ML23047A006
| ML23047A006 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/21/2023 |
| From: | Samson Lee Plant Licensing Branch IV |
| To: | Gerfen P Pacific Gas & Electric Co |
| Lee S, 301-415-3158 | |
| References | |
| EPID L-2022-LLA-0029 | |
| Download: ML23047A006 (1) | |
Text
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION February 21, 2023 Ms. Paula Gerfen Senior Vice President, Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant P.O. Box 56, Mail Code 104/6 Avila Beach, CA 93424
SUBJECT:
DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RE: ALTERNATIVE SECURITY MEASURES FOR EARLY WARNING SYSTEM (EPID L-2022-LLA-0029)
Dear Ms. Gerfen:
By letter dated February 16, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22048A526), Pacific Gas and Electric Company (PG&E or the licensee) submitted a license amendment request (LAR) for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon), for approval of alternative security measures for the implementation of an early warning system. The U.S. Nuclear Regulatory Commission (NRC) and the licensee staff held a closed public meeting on April 27, 2022 (ML22126A016). The NRC staff conducted a site visit on August 2-3, 2022. By letters dated June 20, 2022 (ML22173A135), and September 8, 2022 (ML22251A295), the licensee provided a supplement and a revision to the LAR, respectively.
Based on its review of the LAR, as supplemented, the NRC staff determined that, to complete its review, it needs a response to the enclosed request for additional information (RAI). The NRC staff may have additional RAIs. The PG&E staff determined that a draft RAI clarification call was unnecessary. The NRC staff plans to hold a closed public meeting on March 7, 2023.
The PG&E staff requested, and NRC agreed, to an RAI response by March 23, 2023.
The NRCs RAI is enclosed. The NRC staff has determined that the RAI contains security-related information pursuant to Title 10 of the Code of Federal Regulations (10 CFR)
Section 2.390, Public inspections, exemptions, request for withholding. Security-related information, which is provided as Enclosure 1, is indicated by OUO-SRI portion markings within parentheses at the beginning of each paragraph that contains sensitive information.
Accordingly, the NRC staff has prepared a redacted publicly available version of the RAI, which is provided as Enclosure 2.
to this letter contains security-related information. When separated from, this document is DECONTROLLED.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. Please note that if PG&E does not respond to this request by the agreed upon date or provide an acceptable alternate date, we may deny PG&Es application for amendment under the provisions of Title 10 of the Code of Federal Regulations Section 2.108. Please contact me if circumstances result in the need to revise the agreed upon response date.
In addition, the LAR review is complex and a first-of-a-kind licensing application. Given this complexity and the remaining open questions on the request, the NRC will not meet the estimated schedule and resources provided when the application was accepted. The NRC staff plans to revise the estimated review schedule and resource after review of the RAI response and will communicate with the PG&E staff.
If you have any questions, please contact me at 301-415-3168 or via email at Samson.Lee@nrc.gov.
Sincerely,
/RA/
Samson S. Lee, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323
Enclosures:
- 1. RAI (security-related information; nonpublic)
- 2. RAI (redacted version; public) cc: Listserv without Enclosure 1
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION ENCLOSURE 2 (REDACTED)
REQUEST FOR ADDITIONAL INFORMATION PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323 Security-related information pursuant to Section 2.390 of title 10 of the Code of Federal Regulations has been redacted from this document.
Redacted information is identified by black space.
OFFICIAL USE ONLY SECURITY RELATED INFORMATION OFFICIAL USE ONLY SECURITY RELATED INFORMATION (U) REQUEST FOR ADDITIONAL INFORMATION (U) RELATED TO LICENSE AMENDMENT REQUEST RE:
(U) ALTERNATIVE SECURITY MEASURES FOR EARLY WARNING SYSTEM (U) FACILITY OPERATING LICENSE NOS. DPR-80 AND DPR-82 (U) PACIFIC GAS AND ELECTRIC COMPANY (U) DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 (U) DOCKET NOS. 50-275 AND 50-323 1.0 (U) BACKGROUND (U) By letter dated February 16, 2022 (Agencywide Documents Access and Management System Accession No. ML22048A526), Pacific Gas and Electric Company (PG&E or the licensee) submitted a license amendment request (LAR) for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon or DCPP), for approval of alternative security measures for the implementation of an early warning system (EWS). The U.S. Nuclear Regulatory Commission (NRC) and the licensee staff held a closed public meeting on April 27, 2022 (ML22126A016). The NRC staff conducted a site visit on August 2-3, 2022. By letters dated June 20, 2022 (ML22173A135), and September 8, 2022 (ML22251A295), the licensee provided a supplement and a revision to the LAR, respectively.
(U) Based on its review of the LAR, the NRC staff determined that, to complete its review, it needs a response to its requests for additional information (RAIs) in section 2.0 below.
2.0 (U) REQUEST FOR ADDITIONAL INFORMATION (U) The RAI questions below are based on the information in the September 8, 2022, request.
2.1 (U) Attachment 2, Section 3.A., Alternative to 10 CFR 73.55(i)(2)
(U) RAI-1 (U) Regulatory Basis:
(U) Consistent with Title 10 of the Code of Federal Regulations (10 CFR) 73.55(b)(ii), the licensee must [p]rovide defense-in-depth through the integration of systems, technologies, programs, equipment, supporting processes, and implementing procedures as needed to ensure the effectiveness of the physical protection program.
(U) Consistent with 10 CFR 73.55(c)(3), [t]he 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.
OFFICIAL USE ONLY SECURITY RELATED INFORMATION OFFICIAL USE ONLY SECURITY RELATED INFORMATION (U) Consistent with 10 CFR 73.55(e)(1)(ii), the licensee shall [d]escribe in the physical security plan, physical barriers, barrier systems, and their functions within the physical protection program.
(U) The requirement in 10 CFR 73.55(i)(2) states, [i]ntrusion 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.
(U) The requirements in 10 CFR 73.55(i)(3) and (i)(3)(i) state, [t]he licensees intrusion detection and assessment systems must be designed to: [p]rovide visual and audible annunciation of the alarm.
(U) The requirements in Appendix B to 10 CFR Part 73, Section II, Training and qualifications, state, in part:
(U) A. Training requirementsEach individual who requires training to perform assigned security-related job tasks or job duties as identified in the licensee physical security or contingency plans shall, prior to assignment, be trained to perform these tasks and duties in accordance with the licensee or the licensee's agent's documented training and qualifications plan. The licensee or the agent shall maintain documentation of the current plan and retain this documentation of the plan as a record for three years after the close of period for which the licensee possesses the special nuclear material under each license for which the plan was developed and, if any portion of the plan is superseded, retain the material that is superseded for three years after each change.
(U) The requirements in Appendix B to 10 CFR Part 73, Section VI C., Duty Training, state:
(U) 1. Duty training and qualification requirements. All personnel who are assigned to perform any security-related duty or responsibility shall be trained and qualified to perform assigned duties and responsibilities to ensure that each individual possesses the minimum knowledge, skills, and abilities required to effectively carry out those assigned duties and responsibilities.
(U) (a) The areas of knowledge, skills, and abilities that are required to perform assigned duties and responsibilities must be identified in the licensees Commission-approved training and qualification plan.
(U) (b) Each individual who is assigned duties and responsibilities identified in the Commission-approved security plans, licensee protective strategy, and implementing procedures shall, before assignment:
(U) (1) Be trained to perform assigned duties and responsibilities in accordance with the requirements of this appendix and the Commission-approved training and qualification plan.
(U) (2) Meet the minimum qualification requirements of this appendix and the Commission-approved training and qualification plan.
(U) Issue (U) Request:
(1)
(2)
(3)
OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION (U) (3) Be trained and qualified in the use of all equipment or devices required to effectively perform all assigned duties and responsibilities.
(4)
(U) The licensee request is silent on whether the training and qualification of the EWS operators are documented in all applicable sections of the site Security Plan (e.g., the Training and Qualification Plan critical task matrix, etc.). Provide confirmation that all applicable sections of the DCPP Security Plans will clearly identify the training and qualifications of the EWS positions.
(U) RAl-2 (U) Regulatory Basis:
(U) The requirements of 10 CFR 73.55(e)(9)(vi) state in part, "At a minimum, the following shall be located within a vital area: (A) The secondary power supply systems for alarm annunciation equipment... ".
OFFICl,C.,b US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION
(U) Issue:
(U) Request:
OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION (U) Considering that the EWS is declared a required system by the licensee, the NRC staff requests the licensee to confirm that the secondary power supply for the EWS is located in a vital area, in accordance with 10 CFR 73.55(e)(9)(vi)(A).
(U) RAl-3 (U) Regulatory Basis:
(U) The requirement in 1 O CFR 73.55(i)(2) states, "[i]ntrusion 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."
(U) The requirement in 1 O CFR 73.55(i)(4) states, "[b]oth alarm stations required by paragraph (i)(2) of this section must be designed and equipped to ensure that a single act, in accordance with the design basis threat of radiological sabotage defined in § 73.1 (a)(1 ), cannot disable both alarm stations. The licensee shall ensure the survivability of at least one alarm station to maintain the ability to perform the following functions: (A) Detect and assess alarms; (B) Initiate and coordinate an adequate response to an alarm; (C) Summon offsite assistance; and (D)
Provide command and control."
(U) Issue:
(U) Request:
(1)
OFFICl,C.,b US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION
(2)
(3)
(4)
OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION a. (U) communicating with the site control room, SAS, and any other relevant site office;
- b. (U) coordinating an adequate response to an EWS alarm;
- c. (U) summoning offsite assistance; and
- d. (U) providing command and control of the contingency response.
2.2 (U) Attachment 2. Section 3.8.* Alternative to 10 CFR 73.55{i)(4)(ii)(F)
(U) RAl-4 (U) Regulatory Basis:
(U) The requirement in 1 0 CFR 73.SS(b )(3)(ii) states that the physical protection program must
"[p]rovide defense-in-depth through the integration of systems, technologies, programs, equipment, supporting processes, and implementing procedures as needed to ensure the effectiveness of the physical protection program."
(U) Consistent with 10 CFR 73.55(a)(2), "[t]he security plans must identify, describe, and account for site-specific conditions that affect the licensee's capability to satisfy the requirements of this section."
(U) Consistent with 10 CFR 73.55(a)(3), "[t]he licensee is responsible for maintaining the onsite physical protection program in accordance with Commission regulations through the implementation of security plans and written security implementing procedures."
(U) Consistent with 10 CFR 73.55(i)(4 )(ii)(F), the licensee is required to; "[e]nsure that an alarm station operator cannot change the status of a detection point or deactivate a locking or access OFFICl,C.,b US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION
OFFICIAL USE ONLY SECURITY RELATED INFORMATION OFFICIAL USE ONLY SECURITY RELATED INFORMATION control device at a protected or vital area portal, without the knowledge and concurrence of the alarm station operator in the other alarm station.
(U) The requirements in 10 CFR 73.55(n). Maintenance, testing, and calibration, state in part:
(8) Security equipment or systems shall be tested in accordance with the site maintenance, testing and calibration procedures before being placed back in service after each repair or inoperable state.
(U) The requirements in Appendix B to 10 CFR Part 73, Section II., Training and qualifications, state, in part:
(U) A. Training requirementsEach individual who requires training to perform assigned security-related job tasks or job duties as identified in the licensee physical security or contingency plans shall, prior to assignment, be trained to perform these tasks and duties in accordance with the licensee or the licensee's agent's documented training and qualifications plan. The licensee or the agent shall maintain documentation of the current plan and retain this documentation of the plan as a record for three years after the close of period for which the licensee possesses the special nuclear material under each license for which the plan was developed and, if any portion of the plan is superseded, retain the material that is superseded for three years after each change.
(U) The requirements in Appendix B to 10 CFR Part 73, Section VI C., Duty Training, state:
(U) 1. Duty training and qualification requirements. All personnel who are assigned to perform any security-related duty or responsibility shall be trained and qualified to perform assigned duties and responsibilities to ensure that each individual possesses the minimum knowledge, skills, and abilities required to effectively carry out those assigned duties and responsibilities.
(U) (a) The areas of knowledge, skills, and abilities that are required to perform assigned duties and responsibilities must be identified in the licensees Commission-approved training and qualification plan.
(U) (b) Each individual who is assigned duties and responsibilities identified in the Commission-approved security plans, licensee protective strategy, and implementing procedures shall, before assignment:
(U) (1) Be trained to perform assigned duties and responsibilities in accordance with the requirements of this appendix and the Commission-approved training and qualification plan.
(U) (2) Meet the minimum qualification requirements of this appendix and the Commission-approved training and qualification plan.
(U) (3) Be trained and qualified in the use of all equipment or devices required to effectively perform all assigned duties and responsibilities.
(U) Issue:
(U) Request:
OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION (1)
(U) Provide confirmation that there are procedures in place that all EWS operators use when assuming post and that they are trained and qualified on these procedures.
(2)
(U) Provide confirmation that the upgrades listed within the September 8, 2022, request will be entered in all applicable sections of the site's Security Plan and implementing procedures in accordance with 10 CFR 73.55(b)(ii), 10 CFR 73.55(a)(2),
1 O CFR 73.55(a)(3), and that these EWS operators are trained and qualified on these upgrades in accordance with Appendix B to Part 73 of 10 CFR,Section II., "Training and qualifications," and Appendix B to Part 73,Section VI C., "Duty Training".
(U) RAl-5 (U) Regulatory Basis:
(U) The requirement in 10 CFR 73.55(i)(4(ii)(F) states the licensee shall "[e]nsure that an alarm station operator cannot change the status of a detection point or deactivate a locking or access control device at a protected or vital area portal, without the knowledge and concurrence of the alarm station operator in the other alarm station."
(U) Issue:
OFFICl,C.,b US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION
OJ:lilGIAb--USe-ONb¥ SiCURl+¥-Re*bA+eO-'RMA+10N (U) Request:
(U)Bfil:.§ (U) Regulatory Basis:
(U) The requirement in 10 CFR 73.55(aX2) states that "[t]he security plans must identify, describe, and account for site-specific conditions that affect the licensee's capability to satisfy the requirements of this section."
(U) The requirement in 10 CFR 73.55(aX3) states that "[t]he licensee is responsible for maintaining the onsite physical protection program in accordance with Commission regulations through the implementation of security plans and written security implementing procedures."
(U) The requirement in 10 CFR 73.55(d) states that "[t]he licensee shall establish and maintain a security organization that is designed, staffed, trained, qualified, and equipped to implement the physical protection program in accordance with the requirements of this section."
(U) The requirements in Appendix B to 10 CFR Part 73, Section VIC., "Duty Training," state:
(U) 1. Duty training and qualification requirements. All personnel who are assigned to perform any security-related duty or responsibility shall be trained and qualified to perform assigned duties and responsibilities to ensure that each individual possesses the minimum knowledge, skills, and abilities required to effectively carry out those assigned duties and responsibilities.
(U) (a) The areas of knowledge, skills, and abilities that are required to perform assigned duties and responsibilities must be identified in the licensee's Commission-approved training and qualification plan.
(U) (b) Each individual who is assigned duties and responsibilities identified in the Commission-approved security plans, licensee protective strategy, and implementing procedures shall, before assignment:
(U) (1) Be trained to perform assigned duties and responsibilities in accordance with the requirements of this appendix and the Commission-approved training and qualification plan.
(U) (2) Meet the minimum qualification requirements of this appendix and the Commission-approved training and qualification plan.
OFFICIAb USi 0Nb¥ SiCURl+¥(bA+eO)RMATION
(U) Issue:
(U) Request:
(1)
(2)
(3)
OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION (U) (3) Be trained and qualified in the use of all equipment or devices required to effectively perform all assigned duties and responsibilities.
2.3 (U) Attachment 2. Section 3.C.* Alternative to 73.550)(4 ){ii)(G)
(U) RAl-7 (U) Regulatory Basis:
(U) The requirement in 10 CFR 73.55(i)(4)(ii)(G) states that licensees shall "[e]nsure that operators in both alarm stations are knowledgeable of the final disposition of all alarms."
(U) The requirement in 10 CFR 73.55 (i)(4)(i) states, "[b]oth alarm stations required by paragraph (i)(2) of this section must be designed and equipped to ensure that a single act, in accordance with the design basis threat of radiological sabotage defined in § 73.1 (a)(1 ), cannot disable both alarm stations. The licensee shall ensure the survivability of at least one alarm station to maintain the ability to perform the following functions: (A) Detect and assess alarms; OFFICl,C.,b US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION
OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION (8) Initiate and coordinate an adequate response to an alarm; (C) Summon offsite assistance; and (D) Provide command and control."
(U) Issue:
(U) Request:
(1)
(2)
(OUO-SRI)
(3) b.
(U) have sufficient time after becoming knowledgeable of an EWS alarm to be able to perform the alarm station functions required by 1 O CFR 73.55(i)(4)(i)(A)--(D) and enable the licensee to meet the performance objective and requirement in 10 CFR 73.55(b).
OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION
OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION 2.4 (U) Attachment 2. Section 3.0.* Alternative to 10 CFR 73.550}(3}0v}
(U) RAl-8 (U) Regulatory Basis:
(U) The requirements in 10 CFR 73.55(i)(3) and (i)(3)(iv) state that a "licensee's intrusion detection and assessment systems must be designed to" "[e]nsure that alarm devices to include transmission lines to annunciators are tamper indicating and self-checking."
(U) Issue:
(U) The requirements in 10 CFR 73.55(i)(3)(iv) apply to all alarm devices that are necessary for a licensee to meet the performance objective and requirements in 10 CFR 73.55(b). The NRC staff considers an alarm device to be any nonhuman element that initiates, transmits, or receives an alarm signal (i.e., all equipment from the alarm sensors to the annunciators).
(U) Request:
(1)
(U) Provide a complete list of EWS alarm devices (i.e., all nonhuman EWS elements, from sensors to annunciators, that initiate, transmit, or receive an alarm signal) that addresses the following elements:
- a. (U) A description of each EWS alarm device, the function(s) that it performs (i.e.,
initiating, transmitting, or receiving alarm signals), and its operating parameters that are relevant to the tamper-indicating and self-checking requirements (U) For example, for each alarm device, at what operating parameter(s) or operating parameter threshold(s) is a tamper or self-checking alarm signal generated?
b.
(U) The specific location where each EWS alarm device is installed, including the location of all cabling that carries an EWS intrusion, tamper, or self-checking alarm; also consider these questions or points:
(U) How is the owner controlled area defined at Diablo Canyon? Is it the area between the EWS barrier and the protected area (PA) isolation zone, the area outside the EWS barrier, a combination of the two, or something else?
OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION
OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION *
(U) Specify whether an EWS alarm device is located within a detection area covered by an EWS sensor. For example, Regulatory Guide 5.44, section 1.5 (ML003739217) indicates that when the processing electronics are separated from the alarm system sensors and are not located within the detection area of the sensors, the signal lines linking the sensors to the processing electronics should be supervised.
c.
(U) How tampering is automatically detected and annunciated for every EWS alarm device, including all continuous cable runs when line supervision is not used; consider the following points:
(U) For any EWS alarm device that is not protected with automatic tamper detection and annunciation, describe the alternative measure(s) used to provide an equivalent level of tamper protection as the protection required by 10 CFR 73.55(i)(3)(iv).
(U) For example, a licensee could demonstrate that it relies on physical access control to an alarm device at all times in lieu of automatic tamper detection, consistent with sections 1 and 4 in NUREG/CR-5723, "Security System Signal Supervision," dated September 1991 (ML20079H291 ).1 (U) NUREG/CR-5723 is also available in a more legible format on the U.S. Department of Energy's Office of Scientific and Technical Information (OSTI) website at https://Www.osti.gov/servlets/purl/6276408.
OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION
(2)
(3) 2 OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION d.
(U) How the EWS is designed to automatically indicate when:
(U) Any individual EWS alarm device fails, 0
(U) The entire EWS fails, and (U) The EWS is on standby power 0
e.
(U) The method used to provide the same level of line supervision for tamper switches and alarm signal transmission media, regardless of whether these alarm devices are in the secure or access mode.2 (U) Describe the controls for the operation and sensitivity of the EWS, including access point controls, and confirm whether all those controls are in an enclosure(s) that is protected by a tamper switch.
(U) Describe the test procedure(s) used to verify that, for each EWS alarm zone and tamper switch, tamper protection and line supervision capabilities are functional in both access and secure modes. Describe the results of tamper-protection and line supervision testing that the licensee has conducted within the last 30 days.
(U) Appendix A to RG 5.44 defines secure and access modes.
OFFICIAb US!! ONbY Sl!CURITY Rl!bATl!0 INFORMATION
ML23047A001 (Non-Public)
ML23047A006 (Public)
- via email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NSIR/DPCP/RSB/BC(A)
NAME SLee PBlechman CNolan DATE 2/15/2023 2/16/2023 2/15/2023 OFFICE NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME JDixon-Herrity SLee DATE 2/16/2023 2/21/2023