ULNRC-04857, Union Electric Co., Callaway Plant Unit 1, Supplemental Response to the April 29, 2003, Orders to Callaway

Union Electric Co., Callaway Plant Unit 1, Supplemental Response to the April 29, 2003, Orders to Callaway

ML041240033
Person / Time
Site:	Callaway
Issue date:	04/26/2004
From:	Randolph G Union Electric Co
To:	Document Control Desk, Office of Nuclear Security and Incident Response
References
ULNRC-04857, ULNRC-4989
Download: ML041240033 (6)

Text

4 SAFEGUARDS INFORMATION April 26,2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 ULNRC4989 Ladies and Gentlemen:

DOCKET NUMBER 50483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 SUPPLEMENTAL RESPONSE TO THE APRIL 29,2003.

ORDERS TO CALLA WAY Reference 1: ULNRC-04857 dated June 2, 2003 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 Callaway Plant. This Supplemental Response of Union Electric Company (AmerenUE or UE) to Order EA-03-086 supplements the previous response dated June 2, 2003 Reference I that AmerenUE filed filed pursuant to 10 CFR § 50.4 and Section 111, Conditions A.1, B.I 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 IIl.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, AmerenUE is submitting this Supplemental Response for the above-mentioned licensed facility. This submittal includes, as Attachment A, revisions to the Callaway Plant 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 issued NOTE: THE ATTACHMENTS TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ATTACHMENTS, THIS LETTER IS "DECONTROLLED." 0 SAFEGUARDS INFORMATION

7 t.

• ULNRC-4989 April 26, 2004 Page 2 on February 25, 2002, January 7, 2003, and April 29, 2003. As a result, these plans supersede previous submittals of AmerenUE in these areas, including those related to the February 25, 2002, January 7, 2003, and April 29, 2003, Orders. AmerenUE 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.

AmerenUE has developed these plans to be consistent with NEI-03-01 (Revision 1),

NuclearPower PlantAccess Authorization Program(April 2004); NEI-03-09 (Revision 2), Security Officer TrainingProgram(April 2004); and NEI-03-12 (Revision 2 [draft]), Templatefor the Security Plan, Training and QualificationPlan, andSafeguards Contingency Plan. 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, Previous Exemptions to 10 CFR Part 73 is not applicable since no exemptions were previously requested or approved. Attachment E, JustiificationforAlternatives,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 AmerenUE has adopted. AmerenUE will not submit Attachment F, Vehicle Searches will exceed the options allowed in Section 9.4.1.2 of NEI-03-12.

When the final revision of NEI-03-12 is approved by the NRC, AmerenUE will supplement this response, if necessary, to conform with NEI-03-12 as finally approved. However, with the filing of these plans, AmerenUE 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, AmerenUE 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 with the annual audit requirement period.

NOTE: THE ATTACHMENTS TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ATTACHMENTS, TIllS LETTER IS "DECONTROLLED."

ULNRC-4989 April 26, 2004 Page 3 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, AmerenUE 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.

No commitments are made in this transmittal beyond those contained in the plans. In accordance with 10 CFR § 2.202(bf you have any questions concerning this matter, please contact me at (573) 676 8245 or Mr. David Shafer at (314) 554-3104.

Sincerely, Garry Randolph DES/jdg Safeguards Attachments on CD-ROM:

A) Callaway Plant Physical Security Plan Callaway Plant Contingency Plan Callaway Plant Training and Qualification Plan B) Schedule for Completion and Implementation C) Deviations from NEI-03-012 D) Previous Exemptions to 10 CFR Part 73 (None)

E) Justification for Alternatives F) Justification for Vehicle Search Criteria (None)

NOTE: THE ATTACHMENTS TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ATTACHMENTS, THIS LETTER IS "DECONTROLLED."

ULNRC-4989 April 26, 2004 Page 4 In accordance with 10 CFR § 2.202(b)(2), the following affirmation is provided:

STATE OF MISSOURI )

) SS CALLA WAY COUNTY )

Garry L. Randolph of lawful age, being first duly sworn upon oath says that he is Senior Vice President and Chief Nuclear Officer, for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By _ __

G. L. Randolph Senior Vice President &

Chief Nuclear Officer SUBSCRIBED and sworn to before me this 2 '

day of _,r,' / , 2004.

TERRA E COOK Notery PubMlo

• Notary Seal STATE OF MISSOURi Calaway County %J~AAe. (a2O4 MyCmmson E MMay 13,2008 NOTE: THE ATTACHMENTS TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ATTACHMENTS, THIS LETTER IS "DECONTROLLED."

ULNRC-4989 April 26, 2004 Page 5 cc: U.S. Nuclear Regulatory Commission Attn: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 The following are sent without Safeguards CD-ROM attachments:

Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Physical Security Inspector U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 760114005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7E1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street P0 Box 360 Jefferson City, MO 65102-0360 NOTE: THE ATTACHMENTS TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ATTACHMENTS, THIS LETTER IS "DECONTROLLED."

ULNRC-4989 April 26, 2004 LIST OF COMMITMENTS The following table identifies those actions committed to by AmerenUE in this document. Any other statements in this document are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to:.

COMMITMENT Due DatetEvent No commitments are made in this transmittal beyond those contained in the plans.

NOTE: THE ATTACHMENTS TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ATTACHMENTS, THIS LETTER IS "DECONTROLLED."