L-2005-111, Response to NRC Guidance Regarding Mitigation Strategies
| ML051530161 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Seabrook, Turkey Point  |
| Issue date: | 05/27/2005 |
| From: | Stall J Florida Power & Light Co, Florida Power & Light Energy Seabrook |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-02-026, EA-03-086, L-2005-111 | |
| Download: ML051530161 (3) | |
Text
I P.O. Box 14000, Juno Beach, FL 33408-0420 F=PL SAFEGUARDS INFORMATION MAY 2 7 2005 L-2005-111 U.S. Nuclear Regulatory Commission 10 CFR 73.21 ATTN: Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852 RE:
Florida Power and Light Company St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Energy Seabrook, LLC Seabrook Station Docket No. 50-443 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 Florida Power & Light Company (FPL) plants, St. Lucie Units 1 and 2, and Turkey Point Units 3 and 4, and for FPL Energy Seabrook, LLC (FPL Energy Seabrook), the Seabrook 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 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, FPL and FPL Energy Seabrook submitted their response to Section l.B.5.b. of Order EA-02-026 by the August 31, 2002, required date.
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 Florida Power
& Light Company (FPL) plants, St. Lucie Units 1 and 2, and Turkey Point Units 3 and 4, and for FPL Energy Seabrook, LLC (FPL Energy Seabrook), the Seabrook Station. In many ways, Order EA-03-086 complemented or superseded requirements the interim measures imposed by Order EA-02-026.
SAFEGUARDS INFORMATION (ATTACHMENTS 1A, 2A, AND 3A TO THIS LETTER CONTAIN SAFEGUARDS INFORMATION.
UPON SEPARATION THIS PAGE IS DECONTROLLED) an FPL Group company 0
SAFEGUARDS INFORMATION St. Lucie Units 1 and 2, Docket No. 50-335 and 50-389 Turkey Point Units 3 and 4, Docket No. 50-250 and 50-251 Seabrook Station, Docket No. 50-443 L-2005-111, Page 2 of 3 As required by Order EA-03-086, the plans for the above-mentioned licensed facilities have been implemented.
Subsequently, FPL and FPL Energy Seabrook were 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 enhancements 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 ("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, FPL and FPL Energy Seabrook have reviewed the information in your Attachments A and B in accordance with the NEI Guidance and is hereby submitting, as Safeguards Information attachments to this letter, the St. Lucie, Turkey Point, and Seabrook Station evaluations of the information the NRC provided. Attachment 1A reflects the results of a comprehensive and thorough review of the guidance and describes the considerations that FPL either has already implemented, or intends to implement, at St. Lucie by August 31, 2005. Attachment 2A reflects the results of a comprehensive and thorough review of the guidance and describes the considerations that FPL either has already implemented, or intends to implement, at Turkey Point by August 31, 2005. Attachment 3A reflects the results of a comprehensive and thorough review of the guidance and describes the considerations that FPL Energy Seabrook either has already implemented, or intends to implement, at the Seabrook Station by August 31, 2005.
The primary guiding principles used in the conduct of these evaluations 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. Florida Power & Light Company and FPL Energy Seabrook considered "readily available" to mean that the equipment or resources was already licensee owned, under contract, or part of an existing Memorandum of Understanding, or Letter of Agreement. 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.
SAFEGUARDS INFORMATION (ATTACHMENTS 1A, 2A, AND 3ATO THIS LETTER CONTAIN SAFEGUARDS INFORMATION.
UPON SEPARATION THIS PAGE IS DECONTROLLED)
- IN' SAFEGUARDS IFORMATION St. Lucie Units 1 and 2, Docket No. 50-335 and 50-389 Turkey Point Units 3 and 4, Docket No. 50-250 and 50-251 Seabrook Station, Docket No. 50-443 L-2005-111, Page 3 of 3 In accordance with these principles, mitigative strategies are being implemented to address the NRC B.5.b Guidance. However, the availability of equipment identified in Attachments 1 A, 2A, and 3A is subject to change over time and without notice.
Accordingly, these present day capabilities are not considered by FPL and FPL Energy Seabrook to be regulatory commitments.
Attachments 11B, 2B, and 3B to this letter provide the schedules for St. Lucie, Turkey Point, and Seabrook Station, respectively, regarding the implementation of actions resulting from the evaluations documented in Attachments 1A, 2A, and 3A.
Respectfully submitted, J. A. Stall Senior Vice President, Nuclear And Chief Nuclear Officer Attachments:
1A - St. Lucie Units 1 and 2 Evaluation (SGI) 1 B - St. Lucie Units 1 and 2 Schedule 2A - Turkey Point Units 3 and 4 Evaluation (SGI) 2B - Turkey Point Units 3 and 4 Schedule 3A - Seabrook Station Evaluation (SGI) 3B - Seabrook Station Schedule cc:
Regional Administrator, Region I (With Attachments)
Regional Administrator, Region II (With Attachments)
USNRC Project Manager, St. Lucie (With Attachments)
Senior Resident Inspector, USNRC, Turkey Point (w/o Attachments)
Senior Resident Inspector, USNRC, St. Lucie (w/o Attachments)
Senior Resident Inspector, USNRC, Seabrook Station (w/o Attachments)
SAFEGUARDS INFORMATION (ATTACHMENTS 1A, 2A, AND 3ATO THIS LETTER CONTAIN SAFEGUARDS INFORMATION.
UPON SEPARATION THIS PAGE IS DECONTROLLED)