GNRO-2005/00031, Response to NRC Guidance Regarding Mitigation Strategies

Response to NRC Guidance Regarding Mitigation Strategies

ML051570417
Person / Time
Site:	Grand Gulf
Issue date:	05/31/2005
From:	Krupa M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-02-026, EA-03-086, GNRO-2005/00031
Download: ML051570417 (3)

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'lEntergy Entergy Operations, Inc.

Waterloo Rd.

PO. Box 756 Port Gibson, MS 39150 Tel 601 437 6470 Michael A. Krupa Director Nuclear Safety Assurance SAFEGUARDS INFORMATION GNRO-2005/00031 May 31, 2005 Via Overnight Delivery U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852-2378

REFERENCES:

Response to NRC Guidance Regarding Mitigation Strategies Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29

1. March 15, 2002, Entergy Operations, Inc. - Response to Issuance of Order for Interim Safeguards and Security Compensatory Measures (GNRO-2002/00029)

2. February 25, 2005 letter from J. E. Dyer to Holders of Licenses for Operating Power reactors as Listed in Enclosure 1 (GNRI-2005/00044) NRC Staff Guidance for Use in Achieving Satisfactory Compliance with February 25, 2002, Order Section B.5.b.

Dear Sir or Madam:

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 Grand Gulf Nuclear 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 1Ll.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, Grand Gulf was required to complete implementation of the requirements of Section ll.B.5.b. of Order EA-02-026 by August 31, 2002.

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

IIt

I GNRO-2005/00031 Page 2 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 "DBT Order") and other security related Orders (collectively "Orders") for the Grand Gulf Nuclear Station. In many ways, Order EA-03-086 complemented or superseded the interim measures imposed by Order EA-02-026.

As required by Order EA-03-086, the plans for the above-mentioned licensed facility have been implemented. Subsequently, Grand Gulf 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 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, Grand Gulf 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), Grand Gulf's evaluation of the information the NRC provided. The Enclosure reflects the results of our review of the guidance and describes the considerations that Grand Gulf either has already or intends to implement at Grand Gulf Nuclear 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 ureadily available," and (2) if equipment is readily available, can it be effectively utilized in a licensee's mitigating strategy. Grand Gulf 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.

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

GNRO-2005/00031 Page 3 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 Grand Gulf s commitment management system.

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

Respectfully submited, 9'

MAK/CAB/amt

Attachment:

Schedule for Completion of Actions and List of Regulatory Commitments

Enclosure:

Grand Gulf Evaluation of NRC B.5.b Guidance cc:

U. S. Nuclear Regulatory Commission ATTN: J. E. Dyer (w/o Enclosure)

Director, Office Of Nuclear Reactor Regulation Mail Stop OWFN/5 E7 Washington, D. C. 20555-0001 NRC Senior Resident Inspector (w/o Enclosure)

Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Dr. Bruce S. Mallett (w/o Enclosure)

Regional Administrator, Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 760114005 U. S. Nuclear Regulatory Commission ATTN: Mr. Bhalchandra Vaidya, NRRIDLPM ATTN: ADDRESSEE ONLY ATTN: U. S. Postal Delivery Address Only Mail Stop OWFN/7D-1 Washington, D.C. 20555-0001 Mr. D. E. Levanway (Wise Carter), w/o Enclosure Mr. L. J. Smith (Wise Carter), w/o Enclosure Mr. N. S. Reynolds, w/o Enclosure Mr. J. N. Compton, w/o Enclosure Notice: Enclosure contains "Safeguards Information." Upon separation of the Enclosure, this letter and the Attachment are "Decontrolled."