W3F1-2005-0038, Response to NRC Guidance Regarding Mitigation Strategies
| ML051570430 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/31/2005 |
| From: | Harris A Entergy Nuclear South, Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-02-026, EA-03-086, W3F1-2005-0038 | |
| Download: ML051570430 (4) | |
Text
SAFEGUARDS INFORMATION Entergy Nuclear South Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Tn tfa -axel 504-739-6475 aharris@entergy.com Alan J. Harris Director, Nuclear Safety Assurance Waterford 3 W3F11-2005-0038 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:
Response to NRC Guidance Regarding Mitigation Strategies Waterford Steam Electric Station, Unit 3 (Waterford 3)
Docket No. 50-382 License No. NPF-38
REFERENCES:
- 1. March 15, 2002, Entergy Operations, Inc.- Response to Issuance of Order for Interim Safeguards and Security Compensatory Measures (W3Fl -2002-0024)
- 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
Dear Sir or Madam:
The NRC issued an Order for Interim Safeguards and Security Compensatory Measures (Order EA-02-026 or Interim Compensatory Measures (ICM) Order) dated February 25, 2002, for the Waterford 3 Steam Electric Station.
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 emergency planning on an interim basis until final requirements were established. Among other requirements, Entergy was required to complete implementation of the requirements of Section lI.B.5.b of Order EA-02-026 by August 31, 2002.
Notice: Enclosure contains "Safeguards Information". Upon Separation of the Enclosure, this letter and the Attachment are "Decontrolled."
SAFEGUARDS INFORMATION A
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W3Fl-2005-0038 SAFEGUARDS INFORMATION Page 2 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 Design Basis Threat (DBT) Order) and other security related Orders (collectively "Orders") for Waterford 3. In many ways, Order EA-03-086 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, Entergy 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 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, Entergy 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 ), Entergy's evaluation of the information the NRC provided. The Enclosure reflects the results of our review of the guidance and describes the considerations that Entergy either has already or intends to implement at Waterford 3 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. Entergy 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 Entergy's commitment management system.
Notice: Enclosure contains "Safeguards Information". Upon Separation of the Enclosure, this letter and the Attachment are "Decontrolled."
SAFEGUARDS INFORMATION
W3Fl -2005-0038 Page 3 SAFEGUARDS INFORMATION The Attachment to this letter is the schedule that Entergy has developed regarding the implementation of identified commitments resulting from the evaluations documented in the Enclosure.
Respectfully submitted, Director, Nuclear Safety Assurance AJH/GCS/cbh Attachment -Schedule for Completion of Actions and List of Regulatory Commitments Enclosure - Entergy's Evaluation of NRC B.5.b Guidance Notice: Enclosure contains "Safeguards Information". Upon Separation of the Enclosure, this letter and the Attachment are "Decontrolled."
SAFEGUARDS INFORMATION
W3Fl-2005-0038 SAFEGUARDS INFORMATION Page 4 cc:
(w/Attachment and Enclosure)
U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 cc:
(w/o Attachment and Enclosure)
Dr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 Mr. J. E. Dyer Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Winston & Strawn ATTN: N.S. Reynolds 1700 K Street, NW Washington, DC 20006-3817 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004 Notice: Enclosure contains "Safeguards Information". Upon Separation of the Enclosure, this letter and the Attachment are "Decontrolled."
SAFEGUARDS INFORMATION