ML20249B600

Requests Exemptions from Requirements of 10CFR73.55(e)(1) & (f)(1) W/Respect to Continuous Manning of Central Alarm Station for Plant.Encl Withheld (Ref 10CFR2.790(a))

ML20249B600
Person / Time
Site:	Vogtle
Issue date:	06/15/1998
From:	Woodard J SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LCV-1134, NUDOCS 9806230359
Download: ML20249B600 (4)

Text

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A J.D. Woodard Southern Nuclear Operating Company. Inc.

- Executwe Vice Prescent 40 invemess Center Parkway PO Box 1295 Birmingham, Alabama 35201 Tel 205 992 5086 SAFEGUARDS SOUTHERN L k INFORMATION COMPANY ONCE DETACHED FROM THtS June 15, 1998 PACKAGE THIS PAGE IS Energy to Serve Your World" DECONTROLLED. LCV-1134 Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Vogtle Electric Generating Plant Request for Exemption from the Requirements of 10 CFR 73.55(eWl) and (fRI) for a Defined Deolovment Strategy Ladies and Gentleman:

In accordance with the requirements of Title 10 Code of Federal Regulations (CFR) 73.5, " Specific Exemptions", this letter requests exemptions from the requirements of 10 CFR 73.55(e)(1) and (f)(1) with respect to continuous manning of the Central Alarm Station for the Vogtle Electric Generating Plant (VEGP) during a specific contingency. Corresponding changes will be made in VEGP's Physical Security and Contingency Plan relative to the Central Alarm Station (CAS) manning during the specific contingency discussed herein upon exemption approval.

l In accordance to 10 CFR 73.55(a), the Commission may authorize a licensee to provide alternative measures for protection against radiological sabotage providing the licensee demonstrates that the alternative measures have "the same high assurance objective" and meet "the general performance requirements" of the regulation and "the overall level of system performance provides protection against radiological sabotage equivalent to that which would be provided" by the regulation.

Rule Exemntion Reauest and Proposed Revision to Physical Security Plan Title 10 CFR 73.55(e)(1), " Detection Aids" and (f)(1), " Communication Requirements", specify that all alarms which annunciate in the licensee's facility must annunciate in a continuously manned CAS located within the protected area and in at least one other continuously manned station not necessarily on site, and that each armed response individual on duty shall be capable of maintaining continuous communication with an individual in each continuously manned alarm station. The "other continuously manned station" is commonly referred to as the " Secondary Alarm Station (SAS)." In accordance with 10 CFR 73.55(h), , f each licensee shall establish, maintain and follow an NRC approved safeguards contingency plan for

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i SAFEGUARDS INFORMATION U. S. Nuclear Regulatory Commission ON S Page 2 of 4 T G S DECONTROLLED. LCV-Il34 responding to threats, thefts and radiological sabotage. If this exemption is granted, applicable sections of the VEGP Physical Security and Contingency Plan and the Vogtle Security Response Plan will be revised to reflect that a deployment strategy which allows the CAS to be abandoned is authorized and may be utilized in response to this contingency. During any contingency, armed response individuals have alternative, personal connoication capabilities so that command and control is not lost and continuous communication is maintained between security force personnel. The details of the specific contingency and deployment strategy are described in the Enclosure.

The Enclosure contains safeguards information that has been determined to be exempt from public disclosure in accordance with 10 CFR 73.21, " Safeguards Infonnation." Therefore, it should not be placed in the NRC Public Document Room (PDR). This letter, without the Enclosure, may be placed in the PDR in accordance with 10 CFR 2.790 (a).

Hasis for the Exemption Request Pursuant to 10 CFR 73.5, " Specific Exemptions," the Commission may, upon application of any interested person, grant such exemptions in Part 73 as it determines are authorized by law and will not endanger life or property for the common defense and security and are otherwise in the public interest. Pursuant to 10 CFR 73.55, the Commission may authorize the licensee to provide alternative measures for protection against radiological sabotage providing the licensee demonstrates that the alternative measures have "the same high assurance objective" and meet "the general performance requirements" of the regulation and "the overall level of system perfonnance provides protection against radiological sabotage equivalent" to that which would be provided by the regulation.

In 1995, VEGP began preparations for the NRC's Operational Safeguards Response Evaluation (OSRE) and initiated a new target analysis based upon a risk assessment of critical equipment. A new interdiction l strategy and a revised deployment plan for various scenarios were developed Although prior strategies and I

deployment plans werejudged to fulfill regulatory requirements, the new strategy and revised deployment plan iacreased security effectiveness. As the OSRE report dated May 21,1996, observed, the improved interdiction logic was an " intelligent and efficient use of response assets, and demonstrated an effective protection strategy."

For a subset of scenarios, as identified in the Enclosure, in which the CAS may be intermittently unmanned, the VEGP Security Response Plan continues to achieve high assurance of security efh.:iveness and is consistent with the overall purpose of the NRC regulations for response to design basis threats (DBT). The requested exemption, if granted, would only be applicable to an actual event; as in the past, a " shadow force" would be utilized during training drills and practice scenarios to permit continuous manning of the CAS. NRC approval of the requested exemption would permit a more effective and efficient deployment logic for response, and a corresponding strategy for inclusion to the VEGP Security Response Plan.

Cost Benefit l l

Southern Nuclear Operating Company has estimated savings for this action, assuming the remaining plant life of 30 years and one (1) full-time equivalent armed responder, for a total of $4,024,987. The full time equivalent would be required for compliance with 7166/4/n 'M W n Mnn the scenarios identified in Enclosure.

SAFEGUARDS INFORMATION ONCE DETACHED FROM THIS PACKAGE THIS PAGE IS DECONTROLLED.

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I SAFEGUARDS INFORMATION ONCE DETACHED FROM THIS PACKAGE THIS PAGE IS U. S. Nuclear Regulatory Commission DECONTROLLED. Page 3 of 4 I

LCV-ll34 Special Circumstances Title 10 CFR 50.12 authorizes the Commission to grant an exemption from the requirements of specific regulations when "special circumstances" are present. This criteria does not add substantive requirements to the application of 10 CFR 73.5, but does add clarity to the exemption process and provide additional guidance to licensees and the public on when exemptions may be appropriate [50 Federal Register, November 14,1985]. Among several situations, "special circumstances are present whenever . .

application of the regulation would not serve the underlying purpose of the rule or is not necessary to l achieve the underlying purpose of the rule," Title 10 CFR 50.12(a)(2)(ii). Southern Nuclear believes that such circumstances are present in this instance and the requested exemption is warranted in that, with the implementation of the particular deployment strategy permitted by the exemption, the general performance objective and requirenients of 10 CFR 73.55(a) will be met and the overall level of security planning and performance will continue to provide an exceedingly high assurance of protection against radiological ~

sabotage equivalent to the performance which would be provided with literal compliance of 73.55(er 3 and (f)(1) during deployment.

Previous ReInted Submittals:

The subject deployment strategy was previously addressed in SNC letter LCV-0811 A dated November 25, 1996, "VEGP Physical Security and Contingency Plan - Amendment 31, Revision 1" and submitted in accordance with the requirements of 10 CFR 50.90. By NRC letter, Louis L. Wheeler to C. K. McCoy dated April 30,1997, " Denial of Request for Approval of Revision 1 to Amendment 31, VEGP Physical Security and Contingency Plan," the staff determined that the requested Security Plan change should not be approved. The subject deployment strategy can also be located under several other correspondences: NRC TAC Nos. M95903 and M95904; NRC Inspection Report Nos. 50-424.,425/97-03-03 and Notice of Violation dated April 4,1997; SNC's NOV response, letter no LCV-1009- A, dated May 27,1997; and closed by NRC letter dated July 31,1997, from Johns P. Jaudon to C. K. McCoy. The granting of the requested exemption will not change or modify those prior, related matters. The requested exemption will permit this strategy to be implemented and the corresponding VEGP Physical Security and Contingency Plan changes to be incorporated under the requirements of 10 CFR 50.54 (p), without re-submission pursuant to 10 CFR 50 90. Southern Nuclear Operating Company requests review and approval of this exemption requests by September,1998.

If there are any questions, please do not hesitate to contact this office.

Sincerely, J. D. Voodard l CKM/AD/AFS Enclosure and xe: (Continued next page) SAFEGUARDS INFORMATION ONCE DETACHED FROM THiS PACKAGE THIS PAGE IS =

DECONTROLLED.

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a SAFEGUARDS INFORMATION l . . ONCE DETACHED FROM THIS p388 4 0g4 U. S. Nuclear Regulatory Commission PACKAGE THIS PAGE IS i

DECONTROLLED. LCV-1134 Enclosure (SGI) : " Justification and Specific Contingency Relative to Request for Exemption from the Requirements of 10 CFR 73.55(e)(1) and (f)(1)"

xc: Southem Nuclear Ooeratina Comnany Mr. J. B. Beasley Jr. (w/o)

Mr. M. Sheibani (w/o)

Ms. R. H. Parker (w)

SNC Document Management (w/o)

U. S. Nuclear Reculatory Commission Mr. L. A. Reyes, Regional Administrator (w)

Mr. D. H. Jaffe, Senior Project Manager, NRR (w/o)

Mr. J. Zeiler, Senior Resident Inspector, VEGP (w/o)

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l SAFEGUARDS  !

INFORMATION ONCE DETACHED FROM THIS PACKAGETHIS PAGE IS DECONTROLLED.

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