(i)(1) and 10 CFR 73.55(i)(2)? Describe the assessment capabilities and the requirements of the security officers in BREs and the assessment capabilities of the alarm stations. Additionally, the licensee should make appropriate changes during the next revision of the sites SCP to ensure to ensure the language clearly articulates the assessment capabilities to the security officers in BREs and those in the alarm stations in accordance with 10 CFR 73.55(c)(5).