ML051570458
| ML051570458 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/26/2005 |
| From: | Keith Young AmerenUE |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-02-026, EA-03-086, ULNRC-5155 | |
| Download: ML051570458 (4) | |
Text
Union Electric Callaway Plant PO Box 620 Fulton, MO 65251 May 26, 2005 ULNRC-5155 WAmereilUE U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
FACILITY OPERATING LICENSE NPF-30 RESPONSE TO NRC GUIDANCE REGARDING MITIGATION STRATEGIES The NRC issued Orders For Interim Safeguards and Security Compensatory Measures ("Order EA-02-026" or "ICM Order") dated February 25, 2002, for the Callaway Nuclear Plant.
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, Union Electric 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 Threat for Operating Power Reactors ("Order EA-03-086" or "DBT Order") and other security related Orders (collectively "Orders") for the Callaway Nuclear Plant. In many ways, Order EA-03-086 complemented or superseded requirements the interim measures imposed by Order EA-02-026.
The enclosed document contains Safeguards Information within the scope of 10 CFR 73.21.
Removal of enclosures declassifies this document.
Ke-r a subsidiary of Ameren Corporation
Z ULNRC-5155 May 26, 2005 Page 2 As required by Order EA-03-086, the plans for the above-mentioned licensed facility have been implemented. Subsequently, Union Electric was requested to respond to the letter from J.E. Dyer, Director, Office of Nuclear Reactor Regulation, 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, Union Electric 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), Union Electric'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 Union Electric either has already or intends to implement at Callaway Nuclear Plant 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. Union Electric 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 Union Electric's commitment management system.
2 ULNRC-5 155 May 26, 2005 Page 3 to this letter is the schedule that Union Electric has developed regarding the implementation of commitments resulting from the evaluations documented in.
Sincerely, Keith D. Young Manager, Regulatory Affairs KDY/rgh Enclosure (1 original and 3 copies)
ULNRC-5155 May 26, 2005 Page 4 cc:
U.S. Nuclear Regulatory Commission (Original and 3 copies)
Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Mr. Bruce S. Mallett (2 copies)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Physical Security Inspector U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 The following are sent without attachments:
Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)
Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7E1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360