JAFP-04-0062, Supplemental Response to Issuance of Orders to Modify License for Revised Design Basis Threat and Compensatory Measures Related to Security Force Training and Fitness-For-Duty
| ML041270121 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 04/29/2004 |
| From: | Ted Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-03-086, JAFP-04-0062 | |
| Download: ML041270121 (5) | |
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1 Entergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
James A. Fitzpatrick NPP RO. Box 110 Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 T.A. Sullivan Site Vice President -JAF April 29, 2004 JAFP-04-0062 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 301-415-7000
SUBJECT:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 Entergy Operations, Inc., Entergy Nuclear Operations, Inc. -
Supplemental Response to Issuance of Orders to Modify License for Revised Design Basis Threat and Compensatory Measures Related to Security Force Training and Fitness-For-Duty
REFERENCES:
See Below
Dear Sir or Madam:
The NRC issued Entergy 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 James A. FitzPatrick Nuclear Power Plant (JAF). This Supplemental Response of JAF to Order EA-03-086 supplements the previous response dated June 3, 2003 that Entergy 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 IIL.A also requires licensees to revise the security force training and qualification plan to implement the revised DBT. These revised plans, along with NOTICE: Attachments A and E contain "Safeguards Information." Upon separation of Attachments A and E from this letter, this letter, and Attachments B, C, and D become "DECONTROLLED" 50 SAFEGUARDS INFORMATION 40
SAFEGUARDS INFORMATION JAFP-04-0062 Page 2 of 5 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, JAF is submitting this Supplemental Response for the above-mentioned licensed facility. This submittal includes, as Attachment A, revisions to the JAF 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 JAF's previous submittals in these areas, including those related to the February 25, 2002, January 7, 2003, and April 29, 2003, Orders. JAF 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.
JAF 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), 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 73, is a listing of any exemptions to 10 CFR Part 73 previously granted to JAF and an explanation of their status under the plans hereby submitted. Attachment E, Justification for Alternatives, includes the justification for the alternatives provided in NEI-03-12 that JAF has adopted.
When the final revision of NEI-03-12 is approved by the NRC, JAF will supplement this response, if necessary, to conform with NEI-03-12 as finally approved by the NRC. However, with the filing of these plans, JAF 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, JAF will be in compliance with all applicable security requirements. For the purpose of complying with the requirements of 10 CFR 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 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 NOTICE: Attachments A and E contain "Safeguards Information." Upon separation of Attachments A and E from this letter, this letter, and Attachments B, C, and D become "DECONTROLLED" SAFEGUARDS INFORMATION
SAFEGUARDS INFORMATION JAFP-04-0062 Page 3 of 5 specific requirements of the Orders, JAF 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.
As requested the attachments to this letter are being transmitted on CD-ROM.
Contact:
Name Jonathan LaPlante Mailing Address:
James A. FitzPatrick NPP P.O. Box 110 Lycoming, New York 13093 E-Mail Address:
ilaplan(Wienterav.com Phone Number:
(315) 349-6406 Document Components:
001 Transmittal Letter.pdf 16,900 bytes 002 Attachment A, Security Plan.pdf 654,000 bytes 003 Attachment B, Action Completion Schedule.pdf 7,580 bytes 004 Attachment C, Deviations from NEI-03-12.pdf 7,460 bytes 005 Attachment D, Previous Exemptions to 10 CFR Part 73.pdf 7,020 bytes 006 Attachment E, Justification for Altematives.pdf 57,000 bytes 007 Signed Security Plan Cover Page.pdf 39,400 bytes If you have any questions or require additional information, please contact Mr. Jonathan LaPlante, JAF Security Manager, at 315-349-6406.
This letter contains no new commitments.
Zc9 I declare under penalty of perjury that the foregoing is true and correct. Executed on the _th day of April 2004.
Sincerely, T. A. Sullivan Site Vice President, JAF TAS/AH/ed NOTICE: Attachments A and E contain "Safeguards Information." Upon separation of Attachments A and E from this letter, this letter, and Attachments B, C, and D become "DECONTROLLED" SAFEGUARDS INFORMATION
SAFEGUARDS INFORMATION JAFP-04-0062 Page 4 of 5 Attachments Attachment A - New Physical Security Plan, New Safeguards Contingency Plan, New Training and Qualification Plan Attachment B - Action Completion Schedule Attachment C - Deviations from NEI-03-12 Attachment D - Previous Exemptions from 10 CFR Part 73 Attachment E - Justification for Alternatives REFERENCES Entergy letter from Gary J. Taylor, CEO, Entergy Operations, Inc.,
Entergy Nuclear Operations, Inc. dated June 3, 2003 to DCC - Response to Issuance of Orders to Modify License for Revised Design Basis Threat and Compensatory Measures Related to Security Force Training and Fitness-For-Duty (JPN-03-013).
NRC Letters from Samuel J. Collins to Holders of Licenses for Operating Power Reactors as listed in Enclosure 2, dated April 29, 2003 Regarding Issuance of Order Requiring Compliance with Revised Design Basis Threat for Operating Power Reactors (EA-03-086), Issuance of Order for Compensatory Measures Related to Training Enhancements on Tactical and Firearms Proficiency and Physical Fitness Applicable to Armed Nuclear Power Plant Security Force Personnel (EA-03-039) and Issuance of Order for Compensatory Measures Related to Fitness-For-Duty Enhancements Applicable to Nuclear Facility Security Force Personnel (EA-03-038) cc:
all w/o attachments G. Taylor M. Kansler J. Herron R. Goodrich J. McCann Mr. Hubert Miller Regional Administrator, Region 1 U. S. Nuclear Regulatory Commission, 475 Allendale Road King of Prussia, PA 19406-1415 Arlington, TX 76011-8064 NOTICE: Attachments A and E contain "Safeguards Information." Upon separation of Attachments A and E from this letter, this letter, and Attachments B, C, and D become "DECONTROLLED" SAFEGUARDS INFORMATION
SAFEGUARDS INFORMATION JAFP-04-0062 Page 5 of 5 Mr. Guy Vissing, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555-0001 Resident Inspector's Office James A. FitzPatrick Nuclear Power Plant U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093-0136 NOTICE: Attachments A and E contain "Safeguards Information." Upon separation of Attachments A and E from this letter, this letter, and Attachments B, C, and D become "DECONTROLLED" SAFEGUARDS INFORMATION