NOC-AE-04001710, Supplemental Response to the April 29, 2003, Orders to South Texas Project
| ML041240207 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/27/2004 |
| From: | Sheppard J South Texas |
| To: | Document Control Desk, Office of Nuclear Security and Incident Response |
| References | |
| EA-03-086, NOC-AE-04001710 | |
| Download: ML041240207 (5) | |
Text
Nuclear Operating Company S 3UARDS INFORMATIONl South 7=s Pf ctEkct* Gemr3nASUon RO. &a*2839 WTdmxrah 7res7743 VVV%-
April 27,2004 NOC-AE-04001710 U. S. Nuclear Regulatory Commission Attention: Document Control Desk ATTACHMENTS CONTAIN SAFEGUARDS INFORMATION One White Flint North UPON SEPARATION THIS 11555 Rockville Pike PAGE IS DECONTROLLED Rockville,MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 Supplemental Response to the April 29, 2003, Orders to South Texas Proiect
Reference:
Letter, J. J. Sheppard to NRC Document Control Desk "Answer, Response and Request for Clarification in Response to April 29, 2003, Order Requiring Compliance with Revised Design Basis Threat for Operating Power Reactors (EA-03-086)," June 2, 2003 (NOC-AE-03001538)
The NRC issued an Order dated April 29, 2003, Requiring Compliance with Revised Design Basis Threat ("Order EA-03-086" or "Order") and other security-related Orders (collectively "Orders") for the South Texas Project. This Supplemental Response of STP Nuclear Operating Company (STPNOC) to Order EA-03-086 supplements the previous response dated June 2, 2003 that STPNOC filed pursuant to 10 CFR § 50.4 and Section III, Conditions A.1, B.1, and B.2.
Order EA-03-086 imposes license conditions on nuclear power plants licensed pursuant to the Atomic Energy Act of 1954 and Title 10 of the Code of Federal Regulations.Section III.A of the Order requires licensees to revise their physical security plans and safeguards contingency plans to provide protection against the revised design basis threat (DBT) set forth in Attachment 2 to the Order.Section III.A also requires licensees to revise the security force training and qualification plan to implement the revised DBT. These revised plans, along with an implementation schedule, were required to be submitted to the Commission for review and approval no later than April 29, 2004.
In accordance with the Order and 10 CFR § 50.4, STPNOC is submitting this Supplemental Response for the above-mentioned licensed facility. This submittal includes, as Attachment A, revisions to the South Texas Project Physical Security Plan, the Contingency Plan, and the Training and Qualification Plan as required by Order EA-03-086. These plans contain the integrated commitments to comply with Order EA-03-086 and the other security-related Orders STI:31726159 lSAFEGUARDS INFORMATION lh
NOC-AE-04001710 SAFEGUARDS INFORMATION I , age 2 of 4 issued on February 25, 2002, January 7, 2003, and April 29, 2003. As a result, these plans supersede previous submittals of STPNOC in these areas, including those related to the February 25, 2002, January 7, 2003, and April 29, 2003, Orders. STPNOC will continue to implement the provisions of those previous submittals except to the extent that they are superseded by these plans. All changes that have been or will be made have been evaluated to ensure that they do not compromise plant safety.
STPNOC has developed these plans to be consistent with NEI-03-01, (Revision 1), Nuclear Power PlantAccess Authorization Program(April 2004); NEI-03-09, (Revision 2 (draft)),
Security Officer Training Program (April 2004); and NEI-03-12, (Revision 2 (draft)), Template for the Security Plan, Trainingand QualificationPlan, Safeguards Contingency Plan, (April 2004). The schedule for completing those actions, which includes the identification of major transitional activities, is provided in Attachment B to this submittal. To facilitate the NRC's review, any provisions that are different from NEI-03-12 are identified and the justification provided in Attachment C, Deviationsfrom NEI-03-12, to this submittal. Attachment D, JustificationforAlternatives, includes the justification for any of the alternatives provided in NEI-03-12 or in "NRC Guidance on Implementation of the April 2003 Revised Design Basis Threat" that STPNOC has adopted.
When the final revision of NEI-03-12 is approved by the NRC, STPNOC will supplement this response, if necessary, to conform with NEI-03-12 as finally approved. However, with the filing of these plans, STPNOC will be implementing its revised protection strategy and completing plant modifications and security personnel training pursuant to these plans to ensure that implementation will be completed by October 29, 2004, as required by the Orders. Upon completion of the implementation of these plans, STPNOC will be in compliance with all applicable security requirements. For the purpose of complying with the requirements of 10 CFR Part 73 to conduct an annual audit, the date of the letter that will be submitted to the NRC pursuant to Order EA-03-086 certifying that implementation of the plans is complete will be the effective date for determining commencement of the annual audit requirement period.
Because of the requirement for these plans to be fully implemented by October 29, 2004; the need to integrate the requirement of the revised DBT Order with the Orders issued February 25, 2002, January 7, 2003, and April 29, 2003; and the Commission's determination that it would be appropriate to exercise enforcement discretion to accommodate any transitional issues which may arise as licensees, in good faith, take reasonable actions to implement the specific requirements of the Orders, STPNOC requests that enforcement discretion be exercised during the transition period until full implementation of the plans is accomplished and the physical plant modifications and security force training are complete. At that time, the revised plans will be fully implemented and the exercise of enforcement discretion will no longer be necessary.
ATTACHMENTS CONTAIN SAFEGUARDS INFORMATION UPON SEPARATION THIS PAGE IS DECONTROLLED SAFEGUARDS INFORMATION STI:31726159
NOC-AE-04001710 l SAFEGUARDS INFORMATION I Page 3 of 4 The attachments to this letter contain safeguards information and should be withheld from public disclosure in accordance with 10 CFR 73.21.
Attachment E contains one copy of the entire Plan submittal (Attachments A, B, C, D, and this letter) on CD-ROM as allowed by NRC Regulatory Issues Summary 2001-05, dated January 25, 2001.
Please direct any questions regarding this letter to Mr. Mark McBurnett at (361) 972-7206.
In accordance with 10 CFR § 2.202(b), the following affirmation is provided:
I declare under penalty of perjury that the foregoing is true and correct.
Executed on: '&7Lo l J. J. Sheppard President & Chief Executive Officer rdp Attachments: A) South Texas Project Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Rev. 0 B) Schedule for Completion and Implementation C) Deviations from NEI-03-12 D) Justification for Alternatives E) CD-ROM - Plan Submittal ATTACHMENTS CONTAIN SAFEGUARDS INFORMATION UPON SEPARATION THIS PAGE IS DECONTROLLED STI: 31726159 l SAFEGUARDS INFORMATION l
NOC-AE-04001710 SAFEGUARDS INFORMATION I age 4 of 4 cc:
(*** electronic copy w/out Attachments)
(paper copy)
Bruce S. Mallett wioutAffachments A. H. Gutterman, Esquire ***
Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 L. D. Blaylock ***
Arlington, Texas 76011-8064 City Public Service Jeffrey Cruz Wiout Attachments Michael K. Webb ***
U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MN116 Wadsworth, TX 77483 R. L. Balcom ***
Texas Genco, LP Senior Physical Security Inspector, Region IV A. Ramirez ***
U.S. Nuclear Regulatory Commission City of Austin 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 C. A. Johnson ***
(wv/out Attachments) AEP Texas Central Company Richard A. Ratliff wioutAttachnments Jon C. Wood ***
Bureau of Radiation Control Matthews & Branscomb Texas Department of Health 1100 West 49th Street Austin, TX 78756-3189 C. M. Canady iv/outAttachments City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 ATTACHMENTS CONTAIN SAFEGUARDS INFORMATION UPON SEPARATION THIS PAGE IS DECONTROLLED SAFEGUARDS INFORMATION l
Nuclear Operating Compy l SAFEGUARDS INFORMATION l South Thos Pftd Ekdrkc GMcncrangSZauon PO BW 2&89 Wrj, TMos 7743 .
- April 29, 2004 NOC-AE-04001723 STI 31741738 U. S. Nuclear Regulatory Commission Attention: Roland Wood ATTACHMENTS CONTAIN SAFEGUARDS INFORMATION One White Flint North UPON SEPARATION THIS 11555 Rockville Pike PAGE IS DECONTROLLED Rockville, MD 20852 South Texas Project Replacement CD-ROM - South Texas Project Security Plan
Reference:
Letter, J. J. Sheppard to NRC Document Control Desk "Supplemental Response to the April 29, 2003, Orders to South Texas Project," April 27, 2004 (NOC-AE-04001710)
Attachment A contains four copies of the CD-ROM provided in the submittal referenced above.
The CD-ROMs contain safeguards information and should be withheld from public disclosure in accordance with 10 CFR 73.21.
Please direct any questions regarding the CD-ROMs to Robyn Savage at (361) 972-7438.
Scott M. Head Manager, Licensing rdp Attachments: A) CD-ROM - Plan Submittal (4 copies) l SAFEGUARDS INFORMATION l