PLA-5897, Response to NRC B.5.b Guidance Document
| ML051570440 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/27/2005 |
| From: | Mckinney B Susquehanna |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-02-026, EA-03-086, PLA-5897 | |
| Download: ML051570440 (4) | |
Text
SAFEGUARDS INFORMATION XA,.
a..
Senior Vice President and Chief Nuclear Officer 769 Salem Boulevard 1o
- 4I Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 TM btmckinneytpplweb.com MAY 21 Z205 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO NRC B.5.b GUIDANCE DOCUMENT, DATED FEBRUARY 25, 2005 Docket Nos. 50-387 PLA-5897 and 50-388 The NRC issued Orders For Interim Safeguards and Security Compensatory Measures
("Order EA-02-026" or "ICM Order") dated February 25, 2002, for PPL Susquehanna, LLC (PPL).
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, PPL 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 Threatfor Operating Power Reactors ("Order EA-03-086" or "DBT Order") and other security related Orders (collectively "Orders") for PPL. In many ways, Order EA-03-086 complemented or superseded requirements from the interim measures imposed by Order EA-02-026.
As required by Order EA-03-086, the plans for PPL have been implemented.
Subsequently, PPL 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 enhancements to current mitigation strategies by August 31, 2005.
NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION
% Z"53 i/l
SAFEGUARDS INFORMATION U.S. Nuclear Regulatory Commission PLA-5897 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.S.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, PPL 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), PPL'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 PPL either has already or intends to implement at Susquehanna SES 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. PPL 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 PPL's commitment management program. to this letter is the schedule that PPL has developed regarding the implementation of commitments resulting from the evaluations documented in.
NOTE: ATTACHMENT I TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION
SAFEGUARDS INFORMATION U.S. Nuclear Regulatory Commission PLA-5897 Should you have any questions or require additional information, please contact Mr. Ronald E. Smith, Manager, Site Preparedness and Response, at (570) 542-3298.
T. Kinney Attachments: 1) PPL Response Template (Safeguards)
- 2) Implementation Schedule (Non-Safeguards) cc:
Mr. Richard Guzman Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike - Mail Stop 8 B 1A Rockville, MD 20852-2738 Mr. A. J. Blamey Sr. Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 35 Berwick, PA 18603-0035 Mr. Samuel J. Collins Regional Administrator 475 Allendale Rd.
King of Prussia, PA 19406 NOTE: ATTACHMENT I TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION
SAFEGUARDS INFORMATION U.S. Nuclear Regulatory Commission PLA-5897 bcc:
A. M. Bannon (SRC)
T. L. Harpster L. G. Oberrender G. F. Ruppert R. A. Saccone R. R. Schechterly R. R. Sgarro M. R. Sleigh R. E. Smith B. L. Shriver T. G. Wales (DBD)
NRA Files DCS Attn: R. Beidleman GENPL4 w/o att.
NUCSA4 w/o att.
NUCLC w/o att.
NUCSB3 w/o att.
NUCSB3 w/o att.
NUCSA3 w/o att.
GENPL4 w/o att.
NUCNG NUCSA4 w/o att.
GENTW15 w/o att.
GENPL4 w/o att.
GENPL4 wlo att.
GENPL4 w/o att.
NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."
SAFEGUARDS INFORMATION