ND-20-1220, Report of Changes Incorporated Into Revision 6 to the Security Plan, Training and Qualification Plan, and Safeguards Contingencv Plan

Report of Changes Incorporated Into Revision 6 to the Security Plan, Training and Qualification Plan, and Safeguards Contingencv Plan

ML20296A245
Person / Time
Site:	Vogtle
Issue date:	10/21/2020
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-20-1220
Download: ML20296A245 (6)

Text

.1 I. I I Michael J. Yox 7825 River Road Southern Nuclear Regulatory Affairs Director Waynesboro, GA 30830 Vogtle3& 4 706-848-6459 tel October 21, 2020 Docket No.: 52-025 ND-20-1220 52-026 10 CFR50.54(p)(2)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant - Units 3 & 4 Report of Changes Incorporated into Revision 6 to the Security Plan, Training and Qualification Plan, and Safeguards Contingencv Plan Ladies and Gentlemen:

In accordance with the reporting requirements of 10 CFR 50.54(p), Southern Nuclear Operating Company (SNC) hereby submits a report containing a description of the changes incorporated into Revision 6 of the Vogtle Electric Generating Plant (VEGP) 3&4 Security Plan, which includes the Training and Qualification Plan and the Safeguards Contingency Plan, which was implemented on September 24, 2020. SNC has reviewed the changes incorporated into Revision 6 in accordance with the provisions of 10 CFR 50.54(p)(2) and determined that this revision does not decrease the safeguards effectiveness of the Security Plan.

In accordance with 10 CFR 52.3(b)(4), the appropriate copies are being provided to the NRC Document Control Desk and the Region II Office. provides a description of the changes incorporated into the SNC VEGP 3&4 Security Plan by Revision 6. At the next annual Updated Final Safety Analysis Report (UFSAR) submittal, the latest revision of the Vogtle Electric Generating Plant(VEGP)3&4 Security Plan will be submitted in accordance with 10 CFR 50.71(e) as an incorporated by reference document to the UFSAR.

This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security-related information.

Should you have questions regarding the enclosed information, please contact Kelli Roberts at (706) 848-6991.

Respectfully submitted, Michael J. Yox L/

Regulatory Affairs Director Vogtle 3 & 4 Southern Nuclear Operating Company

Enclosure:

1) Description of Changes Incorporated into Revision 6 of the SNC VEGP 3&4 Security Plan MJY/LBP/sfr

U.S. Nuclear Regulatory Commission ND-20-1220 Page 2 of 3 go:

Southern Nuclear Qperatino Company / Georgia Power Comoanv Mr. S. E. Kuczynski (w/o enclosures)

Mr. P. P. Sena III {\n/o enclosures)

Mr. M. D. Meier (w/o enclosures)

Mr. G. Chick Mr. S. P McGavin Mr. S. Stimac Mr. P. Martino Mr. D. L. McKinney (w/o enclosures)

Mr. T. W.Yelverton (w/o enclosures)

Mr. B. H. Whitley Ms. C. A. Gayheart Ms. M. Ronnlund Mr. D. L. Fulton Mr. M. J. Vox Mr. M. P. Long Mr. C. T. Defnall Mr. J. Tupik Ms. S. Agee Mr. M. Humphrey Ms. A. C. Chamberlain M S. Leighty M N. Kellenberger M E. Riffle Ms. K. Roberts Mr. J. Haswell Mr. D. T. BIythe Mr. K. Warren Mr. A. S. Parton Document Services RP/PE: VND.LI.LOO File AR.01.02.06 Nuclear Reoulatorv Commission Mr. M. King (w/o enclosures)

Ms. M. Bailey w/o enclosures)

Mr. C. Patel Mr. C. Santos Mr. B. Kemker Mr. J. Eargle Mr. G. Khouri Mr. C. J. Even Mr. A. Lerch Mr. S. Walker Mr. N.D. Karlovlch Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. V. Hall Mr. M. Webb

U.S. Nuclear Regulatory Commission ND-20-1220 Page 3 of 3 State of Georoia Mr. R. Dunn Oolethorpe Power Corporation Mr. M. W. Price Ms. A. Whaley Municipal Electric Authority of Georoia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinahouse Electric Company. LLC Mr. L. Oriani (w/o enclosures)

Mr. T. Rubenstein (w/o enclosures)

Mr. M. Corletti Mr. D. Hawkins Mr. J. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.

Mr. S. Roetger, Georgia Public Service Commission Mr. R.L. Trokey, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham

U.S. Nuclear Regulatory Commission ND-20-1220 Enclosure 1 Page 1 of 3 Southern Nuclear Operating Company ND-20-1220 Enclosure 1 Vogtle Electric Generating Plant(VEGP) Units 3 & 4 Description of Changes Incorporated into Revision 6 of the SNC VEGP 3&4 Security Plan

U.S. Nuclear Regulatory Commission ND-20-1220 Enclosure 2 Page 2 of 3 ND-20-1220 Enclosure 1 Description of Changes Incorporated Into Revision 6 of the SNC VEGP 3&4 Security Plan Description of Chances This revision of the SNC VEGP 3&4 Security Plan Is performed to Incorporate Revision 1 of the Special Nuclear Material Physical Protection Program (SNMPPP). Revision 1 of the SNMPPP Is an attachment to Appendix E of the VEGP 3&4 COL Physical Security Plan.

Revision 1 to the SNMPPP adds additional scope related to the physical protection of the VEGP Units 3& 4 Protection and Safety Monitoring System (PMS) Nuclear Instrumentation System (NIS) Intermediate Range (IR) Detectors during transfer from their controlled access area(CAA) within the VEGP Units 1 & 2 Protected Area(PA)to Installation In their final locations within their respective VEGP Units 3 & 4 reactor cavities. While Installed In their final location, the IR Detectors will be protected In accordance with the SNMPPP until VEGP Units 3 & 4, respectively, establish a Protected Area(PA)that compiles with 10 CFR 73.55. Protections for the IR Detectors In accordance with the SNMPPP and/or 10 CFR 73.55 meet or exceed the requirements contained In 10 CFR 73.67 for protection of Special Nuclear Material(SNM)of low strategic significance.

A descriptive listing of changes to Revision 1 Is given below. Clarifying, editorial, and formatting changes are excluded from this listing.

• A "Revision History" page Is added. A note Is Included on the page to Identify that Sections 5.3, 5.4, 5.6, 5.9, and 5.10 of the SNMPPP cannot be revised without prior approval from the NRC as per license condition 2.D(12)(e).

• Section 1,"Scope" Is revised to Identify that protection of the IR Detectors Is Included within the scope of the SNMPPP,to provide a physical description of the IR Detectors, to denote that the CAA for the IR Detectors will not be a Critical Target Area (CTA), and to note that the SNMPPP will be Implemented at the receipt of new fuel or the IR detectors on VEGP Unit 3, when applicable.

• Section 2,"Definitions" Is revised to modify the definition of an Armed Security Officer(ASO)

In context to their duties related to the SNMPPP and to add the definitions for Watchperson, Owner-Controlled Area, and Construction-Controlled Area as they relate to the SNMPPP.

• Section 3,"Organizational Requirements" Is revised to update the titles of select security organization positions that have responsibility for Implementing various elements of the SNMPPP and to Indicate that the organizational and management structure for activities associated with SNM not related to physical protection are described In applicable Reactor Engineering procedures.

Section 4,"SNM Physical Protection Program" Is revised to reflect the use of a TCAA as necessary and to modify the listing of organizational positions with authority to revise the SNM physical protection procedures based on changes to the organization subsequent to Revision 0 to the SNMPPP.

U.S. Nuclear Regulatory Commission ND-20-1220 Enclosure 2 Page 3 of 3

• Section 5,"Site Physical Protection Measures" is revised to reflect that Section 5 applies only to physical protection of new fuel assemblies and to replace the procedural steps listed in section 5.1 with a procedural reference to ensure application of the current processes.

• Section 6,"Site Physical Protection Measures for SNM in the Form of Intermediate Range Detectors" is added in its entirety to address the physical protection program associated with the IR Detectors.

• Section 7,"Shipment/Handling"(previously section 6), is revised to note that procedural controls are in place to assure that SNM in fuel is not shipped inadvertently with shipments of non-fuel SNM waste; to specify that the SNMPPP will not be utilized to perform any action associated with the export or import of SNM; and to add two new subsections that describe shipping and handling processes for the new fuel and IR detectors, respectively.

• Section 8,"Reporting" is added in its entirety to discuss reporting requirements associated with the loss of a SNM shipment and/or a theft or unlawful diversion involving SNM.

• Section 9,"Figures"(previously section 7), is revised to add the figures associated with physical protection of the IR detectors.

• Section 10,"Notes" is added in its entirety to clarify a cross-reference to the PSP that is administrative in nature and does not alter the effectiveness of the program.