ML093370143
| ML093370143 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 11/30/2009 |
| From: | Duncan R Florida Power Corp, Progress Energy Florida |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RA-09-017 | |
| Download: ML093370143 (17) | |
Text
Attachment 1 to this letter contains Prgrss n
SECURITY-RELATED Pogress Energy INFORMATION -WITHHOLD 10 CFR 73.5 UNDER 10 CFR 2.390.
PO Box 1551 Upon removal of Attachment 1 411 Fayetteville Street Mall this letter is uncontrolled.
Raleigh NC 27602 Serial: RA-09-017 November 30, 2009 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555-0001 CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302 / LICENSE NO. DPR-72 REQUEST FOR EXEMPTIONS FROM PHYSICAL SECURITY REQUIREMENTS Ladies and Gentlemen:
In accordance with the requirements of 10 CFR 73.5, Florida Power Corporation (FPC), now doing business as Progress Energy Florida, Inc., requests the Nuclear Regulatory Commission (NRC) approve exemptions from specific requirements of 10 CFR Part 73, "Physical Protection of Plants and Materials." The exemptions requested would extend the compliance due date for Crystal River Unit 3 for certain measures required by the revised rule.
The NRC issued a Final Rule for revised security requirements in the Federal Register dated March 27, 2009. Pursuant to the Final Rule, the revised security requirements must be implemented by March 31, 2010. FPC has performed an extensive evaluation of the Final Rule and will achieve compliance with a vast majority of the revised rule by the March 31, 2010, compliance date.
FPC has determined, however, that implementation of four specific provisions of the Final Rule will require more time to implement because they involve upgrades to the security system that require significant physical modifications (e.g., relocating and upgrading the intrusion detection system, construction of a building addition, and the addition of uninterruptable power supplies). Therefore, additional time beyond the March 31, 2010, date is requested to complete these security modifications. Additional details regarding the specific provisions of the rule for which exemptions are requested, and the length of the exemptions are provided in Attachment 1.
This letter contains the following attachments:
" Attachment 1: Exemption Request for Crystal River Unit 3 (Contains Security-Related Information - Withhold Under 10 CFR 2.390)
" Attachment 2: Redacted Version of Exemption Request for Crystal River Unit 3 As noted above, Attachment 1 contains security-related information associated with the physical protection of the Crystal River Unit 3, as described in 10 CFR 2.390(d)(1).
Accordingly, FPC requests that the information contained in Attachment 1 be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. to this letter contains SECURITY-RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390.
Upon removal of Attachment 1 this letter is uncontrolled.
United States Nuclear Regulatory Commission RA-09-017 Page 2 This letter contains no regulatory commitments.
If you should have any questions regarding this submittal, please contact Ed O'Neil, Director
- Nuclear Protective Services, at (919) 546-2151.
I declare under penalty of perjury that the foregoing is true and correct. Executed on November 30, 2009.
S *c rely, eR. J Du can 11 Vice esident, Nuclear Operations Progress Energy, Inc.
RJD/dbm Attachments:
- 1. Exemption Request for Crystal River Unit 3 (Contains Security-Related Information -
Withhold Under 10 CFR 2.390)
- 2. Redacted Version of Exemption Request for Crystal River Unit 3 c:
J. Wiggins, USNRC Director.- Office of Nuclear Security and Incident Response L. Reyes, USNRC Regional Administrator - Region II USNRC Resident Inspector - CR-3 F. Saba, NRR Project Manager - CR-3 to this letter contains SECURITY-RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390.
Upon removal of Attachment 1 this letter is uncontrolled.
Redacted Version of Exemption Request for Crystal River Unit 3
United States Nuclear Regulatory Commission to RA-09-017 Page 1 of 14 Crystal River Unit 3 Docket No. 50-302 / License No. DPR-72 Request for Exemption from Specific Provisions in 10 CFR 73.55 A. Background The NRC recently issued a Final Rule for revised security requirements in the Federal Register dated March 27, 2009. Pursuant to 10 CFR 73.55(a)(1) of the Final Rule, the revised security requirements in 10 CFR 73.55 must be implemented by March 31, 2010.
Florida Power Corporation (FPC), now doing business as Progress Energy Florida, Inc., has completed an extensive evaluation of these new requirements. This evaluation included a new comprehensive blast analysis for each of Progress Energy's four nuclear sites. The comprehensive blast analysis included consideration of equipment necessary to maintain the four required alarm station functions, consideration of explosives as allowed by the Design Basis Threat (DBT), and the research of construction records to determine exact wall construction. Additionally, as resolutions to identified vulnerabilities were evaluated, FPC's internal adversary team was consulted to assure that thorough resolutions were chosen.
As a result of this extensive evaluation, FPC has determined that the Crystal River Unit 3, (CR-3) site will be in compliance with the vast majority of the requirements in the Final Rule within the brief implementation period. Significant efforts are being expended to comply with the revised rule requirements in the Final Rule. These efforts include:
implementation of the new safety/security interface requirements, revising and implementing the Training and Qualification Plan in accordance with the new requirements, revising and implementing the new increased drill and exercise requirements, and resolving the major logistical challenges involved with the increased number of drills and exercises involving the adversary team and Multiple Integrated Laser Engagement System (MILES) gear. To address some of the logistical challenges, Progress Energy plans to centrally control the MILES gear and is voluntarily adopting the Department of Energy standards for issuance of the MILES gear for drills and exercises.
However, FPC has determined that implementation of four specific parts of the revised requirements will require additional time since they involve significant physical upgrades to the CR-3 security system. These changes are significant physical modifications that will benefit the CR-3 defensive strategy beyond the minimum requirements necessary to meet the
{
new security requirements.
Prior to the issuance of the Final Rule, Progress Energy had embarked on several significant security improvement initiatives to enhance the fleet's protective strategy, replace aging security equipment, and standardize security systems across the company's four nuclear
United States Nuclear Regulatory Commission to RA-09-017 Page 2 of 14 sites. At CR-3, this involves upgrading the firing range, installing additional {
} and replacing the intrusion detection system.
Another major security project that is planned is the expansion of the Protected Area (PA) to include a new dry fuel storage facility. These projects are not directly associated with the Final Rule, but are integral considerations into the decisions on how best to meet the Final Rule.
Upon review of the Final Rule, FPC identified four projects necessary to achieve compliance with the Final Rule. These projects are:
Projects 1, 2, and 3, involve significant modifications which, once completed, will provide a robust defensive posture beyond that which would be achieved through only relocating the existing IDS equipment. Project 4 will ensure that a margin of safety is maintained during single act scenarios.
B. Proposed Exemptions FPC requests exemptions, from the implementation date only, for the four items listed below. FPC will maintain the current CR-3 site protective strategy in accordance with the current Physical Security Plan. The current CR-3 site protective strategy has been approved by the NRC staff as providing a high assurance for the protection of the facility and public from the effects of radiological sabotage. Accordingly, the requested exemptions to defer compliance with provisions of 10 CFR 73.55 until November 15, 2010, and December 15, 2010, respectively, "will not endanger life or property or the common defense and security, and are otherwise in the public interest. "
Item 1
United States Nuclear Regulatory Commission to RA-09-017 Page 3 of 14 Item 2
United States Nuclear Regulatory Commission to RA-09-017 Page 4 of 14 Item 3 Item 4
United States Nuclear Regulatory Commission to RA-09-017 Page 5 of 14 C. Basis for Exemptions FPC is seeking exemptions from the March 31, 2010, compliance date to November 15, 2010, and December 15, 2010, for provisions listed in 10 CFR 73.55 as discussed in Section B. CR-3 management has approved the plan to construct a building addition, install the new backup power system, and relocate the IDS. These projects include several significant plant modifications:
United States Nuclear Regulatory Commission to RA-09-017 Page 6 of 14 A schedule for these projects is summarized in Table 1 below which shows critical milestones.
These plant modifications are significant in scope involving the construction of new facilities, extensive design and procurement efforts, and work with high voltage cabling and the personnel safety risk associated with such work. These modifications warrant a thorough review of the safety-security interface and must be coordinated with the steam generator replacement outage. All of these efforts require careful design, planning, procurement, and implementation efforts as discussed below.
The steam generator replacement outage, currently underway at CR-3, is the largest outage in CR-3's history and involves a much greater scope of work and number of workers than a normal refueling outage. Over 3000 supplemental workers are supporting the refueling outage. In addition to the steam generators, other large components are being replaced during this extended outage (e.g., moisture separator reheaters, large heat exchangers) requiring the movement of extremely heavy loads within the PA. Major work is also being done in support of the upcoming extended power uprate. Due to CR-3's small footprint, logistical challenges abound for the movement of personnel and materials into and out of the protected area. Additionally, {
} FPC believes that it is important, during this high activity period, to maintain personnel focus on outage activities to assure a safe and secure outage and defer physical work on the security upgrades until after the refueling outage is completed.
Design work has begun for the modifications; however, the.designs are currently in the early stages. Therefore, there are many details that have yet to be carefully worked out to support procurement, construction, and operation. The selection of the engineering firm is complete and the detailed design package for these projects is in progress. FPC has expedited the processes to this point by sole sourcing the blast analysis, conceptual design work, and
United States Nuclear Regulatory Commission to RA-09-017 Page 7 of 14 detailed design work, thus eliminating the time that would have been required to move through the competitive bidding process.
Item 1 Item 1 involves the installation of new IDS equipment {
} Additional time beyond the March 31, 2010, compliance date is needed to design, procure, construct and test the new intrusion detection system. This project depends on several supporting projects being completed, {
The presence of the underground interferences further complicates the design and construction of an already complex project.
CR-3 sits on top of an engineered "berm" that was built to protect the plant from flooding.
The "berm" is protected from erosion by concrete wave steps. Design and construction is further complicated due to the "berm" and concrete "wave steps." Special consideration must be taken during the design and construction phases to assure that the excavation and trenching does not degrade the "berm" and "wave steps" reducing their effectiveness in flood protection and erosion control. Similarly, mounting camera or fence poles on the
"'wave steps" must also be given special consideration during the design and construction phases.
Approximately five months are needed to reach the 70 percent complete design point at
United States Nuclear Regulatory Commission to RA-09-017 Page 8 of 14 which time construction can begin to relocate {
} and start the necessary excavation and trenching for the necessary cable runs. Procurement activities will run in parallel with the 70 percent design phase activities as design information becomes available to support procurement.
New power and data cables must be routed to each IDS zone and {
}. Routing of the new power and data cables will require the installation of new duct banks which involves excavation and trenching within the PA. Excavation and trenching within the PA cannot begin, due to logistical reasons (e.g., personnel and material movement), until the steam generator replacement outage is completed. Excavation and trenching in the PA is a slow process which typically involves hand excavating the surface and then vacuuming away the loose dirt to prevent the inadvertent severance of underground power, communications, and piping systems that could disrupt plant operations or security systems. Excavation and trenching are further complicated due to the "berm" and "wave steps" as discussed above. Excavation and trenching must be performed in a very controlled manner in and around the PA and requires significant time to complete. Additionally, this work must be coordinated as to not disrupt normal plant operations. Approximately four months are necessary to complete the excavation and trenching, install the necessary duct banks, and route the necessary cabling to support the new IDS and {
}
Once the necessary cables are routed to the new and relocated equipment, tie-in of the new and relocated equipment can begin. Tie-in of the equipment must be carefully planned and done in a way that minimizes disruptions to the operating security systems. Final tie-in and acceptance testing cannot take place until {
} IDS and {
} integrated acceptance testing will require approximately one month once {
} Compliance with Items 1 and 2 will be achieved at the completion of the integrated acceptance testing.
Based on industry operating experience, FPC believes that the detection capabilities of the new system are superior (e.g.,
fewer false and nuisance alarms) to the existing system and will require less maintenance.
Superior intrusion detection capabilities combined with lower maintenance will result in a more robust IDS at CR-3.
Item 2
United States Nuclear Regulatory Commission to RA-09-017 Page 9 of 14 Item 3 The new {
} building addition will be constructed of reinforced concrete in a way that will withstand a single act and be located away from the PA barrier. Substantial time is needed to complete the design to the point where building construction can begin. This includes not only the design of the new building addition, but also the design of {
} These designs must be integrated to assure that the new building addition can adequately support the {
} that will be located in the new building addition.
The design of the new building addition must include evaluation of underground interferences and the condition of connecting duct banks and conduit. Underground interferences such as underground power, communications, and piping systems that could disrupt plant operations will first have to be relocated from the area before construction can proceed. Further complicating the design and construction is the "berm" upon which CR-3 sits. A reinforced structure like this must have a solid foundation and engineering practices require a ground compaction study. Significant remediation was required for a similar structure nearby.
Design of the new building addition and design of {
} will proceed in parallel.
Approximately three and one-half months are necessary to reach the 30 percent design complete phase before procurement of the required construction materials can begin.
Construction of the new building addition will begin shortly thereafter and run concurrent with the final design of the new building addition.
The construction of this new {
} building addition inside the PA is a significant construction project. Due to blast considerations, the structure must be hardened and connected to existing electrical duct bank via underground connections. It will be located
United States Nuclear Regulatory Commission to RA-09-017 Page 10 of 14 inside the very compact CR-3 protected area {
} therefore, construction must be carefully coordinated to not impact emergency ingress/egress or normal plant operations. Approximately five months are necessary to complete the new building addition.
Approximately one additional month will be required to complete the integrated testing of the new IDS and {
} Compliance with Items 1 and 2 will be achieved at the completion of the integrated acceptance testing.
Item 4 See Item 3 for the bases for the time necessary to complete the new building addition and install {
}
United States Nuclear Regulatory Commission to RA-09-017 Page 11 of 14 Summary As indicated above, FPC is expending a great deal of effort in the design and planning phases of these projects to ensure a sound safety-security interface.
- Operating experience from the implementation of previous security orders has shown that decisions made within a compressed schedule to meet an aggressive deadline may meet the intent of the regulation, but since there is not adequate time to thoroughly research and evaluate all available options and considerations, they often create unintended consequences that have long-term adverse impacts on the site.
Additional time for design and implementation will help to avoid adverse consequences associated with these projects.
- The sequencing of many activities within a compressed time frame presents a number of challenges. Many activities have to be completed in series with each other while other activities can be accomplished in parallel. Additional time will provide for better planning and execution of the plan to better assure personnel safety and a sound safety-security interface throughout the construction portion of the project.
These modifications will provide several long term security benefits for CR-3:
FPC believes that the additional time necessary to complete this project is warranted based on the strengthened security posture that will be achieved through the implementation of these projects.
FPC believes that the significant scope of the modifications and the time necessary to safely construct and test the modifications justify an exemption to the March 31, 2010, compliance date of the Final Rule. Therefore, FPC believes that our actions are in the best interest of protecting public health and safety through the security changes that will be instituted.
D. Environmental Assessment Florida Power Corporation (FPC), now doing business as Progress Energy Florida, Inc., is requesting an exemption for Crystal River Unit 3, (CR-3), in accordance with 10 CFR 73.5,
United States Nuclear Regulatory Commission to RA-09-017 Page 12 of 14 "Specific exemptions." The requested exemption would defer the compliance date from March 31, 2010, as specified in 10 CFR 73.55(a)(1), to November 15, 2010, and December 15, 2010, for specific provisions of 10 CFR 73.55. The proposed action is needed to allow additional time for the design and installation of security modifications that are expected to provide long term benefits in security posture and capabilities. In lieu of full compliance with the four provisions of 10 CFR 73.55, as revised on March 27, 2009, FPC will maintain the current CR-3 site protective strategy in accordance with the current Physical Security Plan. The current CR-3, site protective strategy has been approved by the NRC staff as providing a high assurance for the protection of the facility and public from the effects of radiological sabotage.
Deferral of compliance from March 31, 2010, to November 15, 2010, and December 15, 2010, for specific provisions of 10 CFR 73.55 is a compliance date change only and, therefore, does not result in any physical changes to structures, systems, and components (SSCs) or land use at CR-3. Therefore, the deferral of the compliance date does not involve:
" any change to the types, characteristics, or quantities of non-radiological effluents discharged to the environment.
" any changes to liquid radioactive effluents discharged to the environment.
" any changes to gaseous radioactive effluents discharged to the environment.
" any change in the type or quantity of solid radioactive waste generated.
" any change in occupational dose under normal or Design Basis Accident (DBA) conditions.
- any change in the public dose under normal or DBA accident conditions.
- any land disturbance.
Conclusion There is no significant radiological environmental impact associated with the proposed exemption. The proposed exemption will not affect any historical sites nor will it affect non-radiological plant effluents.
United States Nuclear Regulatory Commission to RA-09-017 Page 13 of 14 Table 1: Project Schedule Milestones*
- The dates and sequences provided in this milestone schedule are best estimates based on information available at the time the schedule was developed and may change as designs are finalized and construction proceeds.
Therefore, these dates and sequences are not considered to be regulatory commitments.
United States Nuclear Regulatory Commission to RA-09-017 Page 14 of 14 Figure 1: Crystal River Unit 3 Protected Area