ML12284A018

NRR E-mail Capture - (D91660) Request for Additional Information (RAI) Draft Questions Corporate Security Plans Submitted 7/30/2012

ML12284A018
Person / Time
Site:	Kewaunee
Issue date:	10/05/2012
From:	Feintuch K Division of Operating Reactor Licensing
To:	Earle M Dominion Energy Co
References
TAC D91660
Download: ML12284A018 (4)

Text

1 NRR-PMDAPEm Resource From:

Feintuch, Karl Sent:

Friday, October 05, 2012 2:07 PM To:

'margaret.earle@dom.com' Cc:

Sreenivas, V; Kim, James; Cotton, Karen; Costa, Richard

Subject:

(D91660) Request for Additional Information (RAI) draft questions Re: corporate security plans submitted 7/30/2012 Attachments:

MExxxx Ke and Fleet Sec Plan Draft RAI Questions.pdf By letter dated July 30, 2012 (Agencywide Documents Access and Management System Accession No. ML12214A581), Dominion Generation, submitted Dominions Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 15 for the Kewaunee Power Station. The enclosure to the letter contained Safeguards Information and has been withheld from public disclosure.

The Reactor Security Licensing Branch (RSLB) staff is currently reviewing the submittal to ensure compliance with Title 10 of the Code of Federal Regulations, Section 50.54(p)(2). The RSLB staff has determined that additional information is necessary to complete its review.

The Request for Additional Information (RAI) items are attached. The attachment is identical to that sent to you informally in an email message dated October 4, 2012.

A clarification conference call to discuss these questions is scheduled on October 10, 2012, at 1:30 PM ET.

You have received RAI questions for other Dominion fleet plants. At the meeting a collective response schedule will be discussed appropriate to the corporate structure of your security plans. V. Sreenivas will be conducting the conference call on October 10, 2012.

Karl Feintuch 301-414-3079 USNRC PM for Kewaunee Power Station PM, Dominion Fleet

Hearing Identifier:

NRR_PMDA Email Number:

500 Mail Envelope Properties (Karl.Feintuch@nrc.gov20121005140600)

Subject:

(D91660) Request for Additional Information (RAI) draft questions Re: corporate security plans submitted 7/30/2012 Sent Date:

10/5/2012 2:06:51 PM Received Date:

10/5/2012 2:06:00 PM From:

Feintuch, Karl Created By:

Karl.Feintuch@nrc.gov Recipients:

"Sreenivas, V" <V.Sreenivas@nrc.gov>

Tracking Status: None "Kim, James" <James.Kim@nrc.gov>

Tracking Status: None "Cotton, Karen" <Karen.Cotton@nrc.gov>

Tracking Status: None "Costa, Richard" <Richard.Costa@nrc.gov>

Tracking Status: None

"'margaret.earle@dom.com'" <margaret.earle@dom.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1352 10/5/2012 2:06:00 PM MExxxx Ke and Fleet Sec Plan Draft RAI Questions.pdf 65068 Options Priority:

Standard Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Recipients Received:

Enclosure NSIR REVIEW - TAC D91660 10 CFR 50.54(p)(2) CHANGES TO SECURITY PLAN DOMINION ENERGY KEWAUNEE, INC KEWAUNEE POWER STATION DOCKET NO. 50-305 LICENSE NO. DPR-43 By letter dated July 30, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12214A581), Dominion Generation, submitted Dominions Physical Security Plan (PSP), Training and Qualification Plan (T&QP), and Safeguards Contingency Plan (SCP), Revision 15 for the Kewaunee Power Station. The enclosure to the letter contained Safeguards Information and has been withheld from public disclosure. The U.S. Nuclear Regulatory Commission (NRC) staff is currently reviewing the submittal to ensure compliance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(p)(2). The NRC staff has determined that the additional information requested below is needed to complete its review.

1. Section 15.1 of the PSP describes illumination at the site. Describe the type of alternative technology being implemented at the protected area perimeter to augment illumination. Describe how the alternative technology provides the capability to perform protected area perimeter assessment in no-light or low-light conditions and specifically during the loss of normal power. Describe how the alternative technology is integrated within the protected area perimeter intrusion detection and assessment systems to meet the requirements of 10 CFR 73.55(e)(7)(i)(C), 73.55(i)(2), and 73.55(i)(3)(vii). See Security Frequently Asked Question (SFAQ) 10-15. Additionally, appropriate changes should be made during the next revision of the sites PSP to ensure the language clearly describes the type(s) of technology used to augment illumination for the assessment of the PA perimeter in no-light or low light conditions and during the loss of normal power, and how the technology meets the requirements of 10 CFR 73.55(e)(7)(i)(C), 73.55(i)(2),

and 73.55(i)(3)(vii).

Regulatory Basis:

Consistent with 10 CFR 73.55(c)(3), the licensee shall establish, maintain, and implement a Physical Security Plan which describes how the performance objective and requirements set forth in this section will be implemented.

Consistent with10 CFR 73.55(e)(7)(i)(C), isolation zones shall be monitored with assessment equipment designed to satisfy the requirements of Section 73.55(i) and provide real-time and play-back/recorded video images of the detected activities before and after each alarm annunciation.

Consistent with 10 CFR 73.55(i)(2), intrusion detection equipment must annunciate and video assessment equipment shall display concurrently, in at least two continuously staffed onsite alarm stations, at least one of which must be protected in accordance with the requirements of the central alarm station within this section.

Consistent with 10 CFR 73.55(i)(3)(vii), the licensees intrusion detection and assessment systems must be designed to ensure intrusion detection and assessment equipment at the protected area perimeter remains operable from an uninterruptible power supply in the event of the loss of normal power.

Consistent with 10 CFR 73.55(i)(6)(iii), the licensee shall describe in the security plans how the lighting requirements of this section are met and, if used, the type(s) and application of low-light technology.

2. Section 15.1 of the PSP describes illumination for all the Dominion sites. The last paragraph of Section 15.1 describes a loss of power scenario that seems to apply to all sites. In Section 7 of the SCP, on page C-28, the description for loss of power scenario is described differently for Kewaunee than in Section 15.1 of the PSP.

These descriptions seem to be contradictory. Clarify how Kewaunee Power Station meets the illumination requirements of 10 CFR 73.55(i)(6) in a loss of power scenario. Additionally, appropriate changes should be made during the next revision of the sites PSP and SCP to ensure the language is consistent and clearly describes the effect of a loss of power on illumination at Kewaunee Power Station.

Regulatory Basis:

Consistent with 10 CFR 73.55(c)(3), the licensee shall establish, maintain, and implement a Physical Security Plan which describes how the performance objective and requirements set forth in this section will be implemented.

Consistent with 10 CFR 73.55(i)(6)(i), the licensee shall ensure that all areas of the facility are provided with illumination necessary to satisfy the design requirements of Section 73.55(b) and implement the protective strategy.

Consistent with 10 CFR 73.55(i)(6)(ii), the licensee shall provide a minimum of 0.2 foot-candles, measured horizontally at ground level, in the isolation zones and appropriate exterior areas within the protected area. Alternatively, the licensee may augment the facility illumination system by means of low-light technology to meet the requirements of this section or otherwise implement the protective strategy.

Consistent with 10 CFR 73.55(i)(6)(iii), the licensee shall describe in the security plans how the lighting requirements of this section are met and, if used, the type(s) and application of low-light technology.