ML102380401
| ML102380401 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/24/2010 |
| From: | St.Onge R Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC ME3022, TAC ME3032 | |
| Download: ML102380401 (21) | |
Text
Richard J. St. Onge JSOUTHERN EDISON CALIFORNIA An EDISON INTERNATIONAL Company Director Nuclear Regulatory Affairs 10 CFR 73.5 August 24, 2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
SUBJECT:
Docket Nos. 50-361 and 50-362 Request for Exemption from Physical Security Requirements San Onofre Nuclear Generating Station, Units 2 and 3
References:
(A) SCE (A. E. Scherer) letter to NRC dated December 13, 2009,
Subject:
Request for Exemption from Physical Security Requirements, San Onofre Nuclear Generation Station, Units 2 and 3 (B) NRC (J. R. Hall) letter to SCE (R. T. Ridenoure) dated March 16, 2010, subject: San Onofre Nuclear Generating Station, Units 2 and 3 - Exemption from the Requirements of 10 CFR Part 73, Section 55 (TAC Nos. ME3022 and ME3032)
Dear Sir or Madam:
In accordance with the requirements of 10 CFR 73.5, Southern California Edison (SCE) hereby requests the Nuclear Regulatory Commission (NRC) to approve an exemption from specific requirements of 10 CFR 73, "Physical Protection of Plants and Materials",
for the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3, by extending the due date for the implementation of certain measures.
The NRC issued a Final Rule for security requirements in the Federal Register dated March 27, 2009. Pursuant to the Final Rule, upgrades to meet the new security requirements must be implemented by March 31, 2010. In Reference (A), SCE requested additional time to implement specific upgrades to meet the new requirements. The NRC approved the requested exemption in Reference (B). SCE has determined that additional time will be needed, beyond the currently approved exemption dates, to complete the specific upgrades described in Reference (A).
Enclosure 1 to this letter describes: the specific new requirements of the Final Rule for which an exemption from the due date is requested; the existing capability of the P.O. Box 128 San Clemente, CA 92674
Document Control Desk August 24, 2010 SONGS security system with respect to those requirements; the upgrades being performed to meet those requirements, including additional work beyond that described in Reference (A); the dates for completion of the upgrades; and a description of how a high level of assurance will be maintained until the upgrades are complete. to this letter contains supporting information for the requested exemption, including detailed schedules. to this letter contains an environmental assessment of the requested exemption.
SCE is requesting, for a limited scope of upgrades, that the implementation due dates be extended to the dates identified in Enclosure 1. Pending NRC approval, SCE commits to the new implementation dates identified in Enclosure 1.
A Safeguards Information version of this letter was signed and submitted to the NRC on this date. Safeguards and Security-Related Information has been removed from this letter and it may be made available for public disclosure.
In accordance with 10 CFR 73.5, this exemption is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest.
SCE requests approval of this exemption by October 31, 2010. The exemption is requested to be effective upon issuance.
If you should have any questions regarding this submittal, please contact Mr. S. D. Root at 949-368-6480.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on A )0, Richard J. St. Onge
Document Control Desk August 24, 2010 Enclosures (3) cc: (with Enclosures)
R. Hall, NRC Project Manager, San Onofre Units 2 & 3 E. E. Collins, Regional Administrator, NRC Region IV G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 & 3
ENCLOSURE 1 San Onofre Nuclear Generating Station, Units 2 and 3 Request for Exemption from Physical Security Requirements
ENCLOSURE 1 San Onofre Nuclear Generating Station Units 2 and 3 Request for Exemption from Physical Security Requirements
References:
(A) SCE (A. E. Scherer) letter to NRC dated December 13, 2009,
Subject:
Request for Exemption from Physical Security Requirements, San Onofre Nuclear Generation Station, Units 2 and 3 (B) NRC (J. R. Hall) letter to SCE (R. T. Ridenoure) dated March 16, 2010, subject: San Onofre Nuclear Generating Station, Units 2 and 3 - Exemption from the Requirements of 10 CFR Part 73, Section 55 (TAC Nos. ME3022 and ME3032)
A. Specific Requirements of Part 73 for which an Exemption is Requested Southern California Edison (SCE) requests an exemption, from the March 31, 2010 implementation due date only, for implementing two specific requirements of 10 CFR 73.55 at San Onofre Nuclear Generating Station (SONGS):
- 1. [ ... I Specific requirement that cannot be met by March 31, 2010: [ ...
Reference (A) previously requested and Reference (B) approved moving the SONGS due date for this requirement to [ ... ].
Proposed implementation due date: SCE requests that the SONGS implementation due date for this requirement be extended to [ ... ].
2 . [ ... ]
Specific requirement that cannot be met by March 31, 2010: [ ...
Reference (A) previously requested and Reference (B) approved moving the SONGS due date for this requirement to [ ...
Proposed implementation due date: SCE requests that the SONGS implementation due date for this requirement be extended to [ ... ].
B. Existing Capability of SONGS Security System The existing capability of [ ... ] are described in Enclosure 1 to Reference (A).
C. Upgrades Being Performed to Meet Above Requirements
- 1. [ ... I 1
ENCLOSURE 1 San Onofre Nuclear Generating Station Units 2 and 3 Request for Exemption from Physical Security Requirements The [ ... ] modifications are not critical path and do not affect the completion date for [ .. ]. The critical path work remains [ ... ] as described in Section C.2 below.
2 . [ ...
As described in Enclosure 2 Attachment 1 to this Exemption Request, there have been significant schedule impacts to this work, for which SCE has implemented recovery actions. However, as shown in Enclosure 2 Attachments 1 and 2 to this Exemption Request, SCE cannot complete [ ... ] until after the current [ ... ]
commitment date, even with the recovery actions.
As described in Enclosure 2 Attachment 1, SCE has developed the high confidence schedule for completing this work shown in Enclosure 2 Attachment 3, based on the recovery schedule plus margins to allow for uncertainty in the scope and schedule of the remaining work. Based on this schedule, SCE expects to complete [ ... ].
SCE commits to complete this work [ ... ].
- 3. [ ... ]
As described in Enclosure 2 Attachment 1 to this Exemption Request, there have been significant schedule impacts to this work, for which SCE has implemented recovery actions. However, as shown in Enclosure 2 Attachments 1 and 2 to this Exemption Request, SCE cannot complete [ ... ] until after the current [ ...
commitment date, even with the recovery actions.
As described in Enclosure 2 Attachment 1, SCE has developed the high confidence schedule for completing this work shown in Enclosure 2 Attachment 3, based on the recovery schedule plus margins to allow for uncertainty in the scope and schedule of the remaining work. Based on this schedule, SCE expects to complete [ ...
SCE commits to complete this work [ ... ].
D. How High Assurance Will Be Maintained High assurance of public health and safety and common defense and security will be maintained while the above upgrades are being completed, as described below:
- 1. [ ...
- 2. [ ...
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ENCLOSURE 2 San Onofre Nuclear Generating Station, Units 2 and 3 Supporting Information for Exemption from Physical Security Requirements
ENCLOSURE2 contains the following supporting information for the requested exemption from Physical Security Requirements:
Attachment 1 - Summary of Schedule Impacts and Recovery Actions Attachment 2 - Recovery Schedule Attachment 3 - High Confidence Schedule 1
ENCLOSURE 2 Attachment 1 Summary of Schedule Impacts and Recovery Actions 2
ENCLOSURE 2 Attachment 1 Summary of Schedule Impacts and ReCovery Actions
Reference:
(A) SCE (A. E. Scherer) letter to NRC dated December 13, 2009,
Subject:
Request for Exemption from Physical Security Requirements, San Onofre Nuclear Generation Station, Units 2 and 3
- 1. Impacts to Reference (A) Implementation Schedule The overall implementation schedule has been extended beyond that anticipated at the time of the Reference (A) exemption request as a result of the following.
1.1. The project schedule at the time of the Reference (A) exemption request underestimated the engineering and construction complexity and time required for the original scopes of work for [ ..
1.2. The [ ... ] scope was significantly increased to provide a more robust design with respect to [ ... ]. This delayed completion of [ ... ] This requires engineering, procurement, work order planning and construction for the following additional work: [ ... ]
1.3. As the design developed, additional work not in the original schedule was identified. This additional work delayed completion of the work for [ ... ]. The increases include: [ ... ]
1.4. Availability of critical path resources was less than assumed in the first 3 months of 2010 due to unexpected impacts. This delayed completion of the work for [
... ]. The impacts included:
1.4.1. The Unit 2 Steam Generator Replacement (SGR) outage continued into April 2010 (3 months longer than planned), reducing the availability of Station resources to develop the Engineering Change Packages (ECPs) for
[ ... ].
1.4.2. ISFSI modifications to achieve compliance with the new requirements of 10 CFR 73.55 [ ... ] were not identified until January 2010 and needed to be implemented by March 31, 2010, reducing availability of Station resources for [ ... ].
1.5. There have been significant material/supply delays. This delayed completion of the work for[ ...
1.5.1. A 4 week delay in new equipment delivery [ ... ] resulted from delay in completing submittal, review and approval of the vendor documents. (This delay is included in the recovery schedule provided as Attachment 2 to this Enclosure.)
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ENCLOSURE 2 Attachment 1 1.5.2. An additional 6 week delay in new equipment delivery [ ... ] is projected as a result of problems identified during factory acceptance testing.
Resolution of these problems requires [ ... ]. (This delay was identified after the recovery schedule was developed and is therefore not included in the schedule provided as Attachment 2 to this Enclosure.)
- 2. Recovery Schedule for Implementation SCE developed a recovery schedule for implementation based on the currently identified scope of work, schedule recovery actions, and more detailed schedule inputs (including work hour limitations) for construction. The Project team is currently working to the recovery schedule. A snapshot of the recovery schedule is provided as to this Enclosure.
2.1. Schedule recovery actions 2.1.1. The Project team has commenced using the Outage Control Center (OCC) model. This has centralized the work groups to improve communication and work flow, and to bring site awareness to the project.
2.1.2. Construction is working 2 shifts with dedicated teams [ ... ]. SCE currently expects to continue double shifts through completion of [ ... ].
2.1.3. Engineering is tracking ECPs and due dates at the individual drawing level, to expedite work order planning and construction preparation.
2.2. More schedule detail 2.2.1. Ten of 13 ECPs have been issued for the [ ... ] scope of work.
Construction durations for this portion of the schedule are based on the detailed work orders generated by planners from the issued ECPs [ ... ].
2.2.2. Engineering, procurement and construction durations for the remaining portion of the work [ ... ] are based on design information not available in December 2009.
2.3. Scope prioritization Some of the modifications that SCE is making are not required to comply with 10 CFR 73.55, and are being moved later in the schedule to allow focus on the compliance-related work activities:
2.3.1. The integration of [ ... ] into the security computer system may be deferred until after [ ... ]. This work must be completed prior to [ ... ].
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ENCLOSURE 2 Attachment 1 2.3.2. The upgrade to the cooling system for [ ... ] may be deferred until after the commitment date for [ ... ]. Compensatory measures (e.g., temporary fans) can be implemented should conditions warrant additional cooling.
- 3. High Confidence Schedule for Implementation SCE developed a high confidence schedule for implementation, in order to provide a firm basis for new commitment dates. The high confidence schedule is based on the recovery schedule, plus margins to allow for uncertainties in the scope and schedule of the remaining work. The high confidence schedule, showing the margins, is provided as Attachment 3 to this Enclosure.
3.1.[ ...
The scope for this work is known with high confidence, based on the issued status the ECPs. However, there are significant uncertainties in the schedule for this work, including the following:
3.1.1. Resolution of the factory acceptance test issues for [ ... ] is still ongoing.
The actual time required for trouble shooting and system changes could be substantially longer than currently projected (e.g., if the system changes involve[ ... ]).
3.1.2. The [ ... ] design has been based on component specifications [ ... ]
vs. actual [ ... ]. If the actual [ ... ] is more than design, a large number of [ ... ] may need to be added to the design and installed.
3.1.3. Any integration problems between plant systems and the new [ ... ] can only be identified and resolved after the new equipment is connected to plant systems and testing begins.
3.1.4. Rework and emergent material needs have the potential to impact the schedule.
3.1.5. Emergent operating, refueling and SGR outage issues could impact the availability of qualified resources [ ... ] and movement of delivered material and equipment into the SONGS Protected Area.
[ .... I 3.2.[ ... ]
The schedule for this work is known with lesser confidence, because [ ... ] is still in service and unavailable for detailed walkdowns and examinations. [ ... ].
Uncertainties in the duration of this work include:
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ENCLOSURE 2 Attachment 1 3.2.1. Detailed estimates of resource requirements and durations cannot be made until the work orders are written. The work orders for [ ... ] cannot be written until the ECPs are issued. Engineering for [ ... ] follows the engineering for [ ... [ which is nearing completion.
3.2.2. Rework and emergent material needs have the potential to impact the schedule.
3.2.3. Emergent operating, refueling and SGR outage issues could impact the availability of qualified resources [ ... ] and movement of delivered material and equipment into the SONGS Protected Area.
[I... ]
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ENCLOSURE 2 Attachment 2 Recovery Schedule 7
ENCLOSURE 2 Attachment 2
[ ... I 8
ENCLOSURE2 Attachment 3 High Confidence Schedule 9
ENCLOSURE 2 Attachment 3
[ ... I 10
ENCLOSURE 3 San Onofre Nuclear Generating Station, Units 2 and 3 Environmental Assessment for Exemption from Physical Security Requirements
ENCLOSURE3 San Onofre Nuclear Generating Station, Units 2 and 3 Environmental Assessment for Exemption from Physical Security Requirements
- 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.
SCE 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 the implementation schedule for security changes required by 10 CFR 73.55. These security changes will not result in changes to the design basis requirements for the structures, systems, and components (SSCs) at the San Onofre Nuclear Generating Station (SONGS) 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 as a result of the proposed activity 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.
SCE Response There are no expected changes to the liquid radioactive effluents discharged as a result of these proposed exemptions. The proposed exemptions will not result in any different quantity or change in isotopic composition for liquid radioactive discharges. These proposed exemptions will not result in changes to the design basis requirements for the SSCs at the SONGS that function to limit the release of liquid radiological effluents during and following postulated accidents. There will be no change in the SSCs or plant procedures that govern the operation of the SSCs used to collect, transfer, process, discharge, or control liquid radioactive effluents from SONGS. All SSCs associated with limiting the release of liquid radiological effluents will therefore continue to be able to perform their functions. Liquid radioactive releases will continue to be controlled well below regulatory limits. 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.
SCE 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 San Onofre Nuclear Generating Station, Units 2 and 3 Environmental Assessment for Exemption from Physical Security Requirements
- 4. Describe any change in the type or quantity of solid radioactive waste generated as a result of the proposed exemptions.
SCE Response These proposed exemptions will not result in changes to the design basis requirements for the structures, systems, and components (SSCs) at the SONGS that function to limit the release of solid waste during and following postulated accidents. All SSCs associated with collecting, processing, and controlling 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.
SONGS has a radiation survey program and procedures to handle any contaminated excavated soil that is inside the protected area or radiation control areas. Any contaminated solids, including debris and dirt, will be handled in accordance with plant procedures and disposed of to meet all regulatory requirements.
- 5. What is the expected change in occupational dose as a result of the proposed exemptions under normal and design basis accident conditions?
SCE Response No change in occupational dose is expected during normal or design basis accident conditions as a result of the proposed exemptions. The plant will continue to be operated using existing procedures and programs. 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?
SCE Response Dose to the public will not be affected 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.
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ENCLOSURE 3 San Onofre Nuclear Generating Station, Units 2 and 3 Environmental Assessment for Exemption from Physical Security Requirements
- 7. What is the impact to land disturbance for the proposed exemptions?
SCE Response The proposed exemptions concern the implementation schedule for specific security changes required by 10 CFR 73.55. These specific security changes will be implemented within previously disturbed areas of the SONGS site that are not environmentally sensitive.
A SONGS environmental survey of sensitive areas has previously been completed and environmentally sensitive areas have been identified. SONGS procedure S0123-IX-2.9 addresses land disturbance, including endangered or threatened plant, habitat, and archaeological assessments.
==
Conclusion:==
There is no significant radiological environmental impact associated with the proposed exemptions at SONGS. These proposed changes will not affect any historical sites nor will they affect non-radiological plant effluents.
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