ML051530163
| ML051530163 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/27/2005 |
| From: | Douet J Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-02-026, EA-03-086 | |
| Download: ML051530163 (4) | |
Text
SAFEGUARDS INFORMTI llhlDQNOCtAsPTAnnrf f';JVOTPAGEWM Tennessee Valley Authority, Post Office Box 2000, Soddy Daisy, Tennessee 37384-2000 James 'Randy' Douet Site Vice President Sequoyah Nuclear Plant May 27, 2005 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852 Gentlemen:
In the Matter of
)
Docket Nos. 50-327 Tennessee Valley Authority
)
50-328 SEQUOYAH NUCLEAR PLANT (SQN)
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 SQN.
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, TVA 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")
aSAFEGUARDS 1NFOATf1GN
SAFEGUARDS INFORMA7UN.
U.S. Nuclear Regulatory Commission Page 2 May 27, 2005 P
%~hcLASSFr~nz':.
and other security-related Orders (collectively "Orders") for SQN.
In many ways, Order EA-03-086 complemented or superseded for requirements the interim measures imposed by Order EA 026.
As required by Order EA-03-086, the plans for the above-mentioned licensed facility have been implemented.
Subsequently, TVA 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, 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, TVA 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 1),
TVA's evaluation of the information that NRC provided. reflects the results of a comprehensive and thorough review of the guidance and describes the considerations that TVA either has already or intends to implement at SQN by August 31, 2005.
WIUARfDS \\WFOM11
SAFEGUARDS INFOR MATON Nuclear Regulatory Commission Page 3 JTh3SVAC!MEW May 27, 2005 OTACHDNT 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.
TVA considered "readily available" to mean that the equipment or resources were already licensee owned, under U.S. 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 TVA's commitment management system. to this letter contains SQN's commitment to complete the actions regarding the implementation of the mitigative strategies'to address NRC B.5.b Guidance.
If you have any questions about this response, please contact Paul Pace at (423) 843-7170 or J. D. Smith at (423) 843-6672.
Sincerely, J. Randy Douet Enclosures cc:
See page 4
&VEGUARDS IONKFORAT90),fRi
ANFGt1V alt Nuclear Regulatory Commission Page 4 May 27, 2005
~-aAS3~lCATIO%
cc (Enclosures):
Mr. J. E. Dyer Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Dr. William D. Travers Regional Administrator, Region II U.S. Nuclear Regulatory Commission Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30323-8931 U19i7THOZZED DISCLOSURE IS SUBJBCT TO AEM6CTUAWIE AND CRWHAINAL PEXAL¶!E REVIEWED PAIF IFICAT O0 N~AME TITLE" ORGAMAYMIo DATE
&VFGUARDS NFRA ~