LIC-09-0071, Request for Exemption from Physical Security Requirements
| ML100050032 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/31/2009 |
| From: | Reinhart J Omaha Public Power District |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LIC-09-0071 | |
| Download: ML100050032 (12) | |
Text
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~~e iiililii Omaha Public Power Oistnct Omaha Public Power Oistrict FortCalhoun Fort CalhounStation Station 9610 Power 9610 Lane PowerLane Blair,NE Blair, NE 68008 68008 SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION --WITHHOLD WITHHOLD UNDERUNDER 10 CFR 2.390.
UPON SEPARATION UPON SEPARATION OF ENCLOSURES ENCLOSURES 1 AND 2, THIS LETTER AND AND ENCLOSURES 3, ENCLOSURES 3,4, 4, AND 5 ARE DECONTROLLED.
December 31 31,, 2009 LIC-09-0071 LlC-09-0071 u.s.
U.S. Nuclear Regulatory Commission Commission Attn: Document Document Control Desk
- Mail Station P1-137 Washington, D.C. 20555 Washington,
References:
- 1. Docket No. 50-285 50-285
- 2. Federal Register Notice, "Power Reactor SecuritySecurity Requirements; Final March 27, 2009 (74 FR 13926)
Rule," dated March 13926)
SUBJECT:
Request for Exemption Exemption from Physical Security Requirements Requirements
'" -. -. In accordance In accordance with the requirements requirements of 10 CFR 73.5, the Omaha Public Power District (OPPD) requests the Nuclear Regulatory Commission (NRC)
Nuclear Regulatory (NRC) approve an exemption exemption forfor Fort Calhoun Station (FCS), Unit Unit No.1 No. 1 from specific requirements requirements of 10 CFR Part 73, "Physical ProtectionProtection of Plants and Materials." The requested requested exemption would extend the date for complying complying with certain new new security requirements issued by the NRC as as published in the Federal Register on March 27, 2009 (Reference published (Reference 2).
Pursuant Pursuant to the Final Rule, the new security requirements must be implemented security requirements implemented by March March 31, 2010.
31,2010. OPPD has evaluated these new requirements has evaluated these new requirements and determined determined that many of them can be implementedimplemented by that date. However, However, specific specific parts parts of the new new requirements requirements will require require more time to implementimplement since they involve significant physical upgrades upgrades to the the FCS security system, which will have a large impact impact on the FCS security security strategy.
Therefore, Therefore, additionaladditional time is requested to complete complete the security security modifications.
modifications.
As described described in the Enclosures, OPPD is requesting requesting that the implementation implementation date for certain certain new security requirements contained security requirements contained in in 10 CFR CFR 73.55 be extended extended from March March 31,2010 31,2010 to October 5,2011. The October 5,2011. The requested requested date date is based on the time time required required to design design SECURITY-RELATED SECURITY-RELATED INFORMATION INFORMATION -WITHHOLD
- WITHHOLD UNDERUNDER 10 CFR CFR 2.390.
2.390.
UPON SEPARATION UPON SEPARATION OF ENCLOSURES ENCLOSURES 1 AND AND 2, THIS LETTER LETTER ANDAND ENCLOSURES ENCLOSURES 3,4, 3, 4, AND AND 5 AREARE DECONTROLLED.
DECONTROLLED.
Employment Employment with Equal OpportunityOpportunity ý ý,R,4171
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION -WITHHOLD
- WITHHOLD UNDERUNDER 10 CFR 2.390.
UPON SEPARATION ENCLOSURES I1 AND SEPARATION OF ENCLOSURES AND 2, THIS LETTER AND AND ENCLOSURES ENCLOSURES 3,4, AND DECONTROLLED.
AND 5 ARE DECONTROLLED.
U.
U. S. Nuclear Nuclear Regulatory Commission LlC-09-0071 LIC-09-0071 Page 2 and construct modifications of this scope, considering impediments impediments to construction construction such as a planned refueling outage and winter weather weather conditions.
OPPD's OPPO's current security security program and the new security requirements requirements that will be be implemented implemented by March 31, 31, 2010, provide provide continued assurance of public health and safety continued assurance and the common common defense defense and security. Accordingly, the requested requested exemption exemption is authorized authorized by law and will not endanger endanger life or property or the common defense and security in accordance accordance with 10 10 CFR 73.5.
OPPD OPPO requests approval of this exemption exemption request by March March 1, 2010 to allow time to prepare prepare and implement implement compensatory compensatory measures if if the exemption is not granted. If granted, the proposed exemption exemption is requested requested to be effective effective upon issuance.
Enclosure exemption requested and Enclosure contains the exemption Enclosure 2 provides provides the basis for the the proposed proposed exemption.
exemption. Enclosures 1 and 2 contain security-related security-related information information asas described in 10 CFR 2.390(d)(1) described 2.390(d)(1) associated with the physical protection of FCS.
Accordingly, OPPO OPPD requests that Enclosures Enclosures 1 and 2 be withheld from public disclosure public disclosure in accordance accordance with the provisions of 10 10 CFR 2.390.
Enclosures 3 and 4 are versions of Enclosures Enclosures Enclosures 1 and 2 respectively that are suitable for public disclosure. Enclosure Enclosure 5 provides an Environmental Environmental Assessment Assessment that is also suitable for public disclosure.
disclosure.
This letter contains no NRC commitments.
SECURITY-RELATED SECURITY-RELATED INFORMATION INFORMATION -WITHHOLD
- WITHHOLD UNDERUNDER 10 CFR 2.390.
2.390.
UPON SEPARATION UPON ENCLOSURES 1 AND SEPARATION OF ENCLOSURES AND 2, THIS LETTER LETTER ANDAND ENCLOSURES 3,4, AND ENCLOSURES AND 5 ARE DECONTROLLED.
DECONTROLLED.
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION --WITHHOLD WITHHOLD UNDER UNDER 10 2.390.
ENCLOSURES I1 AND SEPARATION OF ENCLOSURES UPON SEPARATION AND 2, THIS LETTER AND AND ENCLOSURES 3, ENCLOSURES 4, AND 3,4, DECONTROLLED.
AND 5 ARE DECONTROLLED.
U. S. Nuclear Nuclear Regulatory Regulatory Commission LIC-09-0071 LlC-09-0071 Page 3 If you should have have any additional questions or require require additional information, please please contact Mr. Bill Hansher Hansher at (402) 533-6894.
Sincerely, 2£y Jf ey A. Reinhart A. Reinhart Site Vice President JARPMLE/mle JARIMLE/mle
Enclosures:
- 1. Request for Exemption Physical Security Requirements Exemption from Physical Requirements (Security Related Information - Withhold Under Information Under 10 CFR 2.390)
- 2. Basis for Proposed Proposed Exemption Exemption (Security Related Information - Withhold Under 10 Related Information CFR 2.390)
- 3. Request for Exemption Exemption from Physical Security Requirements (For Public Disclosure)
Security Requirements
- 4. Basis for Proposed Exemption Disclosure)
Exemption (For Public Disclosure)
- 5. Environmental Environmental Assessment (For Public Disclosure) c: E. E. Collins, NRC Regional Administrator, Region IV IV L. E. Wilkins, NRC Project Manager L. Manager J. C. Kirkland, NRC Senior Resident Resident Inspector Inspector SECURITY-RELATED INFORMATION --WITHHOLD SECURITY-RELATED INFORMATION WITHHOLD UNDER UNDER 10 CFR 2.390.
UPON UPON SEPARATION SEPARATION OF ENCLOSURES ENCLOSURES 1 AND AND 2, THIS LETTER ANDAND ENCLOSURES 3, 4, AND ENCLOSURES AND 5 ARE DECONTROLLED.
DECONTROLLED.
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION -WITHHOLD
- WITHHOLD UNDER UNDER 10 CFR 2.390.
2.390.
UPON SEPARATION UPON SEPARATION OF ENCLOSURES ENCLOSURES 1 AND AND 2, THIS LETTER LETTER ANDAND ENCLOSURES 3, 4, AND ENCLOSURES AND 5 ARE DECONTROLLED.
DECONTROLLED.
LIC-09-0071 LlC-09-0071 Enclosure Page 1 Omaha Public Power Omaha Public Power District District Request for Exemption Request Exemption from Physical Security Requirements Requirements A. BACKGROUND BACKGROUND The NRC issued a Final Rule for new security requirements requirements in the Federal Register Register (FR) dated March 27, 2009 (74 FR 13926). Pursuant Pursuantto to 10 CFR 73.55(a)(1) 73.55(a)(1) of the the Final Rule, the new security requirements must be implementedimplemented by March 31, 31, 2010. The Omaha Omaha Public Power District (OPPD) has evaluated evaluated these new requirements requirements and determined determined that many of them can be implementedimplemented by then.
However, OPPD has also determined implementation of specific parts of the determined that implementation the new requirements requirements will require significant significant security security modifications.
modifications. Thus, additional March 31, time beyond the March 2010 date is requested 31,2010 requested for compliance with the Final compliance with the Final Rule will require Fort Calhoun Station (FCS),
Rule. Full compliance
. Unit No.1 No. 1 to upgrade upgrade the capability of its security security system. The upgrade upgrade will be be completed by October 5,2011 after which OPPD will be in full compliance.
5, 2011 after B. FCS SECURITY SECURITY SYSTEM SYSTEM UPGRADE UPGRADE FCS is a single unit plant located in Washington Washington County Nebraska Nebraska on the banks of the Missouri river.
The FCS Security Security System upgrade will include the following major items:
- 1. Ensure certain certain security-related security-related equipment equipment remains capable of performing *its its design function at all times.
- 2. Relocate Relocate certain security-related security-related equipment to hardened hardened areas. A second second option involves the elimination of specific specific target functions with the use of digital network technologies.
network
- 3. Upgrade Upgrade certain delay barriers barriers and intrusion intrusion detection detection equipment and add or surveillance equipment.
relocate surveillance Due to the amount amount of design, procurement procurement and installation activities, completion completion of some of the new requirements requirements contained contained in 10 CFR 73.55 will require additional SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION -WITHHOLD
- WITHHOLD UNDER UNDER 10 10 CFR 2.390.
2.390.
UPON SEPARATION ENCLOSURES 1I AND SEPARATION OF ENCLOSURES AND 2, THIS LETTER LETTER ANDAND ENCLOSURES 3, 4, AND ENCLOSURES AND 5 ARE DECONTROLLED.
DECONTROLLED.
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION -WITHHOLD
- WITHHOLD UNDER UNDER 10 CFR 2.390.
2.390.
UPON SEPARATION UPON SEPARATION OF ENCLOSURES ENCLOSURES 1 AND AND 2, LETTER AND 2, THIS LETTER AND ENCLOSURES 3, ENCLOSURES 3,4,4, AND DECONTROLLED.
AND 5 ARE DECONTROLLED.
LIC-09-0071 LlC-09-0071 Enclosure Page 2 time beyond beyond March March 31,2010.
31, 2010. With NRC approval of this exemptionexemption request, the the 10 10 CFR 73 provisions required to be implementedimplemented by March 31, 2010 will be March 31, be complete except for the items described described in Section C below. The items described in Section Section C, subject subject to this request for an exemption, implemented by exemption, will be implemented 5, 2011 at which point FCS will be in full compliance October 5,2011 compliance with the Final Rule.
C. PROPOSED EXEMPTION PROPOSED OPPD requests an exemption compliance (March 31, exemption from the date of compliance 31, 2010) required by the Final Rule for the items described described below to allow sufficient time to to complete modifications modifications necessary necessary for full compliance with the Final Rule. FCS's FCS's current security program program and the new security requirements requirements that will be be implemented by March 31, implemented 2010, provide 31,2010, provide continued continued assurance assurance of public health and safety, and the common common defense defense and security. OPPD will determine determine the optimum optimum methods to address address the issues itemized itemized below subject subject to this request for an exemption, exemption, and will implement implement them by October October 5, 2011 at which point FCS will be 5,2011 be in full compliance with the Final Rule. Accordingly, the requested exemption exemption is authorized authorized by law and will not endanger endanger life or property or the common defense defense and security in accordance accordance with 10 CFR 73.5.
Item No.
No.11 assessment of certain An assessment certain security-related security-related equipment was performedperformed and while while adequate, adequate, enhancements enhancements are needed. needed. Two conceptual conceptual designs designs are under under consideration.
consideration.
Item No.
No.22 Certain security-related security-related equipment must be relocated relocated or have additional protection additional protection provided. An alternative involves alternative involves the use of digital network technology.
No. 3 Item NO.3 Certain delay barriers barriers and intrusion intrusion detection detection equipment equipment must be enhanced enhanced and SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION --WITHHOLD WITHHOLD UNDER UNDER 10 CFR 2.390.
UPON SEPARATION UPON SEPARATION OF ENCLOSURES ENCLOSURES AND 1 AND 2, THIS LETTER AND AND ENCLOSURES 3, 4, AND ENCLOSURES AND 5 ARE DECONTROLLED.
DECONTROLLED.
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION --WITHHOLD WITHHOLD UNDER 10 CFR 2.390.
SEPARATION OF ENCLOSURES UPON SEPARATION ENCLOSURES 1 AND 2, THIS LETTER AND AND ENCLOSURES ENCLOSURES 3, 4, AND 5 ARE DECONTROLLED.
DECONTROLLED.
LIC-09-0071 LlC-09-0071 Enclosure Page 3 surveillance equipment added surveillance equipment added or relocated.
relocated.
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION -WITHHOLD
- WITHHOLD UNDER 10 CFR 2.390.
UPON SEPARATION SEPARATION OF ENCLOSURES ENCLOSURES 1 AND 2, THIS LETTER AND AND ENCLOSURES ENCLOSURES 3, 4, AND 5 ARE DECONTROLLED.
DECONTROLLED.
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION - WITHHOLD WITHHOLD UNDER UNDER 10 CFR 2.390.
UPON UPON SEPARATION SEPARATION OF ENCLOSURES ENCLOSURES 1 AND AND 2, 2, THIS LETTER LETTER ANDAND ENCLOSURES 3,4, AND ENCLOSURES AND 5 ARE DECONTROLLED.
DECONTROLLED.
LlC-09-0071 LIC-09-0071 Enclosure Page 1 Basis for Proposed Proposed Exemption The Omaha Omaha Public Power District (OPPD) is requesting an exemption from the March March 31, 31, 2010 date date for compliance compliance with 10 10 CFR 73.55. The basis for requesting an exemption from March 31,2010 31, 2010 to October 5, 2011 is to allow for completion 5,2011 completion of required upgrades upgrades toto the Fort Calhoun Station (FCS), Unit No.1 No. 1 security system. The upgrade upgrade will require significant installation activities. These activities, addressing significant design, procurement, and installation addressing the new Part 73 rule requirements, include the enhancement enhancement of security system relocation of equipment equipment, the relocation equipment to hardened hardened areas, and modification modification of security computer system software.
software.
Using established construction, testing, and established processes, the duration (study, design, construction, turnover) of a project of this magnitude magnitude is typically 18 - 24 months. This timeframe is further challenged challenged by resources resources and the logistical impacts of aa plant refueling outage and severe cold weather conditions. OPPD is continuing efforts to implementimplement the remaining remaining new Part 73 requirements requirements identified identified in the Final Rule and associated associated Regulatory Guides Regulatory Guides issued in July 2009 by the March March 31,2010 31, 2010 compliance compliance date.
An overview overview of the work activities associated with the physical modifications modifications is as follows:
Modifications Overview Physical Modifications Overview The scope of the physical modifications modifications includes:
- 1. Enhancements Enhancements to ensure certain security-related equipment remains capable of security-related equipment performing its design function at all times.
performing Relocate certain security-related
- 2. Relocate security-related equipment equipment to hardened hardened areas. A second option involves the elimination elimination of specific target functions with the use of digital network technologies.
technologies.
- 3. Upgrade Upgrade certain delay delay barriers and intrusion detection detection equipment and add or relocate relocate surveillance equipment.
surveillance The current current NRC approved approved FCS Physical Physical Security Plan contains adequate adequate compensatory measures such that the additional time requested to implement measures implement these modifications modifications will SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION ~-WITHHOLD WITHHOLD UNDER UNDER 1010 CFR 2.390.
UPON SEPARATION UPON SEPARATION OF ENCLOSURES ENCLOSURES 1 AND AND 2, THIS LETTER AND AND ENCLOSURES 3, 4, AND ENCLOSURES AND 5 ARE DECONTROLLED.
DECONTROLLED.
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION -WITHHOLD
- WITHHOLD UNDERUNDER 10 CFR 2.390.
UPON SEPARATION UPON SEPARATION OF ENCLOSURES ENCLOSURES AND 1 AND 2, THIS LETTER ANDAND ENCLOSURES ENCLOSURES 3, 4, AND DECONTROLLED.
AND 5 ARE DECONTROLLED.
LIC-09-0071 LlC-09-0071 Enclosure Page 2 not negatively impact the overall overall FCS physical protection protection program or protective protective strategy.
A project milestone modifications associated milestone schedule for the physical modifications associated with this this exemption exemption request has been developed.
developed. These milestones represent represent the design, completed to comply with the new Part 73 installation and testing activities which must be completed 73 requirements. The milestone schedule schedule was developed developed based on current information and and anticipated challenges.
anticipated SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION -WITHHOLD
- WITHHOLD UNDERUNDER 10 CFR 2.390.
2.390.
UPON SEPARATION OF ENCLOSURES UPON SEPARATION ENCLOSURES 1 AND AND 2, THIS LETTER LETTER ANDAND ENCLOSURES ENCLOSURES 3, 4, AND AND 5 ARE DECONTROLLED.
DECONTROLLED.
SECURITY-RELATED SECURITY-RELATED INFORMATION INFORMATION --WITHHOLD WITHHOLD UNDERUNDER 10 CFR 2.390.
UPON SEPARATION SEPARATION OF ENCLOSURESENCLOSURES 1 AND AND 2, THIS LETTER LETTER AND AND ENCLOSURES 3, ENCLOSURES 4, AND 3,4, DECONTROLLED.
AND 5 ARE DECONTROLLED.
LIC-09-0071 LlC-09-0071 Page 1 Fort Calhoun Station, Unit No.1 No. I Environmental Assessment Environmental Assessment
- 1. Describe Describe any change to the types, characteristics, characteristics, or quantities quantities of non-radiological effluents discharged non-radiological effluents discharged to the environment environment as a result of the proposed proposed exemption.
Response
OPPD Response There are no expected changes in the types, characteristics, characteristics, or quantities quantities of non-radiological non-radiological effluents discharged discharged to the environment environment associated associated with the proposed exemption. The proposed exemption exemption. exemption will allow an extension extension to the date date for compliance compliance with certain requirements of the Final Rule, "Power Reactor Security Requirements" certain new requirements published published in the Federal Federal Register on MarchMarch 27, 2009 (74 FR 13926).
13926). Extending the date of compliance for certain new requirements requirements of the Final Rule from March 31, 31, 2010 to October 5, 2011 will allow October allow sufficient sufficient time for security security modifications modifications to occur. The The requested exemption requested exemption will not result in changes to the design basis requirements for the the components (SSCs) at Fort Calhoun structures, systems, and components Calhoun Station (FCS), Unit No.1 No. 1 that function to limit the release of non-radiological non-radiological effluents during and following following postulated accidents. All the SSCs associated with limiting the release postulated offsite release of offsite non-radiological effluents non-radiological effluents will therefore continue to be able to perform their functions. As As a result, there is no significant non-radiological effluent significant non-radiological effluent impact. There are no materials or chemicals introduced into the plant that could affect characteristics or types of affect the characteristics non-radiological effluents. In addition, the method of operation of non-radiological non-radiological non-radiological waste waste systems will not be affected by the proposed exemption.
proposed exemption.
- 2. Describe any changes to liquid radioactive effluents discharged discharged as a result of the proposed proposed exemption.
Response
OPPD Response The proposed proposed exemption will allow an extension to the date for compliance compliance with certain new requirements requirements of the Final Rule to allow sufficient time for security modifications modifications to occur. There There is no expected expected change to the liquid radioactive effluents effluents discharged as a SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION -WITHHOLD
- WITHHOLD UNDERUNDER 10 CFR 2.390. 2.390.
UPON SEPARATION ENCLOSURES 1 AND SEPARATION OF ENCLOSURES AND 2, THIS LETTER AND AND ENCLOSURES 3, ENCLOSURES 3,4, 4, AND AND 5 ARE DECONTROLLED.
DECONTROLLED.
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION --WITHHOLD WITHHOLD UNDER UNDER 10 10 CFR 2.390.
UPON SEPARATION SEPARATION OF ENCLOSURES ENCLOSURES 1 I AND AND 2, 2, THIS LETTER AND AND ENCLOSURES ENCLOSURES 3, 4, AND AND 5 ARE DECONTROLLED.
DECONTROLLED.
LIC-09-0071 LlC-09-0071 Enclosure Enclosure 5 Page Page 2 result of the proposed proposed exemption. The proposed exemption exemption will not interact interact to produce produce quantity or type of radioactive any different quantity radioactive material material in the reactor coolant system. The The proposed proposed exemption exemption will not result in changes to the design basis requirements requirements for the the SSCs at FCS that function function to limit the release release of liquid radiological radiological effluents effluents during during and following postulated postulated accidents. All SSCs associated associated with limiting the release of liquid liquid radiological radiological effluents will therefore therefore continue to be able to perform perform their functions. As a result, there is no liquid radiological effluent impact.
- 3. Describe any changes to gaseous radioactive effluents discharged as a result
- 3. Describe any changes to gaseous radioactive effluents discharged as a result proposed exemption.
of the proposed OPPD Response
Response
The proposed proposed exemption exemption will allow an extension to the date for compliance compliance with certain
. new requirements of the Final Rule to allow sufficient time for security modifications modifications to occur. For the same reasons as described described in number number 2 above, the proposed exemption would have no effect on the characteristics characteristics of gaseous gaseous radioactive effluents.
- 4. Describe any change in the type or quantity quantity of solid radioactive radioactive waste generated generated as a result of the proposed proposed exemption.
OPPD Response
Response
The proposed proposed exemption will allow an extension to the date for compliance with certain new requirements of the Final Rule to allow sufficient modifications to sufficient time for security modifications occur. The requested exemption exemption will not result in changes changes to the design basis design basis requirements requirements for the SSCs at FCS that function to limit the release of solid waste during during associated with limiting the release and following postulated accidents. All SSCs associated release of solid radioactive radioactive waste will therefore continue to be able to perform their function.
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION --WITHHOLD WITHHOLD UNDER UNDER 10 CFR 2.390. 2.390.
UPON UPON SEPARATION SEPARATION OF ENCLOSURES ENCLOSURES 1 I AND AND 2, THIS LETTER AND AND ENCLOSURES 3, 4, AND ENCLOSURES AND 5 ARE DECONTROLLED.
DECONTROLLED.
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION - WITHHOLD WITHHOLD UNDERUNDER 10 CFR 2.390.
2.390.
UPON SEPARATION UPON ENCLOSURES 1 AND SEPARATION OF ENCLOSURES AND 2,2, THIS LETTER AND LETTER AND ENCLOSURES 3, 4, AND ENCLOSURES AND 5 ARE DECONTROLLED.
DECONTROLLED.
LIC-09-0071 Enclosure Page 3
- 5. What is the expected expected change change in occupational occupational dose as a result of the proposed proposed exemption under under normal and design basis accident accident conditions?
conditions? .
OPPD Response
Response
The proposed exemption exemption will allow an extension to the date for compliance compliance with certain requirements of the Final Rule to allow sufficient time for security modifications new requirements modifications to occur. As such, such, no change in occupational change occupational dose as a result of the proposed exemption under normal or design design basis accident conditions is expected.
expected.
- 6. What is the expected change in the public dose as a result of the proposed
- 6. What is the expected change in the public dose as a result of the proposed exemption exemption under normal and [design basis accident (DBA)] conditions? conditions?
OPPD Response
Response
The proposed proposed exemption will allow an extension to the date date for compliance compliance with certain requirements of the Final Rule to allow sufficient new requirements sufficient time for security modifications modifications to occur. Dose to the public will not be changed by the proposed exemption during normal operations or DBA conditions. As noted in items 2, 3 and 4 above, there is no basis to operations contemplate contemplate an increased increased source of liquid, gaseous gaseous or solid radiological radiological effluents effluents that could contribute to increased increased public exposure exposure during normal operations operations or DBADBA conditions. The proposed security security modifications modifications do not impact systems used during during normal operation or systems used to detect or mitigate a DBA.
normal operation
- 7. What is the impact to land disturbance for the proposed exemption? exemption?
OPPD Response The proposed exemption exemption will allow an extension extension to the date for compliance compliance with certain new requirements of the Final Rule to allow sufficient sufficient time for security security modifications modifications to occur. The security modifications modifications involve the installation installation of new components components and/or software in, software in, on, or around existing equipment, buildings buildings or structures. New buildings are not being added. Therefore, Therefore, the proposed exemption and associated security modifications modifications will have minimal minimal impact impact on land disturbance.
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION --WITHHOLD WITHHOLD UNDER UNDER 10 10 CFR 2.390.
UPON SEPARATION UPON SEPARATION OF ENCLOSURES ENCLOSURES 1 AND AND 2, THIS LETTER AND AND ENCLOSURES 3, ENCLOSURES 3,4, AND 5 ARE DECONTROLLED.
4, AND DECONTROLLED.
SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION - WITHHOLD 2.390.
UNDER 10 CFR 2.390.
WITHHOLD UNDER UPON UPON SEPARATION ENCLOSURES 1 AND SEPARATION OF ENCLOSURES AND 2, THIS LETTER LETTER ANDAND ENCLOSURES 3, 4, AND ENCLOSURES AND 5 ARE DECONTROLLED.
DECONTROLLED.
LIC-09-0071 LlC-09-0071 Enclosure Page 4
==
Conclusion:==
There There is no significant significant radiological environmental impact radiological environmental impact associated with the proposed exemption or associated security modifications at FCS. These proposed changes security modifications changes will not affect affect any historical non-radiological plant effluents.
historical sites nor will they affect non-radiological SECURITY-RELATED INFORMATION -WITHHOLD SECURITY-RELATED INFORMATION - WITHHOLD UNDER UNDER 10 CFR 2.390.
SEPARATION OF ENCLOSURES UPON SEPARATION ENCLOSURES 1 AND AND 2, THIS LETTER LETTER ANDAND ENCLOSURES 3, ENCLOSURES 3,4, 4, AND AND 5 ARE DECONTROLLED.
DECONTROLLED.