ML051530181
| ML051530181 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Peach Bottom, Oyster Creek, Byron, Braidwood, Limerick, Clinton, Quad Cities, LaSalle, Crane |
| Issue date: | 05/31/2005 |
| From: | Jamie Benjamin AmerGen Energy Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-02-026, EA-03-086 | |
| Download: ML051530181 (6) | |
Text
I I
AmerGen.M Exelkn An Exelon Company www.exeloncorp.com Nuclear AmerGen Energy Company, LLC 4300 Winfield Road (I.C.M B.5.b Compliance)
Exelon Generation Warrenville, IL 60555 4300 Winfield Road Warrenville, IL 60555 SAFEGUARDS INFORMATION May 31, 2005 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units I and 2 Facility Operating License Nos. NPF-1 1 and NPF-1 8 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Oyster Creek Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 NOTE: ATTACHMENTS 1 a - 1j AND 3a - 3j TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENTS I a - 1j AND 3a - 3j, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION
U.S. Nuclear Regulatory Commission May 31, 2005 Page 2 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 Three Mile Island Nuclear Station, Unit 1 Facility Operating License No. DPR-50 NRC Docket No. 50-289
SUBJECT:
Response to NRC Guidance Regardinq 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 Braidwood Station Units 1 and 2, Byron Station Units 1 and 2, Clinton Power Station Unit 1, Dresden Nuclear Power Station Units 2 and 3, LaSalle County Station Units 1 and 2, Limerick Generating Station Units 1 and 2, Oyster Creek Generating Station, Peach Bottom Atomic Power Station Units 2 and 3, Quad Cities Nuclear Power Station Units I and 2, and Three Mile Island Nuclear Station Unit 1.
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, Exelon Generation Company, LLC (Exelon) and AmerGen Energy Company, LLC (AmerGen) were required to complete implementation of the requirements of Section lI.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 Braidwood Station Units 1 and 2, Byron Station Units 1 and 2, Clinton Power Station Unit 1, Dresden Nuclear Power Station Units 2 and 3, LaSalle County Station Units 1 and 2, Limerick Generating Station Units 1 and 2, Oyster Creek Generating Station, Peach Bottom Atomic Power Station Units 2 and 3, Quad Cities Nuclear Power Station Units 1 and 2, and Three Mile Island Nuclear Station Unit 1.
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 facilities have been implemented. Subsequently, Exelon and AmerGen were 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 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 (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.
NOTE: ATTACHMENTS Ia -1j AND 3a - 3j TO THIS LETTER CONTAIN SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENTS la - Ij AND 3a - 3j, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION
U.S. Nuclear Regulatory Commission May 31, 2005 Page 3 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, Exelon and AmerGen have reviewed the information in Attachments A and B in accordance with the NEI Guidance and are hereby submitting, as Safeguards Information attachments to this letter (Attachments la - lj), Exelon's and AmerGen's evaluation of the information the NRC provided. Attachments la - lj reflect the results of a comprehensive and thorough review of the guidance and describe the considerations that Exelon and AmerGen either have already or intend to implement at Braidwood Station Units 1 and 2, Byron Station Units 1 and 2, Clinton Power Station Unit 1, Dresden Nuclear Power Station Units 2 and 3, LaSalle County Station Units 1 and 2, Limerick Generating Station Units 1 and 2, Oyster Creek Generating Station, Peach Bottom Atomic Power Station Units 2 and 3, Quad Cities Nuclear Power Station Units 1 and 2, and Three Mile Island Nuclear Station Unit 1 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. Exelon and AmerGen 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 some cases, where full accomplishment of the expectation as written was not achievable, it was appropriate to answer a question regarding readily available as 'Yes' and note the limits, rather than stating the answer as 'No' because it cannot be fully accomplished.
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 Exelon's and AmerGen's commitment management system.
Attachments 2a - 2j to this letter are the schedules that Exelon and AmerGen have developed regarding the implementation of commitments resulting from the evaluations documented in Attachments la - lj.
Attachments 3a - 3j to this letter specify the Exelon and AmerGen commitments resulting from the evaluations documented in Attachments la-1j. Attachments 3a - 3j contain Safeguards Information.
Attachments Ia - lj and 3a - 3j to this letter contain Safeguards Information that must be protected from public disclosure pursuant to IOCFR73.21, 'Requirements for the Protection of Safeguards Information." Exelon and AmerGen therefore request that Attachments la - lj and 3a - 3j be withheld from public disclosure.
NOTE: ATTACHMENTS Ia - Ij AND 3a - 3j TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENTS la-1j AND 3a - 3j, THIS LETTER IS DECONTROLLED."
SAFEGUARDS INFORMATION
U.S. Nuclear Regulatory Commission May 31, 2005 Page 4 If you have any questions, please contact David P. Helker at (610) 765-5525.
Respectfully submitted, iin Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC AmerGen Energy Company, LLC Attachments:
la -lj (Evaluation of B.5.b Guidance) [SAFEGUARDS INFORMATION]
2a - 2j (Schedules) 3a - 3j (Lists of Commitments) [SAFEGUARDS INFORMATION]
NOTE: ATTACHMENTS la - 1j AND 3a - 3j TO THIS LETTER CONTAIN 'SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENTS la - Ij AND 3a - 3j, THIS LETTER IS 'DECONTROLLED."
SAFEGUARDS INFORMATION
U.S. Nuclear Regulatory Commission May 31, 2005 Page 5 cc:
(COVER LETTER AND ALL ATTACHMENTS)
J. E. Dyer, Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region I Regional Administrator - NRC Region III K. N. Jabbour, Lead Project Manager (Exelon/AmerGen sites), Office of Nuclear Reactor Regulation (COVER LETTER AND ATTACHMENT 2 ONLY)
NRC Project Manager, NRR - Braidwood Station NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Oyster Creek Generating Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - TMI Unit 1 NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - TMI Nuclear Station, Unit 1 Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Director, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA Mayor of Lacey Township, Forked River, NJ NOTE: ATTACHMENTS la - lj AND 3a - 3j TO THIS LETTER CONTAIN 'SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENTS la - lj AND 3a - 3j, THIS LETTER IS DECONTROLLED."
SAFEGUARDS INFORMATION
U.S. Nuclear Regulatory Commission May 31, 2005 Page 6 bcc: (COVER LETTER AND ATTACHMENT 2 ONLY)
Site Vice President - Braidwood Station Site Vice President - Byron Station Site Vice President - Clinton Power Station Site Vice President - Dresden Nuclear Power Station Site Vice President - LaSalle County Station Site Vice President - Limerick Generating Station Site Vice President - Oyster Creek Generating Station Site Vice President - Peach Bottom Atomic Power Station Site Vice President - Quad Cities Nuclear Power Station Site Vice President - TMI Unit 1 Vice President - Licensing & Regulatory Affairs Regulatory Assurance Manager - Braidwood Station Regulatory Assurance Manager - Byron Station Regulatory Assurance Manager - Clinton Power Station Regulatory Assurance Manager - Dresden Nuclear Power Station Regulatory Assurance Manager - LaSalle County Station Regulatory Assurance Manager - Limerick Generating Station Regulatory Assurance Manager - Oyster Creek Generating Station Regulatory Assurance Manager - Peach Bottom Atomic Power Station Regulatory Assurance Manager - Quad Cities Nuclear Power Station Regulatory Assurance Manager - TMI Unit 1 Director Licensing - Midwest Director Licensing - Mid-Atlantic PSEG - Financial Controls & Co-Owners Affairs R. I. McLean, State of Maryland R. R. Janati, Commonwealth of Pennsylvania Manager of Energy Practice - Winston & Strawn B. Fore, Clinton Power Station (Electronic Copy)
D. Tubbs, Mid-American Energy (Quad Cities)
PA DEP BRP Inspector - LGS, SSB2-4 PBAPS Nuclear Oversight Manager - PB, SMB4-6 LGS Nuclear Oversight Manager - LGS SMB2-5 Exelon Document Control Desk Licensing (Electronic Copy)
Records Management, KSA NOTE: ATTACHMENTS 1 a - 1j AND 3a - 3j TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENTS la - 1j AND 3a - 3j, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION