View source for W3F1-2010-0059, Day Response to NRC Order EA-10-092, Issuance of Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Waterford Steam Electric Station Independent Spent Fuel Storage Installation.

{{Adams
| number = ML102010064
| issue date = 07/15/2010
| title = Day Response to NRC Order EA-10-092, Issuance of Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Waterford Steam Electric Station Independent Spent Fuel Storage Installation.
| author name = Kowalewski J
| author affiliation = Entergy Nuclear South, Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS/SFST
| docket = 05000382, 07200075
| license number = 
| contact person = 
| case reference number = EA-10-092, W3F1-2010-0059
| document type = Letter type:W
| page count = 8
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:Entergy Nuclear South Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Tel   504 739 6660 jkowale@entergy.com Joseph A. Kowalewski Vice President, Operations Waterford 3 W3F1-2010-0059 July 15, 2010 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards Washington, DC 20555-0001

==Subject:==
20-Day Response to NRC Order EA-1 0-092, "Issuance of Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Waterford Steam Electric Station Independent Spent Fuel Storage Installation" Waterford Steam Electric Station, Unit 3 (Waterford 3)
Docket No. 72-75 General License

==Reference:==
: 1. NRC Letter "Issuance of Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Waterford Steam Electric Station Independent Spent Fuel Storage Installation" dated June 28, 2010 [EA-10-092].

==Dear Sir or Madam:==

In Reference 1, the NRC issued Order EA-10-092 titled, "Issuance of Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access to Waterford Steam Electric Station Independent Spent Fuel Storage Installation" to modify the General License for Waterford Steam Electric Station's (Waterford SES) proposed Independent Spent Fuel Storage Installation (ISFSI). The Order required compliance with the requirements provided in two attachments to the Order. Attachment 1 to the Order is titled "Additional Security Measures (ASMs) for Physical Protection of Dry Independent Spent Fuel Storage Installations (ISFSIs)," dated September 28, 2007. Attachment 2 is titled, "Additional Security Measures for Access Authorization and Fingerprinting at Independent Spent Fuel Storage Installations," dated June 3, 2010.
The enclosure to this letter provides Entergy's required 20-day response to NRC Order EA-10-092.
The regulatory commitments made as a result of this letter are listed in the Attachment titled:
"List of Regulatory Commitments."

W3Fl-2010-0059 Page 2 Also, Entergy has responded by letter W3F1-2010-0060 dated July 15, 2010, with an answer consenting to the Order pursuant to the requirements of 10 CFR Part 2.202, as directed by the Order.
Should you have any questions or require additional information, please contact William Steelman, Acting Licensing Manager, at 504-739-6685.
I declare under penalty of perjury that the foregoing is true and correct. Executed on July 15, 2010.
IV-JAK/WAH

==Enclosure:==
Entergy's 20-Day Response to NRC Order EA-1 0-092, "Issuance of Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Waterford Steam Electric Station Independent Spent Fuel Storage Installation"

==Attachment:==
List of Regulatory Commitments

W3F1-2010-0059 Page 3 cc:    Mr. Elmo E. Collins, Jr.
Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop 08B1 Washington, DC 20555-0001 I

Enclosure W3F1-2010-0059 Entergy's 20-Day Response to NRC Order EA-10-092, "Issuance of Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Waterford Steam Electric Station Independent Spent Fuel Storage Installation"

Enclosure to W3F17-2010-0059 Page 1 of 2 Entergy's 20-Day Response to NRC Order EA-10-092, "Issuance of Order for Implementation of Additional Security Measures and Fingerprinting for Unesco rted Access for Waterford Steam Electric Station Independent Spent Fuel Storage Installation" NRC Order EA-10-092 requires that, effective immediately, the Independent Spent Fuel Storage Installation (ISFSI) General License for Waterford SES be modified as provided in the Order. Responses to Section III, Section A.2, Conditions B.1, B.2, and C.1, of the Order are required within 20 days of the date of the Order. The required Additional Security Measures (ASMs) must be in place no later than 365 days from the date of the Order or 90 days before the first day that spent fuel is initially placed in the ISFSI, whichever is earlier.
The required 20-day response is provided below:
Section A.2 of Attachment 2 to the Order requires the ISFSI Licensee to clearly distinguish which of the two allowed methods described in that Section will be used to comply with the ASMs in Attachment 2. Compliance at Waterford SES will be accomplished by the NRC approved reactor access authorization program for the Waterford SES.
Condition B.1.
Entergy shall, within twenty (20) days of the date of this Order, notify the Commission: (1) if it is unable to comply with any of the requirements described in Attachments 1 and 2; (2) if compliance with any of the requirements is unnecessary, in its specific circumstances; or (3) if implementation of any of the requirements would cause Entergy to be in violation of the provisions of any Commission regulation or the facility license. The notification shall provide Entergy's justification for seeking relief from, or variation of, any specific requirement.
Response B.1 (1): Entergy will comply with all of the pertinent requirements described in Attachments 1 and 2 to the Order. Complete implementation will be achieved no later than 365 days from the date of the Order, or no later than 90 days before the first day that spent fuel is initially placed in the ISFSI, whichever is earlier.
Response B. 1 (2): The specific circumstances of the ISFSI at Waterford SES do not make any of the Order's requirements unnecessary.
Response B.1 (3): Implementation of the requirements in the Order, as described in this response, will not cause Entergy to be in violation of the provisions of any Commission regulation, Part 50 license for Waterford SES, or the General License for the ISFSI.
Condition B.2.
If Entergy considers that implementation of any of the requirements described in Attachments 1 and 2 to this Order would adversely impact the safe storage of spent fuel, Entergy must notify the Commission, within twenty (20) days of the date of this Order, of the adverse safety impact, the basis for its determination that the requirement has an adverse safety impact, and either a proposal for achieving the same objectives specified in  and 2 requirements in question, or a schedule for modifying the facility, to address the adverse safety condition. If neither approach is appropriate, Entergy must supplement its response, to Condition B. 1 of this Order, to identify the condition as a

Enclosure to W3F1-2010-0059 Page 2 of 2 requirement with which it cannot comply, with attendant justifications, as required under Condition B.1.
Response B.2: Implementation of the requirements described in Attachments 1 and 2 to the Order will not adversely impact the safe storage of spent fuel.
Condition C.1.
Entergy shall, within twenty (20) days of the date of this Order, submit to the Commission, a schedule for achieving compliance with each requirement described in Attachments 1 and 2.
Response C. 1: Because the ISFSI at Waterford SES will be located inside the plant's Protected Area, the only pertinent part of Attachment 1 is Section D.
* Completion of the requirement outlined in Section D. 1.a of Attachment 1 to the Order depends on completion of an analysis. The expected date for completion of the analysis is October 28, 2010. Entergy commits to promptly submit the results of the analysis to the NRC.
* Completion of the requirement outlined in Section D. 1i.b of Attachment 1 to the Order depends on completion of the requirement outlined in Section D.1.a, which is discussed above. Entergy commits to inform the NRC of the actions thereafter proposed with respect to the requirement at issue and of the projected date(s) of completion.
* Full compliance with Section D. 1.c, D. 1.d and D. 1.e of Attachment 1 to the Order will be achieved by June 28, 2011.
* Full compliance with Section D.2.a, D.2.b, D.2.c and D.2.d of Attachment 1 to the Order will be achieved by June 28, 2011.
* Full compliance withSection D.3.a and D.3.b of Attachment 1 to the Order will be achieved by June 28, 2011.

Attachment to W3FI-2010-0059 List of Regulatory Commitments

Attachment to W3F17-2010-0059 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE               SCHEDULED ONE-     One)            COMPLETION TIME    CONTINUING            DATE COMMITMENT                        ACTION   COMPLIANCE          (IfRequired)
Entergy will promptly submit the results           X                   November 11, 2010 in writing of analysis performed for Section D.1.a as required in Attachment 2 of NRC Order EA-10-092.
Entergy commits to inform the NRC in               X                   December 16, 2010 writing of the actions thereafter proposed as a result of the completed analysis with respect to the requirement at issue and of the projected date(s) of completion as required in Section D.1.b,  of NRC Order EA-10-092.
Entergy will achieve full compliance with          X                  June 28, 2011 the requirements of Attachments 1 and 2 of NRC Order EA-10-092 by June 28, 2011, and will notify the NRC in writing when full compliance with the Order has been achieved.}}