JAFP-05-0080, Response to NRC Guidance Regarding Mitigation Strategies for James A. Fitzpatrick Nuclear Plant

Response to NRC Guidance Regarding Mitigation Strategies for James A. Fitzpatrick Nuclear Plant

ML051530123
Person / Time
Site:	FitzPatrick
Issue date:	05/26/2005
From:	Ted Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-05-0080
Download: ML051530123 (4)

Text

9 Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. Fitzpatrick NPP vEntergy SAFEGUARDS INFORMATION P.O. Box 110 Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 T.A. Sullivan Site Vice President - JAF May 26, 2005 JAFP-05-0080 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852

SUBJECT:

James A. FitzPatrick Nuclear Power Plant Docket 50-333 Response to NRC Guidance Regarding Mitigation Strategies

REFERENCES:

1. Entergy Nuclear Operations, Inc. letter to USNRC, Dated March 18, 2002, Entergy Operations, Inc. - Response to Issuance of Order for Interim Safeguards and Security Compensatory Measures (JPN-02-005)

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 Orders For Interim Safeguards and Security Compensatory Measures ("Order EA-02-026" or "1CM Order") dated February 25, 2002, for the James A. FitzPatrick Nuclear Power Plant (JAF).

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

1  ?-

SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION 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 and emergency planning on an interim basis until final requirements were established. Among other requirements, Entergy Nuclear Operations, Inc. (ENO) was required to complete implementation of the requirements of Section 2.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 086" or "DBT Order") and other security related Orders (collectively "Orders") for JAF. 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, ENO was requested to respond to your letter dated February 25, 2005, NRC Staff Guidancefor Use in Achieving Satisfactory Compliance with February25, 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. Specifically, nuclear power plant licensees were requested by Enclosure 2, DevelopingMitigating Strategies /

Guidance for NAuclear Power Plants to Respond to Loss of Large Areas of the Plant in Accordance with B.5.b of the February25, 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, ENO 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), ENO's evaluation of the information the NRC provided. The enclosure reflects the results of our review of the guidance and describes the considerations that ENO either has already or intends to implement at JAF by August 31, 2005.

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

SAFEGUARDS INFORMATION Page 2 of 4

SAFEGUARDS INFORMATION 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. ENO 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 strategies are considered to be commitments for that purpose and will be managed in accordance with ENO's commitment management system.

The attachment to this letter identifies the new commitments made in this letter and provides the schedule for implementing them.

Should you have any questions regarding this matter please contact Mr. Kenneth Phy at (315) 349-6967.

Respectfully submitted,

-_ - v-- ,P-- - _.. __ _.

T. A. Sullivan Site Vice President

Attachment:

Schedule for Completion of Actions and List of Regulatory Commitments

Enclosure:

JAF Evaluation of NRC B.5.b Guidance TAS:ed cc: Next page NOTE: THE ENCLOSURE TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ENCLOSURE, THIS LETTER AND THE ATTACHMENT ARE "DECONTROLLED."

SAFEGUARDS INFORMATION Page 3 of 4

SAFEGUARDS INFORMATION, cc:

Mr. James E. Dyer Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Samuel J. Collins Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Patrick D. Milano Project Directorate I Division of Licensing Project Management U. S. Nuclear Regulatory Commission

• 11555 Rockville Pike Rockville, MD 20852 Resident Inspector's Office U. S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 NOTE: THE ENCLOSURE TO THIS LETTER CONTAINS "SAFEGUARDS INFORMATION" AND MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ENCLOSURE, THIS LETTER AND THE ATTACHMENT ARE "DECONTROLLED."

SAFEGUARDS INFORMATION Page 4 of 4