3F0717-01, Submittal of Crystal River Unit 3 - License Amendment Request 321, Revision 1, ISFSI Only Physical Security Plan

Submittal of Crystal River Unit 3 - License Amendment Request #321, Revision 1, ISFSI Only Physical Security Plan

ML17193A237
Person / Time
Site:	Crystal River
Issue date:	07/05/2017
From:	Reising R Duke Energy Florida
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
3F0717-01
Download: ML17193A237 (20)

Text

Crystal River Nuclear Plant

, t{Ci>~ DUKE 15760 W Power Line Street

' I .,'\C ;> ENERGY... 60- 3/JZ-.

Crystal l':iver, FL 34428 Docket 72-10~5 Doc:kel 50-302 Operating Licen!;e No* DPR-72

~z..;,..1055 10 CFR 50.90

~uly 5, 2017 3F0717-01 U.S.* Nuclear Regulatory Commission Attn: Document Control Desi<

Washington, DC 20555-0001

Subject:

.. v

• Crystal River Unit 3 - License Amendment Request #321, Revision 1, ISFSI Only Physical Security Plan

References:

1. *cR-3 to NRC - Crystal River Unit 3 License AitiendmenfRequest ~21, Revjsion 0, ISFSI Only Physical Security Plan dated May 24,.2016.

2. NRC to CR Issuance of Order for Implementation of Additional Measures and Fingerprinting for Unescorted Access at the Crystal River Nuclear Generating Plant Independent Spent Fuel Storage Installation dated February 24, 2016.

3. CR-3 to NRC - Response to NRC Issuance of Order for Implementation of Additional Measures and Fingerprinting for Une5corted Access at the Crystal River Nuclear Generating Plant Independent Spent Fuel Storage Installation and a. Request for Order Relaxation dated February 20, 2017. *

Dear Sir:

Pursuant to 10 PFR 50.90, Duke Energy Flqrida. LLC (DEF), her~by submits Revision 1 to previously submitted licens~ amendment #321 pertaining to the Crystal River Nuclear Plant Unit*

.3 (~R-3) *Physical Security, Training and Qualification and Safeguards Contingency *Plans.

Revision O was submitted on May 24, 2016 (Reference1). This submittal supersedes revision O 1in its *entirety. A. complete list of changes between revision o and revision 1 are contained in Enclosure 9 of this submittal.

• specittcally, this licer:ise ~mendment requests* approval of a new combined Independent Spent

• Fuel Storage Installation (ISFSI) Only Physical Security Plan, Training and Qualification Plan,

• and $afeguards Contingency Plan, referred to from here on out as the PLAN. The PLAN will supei,sede the current Physical Security Plan, Training and Qualification Plan, and Safeguards .

.Contingency Plans at CR-3. The PLAN addresses the future site configuration once the spent

-:fuel in the spent fuel pool has been moved to the ISFSI, with no requirement to return spent fuel

,to the spent fuel pool ("ISFSI only" status). Spent fuel movement to the ISFSI is currently 1scheduled to be completed in 2018.

~DD 1*

~MS-57-&

. . f\)'2fl-SAFEGUARDS DNFOR~rnAT!ON NOTE: ENCLOSURE 1 TO THIS LETTER CONTAINS "SECURITY-RELATED INFORMA110N", tJM.?7 ENCLOSURE 11 TO THIS LETTER CON.TAINS "PROPRIETARY DUKE ENERGY INFORMATION" AND ENCLOSURES 3, 4, 5, 9 and 10 TO THIS LETIER CONTAIN "SAFEGUARDS INFORMATION***

THIS INFORMATION MUST BE PROTECTED ACCORDINGLY.

UPON SEPARATION OF'THESE ENCLOSURES, THIS LETTER IS"DECONTROLLED."

U. S. Nuclear Regulatc;iry Commission 3F0717-01 . Page2of 3 By letter dated February 24,.2016 (Reference 2), CR-3 was issued orders to provide Additional Security Measures (ASM) and Fingerprinting for Unescorted Access at the CR-3 ISFSI. By letter .dated February 20, 2017. (Reference 3), CR-3 responded to the orders how compliance was met for the current approved wet/dry Physical Security Plan (PSP) and how future compliance would be met when this license amendment is approved *and implemented.

Changes were made to the future compliance ASM responses, therefore updated responses.

are attached to this submittal (Enclosure 10). Also attached to this submittal is the CR-3 Local Law Enforcement Agency (LLEA) letter sent to the Citrus County Sheriff's office; which outlines their ~esponse requirements (Enclosure f1).

• An* evaluation of this proposed license amendment (LAR 321, Revision 1) is provided in

• Erclosure* 1. *The proposed changes *have bE!en evaluated in accordance with 10 CFR 5C!l.91(a)(1) using criteria in 10 CFR 50.92(c), and it has been determined that the proposed

.changes involve no significant hazards consideration. The bases for these determinations are included in* Enclosure 2. The PLAN is provided In Enclosure 3. Enclosure 4 contains the

• assumptions used in developing the PLAN. Pursuant fo 10 CFR 73.55(r), alternative measures that have been incorporated Into the proposed. PLAN are discussed in Enclosure 5. A marked-up anCI redline version *of the facility operating license pages for the Physical Protection licen*se

condition, reflecting the commitment change proposed in this submittal, are included as.

'Enclosures 6 and 7. Enclosure a contains a redacted version of Enclosure 1, that when 1

detached from this fetter is decontrolled.

in order to support site transition to "ISFSI only" status, CR-3 is requesting NRC approval of this proposed license amendment.by December 31, 2017. CR-3 requests an implementation period

. 'of 120 days following submittal of written notification to the NRC that all the spent nuclear fuel assemblies have been transferre;d from the spent fuel pool to the ISFSI pad.

CR-3 requests that Enclosure 1, wh.ich ~ontainr;; Security-Related Information and Enclosure 11, which contains Proprietary Duke Energy Information, be withheld from P.Ub!ic disclosure in accordance with 10-CFR 2.390. Enclosures 3, 4, 5, 9 and 10 contain Safeguards Information as

.defined by 10 CFR 73.22 and their disclosure to unauthorized individuals is prohibited by S~ction 147 of the Atomic Energy Act of 1954, as amended. *

,lri acc6rda11ce with 10. CFR 50.91, DEF is notifying the State of Florida of this license amendment request by tran~mitting a copy of this letter and uncontrolled enclosures to the pesignated State Officials; The State will not receive anything Security-Related or Safeguards information.

The CR-3 Plant Nuclear Safety Committee has reviewed this request and recommended. it for approval.

There are ilo regulatory commitments made within this submittal.

SAFEGUARDS INFORMATiON NOTE; ENCLOSURE 1 TO THIS LETTER CONTAINS "SECURITY-RELATED INFORMATIOfll".

ENCLOSURE 11 TO THIS LETTER CONTAINS "PROPRIETARY DUKE ENERGY INFORMATION" AND ENCLOSURES 3,4, 5, 9 and 10TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION*

THIS INFORMATION MUST BE PROTECTED ACCORDINGLY, UPON SEPARATION OF THESE ENCLOSURES, THIS LETTER IS "DECONTROLLED."

U. s. Nuclear Regulatory Commission 3F0717-01 Page 3of3

• If you have any questions regarding this submittal, please contact Mr. Mark Van Sicklen, Licensing Lead, Nuclear Regulatory Affairs, at (352) 563-4795.'

• I declare under penalty of perjury,that the foregoing is true and correct. Executed on July 5, .

• 2011

• Sincerely,

~g

-Ronald Reising, Senior Vice President Operations Support RRR/mvs

Enclosures:

1. Evaluation of Proposed Changes (Security-Related Information)

2. No Significant Hazards Consideration and Environmental Assessment (Uncontrolled)

3. Duke Energy Florida, LLC - Crystal River Unit 3 Independent Spent Fuel Storage Installation Security Pian, Training and Qualification Plan, and Safeguards Contingency _

Plan {Safeguards Information) . .

4. P~ogrammatic Assumptions for ISFSI Only Sites (Safeguards Information)

5. Evaluation.s of Proposed Alternative Measures (Safeguards Information)

6. Facility Operating License Strikeout Pages (Uncontrolled)

7. Facility Operating License Revision Bar Pages (Uncontrolled)

8. REDACTED - Evaluation of Proposed Changes (Uncontrolled) .

9. List of changes between revision O.to revision 1 of this license amen~ment (Safeguards Information) * *

10. Updated future compliance (ISFSl-Only) ASM responses (Safeguards Information) 11, CR-3 LLEA letter to Citrus County Sheritr (Proprietary. Duke Energy Information) xc: NMSS Project Mana.gar State of Florida (Uncontrol.led Enclosures ONLY, No SGI or SRI material)

Regional Administrator, Region I

• Douglas Gamer, NRC Reviewer SAFEGUARDS INIFOIRMAT~ON

. NOTE: ENCLOSURE 1 TQ THIS LETTER CONTAINS "SECURITY-RELATED INFORMATION",

ENCLOSURE 11 TO THIS LETTER CONTAINS "PROPRIETARY DUKE ENERGY INFORMATION" AND C.NCLOSURES 3, 4, 5, 9 and 10 TO THIS LETTER CONTAIN "SAFEGUARDS INFORMATION."

. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY.

UPON SEPARATION OF THESE ENCLOSURES, THIS LETTER IS "DECONTROLLED."

- SAFEGUARDS INlFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

_U. S. Nuclear Regulatory Commission Enclosure 2 3F0717~01 DUKE ENERGY FLORIDA, LLC

- !DOCKET NUMBERS 72 - 1035 and 50 - 302 / .

LICENSE NUMBER DPR - 72

-ENCLOSURE 2 No Significant Hazards Consideration and Envitonmental Assessment (Uncontrolled)

SAFEGUARDS INFORMATION WHEN SEPARAJ'ED THIS PAGE IS DECONTROLLED.

SAFE.GUARDS INFORMATION WHEN SEPA~TED THIS PAGE IS DECONTROLLED.

U. R Nuclear Regulatory C0mmission Enclosur13 2 3F0717-01 Page 1of3 No Significant Hazards Consideration a'nd Environmental Assessme.nt (Uncontrolled)*

°1. REGULATORY.EVALUATION

'  : I 1.1 Applicable Regulatory Requirements/Criteria 10 qFR 73.55 requires licensees to maintain* and implement a Commission-approved Physical Se~urity Plan, ,Trainjng C\l'nd Q1:1alification flan and Safeguards Contingency Plan. 10 CFR 72.212(b)(9) requires licensees*to comply with 10 CFR 73.55, with six (6) additional conditions and exceptions: for general -licensed ISFSls under 10 CFR 72.210 .. The Crystal Riv~r Nuclear Plant Unit 3 (GR-3) Facility Operating License (No. DPR-72)," includes a Physical Security license conditio'n (2.D) that requfres the respective licensees to fully implement .and maintain in effect all provis.ions ~f the Commission-approved Physical Security Protection Plans, including changes made purs~ant to the ~uthority of 10 CFR 50.90 and 10 CFR 50.54(p).

1.2 No Significant Hazards Consideration Determination DEF is requesti,ng approval of tt-113 new Physical Security Plan and the amendment to the *cR-3 Facility Op~rati~g*LiQense (No. QPR-72) to revise the Physical Security license condition 2.D as it relates tq the new Physical S~curjty Plan. The new Duke Energy Florida, LLC - Crystal River Unit *3 lndepenpent Spent Fuel, Stora.ge Installation Security Plan, Training and Qualification Plifri, and Safeguards Contingemcy Plan (PLAN) addresses the protection of fuel on site that is licensed by the iCR-~ Operating,; License. The PLAN .reflects the configuration of CR-3 after all the spent nucle~r fuel is stored iat the ISFSI. The 10 CFR Part 50 license for CR-3 no longer authorizes ~oper~tion ;of the reqctor or ~mplacement or retention of fuel into the reactor vessel.

Al~o based on ~he AREVA Coe~ :Amer:idment 14.approval, CR-3 is no longer required to place .

Spent NµClear j .

Fuel back into the Spent Fuel Pools.

I DEF has evalu~ted

I

Whether orlI.:not a significant hazards

' . consideration is involved with the proposed amendment by focusirag on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment,": as d\scussed below:

1. Does *the proposed ct1ange involve . a significant increase in the probability or consequ~nces of an accicfent previously evaluated?

Respon~e: Nq.

"f:he. prohosed PLAN will become effeQtive after all the spent nuclear fuel has been removec;( from the Spent Fuel Pools with no requirements to return spent fuel to the SFP.

The onlYi current design basis accident is the Fuel Handling Accident (FHA). Once the fuel is r~moved from the p9pl and placed on the ISFSI pad, the FHA will nci longer be credible.

• SAFEGUARDS INFORMATIO'N WHEN SEPARATED THIS PAGE: IS DECONTROLLED.

SAFEGUARDS INFORMATJION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

\

U.S. Nuclear Regulatory Commission 'Enclosure 2 3F0717-01 Page 2 of 3 The proposed amendment has no effect on plant sys~ems, structures, and components (SSCs) and no eff~cf on the- capability of any plant SSC to perform its design .function.

The proposed amendm~nt would not increase the likelihood of the malfunction of any plant SSC. Therefore, the propos~d amendment does not involve a significant increase

• in the probability or consequences of a previously evaluated accident.

2. Does the propos~d change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No. _

The proposed amendment does not involve significant physical alteration of the plant.

Minor modifications are associated with this proposed amendment (e.g., wiring changes in security equipment, the addition of telecommunications equipment, and software changes to the security computer system.) The proposed license amendment would not

.physically change any SSCs involved in the mitigation of any postulated accident. Thus, no new initiators or precursors of a new or different kind of accident are created.

Furthermore, the proposed amendment does not create the possibility of a new- failure mode associated with any,equipment or personnel failures. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Plant safety margins are established through limiting cond~ions.fot operation and safety analysis described in the* FSAR

• Because the 10 CFR Part 50 license for CR-3 *no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as $pecified in* 10 CFR 50.82(a)(2), the oceurrence of postulated accidents associated with reactor operation is no longer credible. The proposed amendment does not involve ~ change in the plant's design, configuration,* or operation.

The modifications associated with this proposed amendment does not affect plant safety or design margins. Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on* t_he above, CR-3 concludes that the proposed amendment presents no significant hazards consideration* under the standards set forth in 10 CFR 50.92(c), and, ac;:cordingly, a finding of "no significant hazards consideration" is justified.

• 1.3 Conclusions In conclusion, based on the considerations discussed above: (1) there is reasonable assurance*

that the health_ and safety of the p_ublic will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will riot be inimical to the common defense and security or to the health and safety of the public. .

SAFEGUARDS.INFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

SAFEGUARDS INFO~ATION WHEN SEPA~TED THIS PAGE IS DECONTROLLED.

U. S. Nuclear Regulatory Commission Enclosure 2 3F071?,.Q1 Page 3of3 *

2. ENVIRONMENTAL CONSIDERATION CR-3 has e~aluated this proposed license amendment against the .criteria* for identification of licensing and regulatory actions requiring environmental assessment . in accordance with 10 CFR 51.21. CR-3 has determined that this proposed license amendment meets the criteria for a catego~ical exclusion set forth in 10 CFR 51.22(c)(12). This determination is based on the fact that thi~ change is *being p~oposed as ~n amendment to a license issued pursuant. to' 10 CFR 50 ~nd relates' solely to safeguards matters (i.e., protection.against sabotage or loss or di\'fersion of ~pecial ~uclear material). The proposed amendment meets the eligibility criterion fot; a categorical ex<?lusion set forth in 10 CFR 51.22(c)(12). Therefore, pursuant to.

10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection.with the issuance of the *amendment. *

• I '

SAFEGUARDS INFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

SAFEGUARDS INFORMJ:ATION

.WHEN SEPARATED THIS PAGE IS DECONTROLLED.

u. s. ~uclear'Regulatory Commission Enclosure 3 3F0717-01 .

DUKE ENERGY .F_LORIDA, LLC DO<;: KET NUMBERS 7? - 1035 and* 50 - 302 I

. L;CENSE NUMBER DPR - 72 .

ENCLOSURE 3 Duke ~nergy Florida, LLC ~_Crystal River Unit 3 Independent Spent fuel Storage Installation Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan (Safeguards Information)

• . SAJFEGUARDS INFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

SAFEGUARD§ INFORMl:ATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

_ U. S. Nuclear Regulatory Commission Enclosure 4 3F0717-01 .

DUKE ENERGY FLORIDA, LLC DOCKET NUMBERS 72 - 1035 and* 50 - 302 /

L~CE"NSE NUMBER DPR - 72 ENCLOSURE4 Programmatic Assumptions for ~SFSI Only Sites (Safeguards Information)

SAFEGUARDS INFORMATION WHEN ~EPARATED THIS PAGE IS DECONTROLLED.

(

• SAFEGUARD§ INFORMATION WHEN SEPARATED THIS PAGE IS pECONTROLLED.

U. S. Nuclear Regulatory Commission Enclosure 5

• 3F0717-01 DUKE ENERGY FLORIDA, LLC POCKET NUMBERS* 72 - 1035 and 50 - 302 /

LICENSE NUMBER DPR - 72 ENCLOSURE 5 Evaluations of Proposed Alternative Measures (Safeguards Information)

SAFEGUARDS INFORMATION WHEN SEPARATED THIS PAGE is DECONTROLLE.D.

• SAFEGUARDS INFORMA'fliON WHEN SEPARATED THIS PAGE IS DECONTROLLED.

DUKE ENERGY FLORIDA, :LLC.

!DOCKET NUMBERS 72 - 1035 a11d 50 .. 302 I

. LICENSE NUMBER DPR - 72 ENCLOSURE 6 IFacilnty Operating License Strikeout Pages

• (Uncontrolled)

. SAFEGUARDS INFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

SAFEGUARDS INFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

U.S. Nuclear Regulatory Commission Enclosure 7 3F0717-01 DUKE ENERGY FLORIDA, LLC DOCKET NUMBERS 72 - 1035 and 50 - 302 I LICENSE NUMBER DPR -.72 ENCLOSURE 7 Facility Operating License Revision Bar Pag*es (Uncontrolled)

SAFEGUARDS INFORMATION*

. WHEN SEPARATED THIS PAGE IS DECONTROLLED.

SA.FEGUARD§ INlFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

• U. S. Nuclear Regulatory Commission. Enclosure 8 3F0717-01 DUKE ENERGY FLORIDA, LLC DOCKET NUMBERS 72 - 1035 and 50 - 302 /

LICENSE NUMBER DPR - 72 ENCLOSURE 8 REDACTED - EVALUATION OF PROPOSED CHANGES SAFEGUARDS INFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

SAF.EGUA]RDS INFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

U.S. Nuclear.Regulatory Commission Enclosure 8 3F0717-01 Page 1of4.

REDACTED- EVALUATION OF PROPOSED CHANGES

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION SAFEGUARDS INFORMATION WHEN Sl;PARATED THIS PAGE IS DECONTRO.lLED.

SAFEGUARDS INFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

U. S. Nuclear Regulatory Commission Enclosure 8 3F0717-01 Pag*e_2of4

• 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, . Duke Energy Florida, LLC (DEF); hereby requests a license amendment pertaining to the Crystal River Nuclear Plant Unit 3 (CR-3) Physical Security, Training and Qualification and Safeguards Contingency Plans, and a proposed revision to the existing Physical Security license condition in the facility operating license. Specifically, the replacement of the existing Physical Security plan, Training and Qualification Plan, and Safeguards Contingency Plan with a new combined Independent Spent Fuel Storage Installation (ISFSI) Only Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, referred to from here on out as the PLAN.

2.0 ' DETAILED DESCRIPTION Pursuant to 10 CFR '50.90, Duke Energy Florida, LLC (DEF), hereby requests a license amendment pertaining to the. Crystal River Nuclear Plant Unit 3 (CR-3) Physical* se*curity, Training and Qualification and Safeguards Contingency Plans, and a proposed revision to. the existing Physical Security license condition in the facility operating licens.e. . Specifically, the replacement of the existing Physical Security plan, Training and Qualification Plan, and Safeguards Contingency Plan with a new combined .Independent Spent Fuel Storage Installation (ISFSI) Only Physical security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, referred to from here on out as the PLAN.

CR-3 has been shutdown sir:ice September 26, 2009. DEF notified the Nuclear Regulatory Commission (NRC) on Feb~uary 20, 2013 of the permanent cessation of po~er operations and that PR-3 had removed all fuel from the reactor. By letter dated March 13, 2913, the NRC acknowledged CR-3's certification* of permanent cessation of power operation and permanent removal of fuel from the reactor vessel. Accordingly, pursuant to 10 CFR 50.82(a)(2), the 1o CFR Part 50 license for CR-3 no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

The PLAN will supersede the current' Physical Security" Plan, Training and Qu_alification Plan, and Safeguards Contingency Plans at CR-3. The new PLAN addresses the future site configuration once the spent fuel in the spent fuel pool has been moved to the ISF.Sl, with no requirem~nt to return spent fuel to the spent fuel pool ("ISFSI only" status). Spent fuel movement to the ISFSI is currently scheduled to be completed in 2018.

By letter dated February 24, 2016 (Reference 2), CR-3 was issued orders to provide Additional

. Security Measures (ASM) and Fingerprinting for Unescorted Access at the CR-3 ISFSI. By letter dated February 20, 2017 (Reference 3), CR-3 responded to the orders how compliance was met for the current approved wet/dry Physical Security Plan (PSP) and how future.

compliance would be met when this license. amendment is approved and implemented.

• Changes were made to the future compliance ASM responses, therefore updated responses SAFJEGUAR.DS INFORMATION WHEN ~EPARATED THIS PAGE IS DECONTROLLED.

SAFEGUARD§ INFO.RMA l'liON WHEN SEPARATED THIS PAGE IS DECONTROLLED.

U. S. Nuclear Regulatory Commission Enclosure 8 3F0717-01 Page 3 of 4 are attached to this submittal (Enclosure 1O). Also attached to this submittal is the CR-3 Local Law Enforcement Agency (LLEA) letter sent to the Citrus County Sheriff's office, which outlines their response requirements (Enclosure 11 ).

A technical evaluation of this proposed license amendment is provided below. The proposed changes have also been evaluated in accordance with 10 CFR 50.91 (a}(1) using criteria in 10 CFR 50.92(c), and it has been determined that the proposed change involves no significant hazards consideration. The bases for these determinations are included in Enclosure 2. The PLAN is provided' in Enclosure 3. Enclosure 4 contains the assumptions used in *devel9ping the PLAN. Purs!Jant to 10 CFR 73.55(r), alternative measures that have been incorporated into the proposed PLAN are discussed in Enclosure 5. A marked-up and redline version of the facility operating licenae p~ges for the. Physical Protection license condition, reflecting the commitment

• change proposed in this submittal, are included as Enclosures 6 and 7. Enclosure 8 contains a redacted version of Enclosure 1, that when detached from this letter is decontrolled.

In order to support site transition to "ISFSI only" status, CR-3 is requesting NRC approval of this

. propos~d license amendment by December 31, 2017. CR~3 requests an implementation period

• of 120 days following submittal *of written notification to the NRC that all the spent nuclear fuel assemblies have been transferred_ from the spent fuel pool to the ISFSI pad.

3.0 TECHNICAL EVALUATION

The PLAN The PLAN will supersede the current Physical Security Plan, Training* and* Qualification Plan, and Safeguards Contingency Plans at CR-3. The new PLAN addresses the *future site configuration once the spent fuel in the spent fuel pool has been moved to the ISFSI, with no requirement to return spent fuel to the spent fuel pool ("ISFSI onl "- status . S ent fuel movem~nt to the ISFSI is current! scheduled to be com leted in 2018.

I.

10 CFR 72.212(b)(9) requires licensees to comply with 10 CFR 73.55, with six (6) additional conditions and exceptions. Therefore, the PLAN was based on the NRG endorsed template for Operating Nuclear Plants, NEI 03,-12 Revision 7, and modified to incorporate the six (6) additional c9nditions and exceptions.

i  !  !  ! .

I  ; i  !

' ' I I I \

I  ; '

I I I . I SAFEGUARDS INFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

SAFEGUARDS INFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.

u.- S. Nuclear Regulatory Commission . Enclosure 8 3F0717-01 Page 4 of 4 i ': I' *I I I I I ' I.:

I ' I I I  ! l 1I I

. I '

' I I I '

I I

1*  :

I I

'I I .

I I

1:  !

I I I .

I I

I i

I

{

i l *I I

CR-3 has taken a methodical approach to integrating 10 CFR 72.212(b)(9) requirements with

• various other Code of Federal Regulation requirements.

• The PLAN complies with these requirements except where' alternative measures have been requested. The PLAN protects against the applicable. secti9ns of the design basis threat of radiological sabotage and ensures the health and safety of the public.

SAFJEGUAJRDS INFORMA'fJrON WHEN SEPARATED THIS PAGE 15 DECONTROLLED.

SAFEGUARDS INFORM:ATION

.WHEN SEPARATED THIS PAGE IS DECONTROLLED.

\ '

U.S. Nuclear Regulatory Commission Enclosure 9

• 3F0717-01 DUKE ENERGY FLORIDA, LLC DOCKET NUMBERS 72 - 1035 and 50 - 302 I LICENSE NUMBER DPR - 72 ENCLOSURE9 LIST OF CHANGES BETWEEN REVIS~ON 0 TO REVISION 1 OF THIS LICENSE AMENDMENT SAFEGUARDS INFORMATION

• SAFEGUARDS INFORMATJION

.WHEN* SEPARATED THIS PAGE IS DECONTROLLED...

U. S: Nuclear Regulatory Commission Enclosure 10 3F0717-01 . .

DUKE ENERGY FLORIDA, LLC DOCKET NUMBERS. .

72 -10.35 and 50 - 302 /

LICENSE NUMBER DPR - 72 ENCLOSURE10 UPDATED FUTURE COMPLIANCE" (ISFS~-ONLY) ASM RESPONS.ES SAFEGUARDS INFORMATION WHEN SEPARATED THIS P~~.E IS DECONTROLLED.

• SAFEGUARDS INFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED..

U. S. NucJear Regulatory Commission Enclosure 11 3F0717-01 .

DUKE ENERGY FLORiDA, LLC DOCKET NUMBERS 72 - 1035 and 50 - 302 I

• LICENSE NUMBER DPR - 72 ENCLOSURE11 CRYSTAL RIV~R

.LOCAL LAW ENFOREMENT AGENCY LETTER TO CITRUS COUNTY SHERIFF SAFEGUARDS INFORMATION WHEN SEPARATED THIS PAGE IS DECONTROLLED.*