ML20236S173
| ML20236S173 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 07/15/1998 |
| From: | Fredrichs T NRC (Affiliation Not Assigned) |
| To: | Mellor R CONNECTICUT YANKEE ATOMIC POWER CO. |
| Shared Package | |
| ML20236S176 | List: |
| References | |
| TAC-MA98350, NUDOCS 9807240177 | |
| Download: ML20236S173 (6) | |
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UNITED STATES L
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WASHINGTON. D.c. 20066-0001
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July 15, 1998
' Mr. Russell A. Mellor l
.Vice President-Operations and Decommissioning Connecticut Yankee Atomic Power Company
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'362 Injun Hollow Road l.
East Hampton, Connecticut 06424-3099 i
SUBJECT:
EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR PART 73 AT j
HADDAM NECK PLANT (TAC NO. M98350) j
Dear Mr. Mellor:
The Commission has issued the enclosed exemption for the Haddam Neck Plant (HNP).' This
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exemption is in response to your application dated June 19,1997, in which you requested L
- exemption from certain portions of 10 CFR 73.55 to allow HNP to discontinue certain
' aspects of the security plan as a result of the permanently shutdown and defueled status of the reactor.
This exemption grants two of the original three requests: (1) devitalization of vital areas,
- and (2) reduction of security shift staffing. Both of these items are discussed in an L
. enclosure to this letter. Furthermore, pursuant to 10 CFR 50.54(p), these changes do not l
require further NRC approval and the site can incorporate these exemptions into the revised security plan and implement the plan upon receipt of this letter. Changes to the plan that
' incorporate these two specific exemptions should be submitted at the time of their implementation.
, The staff identified one exemption request in your June 19,1997, letter that currently is j
L not acceptable for permanently defueled reactor sites. This exemption would remove the f
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' requirement for the design ' vehicle barrier system at the HNP. The reason for the staff's l decision on this issue is discussed in the enclosure to this letter.
L in addition to requesting exemptions from 10 CFR 73.55, as discussed above, your letter of
' June 19,1997, trans.aitted your revised Defueled Site Security Plan for the HNP. The staff l-
- has completed its review of the security plan and has identified two proposed cha.1ges that l
Lcannot be implemented without prior approval of an exemption. Specifically, the changes include elimination of the external isolation zone for the protected area barrier and placement of the alarm station outside the protected area. 10 CFR 73.55(c)(3) requires isolation zones in outdoor areas adjacent to the protected area barrier that are necessary to permit assessment of activities in that area by the security organization.
10 CFR 73.55(e)(1) requires that the alarm station be located within the protected area and
~ that it be bullet-resisting. While the reduction of the size of the protected area at defueled reactors has resulted in NRC approval of other exemption requests to locate the alarm station outside the protected area, an alarm station that is not bullet-resisting could not i
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Mr. Russell A. Mellor ensure that a single act could not remove the capability of calling for assistance or otherwise responding to an alarm, as required by 10 CFR 73.55(e)(1). The staff's decisions on these two issues are also discussed in the enclosure to this letter. The proposed HNP Defueled Site Security Plan should be revised to include externalisolation zones and bullet-resistance of the Central Alarm Station prior to implementation.
Also enclosed is a copy of the Environmental Assessment and Finding of No Significant Impact related to your application.
Sincerely, W
Thomas L. Fredrichs, Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-213
Enclosures:
As stated
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Mr. Russell A. Mellor ensure that a single act could not remove the capability of calling for assistance or otherwise responding to an alarm, as required by 10 CFR 73.55(e)(1). The staff's decisions on these two issues are also discussed in the enclosure to this letter. The proposed HNP Defueled Site Security Plan should be revised to include externalisolation zones and bullet-resistance of the Central Alarm Station prior to implementation.
Also enclosed is a copy of the Environmental Assessment and Finding of No Significant impact related to your application.
Sincerely, Original signed by Thomas L. Fredrichs, Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-213
Enclosures:
As stated DISTRIBUTION:
HARD COPY E-MAIL (Docket File,50-213"2 li EHylton RBurrows (RAB2)
PUBLIC TFredrichs RDudley (RFD)
PDND r/f THarris (SER only) (TLH3)
MFairtile (MBF)
SCollins/FMiraglia OGC (015-B18)
PHarris (PWH1)
BBoger (Orders only)
GHill (2)
AMarkley (AWM)
JFoe SECY (Orders only)
JMinns (JLM3)
SWeiss BMcCabe (Region 1)
LThonus (LHT)
MBoyle (Exemptions only)
Region 1 MWebb (MKW)
MMasnik DWheeler (DXW)
'SEE PREVIOUS CONCURRENCE i
PSGB' PDND:(A)SC qfj TFrejrich ton RSanders RRosano MMasnik 7/jj/98 7/[ /98 6/25/98 7/2/98 7/ 6/98 OGC*
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s AHodgdon JRoe SCollins 7( /98 7/1/98 7/10/98 7/13/98 OFFICIAL RECORD COPY DOCUMENT NAME: G:\\SECY\\FREDRICH\\E-M98350 L____
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t Connecticut Yankee Atomic Power Co.
Haddam Neck Plant Docket No. 50-213 cc:
Lillian M. Cuoco, Esq.
Resident inspector Senior Nuclear Counsel Haddam Neck Plant Northeast Utilities Service Company c/o U.S. Nuclear Regulatory Commission P. O. Box 270 362 injun Hollow Road Hartford, CT 06141-0270 East Hampton, CT 06424-3099 Mr. Kevin T. A. McCarthy, Director Mr. James S. Robinson Monitoring and Radiation Division Manager, Nuclear Investments and Department of Environmental Administration Protection New England Power Company 79 Elm Street 25 Research Drive Hartford, CT 06106-5127 Westborough, MA 01582 Mr. Allan Johanson Mr. G. P. van Noordennen Assistant Director Manager - Nuclear Licensing Office of Policy and Management Northeast Utilities Service Company Policy Development and Planning 362 injun Hollow Road Division East Hampton, CT 06424-3099 450 Capitol Avenue-MS#52ENR P. O. Box 341441 Regional Administrator Hartford, CT 06134-1441 Region i U.S. Nuclear Regulatory Commission Mr. F. C. Rothen 475 Allendale Road Vice President - Work Services King of Prussia, PA 19406 Northeast Utilities Service Company P. O. Box 128 Board of Selectmen Waterford, CT 06385 Town Office Building Haddam, CT 06438 Mr. D. M. Goebel Vice President - Nuclear Oversight Northeast Utilities Service Company P. O. Box 128 Waterford, CT 06385 Mr. J. K. Thayer Recovery Officer, Nuclear Engineering and Support Northeast Utilities Service Company P. O. Box 128 Wsterford, CT 06385 f
g ENCLOSURE j
NRC STAFF EVALUATION OF EXEMPTION REQUESTS AND ADDITIONAL REQUIREMENTS
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I ISSUE:
Exemption from the requirements concerning the total number of guards and armed trained personnelimmediately available at the facility to fulfill response requirements. (ACCEPTABLE)
With the transition from an operating reactor to a permanently shutdown and defueled site, the size of the protected area has been reduced to one area that needs to be monitored and i
protected. For the defueled site, the licensee proposes a security program that provides both security-related equipment and a security force, some of whom are armed, to protect the spent fuel from acts of radiological sabotage. The armed security force members on site will be trained and quelified, and can react to different scenarios based on preplanned contingency events. In addition, the licensee has coordinated with the local law enforcement agency to respond to threats against the site.
l ISSUE:
Exemption for the devitalization of vital areas. (ACCEPTABLE)
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l The licensee is exempt from the requirements in 10 CFR 73.55(c)(1) for maintaining vital i.
areas / vital equipment based on the cessation of operations and the permanent removal of the nuclear fuel from the reactor to the spent fuel pool. Accordingly, the spent fuel building can now be treated as a protected area. Security systems essential for the protection of
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the spent fuel will include locked and alarmed doors, assessment and detection capability, access' controls, search requirements, and other commitments in the currently approved l-security plan.
ISSUE:
Exemption for the deletion of the vehicle barrier system. (NOT ACCEPTABLE)
The requirements in 10 CFR 73.55(c)(7)-(9) include provisions for a vehicle barrier system to prevent unauthorized access by a vehicle. The absence of vehicle barriers would allow a vehicle to be parked next to the spent fuel pool. A large amount of explosives (the exact amount of explosives is sensitive Safeguards Information)is transportable by a vehicle and the amount of damage that such an explosion might cause to the spent fuel pool and the j
fuel itself is unknown. Until the Commission has determined the potential effects of the explosives threat on public health and safety, vehicle barriers shall remain in place (to
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include the proper " standoff" distances to the spent fuel pool). Rearrangement of those barriers to eliminate devitalized areas will be acceptable.
2 ISSUE:
Security Plan change proposed to eliminate an externalisolation zone adjacent to t
j the protected area barrier. (NOT ACCEPTABLE)
An external isolation zone is required in accordance with 10 CFR 73.55(c)(3), for the purpose of maintaining a clear area outside the walls of the spent fuel building to assess unauthorized activities. A licensee is required to ensure assessment capability of the external protected area barrier either by using closed-circuit television (CCTV) cameras, which will be monitored in the Central Alarm Station, or by having permanently manned 1
posts to observe the barrier.
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ISSUE:
Security Plan proposes to locate the central alarm station outside the protected area and does not commit to making the central alarm station or the control room bullet-resisting. (ACCEPTABLE IN PART)
I R'egarding the lack of bullet-resistance for the new control room, since it is basically an administrative area and contains no equipment that would allow it to physically change any of the spent fuel pool parameters, the staff agrees that it does not have to be bullet-resistant. [As a point of clarification, the old reactor control room may be devitalized and it also does not need to be bullet-resistant, since the reactor contains no fuel and is not functional.]
The reduction in size of the protected area at defueled reactors has resulted in NRC approval of other exemption requests to locate the alarm station outside the protected area and such a request, in this case, is also acceptable. However, the alarm station must be continuously staffed and bullet resisting to ensure that a single act could not remove the capability of calling for assistance or otherwise responding to an alarm, as required by 10 CFR 73.55(e)(i). This portion of the request is, therefore, unacceptable.
Principal Contributor: R. Manili