ML051590281
| ML051590281 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/31/2005 |
| From: | Madden F TXU Power |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CPSES-20051062, NRC-EA-02-026, NRC-EA-03-086, TXX-05101 | |
| Download: ML051590281 (4) | |
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Power SAFEGUARDS INFORMATION TXU Power Comanche Peak Steam Electric Station P. O. Box 1002 (E01)
Glen Rose, TX 76043 Tel: 254 897 5209 Fax: 254 897 6652 mike.blevinsetxu.com Mike Blevins Senior Vice President &
Chief Nuclear Officer Ref: NRC-EA-02-026 NRC-EA-03-086 CPSES-20051062 Log # TXX-05101 May 31, 2005 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445/446 RESPONSE TO NRC GUIDANCE REGARDING MITIGATION STRATEGIES
REFERENCE:
NRC Staff Guidance for Use in Achieving Satisfactory Compliance with February 25, 2002, Order Section B.5.b, 'NRC B.5.b.
Guidance," dated February 25, 2005 Mr. Dyer:
The NRC issued Orders For Interim Safeguards and Security Compensatory Measures ("Order EA-02-026" or "ICM Order") dated February 25, 2002, for the Comanche Peak Steam Electric Station (CPSES).
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 ICM 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, TXU Generating Company LP (TXU Power) submitted its response to Section II.B.5.b. to Order EA-02-026 by the August 31, 2002, required date.
Attachment I contains Safeguards Information. Upon separation, this page is decontrolled.
SAFEGUARDS INFORMATION A membcr of the STARS (Sprat6gic Teaming and Resource Sharing) Alliance Callaviay a Comanche Peak Diablo Canyon Palo Verde
- South Texas Project Wolf Creek
TXX-05101 Page 2 of 4 SAFEGUARDS INFORMATION 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 CPSES. In many ways, Order EA-03-086 complemented or superseded requirements the interim measures imposed by Order EA-02-026.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 CPSES have been implemented.
Subsequently, TXU Power was 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 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 ofLarge 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, TXU Power 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), TXU Power's evaluation of the information the NRC provided. Attachment 1 (Safeguards Information) reflects the results of a comprehensive and thorough review of the guidance and describes the considerations that TXU Power either has already or intends to implement at CPSES 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. TXU Power 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 Attachment I contains Safeguards Information. Upon separation, this page is decontrolled.
SAFEGUARDS INFORNIATION
TXX-05101 Page 3 of 4 SAFEGUARDS INFORMATION 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 TXU Power commitment management system. to this letter is the schedule that TXU Power has developed regarding the implementation of commitments resulting from the evaluations documented in.
This communication contains new commitments as identified in Attachment 2 to this transmittal as they apply to CPSES Units 1 and 2.
Attachment I contains Safeguards Information. Upon separation, this page is decontrolled.
SAFEGUARDS INFORMATION
TXX-05101 Page 4 of 4 SAFEGUARDS INFORMATION Respectfully submitted, TXU Generation Company LP By:
TXU Generation Management Company LLC, Its General Partner Mike Blevins By:/FrdW. Madden Director, Regulatory Affairs NSH Attachments: : Comprehensive Review Results as Applicable to CPSES of the Guidance and Considerations in the Reference Document : Schedule for Implementation of Commitments Resulting from the Evaluations Documented in Attachment 1 c:
B. S. Mallett, Region IV M. C. Thadani, NRR Resident Inspectors, CPSES J. E. Dyer, Director, Office of Nuclear Reactor Regulation Attachment I contains Safeguards Information. Upon separation, this page is decontrolled.
SAFEGUARDS INFORMATION