ET 10-0002, Resubmittal of Request for Exemption from Specific 10 CFR Par 73 Requirements

Resubmittal of Request for Exemption from Specific 10 CFR Par 73 Requirements

ML100250025
Person / Time
Site:	Wolf Creek
Issue date:	01/12/2010
From:	Garrett T Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 10-0002
Download: ML100250025 (7)

Text

'WOLF CREEK

'NUCLEAR OPERATING CORPORATION Terry J. Garrett Vice President Engineering January 12, 2010 ET 10-0002 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter ET 09-0028, dated October 27, 2009, from T. J. Garrett, WCNOC, to USNRC

2) Letter ET 09-0029, dated October 27, 2009, from T. J. Garrett, WCNOC, to USNRC

3) Letter ET 09-0033, dated December 15, 2009, from T. J. Garrett, WCNOC, to USNRC

4) Letter ET 09-0034, dated December 15, 2009, from T. J. Garrett, WCNOC, to USNRC

5) Letter ET 09-0035, dated December 15, 2009, from T. J. Garrett, WCNOC, to USNRC

Subject:

Docket No. 50-482: Resubmittal of Request for Exemption from Specific 10 CFR Part 73 Requirements (Non-Safeguards Version)

Gentlemen:

References 1 and 2 requested exemption from specific requirements of 10 CFR 73, "Physical Protection of Plants and Materials," for Wolf Creek Generating Station (WCGS) by extending the deadline for the implementation of certain measures required by the rule. Reference 3 withdrew these requests following a conference call with Nuclear Regulatory Commission (NRC representatives from the Offices of Nuclear Reactor Regulation (NRR), and Nuclear Security and Incident Response (NSIR) on November 10, 2009.

During this call the NRC identified that some of the items requested for exemption were not needed, as they did not represent a change to existing requirements and that additional clarification was needed in order to consider the remaining requests. References 4 and 5 provided the information needed to clarify the requests for exemption from specific 10 CFR Part 73 requirements. Reference 5 provided a redacted version of the attachments from Reference 4 and is free from security related information associated with physical protection of operated facilities, as described in 10 CFR 2.390(d)(1).

P.O. Box 411 / Burlington, KS 66839!/ Phone: (620) 364-8831 , . .

An Equal Opportunity Employer M/F/HCNVET

ET 10-0002 Page 2 of 2 In a call with the NRC Project Manager on January 6, 2010, it was requested that WCNOC resubmit the redacted version of Reference 4 with additional information being redacted. This submittal supersedes Reference 5.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4084, or Mr. Richard D. Flannigan at (620) 364-4117.

Sincerely, Terry J. Garrett TJG/rlt Attachment II - Background (redacted)

Part 73 Exemption Survey (redacted)

HII Environmental Impact of Proposed Action cc: E. E. Collins (NRC), w/a G. B. Miller (NRC), w/a B. K. Singal (NRC), w/a B. Westreich (NRC), w/a Senior Resident Inspector (NRC), w/a

Attachment I to Letter ET 10-0002 Page 1 of 2

Background

The NRC has amended its security regulations and added new security requirements pertaining to nuclear power reactors. These amendments include a complete revision of 10 CFR 73.55. The final rulemaking was made effective on May 26, 2009. The new security requirements associated with these amendments have necessitated configuration changes to Wolf Creek Generating Station (WCGS).

Pursuant to the Final Rule, the new security requirements must be implemented by March 31, 2010. Wolf Creek Nuclear Operating Corporation (WCNOC) has evaluated these requirements and determined that some of the new requirements will require additional time beyond the March 31, 2010, date to complete. Therefore, WCNOC is requesting exemption from the implementation date requirement of the new rule for the following projects required to implement the new rules. Additional information and details in support of the requested extensions are given in Attachment II.

Project 1 - [ I Re.gulation Issue To meet the requirements of this regulation, WCNOC has determined that

] An extension is requested for completion of this project to December 31, 2010.

Attachment I to Letter ET 10-0002 Page 2 of 2 Project 2 - [

Regqulation Issue To meet the requirements of this regulation, WCNOC has determined that a

] An extension is requested for completion of this project to December 31, 2010.

2 Attachment II to Letter ET 10-0002 Page 1 of 2 Part 73 Implementation Survey Need Part 73 Time Utility/ Exemption Primary Reasons(s) for Exemption Requirement Needed Site  ? Needing Beyond (Yes / No) Exemption March 31, 2010 WCGS Yes [ ] Project#1 Details: 12/31/2010 Schedule Related Activities (completion milestones):

Commencement of project: 7/03/2009 Prepare SSD calculations: 8/25/2009 Conceptual Design: 10/29/2009 Prepare Specification/Issue PO: 12/30/2009 Equipment Lead Time (7 months), on site:

8/31/2010 Change Package Completion: 9/30/2010 Planning Completion: 9/30/2010 Equipment Installation Completion:

10/29/2010 Package closeout and plant acceptance:

12/31/2010 Estimated Completion/Extension Request Date: 12/31/2010 Circumstances affecting timely project completion: Affecting the timely completion of this project includes the required preparation of [ ] ahead of conceptual design, 7-month lead time for I ] equipment, and unfavorable weather months affecting construction.

Please note that the abnormally long lead time of seven months has been confirmed with one of WCNOC's long standing vendors,

], and is due to a high volume of upcoming commitments to other nuclear sites. Use of an alternate vendor would leave the plant with a non-integrated Plant Security Computer System (PCSC) and is not a realistic option for consideration.

Attachment II to Letter ET 10-0002 Page 2 of 2 Part 73 Implementation Survey Need Part 73 Time Utility/ Exemption Primary Reasons(s) for Exemption Requirement Needed Site  ? Needing Beyond (Yes /No) Exemption March 31, 2010 WCGS Yes [ ]Project #2 12/31/2010 Details: This project involves a major modification to the existing [

Schedule Related Activities (completion milestones):

Commencement of project (est.): 11/01/2009 Conceptual Design Completion: 1/04/2010 Prepare Specification/Issue PO: 3/08/2010 Equipment Lead Time (7 months), on site:

8/31/2010 Change Package Completion: 9/30/2010 Planning Completion: 9/30/2010 Equipment Installation Completion:

10/29/2010 Package closeout and plant acceptance:

12/3112010 Estimated Completion/Extension Request Date: 12/31/2010 Circumstances affecting timely project completion: Affecting the timely completion of this installation includes a project starting delay and a high volume of concurrent project activity.

Attachment III to Letter ET 10-0002 Page 1 of 1 Part 73 Implementation Survey Environmental Impact of Proposed Action The proposed exemption is administrative, schedule change only with no change to the work being performed, and would have no impact on the environment. Allowing these projects to be completed at a date later than March 31, 2010, will not significantly increase the probability or consequences of an accident, change the types or quantities of radiological effluents that may be released offsite, or result in a significant increase in public or occupational radiation exposure since there would be no change to facility operations that would create a new accident or affect a previously analyzed accident or release path.