LR-N05-0300, Stations, Response to NRC Guidance Regarding Mitigation Strategies
| ML051570060 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 05/31/2005 |
| From: | Levis W Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-02-026, EA-03-086, LR-N05-0300 | |
| Download: ML051570060 (3) | |
Text
William 1Devis PAG Nuclear LLC Svenior Vice President and CNO PO. Box 236, Hancocks Bridge, NJ 08038 tel: 856.339.1100 fax: 856.339.1104 SAFEGUARDS INFORMATION MAY 31 2005 LR-N05-0300 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852 RESPONSE TO NRC GUIDANCE REGARDING MITIGATION STRATEGIES SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311, AND 50-354 FACILITY OPERATING LICENSE NUMBERS DPR-70, DPR-75, AND NPF-57 The NRC issued Orders For Interim Safeguards and Security Compensatory Measures
("Order EA-02-026" or "1CM Order") dated February 25, 2002, for the Salem Generating Station and the Hope Creek Generating 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, PSEG Nuclear, LLC, (PSEG) was required to complete implementation of the requirements of Section II.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 "DBT Order") and other security related Orders (collectively "Orders") for the Salem Generating Station and the Hope Creek Generating Station. In many ways, Order EA-03-086 complemented or superseded requirements the interim measures imposed by Order EA-02-026.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, PSEG was requested to respond to the letter from J.E. Dyer, Director, Office of Nuclear Reactor Regulation, 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, NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ATTACHMENT, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION
I l MAY 3 1 2005 SAFEGUARDS INFORMATION Document Control Desk 2
LR-N05-0300 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 to 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, PSEG 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), PSEG'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 PSEG either has already or intends to implement at Salem Generating Station and Hope Creek Generating 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. PSEG 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 PSEG's commitment management system. to this letter is the schedule that PSEG has developed regarding the implementation of commitments resulting from the evaluations documented in.
NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ATTACHMENT, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION 95-4933
MAY 3 1 2005 SAFEGUARDS INFORMATION Document Control Desk LR-N05-0300 3
Please contact Robin Ritzman at (856) 339-1445 if you have any questions or comments regarding this submittal.
Sincerely, cc:
J. E. Dyer, Director, Office of Nuclear Reactor Regulation Regional Administer, Region 1 Salem Project Manager Hope Creek Project Manager NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ATTACHMENT, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION 95-4933