ML20237E353

Advises That 870921 Rev 8 to Physical Security & Contingency Plan Consistent W/Provisions of 10CFR50.54(p). One Change Not Consistent & Two Require Clarification as Delineated in Encl

ML20237E353
Person / Time
Site:	Browns Ferry
Issue date:	12/18/1987
From:	Barr K NRC OFFICE OF SPECIAL PROJECTS
To:	White S TENNESSEE VALLEY AUTHORITY
References
NUDOCS 8712280286
Download: ML20237E353 (4)

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CLEC 181987 Tennessee Valley Authority ATTN: Mr. S. A. White Manager of Nuclear Power 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Gentlemen:

l SUBJECT.: DOCKET NOS. 50-259, 50-260, AND 50-296 This acknowledges the receipt of your letter of September 21, 1987, which transmitted Revision 8 to the Browns Ferry Physical Security anc Contingency Plans.

Our review of the changes has found most of them to be consistent with the provisions of 10 CFR 50.54(p). Accordingly, they are acceptable for inclusion into the plan; however, one change is not consistent and two require editorial clarification as delineated in the enclosure to this letter.

Our comments were discussed on December 15 and 17,1987, with Mr. L. Ginn of your staff and Ms. C. Perny of this office. To preclude a violation of regulatory requirements, you must not implement the change deemed inconsistent.

Please revert to the commitments in your previously approved plan or, if desired, modify your plan to accommodate the enclosed comments and resubmit corrected plan pages as necessary to maintain plan continuity. Should you want to pursue that change deemed inconsistent, you must submit a request to the Commission's Of fice of Nuclear Reactor Regulation, under the provisions of 10 CFR 50.90 for amendment to your license.

Those changes which were responsive to the Miscellaneous Amendments Rule will be reviewed and acknowledged by separate correspondence from the Office of Nuclear Reactor Regulation.

The enclosure to your letter is being withheld from public disclosure because it contains Safeguards Information and must be protected in accordance with the provisions of 10 CFR Part 73.21.

Should you have any questions concerning this letter, we will be glad to discuss them with you.

Sincerely, Kenneth P. Barr, Acting Assistant Director for Inspection Programs 1 TVA Projects Division Office of Special Projects

Enclosure:

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Tennessee Valley Authority' 2 D{C j g jgg7 Enclosure.

Plan Com:nents cc w/ enc 1:

R. L. Gridley Tennessee Valley Authority SN 1578 Lookout Place Chattanooga, Tennessee 37402-2801 H. P. Pomrehn Tennessee Valley Authority Browns Ferry Nuclear Plant P.O. Box 2000 Decatur, Alabama 35602 M. J. May Browns Ferry Nuclear Plant P.O. Box 2000 Decatur, Alabama 35602 General Counsel Tennessee Valley Authority 400 West Summit Hill Drive E11 B33 Knoxville, Tennessee 37902

0. L. Williams Tennessee Valley Authority 400 West Summit Hill Drive W10 BB5 Knoxville, Tennnessee 37902 Chairman, Limestone County Commission P.O. Box 188 Athens, Alabama 35611 Claude Earl Fox, M.D.

State Health Officer State Department of Public Health State Office Building Montgomery, Alabama 36130 Richard King l c/o U.S. GAO l 1111 North Shore Drive 1 Suite 225, Box 194 Knoxville, Tennessee 37919 {

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, t TVA Representative i 4922 Fairmont Ave. l Bethesda, MD 20B14  !

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Michael H. Mobley, Director Division of Radiological Health T.E.R.R.A. Building 150 9th Avenue North Nashville, Tennessee 37203 TVA Representative 4922 Fairmont Ave.

Bethesda, MD 20814 i

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J. N. Grace '

G. G. Zech, OSP S. D. Ebneter, OSP B. D. Liaw, OSP S. D. Richardson, OSP K. P. Barr, OSP/RII A. J. Ignatonis, OSP/RII A. H. Johnson, OSP/RII J. Rutberg, OGC Chief, PWR Technology Branch NRC Technology Training Center Osborne Office Center Suite 200 Chattanooga, Tennessee 37411 q J

Document Control Desk (RG01), 42-P J Director, Division of Reactor ,

4 Inspection and Safeguards, NRR EWS-305A Region II Licensing File, (50-327) (28VA) TAB 2 NRC Resident Inspector W. Tobin State of Tennessee l 1

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ENCLOSURE REVISION 8 TO THE BROWNS FERRY PHYSICAL SECURITY / i i

CONTINGENCY PLANS Inconsistent Change Section Page Comment i

1.6.5 1-11a Part of this section describes access control requirements shich may- be waived during preplanned drills and exercises. It also describes four actions which must be accomplished if requirements are going to be waived.

Section 5.5 of Regulatory Guide 5.6 identifies protected area access requirements which may be waived during preplanned drills and exercises.

It states that the drill / exercise must stop at the vital area boundary. There is no regulatory authority for relaxation of controls into vital areas during any non-emergency situation.

I Action: Include a statement in the security plan that the relaxation of access control requirements during preplanned drills and exercises does not include access requirements for vital areas of the plant.

Changes Requiring Administrative Clarification Section Page Comment 1.1.1.1 1-2 The heading for this section is: Director, Division of Nuclear Services; however, the narrative describes the duties of the Chief, Nuclear Security Branch.

Action: Change the section heading to reflect the position title it describes.

Appendix B B-3 Attachment B.2 is a layout of the East Access Control Facility. In this revision, the drawing was revised and enlarged; however, that portion of the drawing which showed the location security barrier and bullet proof access control area was deleted. 1 Action: Add the floor plan of the bullet proof access control area to the drawings in  ;

Appendix B. i l

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