ML19092A453

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Safety Evaluation - Vogtle Electric Generating Plant, Units 3 (LAR 18-008)
ML19092A453
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 04/30/2019
From: Chandu Patel
NRC/NRO/DLSE/LB2
To:
City of Dalton, GA, Georgia Power Co, MEAG Power, Oglethorpe Power Corp, Southern Nuclear Operating Co
PATEL C/NRO
Shared Package
ML19092A449 List:
References
EPID L-2018-LLA-0262, LAR 18-008
Download: ML19092A453 (12)
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Text

SAFETY EVALUATION BY THE OFFICE OF NEW REACTORS RELATED TO AMENDMENT NOS. 160 AND 158 TO THE COMBINED LICENSE NOS. NPF-91 AND NPF-92, RESPECTIVELLY SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT UNITS 3 AND 4 DOCKET NOS.52-025 AND 52-026

1.0 INTRODUCTION

By letter dated September 28, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18271A116), as supplemented by letter dated February 4, 2019 (ADAMS Accession No. ML19035A767), Southern Nuclear Operating Company, Inc. (SNC) requested that the U.S. Nuclear Regulatory Commission (NRC or Commission) amend the combined operating licenses (COL) for the Vogtle Electric Generating Plant (VEGP) Units 3 and 4, COL Nos. NPF-91 and NPT-92, respectively.

In License Amendment Request (LAR)18-008 SNC proposes changes to Appendix E of the VEGP Units 3 and 4 Physical Security Plan (PSP) to describe the Transitional Security Measures (TSMs) that will be implemented in the event that Unit 3 is ready to load fuel and begin operation with a contiguous Protected Area (PA) boundary and vehicle barrier system (VBS), and where a secure boundary is needed between VEGP Units 3 and 4. In addition, in LAR 18-008, SNC proposes to revise the plant-specific emergency planning (EP) Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) in Appendix C of the VEGP Unit 4 COL, associated with the presence of a security barrier between the Technical Support Center (TSC) and the Unit 4 control room. According to SNC, the proposed change to the EP ITAAC is necessary to support implementation of the TSMs, and does not involve changes to the approved emergency plan or the plant-specific Tier 2 Design Control Document (DCD).

The February 4, 2019, letter provided additional information that did not change the scope of the original LAR 18-008 or the conclusion of the No Significant Hazards Consideration Determination published in the Federal Register on January 8, 2019 (84 FR 88).

2.0 REGULATORY EVALUATION

The requested amendment revises the COL and licensing basis documents related to physical security and revises EP ITAAC necessary to support the implementation of the TSMs. The staff considered the following regulatory requirements and guidance in reviewing the licensees LAR:

  • Title 10 of the Code of Federal Regulations (10 CFR) 50.47(b)(8) requires that adequate emergency facilities and equipment are provided and maintained to support the emergency response.
  • 10 CFR 52.98(f) requires NRC approval for any modification to, addition to, or deletion from the terms and conditions of a COL.
  • 10 CFR 52.97(b) requires that the ITAAC included in the COL be necessary and sufficient to provide reasonable assurance that the facility has been constructed and will be operated in conformity with the license, the Atomic Energy Act of 1954, as amended (AEA), and the Commissions rules and regulations.
  • 10 CFR 73.55(a)(2) requires the security plan to identify, describe, and account for site-specific conditions that affect the licensees capability to satisfy the requirements of 10 CFR 73.55.
  • 10 CFR 73.1, Purpose and scope, prescribes requirements for the establishment and maintenance of a physical protection system and for protection against the design basis threat (DBT) of radiological sabotage.
  • 10 CFR 73.55(a), Introduction, states, in part, that each nuclear power reactor licensee shall implement the requirements of 10 CFR 73.55 through its Commission approved Physical Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Cyber Security Plan, referred to collectively as security plans, and that the security plans must identify, describe, and account for site-specific conditions that affect the licensees capability to satisfy the requirements of 10 CFR 73.55.
  • 10 CFR 73.55(b), General performance objective and requirements, contains performance-based requirements that specify that a licensees physical protection system will have as its objective to provide high assurance that covered activities are not inimical to the common defense and security and do not constitute an unreasonable risk to public health and safety.
  • 10 CFR 73.55(b)(3)(i) requires the licensee to ensure that the capabilities to detect, assess, interdict, and neutralize threats up to and including the design basis threat of radiological sabotage as state in 10 CFR 73.1 are maintained at all times.
  • 10 CFR 73.55(c), Security plans, states that the licensee must establish, maintain, and implement security plans to meet the requirements of 10 CFR 73.55 and 10 CFR Part 73, Appendices B and C. The licensee must demonstrate through these plans establishment and maintenance of a security organization, the use of security equipment and technology, the training and qualification of security personnel, the implementation of predetermined response plans and strategies, and the protection of digital computer and communication systems and networks. The licensee must have a management system for development, implementation, revision, and oversight of security implementing procedures. The approval process for implementing security procedures must be documented.
  • 10 CFR Part 73, Appendix C, Licensee Safeguards Contingency Plans, describes requirements for a documented plan to give guidance to licensee personnel in order to accomplish specific defined objectives in the event of threats, thefts, or radiological sabotage relating to nuclear power reactors.
  • NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements - Requirements for Emergency Response Capability (Generic Letter No. 82-33), January 1983 (ADAMS Accession No. ML102560009).
  • NUREG-0800, Standard Review Plan, Section 13.6.1, Physical SecurityCombined License and Operating Reactors, Revision 2, dated August 2018 (ADAMS Accession No. ML17291B265), provides guidance for the physical security review of designs of physical security systems.
  • NUREG-0800, Standard Review Plan, Section 14.3.12, Physical Security Hardware - Inspections, Tests, Analyses, and Acceptance Criteria, Revision 2, May 2017 (ADAMS Accession No. ML16320A125), provides guidance for the physical security review of Physical Security Hardware includes, but is not limited to, communication systems, assessment and alarm systems, locks, personnel access control, physical equipment barriers, and surveillance devices.

3.0 TECHNICAL EVALUATION

The staff evaluated the SNCs application to determine if the proposed changes are consistent with the regulations and licensing and design basis information discussed in Section 2.0 of this safety evaluation. The staffs review confirmed that SNCs application and material incorporated by reference provided the information required to review the physical security plan changes.

The staffs evaluation criteria focused on reasonable assurance of adequate protection (i.e.,

confidence based on a reasonable review that the facility will be constructed and will operate in conformity with the license, the provisions of the AEA, and the Commissions regulations).

3.1 PHYSICAL SECURITY PLAN, APPENDIX E ADDITIONS FOR UNIT 3 TRANSITIONAL SECURITY MEASURES In Enclosure 2 of LAR-18-008, SNC described a process to incorporate several TSMs into a future revision of the VEGP Combined License Security Plan, Appendix E Section 1.2.

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This LAR addresses the TSMs related to the transitional boundary between Unit 3 and Unit 4 while Unit 4 is still under construction. Appendix E of the COL Security Plan, Section 1.2 is revised as follows:

Transitional Security Measures (TSMs) will be addressed as revisions to this Appendix. The TSM describe the integration of VEGP Units 3 and 4 with VEGP Units 1 and 2. The TSM outlines how the transitional Vehicle Barrier System (VBS), Intrusion Detection System (IDS),

Closed Circuit Television Systems, and posted armed responders along the interface line between VEGP Units 1 through 3, and 4 integrate while Unit 4 may still be under construction.

3.1.1 VEGP UNITS 3 AND 4 SECURITY PLAN CHANGES The staff has reviewed the SNCs description of the changes in Enclosure 2 of LAR-18-008.

The staff finds the SNCs proposed changes addressed site-specific programmatic elements related to Physical Barriers, Vehicle Control Measures, VBS, Protective Strategy, Detection and Assessment System, and the VEGP Unit 3 Physical Security Hardware (PS) ITAAC for implementation within the site physical protection program as related to the boundary between VEGP Unit 3 and Unit 4, while Unit 4 is still under construction.

Physical Barriers 10 CFR 73.55(e), Physical barriers, states that each licensee shall identify and analyze site-specific conditions to determine the specific use, type, function, and placement of physical barriers needed to satisfy the physical protection program design requirements of 10 CFR 73.55(b). It says that the licensee shall, (i) design, construct, install and maintain physical barriers as necessary to control access into facility areas for which access must be controlled or denied to satisfy the physical protection program design requirements of paragraph (b) of this section, (ii) describe in the security plan, physical barriers, barrier systems, and their functions within the physical protection program.

In Enclosure 2 of LAR-18-008, SNC described the transitional PA barrier constructed on the western boundary of VEGP Units 1 through 3, which consists of a nuisance fence, PA boundary fence, and multiple delay barriers to support the site protective strategy. SNC described how the design features of these barriers are similar to (or equivalent to) the design features of the permanent PA barriers which is installed along the northern and southern boundaries of VEGP Units 1 through 3. SNC also stated that the transitional PA barrier will remain installed until construction of Unit 4 is complete and the final VEGP Units 1 through 4 PA barriers and VBS are in place.

SNC included the following documents to clarify its description.

  • Appendix E, Figure E-1, Transitional Protected Area (PA) Barrier Details, depicts the typical design details and configuration of the transitional PA barrier and associated equipment in relation to the Unit 3 physical plant and the Unit 4 construction area.
  • Appendix E, Figure E-3, Vertical Cross Section of the PA Fence Configuration, depicts a vertical cross section of the PA fence configuration with the typical characteristics of each fence identified.

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Section 11 of the SNCs current security plans provides a general description of how SNC will implement the physical protection program for physical barriers, and that this implementation is in accordance with the performance objectives and requirements of 10 CFR 73.55(b). SNCs proposed changes do not appear to decrease the safeguards effectiveness of the current security plans.

Based on the review of the proposed changes and considering the current security plans the staff finds that the security measures related to the physical barriers proposed by SNC for implementation of site-specific requirements to be included in the SNCs physical protection program are consistent with the acceptance criteria described in NUREG-0800, Section 13.6.1.

SNC has described the specific use, type, function, of the physical barriers and Appendix E, Figure E-3, illustrates the placement of physical barriers to be installed until construction of Unit 4 is complete and the final VEGP Units 1 through 4 PA barriers and VBS are in place. The staff finds that the description provided in the Enclosure 2, of LAR-18-008, is consistent with the current security plans and meets the requirements of 10 CFR 73.55(b) and 10 CFR 73.55(e),

and is, therefore, acceptable.

Vehicle Control Measures Section 73.55(e)(10)(i)(A), Vehicle Control Measures, of 10 CFR states that licensees shall design, construct, install, and maintain a VBS, to include passive and active barriers, at a stand-off distance adequate to protect personnel, equipment, and systems necessary to prevent significant core damage and spent fuel sabotage against the effects of the DBT of radiological sabotage land vehicle bomb assault.

In Enclosure 2 of LAR-18-008, SNC described the transitional VBS to be installed along the western boundary between Units 3 and 4 to provide protection of VEGP Units 1 through 3 safe shutdown structures, systems, and components (SSCs) from a design basis vehicle bomb (DBVB) while Unit 4 is under construction. SNC described how an assessment of the location of safe shutdown equipment and the location of armed responders currently credited in the site defensive strategy and external bullet resistant enclosures (BREs), and the placement of the transitional VBS provides the required safe standoff distance to ensure protection of SSCs and required personnel from the effects of the DBVBs. SNC described that the transitional VBS connects to the VEGP Units 1 through 3 permanent VBS on the northern and southern boundaries of Units 1 through 3 and consists of large concrete blocks specifically designed to withstand penetration of the regulatory defined design basis vehicle. SNC also stated that the transitional PA barrier and transitional VBS, including all associated components, are designed, installed, and shall be tested to meet applicable 10 CFR 73.55 requirements. SNC described how the transitional VBS will remain installed until construction of Unit 4 is complete and the final VEGP Units 1 through 4 PA barriers and VBS are in place.

SNC included the following documents to clarify its description.

  • Appendix E, Figure E-1, depicts the transitional VBS as well as the minimum safe standoff distance along the western boundary of VEGP Units 1 through 3 as evaluated utilizing the criteria in NUREG/CR- 6190.
  • Appendix E, Figure E-3, depicts a transitional VBS installed outside of the transitional PA barrier on the VEGP Units 1 through 3 western boundary to provide regulatory required protection against the DBVBs.

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Section 11.2 of the SNCs current security plans provides a general description of how SNC will implement a program for vehicle barriers (vehicle control measures) to protect against the DBT of radiological sabotage. The staff confirmed that the SNCs PSP provides for inspection, monitoring, and maintenance of the vehicle barrier system.

During the staffs site audit (ADAMS Accession No. ML19077A256), the staff had an opportunity to observe and evaluate the proposed vehicle barriers locations. The staff also reviewed the vehicle control measures and the site-specific analysis documents. The staff determined that these measures integrate systems, technologies, programs, and supporting processes, and observed that the implementing procedures are developed and will provide defense-in-depth against the DBT land vehicle bomb assault for the VEGP site. The staff also determined that these measures provide a VBS at a stand-off distance adequate to protect personnel, equipment, and systems necessary to prevent significant core damage and spent fuel sabotage against the effects of such an assault. Accordingly, the staff concludes that the proposed vehicle control measures are consistent with the physical protection program design requirements of 10 CFR 73.55(b)(3)(ii) and 10 CFR 73.55(e)(10)(i).

The staff finds that the security measures related to the transitional VBS proposed by SNC for implementation of site-specific requirements to be included in the SNCs physical protection program are consistent with the acceptance criteria described in NUREG-0800, Section 13.6.1.

SNC described the utilization of the criteria in NUREG/CR- 6190, and Appendix E, Figure E-3, illustrated the placement of transitional VBS to be installed until construction of Unit 4 is complete and the final VEGP Units 1 through 4 PA barriers and VBS are in place. The staff finds that the description provided in Enclosure 2 of LAR-18-008, is consistent with the current security plans and meets the requirements of 10 CFR 73.5(e)(10)(i)(A), and is, therefore, acceptable.

Protective Strategy Section 73.55(k)(8), Protective Strategy of 10 CFR states the licensee shall establish, maintain, and implement a written protective strategy in accordance with the requirements of this section and Part 73, Appendix C,Section II. Upon receipt of an alarm or other indication of a threat, the licensee shall: (i) determine the existence and level of a threat in accordance with pre-established assessment methodologies and procedures, and (ii) initiate response actions to interdict and neutralize the threat in accordance with the requirements of Part 73, Appendix C,Section II, the safeguards contingency plan, and the licensees response strategy.

In Enclosure 2 of LAR-18-008, SNC described their defensive strategy that combines the strategy and structural features developed by Westinghouse Electric Company (Westinghouse) for design certification of the AP1000 standard single unit site, as delineated in Westinghouses document APP-GW-GLR-066, AP1000 Safeguards Assessment Report, Revision 5 dated July 16, 2010 (also referred to as Technical Report 94 (TR-94)), with the existing SNC Units 1 and 2 fleet strategy, and utilizing external BREs to provide enhanced coverage of the site footprint outside of the physical plant and expand the range of potential engagement and interdiction opportunities associated with incorporating VEGP Units 3 and 4 into a common VEGP Units 1 through 4 PA. SNC stated that the strategy was developed through use of a subject matter expert panel and have been validated with the aid of computer modeling software which is designed to analyze attacks and predict the neutralization of adversary forces. SNC described that all continuously manned defensive positions will have communication systems designed, installed, and tested to fully meet applicable 10 CFR 73.55 requirements. SNC described how the area west of VEGP Unit 3 as defined by the transitional PA barrier, is 6

covered by responders located in a combination of defensive positions built into the VEGP Units 1 through 3 superstructures and strategically placed external BREs, are designed to meet National Institute of Justice Level IV standards. SNC also described how these response locations will be continually manned to provide overlapping lines of sight and fields of fire of the VEGP Units 1 through 3 site. SNC included the following document to clarify the description:

  • Appendix E, Figure E-2, VEGP Unit 3, External Bullet-Resistant Enclosures (BRE)

Approximate Locations, depicts a layout of the transitional barriers in relation to Unit 3 plant structures and approximate locations of BREs incorporated into the current site defensive strategy.

Safeguards Contingency Plan (SCP) Section 7 of the SNCs current security plan describes that SNC will develop, implement and maintain written protective strategy procedures designed to meet the performance objectives of 10 CFR 73.55(a) through (r).

The staff finds that the security measures related to the protective strategy proposed by SNC for implementation of site-specific requirements to be included in the SNCs physical protection program are consistent with the acceptance criteria described in NUREG-0800, Section 13.6.1.

SNC confirmed that a written protective strategy is established that provides the methodology of the sites protective strategy that accounts for and protects the personnel, systems, and equipment required for interdiction and neutralization of threats (10 CFR 73.55 (b)(3)(i)) to prevent significant damage to core and spent-fuel sabotage. Appendix E, Figure E-2, illustrated the placement of the approximate location of the external BREs incorporated into the current site strategy to be installed until construction of Unit 4 is complete and the final VEGP Units 1 through 4 PA barriers and VBS are in place. The staff finds that the description provided in the of LAR-18-008, is consistent with the current security plans and meets the requirements of 10 CFR 73.55(k)(8), and is, therefore, acceptable.

Detection and Assessment System Section 73.55(i)(1), Detection and Assessment System of 10 CFR states that the licensee shall establish and maintain intrusion detection and assessment systems that satisfy the design requirements of 10 CFR 73.55(b) and provide, at all times, the capability to detect and assess unauthorized persons and facilitate the effective implementation of the licensees protective strategy.

In Enclosure 2 of LAR-18-008, SNC stated that the entire length of the transitional PA barrier will be monitored with a Volumetric Perimeter Intrusion Detection and Assessment System (PIDAS). The licensee explained that the design features of the transitional PIDAS are similar to (or equivalent to) the design features of the permanent PIDAS along the northern and southern boundaries of VEGP Units 1 through 3. SNC described that the transitional PIDAS utilizes cameras and thermal cameras to (perform surveillance) monitor detection zones along the transitional PA barrier. Intrusion alarms and assessment video associated with the transitional PIDAS are integrated into the VEGP Units 1 through 3 security computer/video system. SNC explained that the security lighting for the transitional barrier is provided for illumination of the assessment area at a minimum of 0.2 foot-candles per regulatory requirement. Also, the security lighting will be reenergized using a diesel generator and the transitional PIDAS remains operable upon loss of offsite power through use of an uninterruptible power supply.

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Section 15, Sub-Section 15.1, Illumination, of SNCs current security plans describes how all isolation zones and appropriate exterior areas within the PA have lighting capabilities that provide illumination sufficient for the initiation of an adequate response to attempted intrusions.

Sub-Section 15.2, Surveillance, describes how surveillance is accomplished with the aid of human observation and monitoring technology. Sub-Section 15.3, Intrusion Detection Equipment, describes the perimeter IDS and the monitoring with assessment equipment designed to satisfy the requirements of 10 CFR 73.55(i).

Based on the description provided by SNC and considering the similarity with the current security plans, the staff finds that the security measures related to the Detection and Assessment System proposed by SNC for implementation of site-specific requirements to be included in the SNCs physical protection program are consistent with the acceptance criteria described in NUREG-0800, Section 13.6.1. SNCs description of these systems is consistent with the current security plans and includes the required equipment that is relied upon by SNC to provide intrusion detection and assessment (10 CFR 73.55 (b)(3)(i)) of possible threats in the owner controlled area, PA, or vital area related to the transitional boundary between Units 3 and 4, while Unit 4 is under construction. The staff finds that the description provided in Enclosure 2 of LAR-18-008, is consistent with the current security plans and meets the requirements of 10 CFR 73.55(i)(1) and 10 CFR 73.55 (i)(3)(vii) and is, therefore, acceptable.

Probable Maximum Precipitation In the February 4, 2019, letter, SNC informed the staff that a Probable Maximum Precipitation (PMP) Analysis was completed and confirmed that the installation of the transitional barrier does not adversely impact the capability of the runoff routes and drainage systems to handle a PMP event. This completed SNCs evaluation for impact on the PMP analysis due to a transitional barrier. The staff has evaluated PMP analysis at VEGP Units 3 and 4 during the initial licensing of VEGP 3 and 4. The staff considers SNCs evaluation to be adequate protection and no further evaluation is necessary by the staff.

Security ITAACs associated with VEGP Unit 3 As required by paragraph 10 CFR 52.103(g), Operation Under a Combined License, the licensee shall not operate the facility until the Commission makes a finding that the acceptance criteria in the COL are met, except for those acceptance criteria that the Commission found were met under 10 CFR 52.97(a)(2).

In Enclosure 2 of LAR-18-008, SNC stated that the transitional PA barrier and transitional VBS, including all associated components, are included in the scope of the security ITAACs associated with VEGP Unit 3.

The staff reviewed the PS ITAAC systems and components required for the transitional PA barrier and VBS. The staff finds that the PS ITAACs related to the transitional PA barrier and transitional VBS require no additional design commitment or acceptance criteria for compliance with the NRC regulations for the transitional security measures. The current PS ITAAC remain consistent with the Design Commitment, Inspections, Tests, Analyses, and Acceptance Criteria described in NUREG-0800, Section 14.3.12. Enclosure 2 of LAR-18-008 and, the transitional PA barrier and transitional VBS, including all associated components, are included in the scope of the change and are, therefore, acceptable.

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3.2 UNIT 4 PLANT-SPECIFIC EMERGENCY PLANNING ITAAC REVISION Paragraph 50.47(b)(8) of 10 CFR requires that a licensee provide and maintain adequate emergency facilities and equipment to support the emergency response. With regard to the location of the TSC, the corresponding VEGP Unit 3 EP ITAAC E.3.9.05.01.04 (Item No. 852) includes Acceptance Criterion 5.1.4, which states that [t]he TSC is located within the protected area, and no major security barriers exist between the TSC and the control room.

This TSC location ITAAC requirement reflects the guidance in (1) Section 2.2, Location, of NUREG-0696, Functional Criteria for Emergency Response Facilities, which states in part that

[t]here should be no major security barriers between [the TSC and the control room] other than access control stations for the TSC and control room; and (2) Section 8.2, Technical Support Center (TSC), of NUREG-0737, Supplement 1, Clarification of TMI [Three Mile Island] Action Plan Requirements - Requirements for Emergency Response Capability (Generic Letter No.

82-33), which states in part in Subsection 8.2.1.b that the TSC will be [l]ocated within the site protected area so as to facilitate necessary interactions with control room, OSC [Operations Support Center], EOF [Emergency Operations Facility] and other personnel involved with the emergency.

During the licensing process for VEGP Units 3 and 4, the staff determined that since Units 3 and 4 share a common TSC on the VEGP site, and its location is confirmed through Unit 3 ITAAC E.3.9.05.01.04, there was no need to repeat confirmation of the TSC location in an EP ITAAC for Unit 4. However, considering the staggered construction schedule for the two reactor units, and the impact that this might have on the status of the PA boundary supporting both units, SNC determined that the requirements in Unit 3 ITAAC E.3.9.05.01.04 should be repeated for Unit 4. In Section 2, Detailed Description, of Enclosure 1 to LAR-18-008, SNC described the basis for the proposed Unit 4 ITAAC change, as follows:

Unit 4 Plant-Specific Emergency Planning ITAAC Revision The plant-specific VEGP Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 is currently annotated as Verified on VEGP Unit 3. The basis for this annotation is that the Technical Support Center (TSC) is common to both VEGP Units 3 and 4 and would be located in a PA common to VEGP Units 3 and 4. The addition of the Unit 3 western boundary TSMs will result in a major security barrier between the common VEGP Unit 3 and 4 TSC and the Unit 4 control room. Thus, the Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 cannot be verified using the Unit 3 COL Appendix C EP ITAAC No. E.3.9.05.01.04 Completion Notice, while the Unit 3 western boundary TSMs are in place.

The proposed changes will revise the Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 to confirm no major security barriers exist between the TSC and the Unit 4 control room, matching the wording contained in the Unit 3 COL Appendix C EP ITAAC No. E.3.9.05.01.04 Program Commitment, ITA and AC. Once the physical security measures for the site are in their final configuration, and the western boundary TSMs removed or altered (opened), the revised Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 Completion Notice may be submitted.

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The staff finds that the proposed Unit 4 ITAAC change consists of replacing the existing language in VEGP Unit 4 COL Appendix C EP ITAAC Table E.3.9-5, Inspections, Tests, Analyses, and Acceptance Criteria, Item No. 852, with the same wording that exists in VEGP Unit 3 COL Appendix C EP ITAAC Table E.3.9-5, Inspections, Tests, Analyses, and Acceptance Criteria. Specifically, to remove the Verified on VEGP Unit 3 wording under Program Commitment for Unit 4 ITAAC Item No. 852 in Table E.3.9-5, and insert the (Program Commitment; Inspections, Tests, Analyses; and Acceptance Criteria) language from Unit 3 ITAAC E.3.9.05.05.04 (Item No. 852) as a new Unit 4 ITAAC E.3.9.05.01.04 (Item No. 852) in VEGP Unit 4 COL Appendix C EP ITAAC Table E.3.9-5.

The staff finds that the proposed change to Unit 4 ITAAC E.3.9.05.01.04 (Item No. 852) is acceptable because it provides a verification of no security barrier between the TSC and Unit 4 control room, following establishment of the PA supporting both VEGP Units 3 and 4, with regard to the TSC location within the PA and the existence of major security barriers. In addition, the Unit 4 ITAAC change does not involve changes to the approved VEGP Units 3 and 4 Emergency Plan or the plant-specific AP1000 Tier 2 DCD, and is consistent with the guidance in NUREG-0696 and Supplement 1 to NUREG-0737. Therefore, the proposed change to Unit 4 ITAAC E.3.9.05.01.04 (Item No. 852) is acceptable, in support of the establishment of the TSC location, pursuant to the requirements in 10 CFR 50.47(b)(8) for adequate emergency facilities and equipment to support the emergency response.

3.3 TECHNICAL CONCLUSION OF THE PROPOSED CHANGES Based on the above, the staff determined that the changes described in LAR-18-008, as supplemented, are acceptable because the changes do not adversely affect the staffs previous evaluations of the SNCs (SNC Fleet and VEGP Units 3 and 4) security plans. The staff has concluded that the SNCs proposed TSMs contain the necessary programmatic elements to implement an effective physical protection program to provide reasonable assurance of an adequate level of physical protection for the associated safety-related components and equipment while barriers are installed and until construction of Unit 4 is complete and the final VEGP Units 1 through 4 PA barriers and VBS are established. Based on these findings the staff concludes that there is reasonable assurance that the requirements of 10 CFR 73.55 and 10 CFR 73.55 (b)(3)(i) will be met. Therefore, the staff finds that the proposed changes are acceptable.

With respect to 10 CFR 52.97(b), the staff concludes that, with the proposed change to the VEGP Unit 4 EP ITAAC, there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at VEGP Units 3 and 4, and the VEGP Units 3 and 4 EP ITAAC continue to demonstrate compliance with the requirements of 10 CFR 50.47(b)(8). Therefore, within the scope of this license amendment, the staff finds that 10 CFR 52.97(b) is satisfied, and that the requested change to the VEGP Unit 4 EP ITAAC is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations in 10 CFR 50.91(b)(2), on April 2, 2019, the Georgia State official was consulted. The State official had no comments.

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5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the location of a contiguous PA boundary and VBS, and includes a secure boundary between VEGP Units 3 and 4. In addition, the amendment changes a requirement with respect to a VEGP Unit 4 COL EP ITAAC, which addresses the absence of a major security barrier between the TSC and the Unit 4 control room. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite.

Also, there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (Federal Register, 84 FR 88 published on January 8, 2019). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Under 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The staff has concluded, based on the considerations discussed in Section 3.0, that there is reasonable assurance that: (1) the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public. Therefore, the staff finds the changes proposed in this LAR acceptable.

7.0 REFERENCES

1. Southern Nuclear Operating Companys letter to U.S. Nuclear Regulatory Commission, Request for License Amendment - Physical Security Plan, Appendix E Additions for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC Revision (LAR-18-008), September 28, 2018 (SNC Letter No. ND-18-0060) (ADAMS Accession No. ML18271A116).
2. Southern Nuclear Operating Companys letter to U.S. Nuclear Regulatory Commission, Vogtle Electric Generating Plant Units 3 and 4, Supplement to Request for License Amendment: Physical Security Plan, Appendix E Additions for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC Revision (LAR-18-008S1),

February 4, 2019, ADAMS Accession No. ML19035A767.

3. VEGP Units 3 and 4 Security Plan, Revision 3, October 21, 2016 (ADAMS Accession No. ML17100A125).
4. Joseph M Farley Nuclear Plant, Edwin I. Hatch Nuclear Plant and Vogtle Electric Generation Plant Fleet Security Plan, Revision 17, August 13, 2018 (ADAMS Accession No. ML18228A541).
5. NUREG-1959, Intrusion Detection Systems and Sub Systems - Technical Information for NRC Licensees, Revision 1, September 2017 (ADAMS Accession No. ML17250A867),

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provides technical details applicable to designing, installing, employing and maintaining Intrusion Detection Systems and technologies commonly used to protect facilities.

6. NUREG-1964, Access Control Systems: Technical Information for NRC Licensees, April 2011 (ADAMS Accession No. ML11115A078), provides technical details applicable to access control methods and technologies commonly used to protect facilities.
7. NUREG/CR-6190, Update of NUREG/CR-6190 Material to Reflect Postulated Threat Requirements, March 27, 2003 (not publicly available).
8. Regulatory Guide (RG) 5.69, Guidance for the Application of Radiological Sabotage Design Basis Threat in the Design, Development, and Implementation of a Physical Security Program that Meets 10 CFR 73.55 Requirements, September 2007 (contains Safeguards Guards Information (SGI) and, therefore, is not publicly available).
9. RG 5.76, Physical Protection Programs at Nuclear Power Reactors, July 2009, contains SGI and, therefore, is not publicly available.
10. RG 5.81, Target Set Identification and Development for Nuclear Power Reactors, November 2010 (contains SGI and, therefore, is not publicly available).

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