L-PI-09-124, Request for Exemption from Physical Security Requirements

Request for Exemption from Physical Security Requirements

ML100050096
Person / Time
Site:	Prairie Island
Issue date:	11/30/2009
From:	Schimmel M Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-PI-09-124
Download: ML100050096 (12)

Text

Xcel EnergyO November 30, 2009 L-PI-09-124 10 CFR 73.5 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Request For Exemption from Physical Security Requirements In accordance with the requirements of 10 CFR 73.5, Northern States Power Company, a Minnesota Corporation (NSPM).requests the Nuclear. Regulatory Commission (NRC) approve an exemption from specific requirements of 10 CFR Part 73, "Physical Protection of Plants and Materials" for the Prairie Island Nuclear Generating Plant Units 1 and 2 (PINGP) by-extending the deadline for the implementation of new security requirements issued by NRC *in a Final Rule dated March 27, 2009 (74 FR 13926).

Pursuant to the Final Rule, the new security requirements must be implemented by March 31, 2010. NSPM has :evaluated these new requirements and determined that many can be implemented by the required date. However, specific parts of the new

'requirements will require more time to implement since they involve significant upgrades to the security system. These changes involve physical modifications to include [ ].

Enclosure 1 requests exemption from certain 'physical security requirements contained S- 10 in CFR 73.55 while Enclosure 2 provides the basis for the proposed exemption.

Enclosure 3 includes an Environmental Assessment.

NSPM is requesting an extension from the March 31, 2010, implementation date to

• June 30, 201.1, for these specific' requirements based on the time typically required to design and construct modifications of this scope, considering impediments to construction such as'planned refueling outages at both Units 1 and 2 and winter weather conditions as shown in Tables I and-2 of Enclosure 2. NSPM's current security program and the new security requirements that will be implemented by March 31, 2010, will provide continued assurance of public health and safety and common defense and security.

NSPM requests approval of this exemption, request by December 1, 2009 to otherwise allow time to' prepare and implement, compensatory measures if the exemption is not granted.The proposed exemptions are requested to be effective upon issuance.

A Security-Related version of-this letter,, L-PI-09-107, was signed and submitted to the NRC.

'1717 Wakonade Drive East

• Welch, Minnesota 55089-9642 Telephone: 651.388.1121 10

Document Control Desk Page 2 Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

-I declare under penalty of perjury that the foregoing is true and correct.

Executed on November 30, 2009.

Mark A. Schimmel Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power - Minnesota, Enclosures (3) cc: Administrator, Region III, USNRC Project Manager, Prairie Island Nuclear Generating Plant, USNRC, NRR Resident Inspector, Prairie Island Nuclear Generating Plant, USNRC

Enclosure 1 Request for Exemption from Physical Security Requirements

'A. Background The NRC issued a Final Rule for new security requirements in the Federal Register dated March 27, 2009. Per the Final Rule, new security requirements must be implemented by March 31, 2010. Northern States Power Company, a Minnesota

• corporation (NSPM) has evaluated these new requirements and determined that many can be implemented by the required date. However, NSPM has also determined that implementation of specific requirements will require additional time beyond March 31, 2010. NSPM has approved. a plan to [ ]. The study phase hasbeen completed and the design phase[- ] has begun. Construction will be completed by June 30, 2011.

B. Prairie Island Nuclear Generating Plant (PINGP) Security System Upgrade PINGP is a dual unit plant located in Goodhue County, Minnesota [ ].

Due to the-amount of design, procurement and installation activities and in consideration of impediments to construction such as planned refueling outages at both Units 1 and 2 and winter weather conditions as shown in Tables 1 and 2 of Enclosure 2, completion of some of the newrequirements contained in 10 CFR 73.55 will require additional time beyond March 31, 2010. [ ].

With approvalof-this exemption request, the Part 73 provisions required to be implemented.by March 3,1, 2010 will be completed except for the proposed exemptions S -described in Section C below. These items, subject to the request for an exemption, will be implemented by June.30, 2011. PINGP will then be in full compliance with the Final Rule.

C. Proposed Exemptions NSPM.:requests an exemption, from the implementation deadline only, for the three items listed in this section.- PINGP's current security program and the new requirements "that will be implemented by March 31, 2010,0;will provide continued assurance of public health:and safetyandcommon defense and security. Accordingly, the requested exemption is authorized by law and will not endanger life or property or the common defense and security in accordance with 10 CFR 73.5.

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Enclosure 1 Item 1 Recqulation

[I Issue

[I Item 2 Recqulation

[I I Issue

[I Page 2 of 3

Enclosure 1 Item 3 Regulation I[ ]

Issue

[I]

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Enclosure 2 Basis for Proposed Exemption Northern States Power Company, a Minnesota corporation (NSPM) is requesting an exemption from [. ]. The basis for requesting an exemption of the March 31, 2010, date to June 30, 2011, is based on completion of [ ]to address the new Part 73 rule requirements.

Using established processes, the duration (study, design, construction, testing, turnover) of a project of this magnitude is typically 18 - 24 months. This timeframe is further challenged by resources and the logistical impacts of plant refueling outages at both Units 1 and 2 and severe cold weather conditions. NSPM is continuing efforts to implement the remaining new Part 73 requirements identified in the March 27, 2009, Federal Register Notice (Final Rule) and associated Regulatory Guides issued in July 2009 by March 31, 2010.

The following is a more detailed description of the work activities associated with the physical modifications.

Physical Modifications Overview The scope of the physical modifications includes: [ ]

Tables 1 and 2 provide the Project Milestone Schedule for the physical modifications associated with the specific exemptions requested. These milestones represent a schedule driven to comply with the new Part 73 requirements. The milestone schedule

-has been developed based on current information and anticipated impediments to construction such as planned refueling outages at both Units 1 and 2 and winter weather conditions which may impair construction due to frozen ground or extreme cold that creates personnel safety issues.

Figure 1 depicts [ ].

Page 1 of 4 Table 1 [ ]

Page 2 of 4 Table 2 [ ]

Page 3 of 4 Figure 1 [

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Enclosure 3 Environmental Assessment

1. Describe any change to the types, characteristics, or quantities of non-radiological effluents discharged to the environment as a result of the proposed exemptions.

NSPM Response There are no expected changes in the types, characteristics, or quantities of non-radiological effluents discharged to the environment associated with the proposed exemptions. This application is associated with implementation of security changes.

These security changes will not result in changes to the design basis requirements for the structures, systems, and components (SSCs) at the Prairie Island Nuclear Generating Plant (PINGP) that function to limit the release of non-radiological effluents during and following postulated accidents. All the SSCs associated with limiting the release of offsite non-radiological effluents will therefore continue to be able to perform their functions. As a result, there is no significant non-radiological effluent impact. There are no materials or chemicals introduced into the plant that could affect the characteristics or types of non-radiological effluents. In addition, the method of operation of non-radiological waste systems will not be affected by these proposed exemptions.

2. Describe any changes to liquid radioactive effluents discharged as a result of the proposed exemptions.

NSPM Response There are no expected changes to the liquid radioactive effluents discharged as a result of these proposed exemptions. The proposed exemptions will not interact to produce any different quantity or type of radioactive material in the reactor coolant system.

These proposed exemptions will not result in changes to the design basis requirements for the SSCs at the PINGP that function to limit the release of liquid radiological effluents during and following postulated accidents. All SSCs associated with limiting the release of liquid radiological effluents will therefore continue to be able to perform their functions. As a result, there is no significant liquid radiological effluent impact.

3. Describe any changes to gaseous radioactive effluents discharged as a result of the proposed exemptions.

NSPM Response For the same reasons as described in number 2 above, these proposed exemptions would have no affects on-the characteristics of gaseous radioactive effluents.

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Enclosure 3

4. Describe any change in the type or quantity of solid radioactive waste generated as a result of the proposed exemptions.

NSPM Response These proposed exemptions will not result in changes to the design basis requirements for thestructures, systems, and components (SSCs) at the PINGP that function to limit the release of solid waste during and following postulated accidents. All SSCs associated with limiting the release of solid radioactive waste will therefore continue to be able to perform their function. Radiation surveys will be performed in accordance with plant radiation protection procedures on excavated dirt that could be contaminated, such as inside the protected area or radiation control areas, that will be disposed of offsite. Any contaminated dirt will be handled in accordance with plant procedures.

PINGP has a radiation survey program and procedures to handle any contaminated excavated soil that is inside the protected area or radiation control areas.

5. What is the expected change in occupational dose as a result of the proposed exemptions under normal and design basis accident conditions?

NSPM Response Under normal power operation there would be no expected radiological impact on the workforce. There are no other expected changes in normal occupational operating doses. Control room dose is not impacted by the proposed exemptions and would not impact occupational dose.

6. What is the expected change in the public dose as a result of the proposed exemptions under normal and Design Basis Accident (DBA) conditions?

NSPM Response Dose to the public will not be changed by the proposed exemptions during normal operations or DBA conditions. As noted in items 2, 3 and 4 above there is no basis to

-contemplate an increased source of liquid, gaseous or solid radiological effluents that could contribute to increased public exposure during normal operations and DBA conditions. The proposed security changes-do not impact systems used during normal operation nor systems used to detect or mitigate a DBA.

7. What is the impact to land disturbance for the proposed exemptions?

NSPM Response Proposed exemptions involve the [ ]. Land disturbance is considered when performing environmental impact evaluations. Environmental impact evaluations will be completed as required.

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Enclosure 3 A PINGP environmental survey of sensitive areas has previously been completed and environmental sensitive areas have been identified. Procedures are in place to address land disturbance at PINGP. Provisions for dealing with the inadvertent discovery of significant subsurface archaeological deposits are part of the administrative control procedures at PINGP. In the event such deposits are encountered procedure FP-IH-EXC-01, "Excavation and Trenching Controls", states that should the excavation uncover potentially historic or archeological significant items the excavation will stop and the site Environmental Coordinator shall be contacted to evaluate the excavation site.

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Conclusion:==

There is no significant radiological environmental'impact associated with the proposed security changes at PINGP. These proposed changes will not affect any historical sites nor will they affect non-radiological plant effluents.

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