ML20059E122
| ML20059E122 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/03/1994 |
| From: | Shetler J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| DAGM-NUC-93-239, TAC-M76805, NUDOCS 9401100279 | |
| Download: ML20059E122 (3) | |
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{iSMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street. P.O. Box 15830. Sacramento CA 95852-1830,(916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA DAGM/NUC 93-239 January 3, 1994 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
20555' Docket No. 50-312 Rancho Seco Nuclear Station License No. DPR-54 RANCIIO SECO LONG TERM DEFUELED CONDITION PIIYSICAL SECURITY PLAN, AMENDMENT 7
References:
1.
S. Weiss (NRC) to D. Keuter (.SMUD) letter dated July 5,1991, Physical Security License Condition Amendment and Exemption, Rancho Seco Nuclear Generating Station (TAC NO. 76805) 2.
J. Shetler (NRC) to R. E. Cunningham (NRC) letter DAGM/NUC 93-135, dated October 27,1993, Revision 1 to the Rancho Seco Independent Spent Fuel Storage Installation License Application and Safety Analysis Report Attention: Seymour Weiss In accordance with 10 CFR 50.4(b)(4),10 CFR 50.54(p), and 10 CFR 72.7, the District submits for NRC approval the original package and three copies of Amendment 7 to the Rancho Seco Long Term Defueled Condition (LTDC)
Physical Security Plan (PSP). Also enclosed is the 10 CFR 50.59 determination and the 10 CFR 50.54(p)(2) analysis. These analyses conclude that. TDC PSP, L
Amendment 7 does not result in an Unreviewed Safety Question and does not reduce the security effectiveness of the plan, respectively.
The most significant change in Amendment 7 is incorporation of the propa.d Independent Spent Fuel Storage Installation (ISFSI) security measures into the LTDC PSP. The security measures afforded the proposed ISFSI are consistent I
with the current, applicab!e 10 CFR 73 Security Program requirements (including the 10 CFR 73 exemptions previously granted by the NRC) associated gI with spent fuel storage in the Rancho Seco spent fuel pool. Also, LTDC PSP,
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RANCHO SECo NUCLEAR GENERATING STATION D 14440 Twin Cities Road, Herald, CA 95638 9799;(209) 333-2935
Seymour Weiss 2-DAGM/NUC 93-239 Amendment 7 meets the 10 CFR 72 Physical Protection requirements, including the existing 10 CFR 73 exemptions previously granted by the NRC.
10 CFR 72, Sub-part H specifies the physical protection requirements for ISFSis. These requirements include the 10 CFR 73 requirements applicable to ISFSIs (10 CFR 73.180), and the Safeguards Contingency Plan requirements found in 10 CFR 73, Appendix C, excluding Procedures information (10 CFR 73.184).
LTDC PSP, Amendment 7 requires NRC approval prior to implementation because the District requests that the 10 CFR 73.55 and 10 CFR 73, Appendix B and Appendix C exemptions the NRC granted in Reference 1 for fuel storage in the spent fuel pool, be expanded to include fuel storage at the proposed ISFSI.
In accordance with 10 CFR 72.7, Specific Exemptions, the NRC may grant exemptions from certain 10 CFR 72 requirements as the NRC determines "... are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest."
The following information provides the basis for expanding the existing LTDC PSP 10 CFR 73 exemptions to the security measures required for the ISFSI:
The 10 CFR 73 exemptions the NRC granted the District in Reference 1 l
were based, in part, on the implausibility of a 10 CFR 100 release from credible Security threats for Rancho Seco in defueled condition. This also applies to the proposed ISFSI, which has no credible Security threats associated with its operation that could result in 10 CFR 100 releases.
As summarized in Federal Register Volume 55, dated July 18,1990, beginning on page 29181, the NRC concluded in a generic ISFSI study that sabotage events at ISFSIs could not result in a significant threat to the public health and safety.
This same Federal Register states that the primary dry fuel storage a
Security threat is a protracted loss of control of the storage area, and that ISFSI protective measures must include (1) early detection of hostile actions, and (2) a method to quickly summon response forces. LTDC PSP, Amendment 7 meets these ISFSI security measures requirements with (1) physical barriers, (2) electronic alarm surveillance systems, (3) direct, periodic Security personnel surveillance, and (4) communications systems that are designed to ensure early detection and identification of hostile forces and provide the capability to immediately request assistance 3
from Local Law Enforcement Agencies (LLEA),if necessary.
,-.mn
Seymour Weiss DAGM/NUC 93-239 The Pacific Nuclear Corporation NUHOMS storage system, described in the Rancho Seco ISFSI License Application and Safety Analysis Report 1
(Reference 2), provides for substantial protection against any credible Security threat to the proposed ISFSI. This protection is strengthened through the quick assessment capability of on site Security personnel and i
agreements with LLEA to provide a response force when requested.
Based on the above analysis'and the enclosed LTDC PSP, Amendment 7 package, the District believes expanding Rancho Seco's existing 10 CFR 73.55 and 10 CFR 73, Appendix B and Appendix C exemptions to include fuel storage at the proposed ISFSI is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest.
The District has determined that the information contained in the LTDC PSP is not Safeguards Information; however, the enclosed information should be afforded the protection required under 10 CFR 2.790 as information exempt from public disclosure. This information should not be placed in the Public Document Room.
Members of your staff requiring additional information or clarification may contact Mr. Esteban Nava at (916) 452-3211, extension 4402.
Sincerely, ih,pN James R. Shetler W Deputy Assistant General Manager Nuclear B
Enclosures cc w/atch:
K. L. Perkins, NRC, Walnut Creek (2 copies) l
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