ML043120034

Administrative Change to Facility Operating Licenses in Conjunction with the Commission Order EA-03-086 Regarding Revised Design Basis Threat (Dbt); and Revisions to Physical Security Plan, Training and Qualification Plan..

ML043120034
Person / Time
Site:	Cook
Issue date:	10/28/2004
From:	John Nakoski NRC/NRR/DLPM/LPD2
To:	Nazar M Indiana Michigan Power Co
Nakoski J A, NRR/DLPM, 415-1068
References
EA-03-086, TAC MC2910, TAC MC2911
Download: ML043120034 (15)

Text

SAFEGUARDS INFORMATION October 28, 2004 Mr. Mano K. Nazar American Electric Power Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group 500 Circle Drive Bridgman, MI 49107-1395

SUBJECT:

DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 - ADMINISTRATIVE CHANGE TO FACILITY OPERATING LICENSES IN CONJUNCTION WITH THE COMMISSION ORDER EA-03-086 REGARDING REVISED DESIGN BASIS THREAT (DBT); AND REVISIONS TO PHYSICAL SECURITY PLAN, TRAINING AND QUALIFICATION PLAN, AND SAFEGUARDS CONTINGENCY PLAN (TAC NOS. MC2910 AND MC2911)

Dear Mr. Nazer:

By letter dated April 28, 2004, the Indiana Michigan Power Company submitted a supplemental response in accordance with Order EA-03-086, the Order requiring compliance with the revised design basis threat, dated April 29, 2003 (DBT Order), for the Donald C. Cook Nuclear Plant, Units 1 and 2 (D.C. Cook).Section III.A of the DBT Order required licensees to revise physical security plans (PSPs), training and qualification plans (T&Q Plans), and safeguards contingency plans (SCPs) in order to provide protection against the revised DBT set forth in to the DBT Order. These revised plans, along with an implementation schedule, were required to be submitted to the Nuclear Regulatory Commission (NRC or the Commission) for review and approval no later than April 29, 2004.

The NRC staffs review of the D.C. Cook PSP, SCP, and T&Q Plan submitted in your letter dated April 28, 2004, as supplemented on July 8, July 13, July 26, August 12, August 31, September 30, and October 12, 2004, has focused on ensuring that the necessary programmatic elements are contained in these plans in order to provide high assurance that activities involving special nuclear material are not inimical to the common defense and security and do not constitute an unreasonable risk to the public health and safety.

NOTICE: Enclosure 2 contains Safeguards Information. Upon separation from Enclosure 2, this letter and Enclosure 1 are DECONTROLLED.

SAFEGUARDS INFORMATION

M. Nazer The NRC staff has determined that, subject to subsequent inspection and evaluation, these plans contain the necessary programmatic elements that, when effectively implemented, will provide the high assurance that D.C. Cook will be protected against the revised DBT. The NRC staff, therefore, approves the PSP, SCP, and T&Q Plan for D.C. Cook. Ultimately the effectiveness of these plans will be judged on your ability to meet regulatory requirements through facility implementing procedures and site practices. As such, your facility implementing procedures and practices will continue to be subject to future NRC review and inspection, including NRC-conducted force-on-force exercises.

In addition, the NRC staff noted that your PSP included alternatives to certain requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 73.55. In each case, the NRC staff found that the alternative measures provide an equivalent level of protection to that of the associated requirements and meet the high assurance objectives of 10 CFR 73.55(a). The NRC staff, therefore, approves the alternatives shown in the table below. The NRC staffs evaluation is discussed further in the enclosed Safety Evaluation (SE).

Approved Alternatives to the Requirements of 10 CFR Part 73 SE Section PSP Section Alternative to 10 CFR Description 3.6.2 6.2 73.55(c)(3) Isolation zones 3.9.4.3 9.4.3 73.55(d)(4) Protected Area (PA) vehicle search requirements 3.9.4.4 9.4.4 73.55(d)(1) PA personnel search requirements 3.9.5.2 9.5 73.55(d)(1) PA access control requirements 73.55(d)(4) 3.9.6 9.6 73.55(d)(7)(i)(D) Vital Area (VA) barrier access control requirements 3.10.1 10.1 73.55(c)(5) PA illumination requirements 3.13.1 14.1 73.55(c)(1) Temporary reclassification of VAs to PA 73.55(d)(7)(i)(B) status (devitalization)

Finally, consistent with the DBT Order, conforming administrative changes to Facility Operating Licenses (FOLs) are required to ensure implementation of DBT Order requirements.

Therefore, administrative license changes to FOL Nos. DPR-58 and DPR-74 are being made to incorporate the reference to the revised PSP, SCP, and T&Q Plan required by the DBT Order.

These changes comply with the standards and requirements of the Atomic Energy Act of 1954, as amended, and the Commission's rules and regulations set forth in 10 CFR Chapter I.

Please replace the enclosed pages to your FOLs as indicated in Enclosure 1.

M. Nazer A copy of our SE with regard to your security plans (designated as Safeguards Information) is provided in Enclosure 2.

Sincerely,

/RA/

John A. Nakoski, Section Chief Security Plan Review Team Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosures:

1. Administrative Change to FOL Nos. DPR-58 and DPR-74

2. Safety Evaluation (Safeguards Information) cc w/encl 1 only: See Mailing List 1 cc w/encls 1 and 2: Agapito Rodriguez, Security Manager

M. Nazer A copy of our SE with regard to your security plans (designated as Safeguards Information) is provided in Enclosure 2.

Sincerely,

/RA/

John A. Nakoski, Section Chief Security Plan Review Team Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosures:

1. Administrative Change to FOL Nos. DPR-58 and DPR-74

2. Safety Evaluation (Safeguards Information) cc w/encl 1 only: See Mailing List 1 cc w/encls 1 and 2: Agapito Rodriguez, Security Manager DISTRIBUTION (w/o Enclosure 2):

PUBLIC SPRT R/F OGC ACRS THarris CLyon LRaghavan WRuland GHill (4) DLPM DPR TBoyce SReynolds, RIII Accession No.: ML043120034 *See previous concurrence OFFICE SPRT/TL* SPRT/PM* SPRT/LA SPRT/PL OGC* NSIR/SC* NRR/SC NAME DHuyck RFretz CRaynor JPeralta SCole NLO SMorris JNakoski DATE 10/27/04 10/27/04 10/27/04 10/27/04 10/27/04 10/27/04 10/28/04 OFFICIAL RECORD COPY DOCUMENT NAME: E:\Filenet\ML043120034.wpd

Donald C. Cook Nuclear Plant, Units 1 and 2 cc w/o encl.:

Regional Administrator, Region III Michigan Department of Environmental Quality U.S. Nuclear Regulatory Commission Waste and Hazardous Materials Div.

801 Warrenville Road Hazardous Waste & Radiological Lisle, IL 60532-4351 Protection Section Nuclear Facilities Unit Township Supervisor Constitution Hall, Lower-Level North Lake Township Hall 525 West Allegan Street P.O. Box 818 P. O. Box 30241 Bridgman, MI 49106 Lansing, MI 48909-7741 U.S. Nuclear Regulatory Commission Michael J. Finissi, Plant Manager Resident Inspector's Office Indiana Michigan Power Company 7700 Red Arrow Highway Nuclear Generation Group Stevensville, MI 49127 One Cook Place Bridgman, MI 49106 David W. Jenkins, Esquire Indiana Michigan Power Company Mr. Joseph N. Jensen, Site Vice President One Cook Place Indiana Michigan Power Company Bridgman, MI 49106 Nuclear Generation Group One Cook Place Mayor, City of Bridgman Bridgman, MI 49106 P.O. Box 366 Bridgman, MI 49106 Mr. Mano K. Nazar American Electric Power Special Assistant to the Governor Senior Vice President and Chief Nuclear Room 1 - State Capitol Officer Lansing, MI 48909 Indiana Michigan Power Company Nuclear Generation Group Mr. John A. Zwolinski 500 Circle Drive Director, Design Engineering and Buchanan, MI 49107 Regulatory Affairs Indiana Michigan Power Company Nuclear Generation Group 500 Circle Drive Buchanan, MI 49107

INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT, UNIT 1 DOCKET NO. 50-315 ADMINISTRATIVE LICENSE CHANGE TO FACILITY OPERATING LICENSE License No. DPR-58

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. Consistent with Order EA-03-086, the Order requiring compliance with the revised design basis threat (DBT Order), issued on April 29, 2003, conforming administrative changes to Facility Operating Licenses (FOLs) are required to ensure implementation of DBT Order requirements. Therefore, an administrative license change to FOL No. DPR-58 is being made to incorporate the reference to the revised Physical Security Plan, Safeguards Contingency Plan, and Training and Qualification Plan required by the DBT Order. These changes comply with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this administrative license change can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this administrative license change will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this administrative license change is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the FOL is changed, as indicated in the attachment.

3. This administrative license change is effective as of its date of issuance and shall be implemented on or before October 29, 2004.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

John A. Nakoski, Section Chief Security Plan Review Team Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the FOL Date of Issuance: October 28, 2004

CHANGES TO FACILITY OPERATING LICENSE NO. DPR-58 DOCKET NO. 50-315 Replace the following page of Facility Operating License DPR-58 with the attached revised page as indicated. The revised page is identified by revision date and contains marginal lines indicating the area of change.

Remove Page Insert Page 4 4

3. Identification of process sampling points;

4. Procedure for the recording and management of data;

5. Procedures defining corrective actions for off control point chemistry conditions; and

6. A procedure identifying (a) the authority responsible for the interpretation the data, and (b) the sequence and timing of administrative events to initiate corrective actions.

(8) Deleted by Amendment No. 279 (9) Deleted by Amendment No. 279 (10) Deleted by Amendment No. 279 (11) Deleted by Amendment No. 279 D. Physical Protection The Indiana Michigan Power Company shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans1, which contain Safeguards Information protected under 10 CFR 73.21, is entitled:

"Donald C. Cook Nuclear Plant Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 0," submitted by letter dated October 12, 2004.

E. Deleted by Amendment No. 80 F. Deleted by Amendment No. 80 G. In all places of this license, the reference to the Indiana and Michigan Electric Company is amended to read Indiana Michigan Power Company.

H. System lntegrity The licensee shall implement a program to reduce leakage from systems outside containment that would or could contain highly radioactive fluids during a serious transient or accident to as low a practical levels. The program shall include the following:

1 The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.

Amendment No. 279 Revised by letter dated October 28, 2004

INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT, UNIT 2 DOCKET NO. 50-316 ADMINISTRATIVE LICENSE CHANGE TO FACILITY OPERATING LICENSE License No. DPR-74

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. Consistent with Order EA-03-086, the Order requiring compliance with the revised design basis threat (DBT Order), issued on April 29, 2003, conforming administrative changes to Facility Operating Licenses (FOLs) are required to ensure implementation of DBT Order requirements. Therefore, an administrative license change to FOL No. DPR-74 is being made to incorporate the reference to the revised Physical Security Plan, Safeguards Contingency Plan, and Training and Qualification Plan required by the DBT Order. These changes comply with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this administrative license change can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this administrative license change will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this administrative license change is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the FOL is changed, as indicated in the attachment.

3. This administrative license change is effective as of its date of issuance and shall be implemented on or before October 29, 2004.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

John A. Nakoski, Section Chief Security Plan Review Team Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the FOL Date of Issuance: October 28, 2004

CHANGES TO FACILITY OPERATING LICENSE NO. DPR-74 DOCKET NO. 50-316 Replace the following pages of Facility Operating License DPR-74 with the attached revised pages as indicated. The revised pages are identified by revision date and contains marginal lines indicating the area of change.

Remove Page Insert Page 5 5 6 6

(s) Deleted by Amendment No. 26 (t) Deleted by Amendment 63 (u) Deleted by Amendment No. 261 (v) Secondary Water Chemistry Monitoring Program The licensee shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall be described in the station chemistry manual and shall include:

1. Identification of a sampling schedule for the critical control points for these parameters;

2. Identification of the procedures used to measure the values critical parameters;

3. Identification of process sampling points;

4. Procedure for the recording and management of data;

5. Procedures defining corrective actions for off control point chemistry conditions; and

6. A procedure identifying (a) the authority responsible for the interpretation of the data, and (b) the sequence and timing of administrative required to initiate corrective actions.

(w) Deleted by Amendment No. 261 (x) Deleted by Amendment No. 261 (y) Deleted by Amendment No. 261 D. Physical Protection The Indiana Michigan Power Company shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans1, which contain Safeguards 1

The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.

Amendment No. 261 Revised by letter dated October 28, 2004

Information protected under 10 CFR 73.21, is entitled: "Donald C. Cook Nuclear Plant Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 0," submitted by letter dated October 12, 2004.

E. Deleted by Amendment No. 63 F. In all places of this license, the reference to the Indiana and Michigan Electric Company is amended to read Indiana Michigan Power Company.

G. System Integrity The licensee shall implement a program to reduce leakage from systems outside containment that would or could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. This program shall include the following:

1. Provisions establishing preventive maintenance and periodic visual inspection requirements, and

2. Integrated leak test requirements for each system at a frequency not to exceed refueling cycle intervals.

H. Iodine Monitoring The licensee shall implement a program which will ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program shall include the following:

1. Training of personnel,

2. Procedures for monitoring, and

3. Provisions for maintenance of sampling and analysis equipment.

I. Deleted by Amendment No. 261 (1) Deleted by Amendment No. 261 (2) Deleted by Amendment No. 261 J. The licensee is authorized to use digital signal processing instrumentation in the reactor protection system.

Amendment No. 261 Revised by letter dated October 28, 2004