NRC 2010-0031, Request for Exemption from Specific 10CFR73 Requirements
| ML100600565 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 02/26/2010 |
| From: | Meyer L Nextera Energy, Point Beach |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML100690073 | List: |
| References | |
| NRC 2010-0031 | |
| Download: ML100600565 (7) | |
Text
SECURITY-RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 February 26,201 0 NRC 2010-0031 10 CFR 50.73 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units Iand 2 Dockets 50-266 and 50-301 Renewed License,Nos. DPR-24 and DPR-27 Reauest for Exemptionfrom Specific 10 CFR 73 Requirements Pursuant to 10 CFR 73.5, NextEra Energy Point Beach, LLC (NextEra) requests NRC approval of an exemption from specific requirements of 10 CFR 73, "Physical Protection of Plants and Materials," for Point Beach Nuclear Plant (PBNP) Units 1 and 2. The requested exemption would extend the date for implementation required by the new rule from March 31, 2010 to May 28,201 0.
The NRC issued a Final Rule for new security requirements in the Federal Register dated March 27, 2009 (74 FR 13962). Pursuant to the Final Rule, the new security requirements must be implemented by March 31, 2010. NextEra has evaluated these new requirements and determined that most can be implemented by the required date. However, specific parts of the new requirements will require more time to implement because of delays resulting from unforeseen circumstances such as adverse weather, material delivery and testing constraints.
NextEra has determined that its 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. 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.
Enclosure Iprovides technical information and justifications to support the exemption request. provides the Environmental Assessment for the exemption request as required by 10 CFR 51. Enclosure 3 provides a public version of the technical information and justifications contained in Enclosure Iwith the security-related information removed.
Enclosure I to this letter contains sensitive information.
Withhold from public disclosure under 10 CFR 2.390.
Upon removal of Enclosure I,this letter is not controlled.
NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241
SECURITY-RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 Document Control Desk Page 2 The information provided in Enclosure 1 is considered security-related information associated with physical protection of the NextEra operated facilities, as described in 10 CFR 2.390(d)(1).
Accordingly, NextEra requests that the information provided in Enclosure 1 be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390.
NextEra requests approval of this exemption by March 31, 2010 with the exemption effective upon issuance.
This submittal contains no new regulatory commitments or revisions to existing commitments.
If you have any questions or require additional information, please contact Mr. James Costedio at 9201755-7427.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on February 26,201 0.
Very truly yours, NextEra Energy Point Beach, LLC Enclosures cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear -Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC
ENCLOSURE 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 REQUEST FOR EXEMPTION FROM PHYSICAL SECURITY REQUIREMENTS 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 exemption.
There are no expected changes in the types, characteristics, or quantities of non-radiological effluents discharged to the environment associated with the proposed exemption. 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 Point Beach Nuclear Plant (PBNP) Unit 1 and 2, that function to limit the release of non-radiological effluents during and following postulated accidents. The SSCs associated with limiting the release of offsite non-radiological effluents will therefore continue to be able to perform their functions, and 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 this change.
- 2. Describe any changes to liquid radioactive effluents discharged as a result of the proposed exemption.
There are no expected changes to the liquid radioactive effluents discharged as a result of this exemption. The proposed security changes will not interact to produce any different quantity or type of radioactive material in the reactor coolant system. These security changes will not result in changes to the design basis requirements for the SSCs at PBNP Unit 1 and 2 that function to limit the release of liquid radiological effluents during and following postulated accidents. All the SSCs associated with limiting the release of liquid radiological effluents will therefore continue to be able to perform their functions, and 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 exemption.
There are no expected changes to the gaseous radioactive effluents discharged as a result of this exemption. The proposed security changes will not interact to produce any different quantity or type of radioactive material in the reactor coolant system. These security changes will not result in changes to the design basis requirements for the SSCs at PBNP Unit 1 and 2 that function to limit the release of gaseous radiological effluents during and following postulated accidents. All the SSCs associated with limiting the release of gaseous radiological effluents will therefore continue to be able to perform their functions, and as a Page 1 of 3
result, there is no significant gaseous radiological effluent impact.
- 4. Describe any change in the type or quantity of solid radioactive waste generated as a result of the proposed exemption.
There are no expected changes in the type or quantity of solid radioactive waste generated as a result of the proposed exemption. These security changes will not result in changes to the design basis requirements for the SSCs at PBNP Unit 1 and 2 that function to limit the release of solid waste during and following postulated accidents. All the 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 soil that could be contaminated, such as inside the protected area or radiation control areas, that will be disposed of offsite. Any contaminated soil will be handled in accordance with plant procedures. NextEra Energy Point Beach, LLC 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 exemption under normal and design basis accident conditions?
Under normal power operation there would be no expected radiological impact on either the workforce or the public. There are no other expected changes in normal occupational operating doses. Control room dose is not impacted by the proposed security changes and would not impact occupational dose.
- 6. What is the expected change in the public dose as a result of the proposed change under normal and design basis accidents (DBA) conditions?
Dose to the public will not be changed by the proposed security changes during normal operations. 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 and do not impact systems used to detect or mitigate a DBA.
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- 7. What is the impact to land disturbance for the proposed security changes?
Land disturbance is considered when performing environmental impact evaluations.
Non-radiological environmental impact evaluations will be performed as needed to support the proposed security changes.
Provisions for dealing with the inadvertent discovery of significant subsurface archaeological deposits and human remains are formalized in administrative procedures used by PBNP in the unlikely event such deposits and remains are encountered. The procedure states that should the excavation uncover potentially historic or archeological significant items, including human remains, the excavation will stop and corporate Environmental Affairs shall be contacted to evaluate the excavation site. None of the proposed security changes are located in areas that are known to have cultural or historical significance.
==
Conclusion:==
There is no significant radiological environmental impact associated with the proposed security changes at Point Beach Nuclear Plant, Unit 1 and 2. These proposed changes will not affect any historical sites nor will they affect non-radiological plant effluents.
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ENCLOSURE 3 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 REQUEST FOR EXEMPTION FROM PHYSICAL SECURITY REQUIREMENTS PUBLIC VERSION The NRC issued a Final Rule for new security requirements in the Federal Resister on March 27,2009, and these requirements must be implemented by March 31,2010. NextEra Energy Point Beach, LLC (NextEra) has evaluated these new requirements and determined that most can be implemented by the required date. However, NextEra also determined that implementation of certain requirements will require additional time beyond March 31, 2010.
This exemption request proposes to extend the implementation date as discussed in the subsequent sections to provide additional time to complete modifications [security-related information removed]. NextEra proposes to establish full compliance with the new requirements of 10 CFR 73
[security-related information removed].
- 1. Specific requirements that NextEra requires additional time to implement.
10 CFR 73.55 [security-related information removed]
- 2. Justification of the reasons NextEra requires additional time to implement the specific requirements.
Point Beach Nuclear Plant (PBNP) originally had a detailed schedule that met the March 31, 2010, compliance date. Based on the following factors, the margin that was initially reflected in the schedule for the security system upgrades has been reduced to the point where completion of all required implementation activities by March 31, 2010 is uncertain.
a) Adverse weather has delayed outdoor implementation activities, resulting in a loss of approximately one day of work per week. [security-related information removed]. These delays have resulted in the elimination of any margin the project schedule had contained to meet the March 31, 2010 compliance date. [security-related information removed]
b) Material delivery issues have resulted in delays in the implementation. [security-related information removed]
c) [security-related information removed].
d) [security-related information removed]
- 3. Technical information that supports NextEra's solution for meeting the requirement.
Securitv Svstem Uparade - Assessment
[security-related information removed]
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- 4. NextEra's proposed implementation schedule consistent with the scope of work to be conducted and the new compliance date requested.
[security-related information removed]
- 5. An evaluation of the impact that the additional time to implement the requirements will have on the effectiveness of the NextEra's overall physical protection program and protective strategy.
NextEra is in compliance with the security regulations currently in effect. The additional time will not impact the effectiveness of PBNP's overall physical protection program or protective strategy regarding current requirements. NextEra's current security program and the new security requirements that will be implemented by March 31, 2010 provide continued assurance of public safety and common defense and security.
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