RA-10-021, Exemptions Request from Physical Security Requirements

Exemptions Request from Physical Security Requirements

ML102770306
Person / Time
Site:	Robinson
Issue date:	09/30/2010
From:	Duncan R Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-10-021, TAC ME2816
Download: ML102770306 (2)

Text

Attachment 1 to this letter contains

~ Progress SECURITY-RELATED SECURJ[TY -RlELATED gess Energy INFORMATION -WITHHOLD lINlFORMAT[ON 10 CFR 10 CFR 73.5 73.5 UNDER 10 CFR UNJl)ER ClFR 2.390.

PO Box 1551 Upon removal of Attachment Attachment 1 4111 Fayetteville Street Mall 41 this letter is decontrolled.

decontrolled.

Raleigh Raleigh NC 27602 Serial: RA-10-021 September 30, September 2010 30,2010 United States Nuclear Regulatory Regulatory Commission Commission ATTENTION: Document Control Desk ATTENTION:

Washington, Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC ELECTRIC PLANT, UNIT UNIT NO.NO.22 DOCKET NO. 50-261 / LICENSE LICENSE NO. DPR-23 DPR-23 REQUEST FOR EXEMPTIONS FROM PHYSICAL SECURITY FOR EXEMPTIONS SECURITY REQUIREMENTS

REFERENCES:

1. Progress Energy letter from R. J. Duncan II to the Nuclear Nuclear Regulatory Regulatory Commission Commission Document Control Desk titled, Request for for Exemptions fromfrom Physical Security Physical Security Requirements," dated November 30,2009 Requirements," 30, 2009

2. Nuclear Nuclear Regulatory Commission letter from Tracy J. Orfto Orf to Eric McCartney titled, H. B. Robinson Steam Electric Plant, Unit No. 2 ~- Exemption Exemption From From the Requirements Requirements of 10 CFRCFR Part Part 73, 73, Section 73.55 (TAC (TAC No. ME2816),

ME2816), dated March 3, 3, 2010 2010 Ladies and Gentlemen:

In accordance accordance with the requirements requirements of 10 CFR 73.5, Carolina Power & Light Company (CP&L),

(CP&L), now doing business as Progress Energy Carolinas, Inc., requests the Nuclear Carolinas, Inc., Nuclear Regulatory Regulatory Commission (NRC) approve an exemption exemption from a specific requirement of 10 CFR CFR Part 73, 73, "Physical Protection Protection of Plants and Materials."

Materials." The exemption requested would exemption requested compliance due date for H. B. Robinson Steam Electric Plant, Unit No.2, extend the compliance No. 2, for one measure measure required by the revised rule.

The NRC issued a Final Rule for revised security requirements requirements in the Federal Register Register dated dated March 27, 2009.

March 27,2009. Pursuant Pursuant to the Final Rule, the revised security requirements revised security requirements had to be implemented implemented by March 31, 31, 2010. CP&L achieved achieved compliance compliance with a vast majority of the revised rule by the March 31, 2010, compliance 31,*2010, compliance date. By letter dated November 30, 2009, CP&L requested requested exemptions exemptions for additional time to comply comply with two specific provisions provisions of the revised revised rule. These These exemptions exemptions werewere approved by the NRC in a letter dated March March 3, 2010.

CP&L has determined determined that additional additional time, beyond that previously previously approved by the NRC, will be required to achieve compliance compliance with one of the provisions that was addressed in the earlier exemption request. The additional additional time is needed due to the complexity complexity of the design and construction of the projects which lead to unforeseen unforeseen scope scope growth growth and a better understanding understanding of the time necessary necessary for transition to and testing of the new systems. Also, due to a March March 28, 2010, fire in an electrical switchgear 28,2010, switchgear room, the spring spring refueling outage extended outage was extended beyond that originally beyond originally anticipated when project schedules were first developed. Additional time, beyond that approved in Reference 2, is therefore requested to complete complete the necessary Attachment 1 to this letter contains SlECUruTY-RElLATlED SECURITY-RELATED INFORMATION INFORMATION -WITHHOLD -WITHHOlLD UNDER 10 CFR 2.390. Q ,> >

Upon removal removal of Attachment Attachment 1 this letter is decontrolled.

decontrolled. Y - -

Regulatory Commission United States Nuclear Regulatory RA-10-021 RA-I0-021 Page 2 security security modifications. Additional Additional details regarding the specific specific provision of the rule for which exemption exemption is requested, and the length of the exemption exemption is provided in Attachment 1. 1.

This letter contains the following attachments:

• • Attachment Att~chment 1: Exemption Request for the H. B. Robinson Steam Electric Plant, No. 2 (Contains Unit No.2 (Contains Security-Related Security-Related Information - Withhold Under 10 CFR 2.390)

• • Attachment 2: Redacted Redacted Version of Exemption Request Request for the H. B. Robinson Steam No. 2 Electric Plant, Unit No.2 As noted above, Attachment security-related information associated Attachment 1 contains security-related associated with the physical protection of H. B. Robinson Steam Electric Plant, Unit No.

protection ofH. No.2,2, as described in 10 CFR 2.390(d)(1). Accordingly, Accordingly, CP&L requests that the information contained in Attachment 1 be withheld from public disclosure in accordance with the provisions of of 10 CFR 2.390.

This letter contains no regulatory commitments.

CP&L requests approval approval of this exemption request by December 30, 2010, the compliance December 30,2010, compliance date previously approved Reference 2.

approved in Reference If you should have any questions regarding regarding this submittal, please contact Ed O'Neil, Director Director

-- Nuclear 546-2151.

Nuclear Protective Services, at (919) 546-2151.

I declare under penalty of perjury that the foregoing is true and correct. Executed Executed on on September September 30, 2010.

ly, Sinne Vice President, Nuclear Operations Vice President, Nuclear Operations Progress Energy, Inc.

RJD/dbm RJD/dbm Attachments:

1. Exemption

1. Exemption Request for the H. B. Robinson Steam Steam Electric Plant, Unit No.2.

No. 2 (Contains Security-Related Information (Contains Security-Related Information - Withhold Under 10 CFR 2.390) 2.3 90)

2. Redacted Redacted Version of Exemption Request Version Exemption Request for the H. B. Robinson Steam Steam Electric Electric Plant, Unit No. 2 c: J. Wiggins, USNRC Director - Nuclear Security and Incident Response Response L. Reyes, USNRC Regional Regional Administrator Administrator - Region II USNRC Resident Resident Inspector Inspector - HBRSEP, Unit No.2 No. 2 T. Orf, Orf, NRR Project Manager -HBRSEP,

-HBRSEP, Unit No. No.22 Attachment Attachment 1 to this letter contains SECURITY-RELATED INFORMATION SECURITY-RELATED INFORMATION -WITHHOLD UNDER UNDER 10 CFR 2.390. 2.390.

Upon removal removal of Attachment 1 this letter is decontrolled.

decontrolled.