L-05-095, Response to NRC Guidance Regarding Mitigation Strategies
| ML051570411 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/31/2005 |
| From: | Pearce L FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-02-026, EA-03-086, L-05-095 | |
| Download: ML051570411 (3) | |
Text
FENOC SAFEGUARDS INFORMATION Beaver Valley Power Station FirstEnergy Nuclear Operatg Comp.ny Shippingport, PA 15077-0004 L. William Pearce 724-682-5234 Vice President Fax: 724-643-8069 May 31, 2005 L-05-095 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001
Subject:
Beaver Valley Power Station (BVPS), Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Response to NRC Guidance Regarding Mitigation Strategies The NRC issued Orders For Interim Safeguards and Security Compensatory Measures
("Order EA-02-026" or "ICM Order") dated February 25, 2002 for Beaver Valley Power Station (BVPS) Units 1 and 2.
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 III.A of the Order required licensees to implement certain changes in physical security plans and safeguards contingency plans on an interim basis until final requirements were established.
Among other requirements, FirstEnergy Nuclear Operating Company (FENOC) was required to complete implementation of the requirements of Section II.B.5.b. of Order EA-02-026 at BVPS 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 "DBT Order") and other security related Orders (collectively "Orders") for BVPS. In many ways, Order EA-03-086 complemented or superseded requirements the interim measures imposed by Order EA-02-026.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, FENOC was requested to respond to the letter from J.E. Dyer, Director, Office of Nuclear Reactor Regulation, dated February 25, 2005, SAFEGUARDS INFORMATION ATTACHMENT 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."
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Beaver Valley Power Station, Unit No. 1 and No. 2 Response to NRC Guidance Regarding Mitigating Strategies L-05-095 Page 2 SAFEGUARDS INFORMATION 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, 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 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, FENOC has reviewed the information in Attachments A and B in accordance with the NEI Guidance and is hereby submitting, as a Safeguards Information attachment to this letter (Attachment 1), FENOC's evaluation of the information the NRC provided. Attachment 1 reflects the results of a comprehensive and thorough review of the guidance and describes the considerations that FENOC either has already or intends to implement at BVPS 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.
FENOC considered "readily available" to mean that the equipment or resources was 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 actions are considered to be commitments for that purpose and will be managed in accordance with FENOC's commitment management system.
SAFEGUARDS INFORMATION ATTACHMENT 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."
Beaver Valley Power Station, Unit No. 1 and No. 2 Response to NRC Guidance Regarding Mitigating Strategies L-05-095 Page 3 SAFEGUARDS INFORMATION to this letter is the schedule that FENOC has developed for BVPS regarding the implementation of commitments resulting from the evaluations documented in Attachment 1.
If there are any questions concerning this matter, please contact Mr. Gregory H. Halnon, Director Regulatory Affairs at 330-315-7500.
Sincerely,
//
a 0c L. William Pearce Attachments:
- 2) Implementation Schedule for BVPS c:
Mr. T. G. Colburn, NRR Senior Project Manager (w/o attachments)
Mr. P. C. Cataldo, NRC Senior Resident Inspector Mr. S. J. Collins, NRC Region I Administrator SAFEGUARDS INFORMATION ATTACHMENT 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."