NOC-AE-05001889, Response to NRC Guidance Regarding Mitigation Strategies

Response to NRC Guidance Regarding Mitigation Strategies

ML051470105
Person / Time
Site:	South Texas
Issue date:	05/25/2005
From:	Sheppard J South Texas
To:	Office of Nuclear Reactor Regulation
References
EA-02-026, EA-03-086, NOC-AE-05001889, STI: 31886091
Download: ML051470105 (3)

Text

, 90~ IlSAFEGUARDiS INFORMATION I Nuclear Opera.irng Company South Teas Proc/ Eledsn GenefabnSt.ion PO. B 289 AsWh, T,=s 77453 A A AA May 25, 2005 NOC-AE-05001889 U. S. Nuclear Regulatory Commission Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike ATTA CHMENT 1 CONTAINS Rockville, MD 20852 SAFEI GUARDS INFORMATION UPOlNI SEPARATION THIS South Texas Project PAGE IS DECONTROLLED Units 1 and 2 Docket No. STN 50-498 and STN 50-499 Response to NRC Guidance Reclardina Mitioation Strategies The NRC issued Orders for Interim Safeguards and Security Compensatory Measures ("Order EA-02-026" or 'ICM Order") dated February 25, 2002, for the South Texas Project (STP).

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 Il.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, STP Nuclear Operating Company (STPNOC) was 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 the STP. In many ways, Order EA-03-086 complemented or superseded requirements the interim measures imposed by Order EA-02-026.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 STP have been implemented. Subsequently, STPNOC 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 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 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.

SAFEGUARDS INFORMATION STI: 31886091 65 k

1 NOC-AE-05001889 SAFEGUARDS INFORMATION J Page2of3 As requested in the February 25, 2005, letter, STPNOC 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), STPNOC'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 STPNOC either has already or intends to implement at STP by August 31, 2005.

The primary guiding principles used in the conduct of this evaluation were (1) whether or not equipment and resources are 'readily available," and (2) if equipment is readily available, can it be effectively utilized in a licensee's mitigating strategy.

In accordance with these principles, mitigative strategies are being implemented to address the NRC B.5.b. Guidance. Attachment 2 contains the actions and implementation schedule resulting from the evaluations documented in Attachment 1.

The commitments in this letter are described in Attachment 3 and will be managed in accordance with STPNOC's commitment management system.

Attachment 1 to this letter contains Safeguards Information and should be withheld from public disclosure in accordance with 10 CFR 73.21.

If there are any questions regarding this letter, please contact Robyn Savage at (361) 972-7438 or me at (361) 972-8757.

J. J. Sheppard President & Chief Executive Officer Attachments: 1). STPNOC's Evaluation of NRC B.5.b. Guidance (Safeguards Information) 2). Schedule 3). Commitments I .

ATTACHMENT 1 CONTAINS SAFEGUARDS INFORMATION UPON SEPARATION THIS PAGE IS DECONTROLLED STI: 31886091 SAFEGUARDS INFORMATION

I SAFEGUARDS INFORMATION l NOC-AE-05001889 Page 3 of 3 cc: without attachments except as noted with ** cc: without attachments (paper copy) (electronic copy)

Bruce S. Mallett ** A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 David H. Jaffe Arlington, Texas 76011-8064 U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Jack A. Fusco Director, Office of Nuclear Reactor Regulation Michael A. Reed One White Flint North Texas Genco, LP 11555 Rockville Pike Rockville, MD 20852 C. Kirksey City of Austin Richard A. Ratliff Jon C. Wood Bureau of Radiation Control Cox Smith Matthews Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756-3189 Jeffrey Cruz J. J. Nesrsta U. S. Nuclear Regulatory Commission R. K. Temple P. 0. Box 289, Mail Code: MN116 E. Alarcon Wadsworth, TX 77483 City Public Service C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 ATTACHMENT 1 CONTAINS

• SAFEGUARDS INFORMATION UPON SEPARATION THIS PAGE IS DECONTROLLED I SAFEGUARDS INFORMATION Page 1 of 36