BVY 05-058, Response to NRC Guidance Regarding Mitigation Strategies

Response to NRC Guidance Regarding Mitigation Strategies

ML051520107
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	05/26/2005
From:	Thayer J Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 05-058, EA-02-026
Download: ML051520107 (3)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

Vermont Yankee P.O. Box 0500 Entergy 185 Old Ferry Road Brattleboro, VT 05302.0500 Tel 802 257 5271 SAFEGUARDS INFORMATION May 26, 2005 BVY 05-058 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station Docket No. 50-271 Response to NRC Guidance Regarding Mitigation Strategies

REFERENCES:

1. March 18, 2002, letter from Vermont Yankee Nuclear Power Corporation

- Response to Order for Interim Safeguards and Security Compensatory Measures (BVY 02-15)

2. February 25, 2005 letter from J. E. Dyer to Holders of Licenses for Operating Power Reactors as Listed in Enclosure 1 - NRC Staff Guidance for Use in Achieving Satisfactory Compliance with February 25, 2002, Order Section B.5.b (NVY 05-065)

The NRC issued an Order for Interim Safeguards and Security Compensatory Measures

("Order EA-02-026" or 1CM Order") dated February 25, 2002, for the Vermont Yankee Nuclear Power Station.

Order EA-02-026 imposed requirements on nuclear power plants licensed pursuant to the Atomic Energy Act of 1954 and Title 10 of the Code of Federal Regulations. Section Ill.A of the Order required licensees to implement certain changes in physical security and emergency planning on an interim basis until final requirements were established. Among other requirements, Entergy Nuclear Operations, Inc. (ENO) was required to complete implementation of the requirements of Section ilI.B.5.b. of Order EA-02-026 by August 31, 2002.

Subsequently, the NRC issued Orders, dated April 29, 2003, Requiring Compliance with Revised Design Basis Threat for Operating Power Reactors ("Order EA-03-086" or MDBT Order") and other security related Orders (collectively "Orders") for the Vermont Yankee Nuclear Power Station. In many ways, Order EA-03-086 complemented or superseded requirements the interim measures imposed by Order EA-02-026.

NOTICE: Enclosure contains "Safeguards Information." Upon separation of the Enclosure, this letter and the Attachment are "Decontrolled."

SAFEGUARDS INFORMATION -

SAFEGUARDS INFORMATION As required by Order EA-03-086, the plans for the above-mentioned licensed facility have been implemented. Subsequently, ENO was requested to respond to your letter dated February 25, 2005, NRC Staff Guidance for Use in Achieving Satisfactory Compliance with February 25, 2002, Order Section B.5.b, ("NRC B.5.b. Guidance") by May 31, 2005, and to implement appropriate enhancement to current mitigation strategies by August 31, 2005. Specifically, nuclear power plant licensees were requested by Enclosure 2 of the February 25, 2005 letter, Developing Mitigating Strategies / Guidance for Nuclear Power Plants to Respond to Loss of Large Areas of the Plant in Accordance with B.5.b of the February 25, 2002, Order (dated February 24, 2005) ("NRC B.5.b. Guidance"), to the February 25, 2005, letter to review the Areas of Consideration delineated in Attachment A to that Enclosure and evaluate additional considerations for potential inclusion in the licensees' mitigating strategies that licensees deemed appropriate in accordance with the expectations in Attachment B to that Enclosure.

Subsequently, the Nuclear Energy Institute ("NEI"), in conjunction with the NEI Security Working Group, developed and issued guidance for licensee use ("NEI Guidance") to assist licensees in responding to the February 25, 2005, letter.

As requested in the February 25, 2005, letter, ENO has reviewed the information in Attachments A and B in accordance with the NEI Guidance and is hereby submitting, as a Safeguards Information enclosure to this letter (Enclosure), ENO's evaluation of the information the NRC provided. The Enclosure reflects the results of our review of the guidance and describes the considerations that ENO either has already or intends to implement at Vermont Yankee Nuclear Power Station by August 31, 2005.

The primary guiding principles used in the conduct of this evaluation were (1) whether or not equipment and resources were "readily available," and (2) if equipment is readily available, can it be effectively utilized in a licensee's mitigating strategy. ENO considered "readily available" to mean that the equipment or resources were already licensee owned, under contract, or part of an existing Memorandum of Understanding. Further, even if equipment and resources are readily available, the second criterion is to ensure that the equipment can be used in a mitigating strategy in an effective manner. Even if the equipment is readily available, it is of no value if it cannot be effective in implementing the mitigating strategy.

In accordance with these principles, mitigative strategies are being implemented to address the NRC B.5.b. Guidance. These strategies are considered to be commitments for that purpose and will be managed in accordance with ENO's commitment management system.

The Attachment to this letter is the schedule that ENO has developed regarding the implementation of identified commitments resulting from the evaluations documented in the Enclosure.

If you have any questions, or require additional information, please contact Mitch McCluskie at (802) 258-4187.

Sincerely, NOTICE: Enclosure contains "Safeguards Information." Upon separation of the Enclosure, this letter and the Attachment are "Decontrolled."

SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION

(,>y K. Thayer Site Vice President Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station Attachment - Schedule for Completion of Actions and List of Regulatory Commitments Enclosure - ENO Evaluation of NRC B.5.b Guidance cc w/o enclosure:

Mr. Richard B. Ennis, Project Manager License Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8-Bl Washington, DC 20555-0001 Mr. Samuel J. Collins Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 USNRC Resident Inspector Vermont Yankee Nuclear Power Station 320 Governor Hunt Road P. 0. Box 157 Vernon, VT 05354 Mr. David O'Brien Commissioner Department of Public Service 112 State Street, Drawer 20 Montpelier, VT 05620-2601 NOTICE: Enclosure contains "Safeguards Information." Upon separation of the Enclosure, this letter and the Attachment are "Decontrolled."

SAFEGUARDS INFORMATION