WO 04-0022, Supplemental Response to the April 29, 2003, Order

Supplemental Response to the April 29, 2003, Order

ML041270134
Person / Time
Site:	Wolf Creek
Issue date:	04/29/2004
From:	Jacobs D Wolf Creek
To:	NRC/SECY/RAS
References
EA-03-086, WO 04-0022
Download: ML041270134 (4)

Text

-WELF CREEK

-- 'NUCLEAR OPERATING CORPORATION Donna Jacobs Vice President Operations and Plant Manager

- I APR 2 9 2001 WO 04-0022 Secretary Office of the Secretary of the Commission' ATTN: Rulemakings and Adjudications Staff Washington, DC 20555-0001 -

References:

1) Letter dated April 29, 2003 from S. J. Collins, USNRC, to Holders of Licenses for Operating Power Reactors, Order

- Requiring Compliance With Revised Design Basis Threat for Operating Power Reactors.

2) Letter dated June 2, 2003, from B. T. McKinney, to USNRC

Subject:

-Docket50-482: Supplemental Response to the April 29, 2003, Order to Wolf Creek Nuclear Operating Corporation (WCNOC)

Gentlemen:

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 Wolf Creek Generating Station. This Supplemental Response of Wolf Creek Nuclear Operating Corporation (WCNOC) to Order EA-03-086 supplements the previous response dated June 2, 2003 that WCNOC 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, WCNOC is submitting this Supplemental Response for Wolf Creek Generating :Station. This submittal includes, as Attachment A, revisions to the Wolf Creek Generating Station (WCGS) 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 on February 25, 2002, January 7, 2003, and April 29, 2003. As a result, these plans supersede previous submittals of WCNOC in these areas, including those ATTACHMENTS CONTAIN SAFEGUARDS INFORMATION. UPON SEPARATION THIS PAGE IS DECONTROLLED -

P.O. Box 411 / Burlington, KS 66839/ Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET

• - -~. WO 04-0022

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related to the February 25, 2002, January 7, 2003, and April 29, 2003,-Orders. WCNOC 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 comipr6mise plant safety. '  ;-

WCNOC has developed these plans to-be consistent with NEI-03-01 (Revision 1), Nuclear Power Plant Access 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, Training and Qualification Plan, 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, Deviations from NEI-03-12, to this submittal. - Attachment - D, Previous Exemptions to 10 CFR Part 73, is a listinig of any exemptions to 10 CFR Pnrt 73 pteviously -

granted to WCNOC and an explanation-of their status under-the plans.hereby submitted.

Attachment E, Justification for Altematives, includes the justification for any of the alternatives provided in NEI-03-12 or in UNRC Guidance on Implementation of the April 2003 Revised -

Design Basis Threat" that WCNOC has adopted:-

-- i-When the final revision of NEI-03-12 is-appiroved by the NRC, WCNOC will supplement this response, if necessary, to conform with NEI-03-12 as finally approved. -However, with the filing of these plans, WCNOC 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, WCNOC 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 requirements 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,' WCNOC. 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.

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If you have any questions concerning this'matter, please contact me at (620) 364-4246,-or Mr. -

Kevin Moles at (620) 364-4126. -

- - --'.Very truly yours,

.: -.- . -Donfia Jacobs DJ/rIg . -

ATTACHMENTS-CONTAIN SAFEGUARDS INFORMATION. UPOIN SEPARATION ' - ' '

THIS PAGE IS DECONTROLLED

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Attachments A. Wolf Creek Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Rev.0- . -

B. Wolf Creek Implementation Schedule - -

C. Deviations from NEI-03-12 D. Previous Exemptions to 10 CFR Part 73 E. Justification for Alternatives cc: J. N. Donohew (NRC), w/o - -

D. N. Graves (NRC), w/o -

B. S. Mallett (NRC), w/o -------- ---- -

Assistant General Counsel for Materials Litigation and Enforcement (NRC), wlo Director, Office of Nuclear Reactor Regulation, w/o Director of Nuclear Security, Office of Nuclear Security and Incident Response, w/o

-- ~~Document Control Desk, w/o

-Senior Resident Inspector (NRC), w/o ---

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- - '. __ _7' _" 7-  :- - - -

ATTACHMENTS CONTAIN SAFEGUARDS INFORMATION. UPON SEPARATION THIS PAGE-IS DECONTROLLED - -

STATE OF KANSAS Ss)

COUNTY OF COFFIEY )

Donna Jacobs,-of lawful age, being first duly sworn upon oath says that she is Vice President Operations and Plant Manager of Wolf Creek Nuclear Operating Corporation; that she has read the foregoing document and knows the contents thereof; that she has executed the same for and on behalf of said Corporation with full power and authority to do so; and that-the facts

- therein stated are true and correct to the best of her knowledge, information and belief. -

By --

- Donna Jacobs

- Vice Presiden perations and Plant Manager SUBSCRIBED and sworn to before me -this day of Q- 2004.

F FO AL.E- Notary Public STAE OFKANSASlMy Appt Exp. - z- - -

Expiration Date -- f______z ______