DCL-24-040, License Amendment Request 24-02 Request for Approval of DCPP Early Warning System to Meet 10 CFR 73.55(i)(2) and 10 CFR 73.55(e)(9)(vi)(A)

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License Amendment Request 24-02 Request for Approval of DCPP Early Warning System to Meet 10 CFR 73.55(i)(2) and 10 CFR 73.55(e)(9)(vi)(A)
ML24108A113
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 04/15/2024
From:
Pacific Gas & Electric Co
To:
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML24108A111 List:
References
DCL-24-040
Download: ML24108A113 (6)
v • d • e


Text

Security-Related Information - Withhold under 10 CFR 2.390 Enclosure PG&E Letter DCL-24-040

License Amendment Request 24-02 Request for Approval of DCPP Early Warning System To Meet 10 CFR 73.55(i)(2) and 10 CFR 73.55(e)(9)(vi)(A)

1.

SUMMARY

DESCRIPTION (uncontrolled)

2. APPLICABLE REGULATORY REQUIREMENTS (uncontrolled)
3. NO SIGNIFICANT HAZARDS CONSIDERATION ANALYIS (uncontrolled)
4. ENVIRONMENTAL CONSIDERATION (uncontrolled)
5. REFERENCES (uncontrolled)

ATTACHMENTS:

1. Technical Evaluation and Assessment of Alternative Security Measures and Exemptions for Detection and Assessment Systems (Security-Related Information)

ATTACHMENT 1 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1 TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED Security-Related Information - Withhold under 10 CFR 2.390 Enclosure PG&E Letter DCL-24-040

EVALUATION

1.

SUMMARY

DESCRIPTION

The purpose of this license amendment request is to propose, in accordance with 10 CFR 73.55(r), alternative security measures for the implementation of the Early Warning System (EWS) to satisfy the requirements of 10 CFR 73.55(i)(2). Exemption from 10 CFR 73.55(e)(9)(vi)(A) is also proposed in accordance with 10 CFR 73.5.

The Diablo Canyon Power Plant (DCPP) EWS is comprised of barriers and a separate EWS Intrusion Detection System (IDS). It is designed to provide delay and early indication of unauthorized entry into areas of the Owner Controlled Area (OCA) adjacent to the Protected Area (PA). This allows a more rapid security response and a more effective use of security personnel, equipment, and programs. Detection at the EWS has been used to develop responder timelines, and as a result, the EWS is considered required to meet the requirements of 10 CFR 73.55(b).

Based on NRC correspondences (References 1 and 2), EWSs that must meet the requirements of 10 CFR 73.55(b) must also meet the applicable requirements for barriers and IDSs set forth in 10 CFR 73.55(e), (i), (n), and (o).

Pacific Gas and Electric Company (PG&E) is requesting NRC review and approval of alternative security measures to satisfy 10 CFR 73.55(i)(2) in accordance with 10 CFR 73.55(r) and 10 CFR 50.90. PG&E is also requesting approval of an exemption from 10 CFR 73.55(e)(9)(vi)(A), in accordance with 10 CFR 73.5.

to the Enclosure of this letter provides the technical basis for the proposed alternative security measure and exemption, demonstrating that they meet the relevant criteria.

2. APPLICABLE REGULATORY REQUIREMENTS

10 CFR 73.5, Specific Exemptions, allows the Commission to grant exemptions from the requirements of the regulations in part 73 if the exemption is determined to be authorized by law and will not endanger life or property or the common defense and security, and are otherwise in the public interest.

10 CFR 73.55(e)(9)(vi)(A) requires secondary power supply systems for alarm annunciation equipment to be located within a vital area.

10 CFR 73.55(i)(2) requires that intrusion detection equipment must annunciate and video assessment equipment shall display concurrently, in at least two continuously staffed onsite alarm stations, at least one of which must be protected in accordance with the requirements of the central alarm station within this section.

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ATTACHMENT 1 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1 TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED Security-Related Information - Withhold under 10 CFR 2.390 Enclosure PG&E Letter DCL-24-040

10 CFR 73.55(r) Alternative measures states in part:

(1) The Commission may authorize an applicant or licensee to provide a measure for protection against radiological sabotage other than one required by this section if the applicant or licensee demonstrates that:

(i) The measure meets the same performance objectives and requirements specified in paragraph (b) of this section

(2) The licensee shall submit proposed alternative measure(s) to the Commission for review and approval in accordance with §§ 50.4 and 50.90 of this chapter before implementation.

(3) In addition to fully describing the desired changes, the licensee shall submit a technical basis for each proposed alternative measure. The basis must include an analysis or assessment that demonstrates how the proposed alternative measure provides a level of protection that is at least equal to that which would otherwise be provided by the specific requirement of this section.

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ATTACHMENT 1 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1 TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED Security-Related Information - Withhold under 10 CFR 2.390 Enclosure PG&E Letter DCL-24-040

3. NO SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS

PG&E has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The security detection and assessment systems are not an initiator of any Updated Final Safety Analysis Report Chapter 6 or 15 design basis accidents or events, and therefore, the proposed change does not increase the probability of any accident previously evaluated and does not significantly increase the likelihood of the malfunction of facility system, structures, and components (SSCs). The security intrusion detection and assessment systems detect and assess unauthorized persons and facilitate the effective implementation of the security protective strategy and have no significant impact on accident consequences. The proposed change does not physically impact the plant SSCs or the manner in which SSCs perform their design function and does not change how the plant would mitigate an accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different accident from any accident previously evaluated?

Response: No.

The proposed 10 CFR 73.55(r) alternative security measures and 10 CFR 73.5 exemption involve security equipment and do not result in a change to plant SSCs credited to mitigate design basis accidents or the manner in which the plant SSCs provide plant protection. The plant SSCs will continue to perform their function to mitigate a design basis accident or event. The proposed change will not introduce failure modes that could result in a new accident.

Therefore, the proposed change does not create the possibility of a new or different accident from any accident previously evaluated.

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ATTACHMENT 1 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1 TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED Security-Related Information - Withhold under 10 CFR 2.390 Enclosure PG&E Letter DCL-24-040

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

Response: No.

Margin of safety is associated with the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public.

The proposed change does not involve a change to the fission product barriers and does not alter the manner in which technical specification safety limits, limiting safety system settings, or limiting conditions for operation are determined. The safety analysis acceptance criteria are not impacted by this change. The proposed change will not result in plant operation in a configuration outside the existing design basis since the plant SSCs will continue to perform their function to mitigate a design basis accident or event.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above evaluation, PG&E concludes that the proposed change does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4. ENVIRONMENTAL CONSIDERATION

PG&E has evaluated the proposed amendment and has determined that the proposed amendment does not involve (1) a significant hazards consideration, (2) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

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ATTACHMENT 1 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1 TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED Security-Related Information - Withhold under 10 CFR 2.390 Enclosure PG&E Letter DCL-24-040

5. REFERENCES
1. NRC Letter, The U.S. Nuclear Regulatory Commission Inspection Approach Related to Industry Implementation of Early Warning Systems, dated May 26, 2016
2. NRC Letter, Request for Clarification on Use of Early Warning Systems, dated July 11, 2016

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ATTACHMENT 1 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 1 TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED

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