WO 05-0019, Response to NRC Guidance Regarding Mitigation Strategies

Response to NRC Guidance Regarding Mitigation Strategies

ML051570424
Person / Time
Site:	Wolf Creek
Issue date:	05/31/2005
From:	Hedges S Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-02-026, EA-03-086, WO 05-0019
Download: ML051570424 (3)

Text

(ICM B.5.b compliance)

W4LF CREEK NUCLEAR OPERATING CORPORATION Stephen E. Hedges Vice President Operations and Plant Manager May 31, 2005 WO 05-0019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852

Subject:

Docket No. 50-482: Response to NRC Guidance Regarding Mitigation Strategies Gentlemen:

The NRC issued Orders For Interim Safeguards and Security Compensatory Measures ("Order EA-02-026" or 1ICM Order") dated February 25, 2002, for the Wolf Creek Generating Station (WCGS).

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, Wolf Creek Nuclear Operating Corporation (WCNOC) 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 WCGS. In many ways, Order EA-03-086 complemented or superseded requirements the interim measures imposed by Order EA-02-026.

NOTE: ATTACHMENT 1TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ATTACHMENT, THIS LETTER IS

'DECONTROLLED."

SAFEGUARDS INFORMATION

, ,f5 3 P.O. Box 411 I Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET

WO 05-0019 Page 2 of 3 (ICM B.5.b compliance)

As required by Order EA-03-086, the plans for the above-mentioned licensed facility have been implemented. Subsequently, WCNOC 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 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, WCNOC 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), WCNOC'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 WCNOC either has already implemented or intends to implement at WCGS 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. WCNOC 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. The completion of actions required to implement these strategies are considered to be commitments for that purpose and will be managed to completion in accordance with WCNOC's commitment management system. to this letter is the schedule that WCNOC has developed regarding the implementation of commitments resulting from the evaluations documented in Attachment 1.

_ 1 NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS SAFEGUARDS INFORMATIONW AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ATTACHMENT, THIS LETTER IS

'DECONTROLLED."

SAFEGUARDS INFORMATION

WO 05-0019 Page 3 of 3 (ICM B.5.b compliance)

If you have any questions concerning this matter, please contact me at (620) 364-4190, or Mr.

Kevin Moles at (620) 364-4126.

Very truly rs, tephen E. Hedges SEH/rlg Attachments 1) WCNOC's evaluation of the information the NRC provided

2) Schedule for implementation/commitments cc: J. E. Dyer, Director, Office of Nuclear Reactor Regulation, w/a 2 J. N. Donohew (NRC), w/a 1 & 2 W. B. Jones (NRC), w/a 2 B. S. Mallett (NRC), w/a 2 Senior Resident Inspector (NRC), w/a 2 NOTE: ATTACHMENT 1TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ATTACHMENT, THIS LETTER IS

'DECONTROLLED."

SAFEGUARDS INFORMATION