RBG-46443, Response to NRC Guidance Regarding Mitigation Strategies
| ML051570058 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 05/31/2005 |
| From: | Lorfing D Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-02-026, RBG-46443 | |
| Download: ML051570058 (3) | |
Text
~Entergy Entergy Operations, Inc.
River Bend Station 5485 U.S. Highway 61 N St. Francisville, LA 70775 Tel 225381 4157 Fax 225 635 5068 dlorfin@entergy.com David N. Lorfing Manager-Licensing SAFEGUARDS INFORMATION RBG-46443 May 31, 2005 Via Overnight Delivery U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852-2738 301-415-7000
SUBJECT:
REFERENCES:
Response to NRC Guidance Regarding Mitigation Strategies River Bend Station Docket No. 50-458 License No. NPF-47
- 1. March 15, 2002, Entergy Operations, Inc. - Response to Issuance of Order for Interim Safeguards and Security Compensatory Measures (RBG-45922)
- 2. February 25, 2005 letter from J. E. Dyer to Holders of Licenses for Operating Power reactors as Listed in Enclosure 1 NRC Staff Guidance for Use in Achieving Satisfactory Compliance with February 25, 2002, Order Section B.5.b. (RBC-50259)
Dear Sir or Madam:
The NRC issued an Order For Interim Safeguards and Security Compensatory Measures ("Order EA-02-026" or "ICM Order") dated February 25, 2002, for River Bend Station (RBS).
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 1Il.A of the Order required licensees to implement certain changes in physical security and emergency planning on an interim basis until final requirements were established. Among other requirements, RBS was NOTICE: Enclosure contains "Safeguards Information." Upon separation of the Enclosure, this letter and the Attachment are "Decontrolled."
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SAFEGUARDS INFORMATION RBG-46443 Page 2 of 3 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 River Bend Station. In many ways, Order EA 086 complemented or superseded the interim measures imposed by Order EA-02-026.
As required by Order EA-03-086, the plans for the above-mentioned licensed facility have been implemented. Subsequently, RBS 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 of the February 25, 2005 letter, 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 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 the expectations in 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, RBS 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), RBS's evaluation of the information the NRC provided. The Enclosure reflects the results of our review of the guidance and describes the considerations that RBS either has already or intends to implement at River Bend Station 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. RBS considered "readily available" to mean that the equipment or resources were 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 strategies are considered to be commitments for that purpose and will be managed in accordance with the RBS commitment management system.
NOTICE: Enclosure contains "Safeguards Information." Upon separation of the Enclosure, this letter and the Attachment are "Decontrolled."
SAFEGUARDS INFORMATION SICN I_
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SAFEGUARDS INFORMATION RBG-46443 Page 3 of 3 The Attachment to this letter is the schedule that RBS developed regarding the implementation of identified commitments resulting from the evaluations documented in the Enclosure.
Respectfully submitted, Y
David N. Lorfing Manager, Licensing DNL/WJF Attachment - List of Regulatory Commitments and Schedule for Completion Enclosure - RBS Evaluation of NRC B.5.b Guidance cc:
w/a, w/o Enclosure (except as noted)
Mr. W. R. Campbell (ECH)
Mr. J. P. DeRoy (ECH)
Mr. W. A. Eaton (ECH)
Mr. P. D. Hinnenkamp (RBS)
Mr. J. R. McGaha (ECH)
Mr. N. S. Reynolds (W&S)
Mr. G. J. Taylor (ECH)
Mr. Doug Walters (NEI)
Mr. M. J. Wetterhahn (W&S)
Mr. B. S. Mallett, Administrator, RIV w/ Enclosure Mr. J. E. Dyer, Director, NRR w/ Enclosure Mr. M. K. Webb, NRR Project Manager, RBS w/ Enclosure Mr. P. J. Alter, SRI, RBS (w/a via Company Mail)
NOTICE: Enclosure contains "Safeguards Information." Upon separation of the Enclosure, this letter and the Attachment are "Decontrolled."
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