ML102810263

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Boiling Water Reactor Supplemental Response to ISFSI Additional Security Measures Analysis Re Vehicle Paths
ML102810263
Person / Time
Site: La Crosse  File:Dairyland Power Cooperative icon.png
Issue date: 10/05/2010
From: Sanscrainte C
Dairyland Power Cooperative
To:
Document Control Desk, NRC/NMSS/SFST
References
LAC-14139
Download: ML102810263 (3)


Text

CHARLES V. SANS CRAINTE, P.E.

Vice President. Generation DAIRYIAND POWER COOPERATIVE October 5, 2010 In reply, please refer to LAC-14139 DOCKET NO. 72-46 Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Dairyland Power Cooperative (DPC)

La Crosse Boiling Water Reactor (LACBWR)

Possession-Only License No. DPR-45 Supplemental Response to ISFSI Additional Security Measures Analysis Regarding Vehicle Paths

REFERENCES:

(1) Letter dated June 19, 2008, DPC to NRC, Affirmation of Need for Dry Cask Certificate of Compliance Amendment.

(2) Letter dated June 3, 2009, NRC to DPC, and attached Order for Additional Security Measures at the La Crosse Boiling Water Reactor Independent Spent Fuel Storage Installation, EA-09-118.

(3) Letter dated June 22, 2009, DPC to NRC, and attached response to EA-09-118, containing the Additional Security Measures (ASM) for physical protection of the Independent Spent Fuel Storage Installation (ISFSI) and access authorization and fingerprinting.

(4) Letter dated November 2, 2009, DPC to NRC, Supplemental Response to Order of June 3, 2009, Modifying Licenses.

(5) Letter dated November 24, 2009, DPC to NRC, Relaxation of Scheduled Analysis Delivery Date and Notification of Scheduled Fuel Loading.

(6) Letter dated February 18, 2010, NRC to DPC, Relaxation of Schedule for Implementing Requirements of Order for Implementation of ASM and Fingerprinting Unescorted Access to LACBWR ISFSI.

A Touchstone Energy Cooperative filM 3200 East Ave. S.

  • PO Box 817 e La Crosse, WI 54602-0817
  • 608-787-1233
  • 608-787-1462 fax
  • www.dairynet.com

Document Control Desk Page 2 October 5, 2010 (7). Letter dated April 30, 2010, DPC to NRC, ISFSI Additional Security Measures Analysis Results.

(8) Secure teleconference on June 3, 2010, at Prairie Island, MN, Discussion on request for relaxation submittal from DPC to NRC.

Based on the discussions that occurred during our June 3, 2010, conference call Dairyland Power Cooperative (DPC) is requesting relaxation from the specific requirement in section B. 1.d of the Independent Spent Fuel Storage Installation (ISFSI) Additional Security Measures (ASMs) to, "Block all other roads and vehicle paths with two (2) vehicle barriers." To add further to the discussion on June 3, 2010, DPC is providing an explanation as to how it was determined that relaxation was deemed prudent.

As explained in the attachment to Reference 7, DPC concluded that the entire area around the ISFSI, prior to placing the Vehicle Barrier System (VBS) required in B.1 .b, would be considered a vehicle path. DPC's ISFSI is situated on an open grassy prairie having mild terrain changes that do not restrict vehicular traffic. Our assumption was that due to this open prairie, every direction around the ISFSI was an available path for vehicles. With the assumption that every direction could be a potential vehicle path, each ISFSI ASM requirement was addressed individually.

Our VBS design addresses requirement B. 1.b with the placement of a single row of robust vehicle barriers at sufficient stand-off distance to protect the ISFSI against the Design Basis Threat (DBT). We seek relaxation because the VBS is comprised of a single row of vehicle barriers. The language of B. 1.d does not explicitly give relief for an analysis that proves one vehicle barrier is sufficient. B. 1.d specifically requires two vehicle barriers for all vehicle paths regardless of the DBT analysis performed in B. 1.a and B. 1.b.

DPC understands that an interpretation can be made that once the VBS is established as required in B. 1.b, there no longer exists a vehicle path across the open prairie. We did not make that assumption in our interpretation because of the risk involved if that assumption was incorrect and differed with the interpretation of any given individual during inspection. It is our position that the prudent approach, from a licensing standpoint, is to obtain a specific relaxation to remove any ambiguity of meeting the requirement stated in B. 1.d of the ASMs.

Further justification for the relaxation was documented in the attachment to Reference 7.

If you have any questions, please call Michael Brasel of my staff at (608) 689-4220.

Sincerely, DAIRYLAND POWER COOPERATIVE Charles V. Sans Crainte Vice President, Generation CVS: MAB: two

Document Control Desk Page 3 October 5, 2010 cc: Kristina Banovac Project Manager U.S. Nuclear Regulatory Commission Washington, DC 20555 John Hickman Project Manager U.S. Nuclear Regulatory Commission Washington, DC 20555 Mark Satorius Regional Administrator, NRC Region III 2443 Warrenville Rd.

Lisle, IL 60532 Raynard Wharton Senior Project Manager, Division of Spent Fuel Storage and Transport U.S. Nuclear Regulatory Commission Washington, DC 20555 Paul Schmidt Manager, Radiation Protection Section State of Wisconsin PO Box 2659 Madison, WI 53701-26459