ML060820332

Ltr G Williams Response to Entergy'S Operations Request for an Extension to Implement ICMs & Acknowledgement of 20-Day Response to ICMs and Access Authorization (AA) Orders for the Grand Gulf ISFSI

ML060820332
Person / Time
Site:	Grand Gulf
Issue date:	04/07/2006
From:	Strosnider J Office of Nuclear Material Safety and Safeguards
To:	Gerald Williams Entergy Operations
Lewis R NRC/NMSS/SFPO 301-415-3567
References
EA-05-197, EA-05-198
Download: ML060820332 (3)

Text

April 7, 2006 George A. Williams Vice President - Operations Grand Gulf Nuclear Station Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

RESPONSE TO ENTERGY OPERATIONS INC.S REQUEST FOR AN EXTENSION TO IMPLEMENT INTERIM COMPENSATORY MEASURES AND ACKNOWLEDGMENT OF 20-DAY RESPONSE TO INTERIM COMPENSATORY MEASURES AND ACCESS AUTHORIZATION ORDERS FOR THE GRAND GULF NUCLEAR STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Dear Mr. Williams:

On August 26, 2005, the U.S. Nuclear Regulatory Commission (NRC) issued Orders to Entergy Operations Inc. (Entergy) requiring implementation of interim compensatory measures (ICM Order EA 05-197, 70 FR 66474) for security and safeguards, and additional security measures (ASM Order EA 05-198, 70 FR 66475) for access authorization for its independent spent fuel storage installation (ISFSI) at the Grand Gulf Nuclear Station (GGNS). These Orders were issued in response to Commission determination that additional security measures are required after the events of September 11, 2001, and that these security measures should be embodied in Orders, consistent with the established regulatory framework. These actions are interim and are based on the need to take prudent actions to address security requirements in the current threat environment. As a result, the requirements of the Orders must be in place before first receipt of spent fuel and initial operations at an ISFSI, and they do not obviate the need for licensees to continue to meet and maintain the effectiveness of existing security measures taken in response to the events of September 11, 2001.

The ICM and ASM Orders, which were immediately effective, required licensee responses and licensee actions within specified time frames.Section III.A of the Orders required Entergy to immediately start implementation of the requirements listed in Attachment 1 to each Order and to complete implementation no later than April 26, 2006, or the first day that spent fuel was initially placed in the ISFSI, whichever was earlier. For the ASM Order, an exception was provided for ASM B.4, which was to be implemented not later than October 26, 2006, or the first day that spent fuel was initially placed in the ISFSI, whichever was earlier. The timely implementation of the ICM and ASM requirements helps ensure that they are fully effective before the first fuel loading and facilitates NRC inspection to verify the secure use and management of radioactive materials.

In three letters dated November 15, 2005 (GNRO-2005/00062-00064), Entergy submitted its written response to the Orders. First, Entergy waived its rights to an adjudicatory hearing for both Orders EA 05-197 and -198, pursuant to 10 CFR 2.202. Further, Entergy consented to full implementation of the Orders, with the following exception. For the ICM Order EA 05-197,

G. Williams 2 pursuant to Section III.D, Entergy requested that the Director, Office of Nuclear Material Safety and Safeguards, grant relaxation of the Section III.A requirement to fully implement ICM requirements no later than April 26, 2006. Entergy noted that its scheduled date for first spent fuel loading will occur after April 26, 2006, and that its estimated completion date for the GGNS ISFSI is planned for October 2006. Entergy committed to "ensuring all commitments identified in the response letter are completed prior to offloading any spent fuel for movement into the ISFSIs." In particular, Entergy committed that it will not ungrapple any irradiated spent fuel assembly in any ISFSI transfer cask, or the like, before the requirements identified in the ICM Order are completed. This specificity clarifies that Entergy may conduct other ISFSI-related and spent fuel operations within its spent fuel pool, in part, in preparation for the actual offloading of spent fuel from the spent fuel pool.

The staff has reviewed your basis for the relaxation request to Order EA-05-197, and finds that Entergy has shown good cause for relaxation. Entergy's justification for relaxation is consistent with the intent of the ICM Order and provides reasonable assurance of secure use and management of subject radioactive materials. Therefore, the staff grants relaxation to allow the complete implementation of ICM requirements after April 26, 2006, and before ungrappling any irradiated spent fuel assembly in any ISFSI transfer cask, or the like, for removal from the spent fuel pool.

Note that pursuant to Section III.C.2 of the Orders, Entergy is to report to the Commission, in accordance with 10 CFR 72.4, when it has achieved full compliance with all the requirements described in Attachment 1 to both Orders. NRC will determine the effectiveness of your implementation of the ICMs and ASMs through onsite inspections.

Please contact Robert Lewis of my staff at 301-415-3567, to help resolve any issues related to compliance with the requirements in the Orders, or if you have any questions.

Sincerely,

/RA/

Jack R. Strosnider, Director Office of Nuclear Material Safety and Safeguards Docket No. 72-50

G. Williams 2 pursuant to Section III.D, Entergy requested that the Director, Office of Nuclear Material Safety and Safeguards, grant relaxation of the Section III.A requirement to fully implement ICM requirements no later than April 26, 2006. Entergy noted that its scheduled date for first spent fuel loading will occur after April 26, 2006, and that its estimated completion date for the GGNS ISFSI is planned for October 2006. Entergy committed to "ensuring all commitments identified in the response letter are completed prior to offloading any spent fuel for movement into the ISFSIs." In particular, Entergy committed that it will not ungrapple any irradiated spent fuel assembly in any ISFSI transfer cask, or the like, before the requirements identified in the ICM Order are completed. This specificity clarifies that Entergy may conduct other ISFSI-related and spent fuel operations within its spent fuel pool, in part, in preparation for the actual offloading of spent fuel from the spent fuel pool.

The staff has reviewed your basis for the relaxation request to Order EA-05-197, and finds that Entergy has shown good cause for relaxation. Entergy's justification for relaxation is consistent with the intent of the ICM Order and provides reasonable assurance of secure use and management of subject radioactive materials. Therefore, the staff grants relaxation to allow the complete implementation of ICM requirements after April 26, 2006, and before ungrappling any irradiated spent fuel assembly in any ISFSI transfer cask, or the like, for removal from the spent fuel pool.

Note that pursuant to Section III.C.2 of the Orders, Entergy is to report to the Commission, in accordance with 10 CFR 72.4, when it has achieved full compliance with all the requirements described in Attachment 1 to both Orders. NRC will determine the effectiveness of your implementation of the ICMs and ASMs through onsite inspections.

Please contact Robert Lewis of my staff at 301-415-3567, to help resolve any issues related to compliance with the requirements in the Orders, or if you have any questions.

Sincerely,

/RA/

Jack R. Strosnider, Director Office of Nuclear Material Safety and Safeguards Docket No. 72-50 DISTRIBUTION:

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