L-18-061, Units. 1 & 2, Davis-Besse, and Perry, Response to Request for Additional Information Regarding Exemption Request for a Physical Barrier Requirement

Units. 1 & 2, Davis-Besse, and Perry, Response to Request for Additional Information Regarding Exemption Request for a Physical Barrier Requirement

ML18078A033
Person / Time
Site:	Beaver Valley, Davis Besse, Perry
Issue date:	03/16/2018
From:	Moul D FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC 000976, CAC MG0010, CAC MG0012, CAC MG0013, EPID L-2017-LLE-0019, L-18-061
Download: ML18078A033 (8)

Text

ArstEnergx 341 White Pond Drive Solutions

' Akron, Ohio 44320 Donald A. Moul 330-315-6800 President & CNO FirstEnergy Solutions Generation Companies March 16, 2018 L-18-061 10 CFR 73.5 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Response to Request for Additional Information Regarding Exemption Request for a Physical Barrier Requirement

[EPID-L-2017-LLE-0019 (CAC Nos. 000976/05000334/L-2017-LLE-0019 MG0010, 000976/05000334/L-2017-LLE-0019 MG0011, 000976/05000334/L-2017-LLE-0019 MG0012, and 000976/05000334/L-2017-LLE-0019 MG0013)]

By letter dated July 19, 2017 (Accession Number ML17200D139), FirstEnergy Nuclear Operating Company (FENOC) requested a permanent exemption from a requirement of 10 CFR 73.2, "Definitions" for Beaver Valley Power Station Unit Nos. 1 and 2, Davis-Besse Nuclear Power Station, and Perry Nuclear Power Plant.

By e-mail dated February 9, 2018, the Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the FENOC request. The FENOC response to the NRC request for information is attached to this letter.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at 330-315-6810.

Sincerely, Donald A. Moul

Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-18-061 Page 2

Attachment:

Response to Request for Additional Information cc:

NRC Region I Administrator NRC Region Ill Administrator NRC Resident Inspector - Beaver Valley NRC Resident Inspector - Davis-Besse NRC Resident Inspector- Perry NRC Project Manager - FENOC Fleet Director BRP/DEP Site BRP/DEP Representative Utility Radiological Safety Board Branch Chief, OEMA, State of Ohio

Attachment L-18-061 Response to Request for Additional Information Page 1 of 6 The NRC staffs request for additional information is provided in bold text, followed by the FENOC response.

RAl#1:

As required by§§ 73.55(e) and 73.55(e)(3)(i)(B), describe the site-specific conditions and locations, in relation to site layout, that were identified and analyzed to determine the specific use, type, function, and placement of the affected physical barriers (fences) and the need for the vertical bracket configuration at each location. Specifically, clarify the locations of fence sections described in the submittal (i.e., the vertical configuration of barbed wire on the top of limited protected area sections (on gates, near gates, near interfaces with buildings, and on corners at BVPS, and similar configurations at DBNPS and PNPP, to include near the IDS at DBNPS)), and clarify the technical basis/need for the vertical bracket configuration at each location to which it is applied.

Response

Site layouts with the locations and descriptions of the protected area physical barrier fencing sections topped with vertically-oriented brackets containing barbed wire or similar material are provided in Figures 1, 2, and 3 for BVPS, DBNPS, and PNPP, respectively. The response to RAI #2 provides the technical basis or need for the vertical bracket configuration at each location.

RAl#2:

As required by§ 73.55(e)(1), describe the technical basis for the vertical bracket design, construction, installation, and maintenance relative to the capability to control access into facility areas for which access must be controlled or denied, and how the vertical bracket configuration satisfies the physical protection program design requirements of§ 73.55(b).

Specifically, describe how the vertical bracket configuration ensures that the requirements of§§ 73.55(e)(3) and 73.55(e)(8) are effectively met relative to: (1) protection against the design basis threat; (2) performance of the intended function (limit access, channeling to access portals, deterrence, delay, and/or support to access controls); (3) the level of deterrence, delay, and/or support to access controls relied upon by the physical protection program; and (4) the function that the fence performs in support of the protective strategy (to include any impact to adversary or responder timelines that are dependent upon the

Attachment L-18-061 Page 2 of 6 delay assigned to the fence and/or confirm that delay time provided by the vertical bracket configuration has been accounted for in the licensee's protective strategy for both adversary and responder timelines).

§ 73.55(e)(3) states that physical barriers must:

(1) Be designed and constructed to

a. Protect against the design basis threat of radiological sabotage;

b. Account for site-specific conditions; and

c. Perform their required function in support of the licensee physical protection program.

(2) Provide deterrence, delay, or support access control.

(3) Support effective implementation of the licensee's protective strategy.

§ 73.55(e)(8)(i) states in part that the "protected area perimeter must be protected by physical barriers that are designed and constructed to:

(A) Limit access into the protected area to only those personnel, vehicles, and materials required to perform official duties; (B) Channel personnel, vehicles, and materiavls to designated access control portals";

Response

As clarified on a February 7, 2018 phone call regarding the level of detail the NRC staff was expecting for the response to this question, the NRC staff stated RAI #2 is questioning why the angular fence topping design is not acceptable at all locations.

As stated in the exemption request and shown in the response to RAI #1, the vertical bracket configuration is limited to locations on gates, near gates, near interfaces with buildings, and on corners. DBNPS also has vertical brackets in two locations adjacent to the IDS where physical separation clearance is required. Other than the DBNPS locations near the IDS, the vertical bracket configuration at the other locations described in the exemption request is preferred to maintain sufficient tension in the barbed wire strands. The angular brackets use slits in the steel to accommodate the barbed wire.

The majority of the barbed wire is not hard-fastened to the bracket, but fits snugly in the slits when the wire is tensioned. Greater barbed wire tension can therefore be applied when using vertical brackets as opposed to angular brackets on the end of fence runs (which includes on top of gates, adjacent to gates, and adjacent to buildings). Angular corner arms do not provide a good tension point in the barbed wire.

Attachment L-18-061 Page 3 of 6 RAl#3:

Provide any analyses performed to establish or confirm the technical basis for the affected configuration and/or information supporting the capability of the

'affected configuration to satisfy applicable Commission requirements and ensure the effectiveness of the protective strategy, to include any impact to adversary or responder timelines that are dependent upon the delay assigned to the fence and/or confirm that delay time provided by the vertical bracket configuration has been accounted for in the licensee's protective strategy for both adversary and responder timelines. As required by § 73.55(e)(2), the licensee shall retain, in accordance with § 73. 70, all analyses and descriptions of the physical barriers and barrier systems used to satisfy the requirements of this section, and shall protect these records in accordance with the requirements of§ 73.21.

Response

The protective strategy for adversary and responder timelines has been developed in accordance with a FENOC business practice applicable to BVPS, DBNPS, and PNPP, and satisfies applicable Commission requirements. The vertical bracket configuration has no impact to adversary or responder timelines in the protective strategies for the FENOC fleet. This is due to site-specific evaluations that determined the limiting perimeter barrier fence scenarios are most similar to the configuration illustrated on page eight of RIS 2003-06, or the use of mechanical breaching utilizing the same configuration. Whether or not the fence toppings are vertical or angled makes no difference to the protective strategy limiting timelines.

Attachment L-18-061 Page 4 of6

- Gates With Vertical Posts

• Vertical Posts V-N3150.0 E8550.0

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Figure 1. BVPS Location of Protected Area Physical Barrier Fencing Sections Topped With Vertically-oriented Brackets.

Attachment L-18-061 Page 5 of 6

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- Gates With Vertical Posts eee Vertical Fencing NearIDS Figure 2. DBNPS Location of Protected Area Physical Barrier Fencing Sections Topped With Vertically-oriented Brackets

Attachment L-18-061 Page 6 of 6 e

Gates With Vertical Posts Vertical Posts 0 I 0

Figure 3. PNPP location of Protected Area Physical Barrier Fencing Sections Topped With Vertically-oriented Brackets.