ML23223A014
| ML23223A014 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 08/10/2023 |
| From: | John Lamb Plant Licensing Branch II |
| To: | Chamberlain A Southern Nuclear Operating Co |
| References | |
| L-2023-LLE-0018, L-2023-LLE-0021 | |
| Download: ML23223A014 (4) | |
Text
From: John Lamb Sent: Thursday, August 10, 2023 5:14 PM To: Chamberlain, Amy Christine Cc: Brown, R. Keith; Pournaras, DeLisa S.; Lowery, Ken G.; Joyce, Ryan M.;
Quarles, Adam Graham; Sparkman, Wesley A.
Subject:
Acceptance Review - SNC Fleet Exemption to 10 CFR 73.2, "Physical Barriers" (EPID Nos. L-2023-LLE-0018 and L-2023-LLE-0021)
- Amy, By letter dated July 7, 2023 (Agencywide Documents and Access Management System Accession Nos. ML23188A163 (public) and ML23188A164 (non-public), Southern Nuclear Operating Company (SNC) submitted an exemption request for ] for Title 10 of the Code of Federal Regulations (10 CFR) 73.2, Definitions for Physical barrier, for Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2, Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2, and Vogtle Electric Generating Plant (Vogtle), Units 1, 2, 3, and 4.
In accordance with the provisions of 10 CFR 73.5, SNC requests a permanent, partial exemption from the requirements of 10 CFR 73.2 for Hatch, Units 1 and 2, Farley, Units 1 and 2, and Vogtle, Units 1, 2, 3, and 4. The regulation at 10 CFR 73.2 requires, in part, that fences for a physical barrier be topped by three or more strands of barbed wire or similar material on brackets angled inward or outward between 30 and 45 degrees from the vertical. SNC requests an exemption since not all protected area physical barrier fencing sections meet this requirement.
The purpose of this e-mail is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this exemption request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
The regulation 10 CFR 73.2 states, in part:
Physical barrier means:
(1) Fences constructed of No. 11 American wire gauge, or heavier wire fabric, topped by three strands or more of barbed wire or similar material on brackets angled inward or outward between 30 and 45 from the vertical, with an overall height of not less than eight feet, including the barbed topping; (2) Building walls, ceilings and floors constructed of stone, brick, cinder block, concrete, steel or comparable materials (openings in which are secured by grates, doors, or covers of construction and fastening of sufficient strength such that the integrity of the wall is not lessened by any opening), or walls of similar construction, not part of a building, provided with a barbed topping described in paragraph (1) of this definition of a height of not less than 8 feet; or (3) Any other physical obstruction constructed in a manner and of materials suitable for the purpose for which the obstruction is intended.
The regulation 10 CFR 73.55(e)(1), 10 CFR 73.55(e)(2), and 10 CFR 73.55(e)(3) state:
Physical barriers. 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 § 73.55(b).
(1) 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 physical security plan, physical barriers, barrier systems, and their functions within the physical protection program.
(2) The licensee shall retain, in accordance with § 73.70, all analyses and descriptions of the physical barriers and barrier systems used to satisfy the requirements of this section, and shall protect these records in accordance with the requirements of § 73.21.
(3) Physical barriers must:
(i) Be designed and constructed to:
(A) Protect against the design basis threat of radiological sabotage; (B) Account for site-specific conditions; and (C) Perform their required function in support of the licensee physical protection program.
(ii) Provide deterrence, delay, or support access control.
(iii) Support effective implementation of the licensees protective strategy.
The NRC staff has reviewed your application and concluded that it does provide technical information in sufficient detail to enable the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed exemption in terms of regulatory requirements and the protection of public health and safety and the environment. Given the lesser scope and depth of the acceptance review as compared to the detailed technical review, there may be instances in which issues that impact the NRC staffs ability to complete the detailed technical review are identified despite completion of an adequate acceptance review. If additional information is needed, you will be advised by separate correspondence.
Based on the information provided in your submittal, the NRC staff has estimated that this licensing request will take approximately 340 hours0.00394 days <br />0.0944 hours <br />5.621693e-4 weeks <br />1.2937e-4 months <br /> for L-2023-LLE-0018 and 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br /> for L-2023-LLE-0021 hours to complete. The NRC staff expects to complete this review one year from the date of this email. If there are emergent complexities or challenges in our review that
would cause changes to the initial forecasted completion date or significant changes in the forecasted hours, the reasons for the changes, along with the new estimates, will be communicated during the routine interactions with the assigned project manager.
These estimates are based on the NRC staffs initial review of the application, and they could change, due to several factors including requests for additional information, and unanticipated addition of scope to the review. Additional delay may occur if the submittal is provided to the NRC in advance or in parallel with industry program initiatives or pilot applications.
If you have any questions, please contact me.
John G. Lamb, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Hearing Identifier: NRR_DRMA Email Number: 2190 Mail Envelope Properties (MN2PR09MB5084FDC77C0E7F96BEB553A3FA13A)
Subject:
Acceptance Review - SNC Fleet Exemption to 10 CFR 73.2, Physical Barriers (EPID Nos. L-2023-LLE-0018 and L-2023-LLE-0021)
Sent Date: 8/10/2023 5:14:11 PM Received Date: 8/10/2023 5:14:00 PM From: John Lamb Created By: John.Lamb@nrc.gov Recipients:
"Brown, R. Keith" <rkbrown@southernco.com>
Tracking Status: None "Pournaras, DeLisa S." <DSPOURNA@SOUTHERNCO.COM>
Tracking Status: None "Lowery, Ken G." <KGLOWERY@southernco.com>
Tracking Status: None "Joyce, Ryan M." <RMJOYCE@southernco.com>
Tracking Status: None "Quarles, Adam Graham" <AGQUARLE@southernco.com>
Tracking Status: None "Sparkman, Wesley A." <WASPARKM@southernco.com>
Tracking Status: None "Chamberlain, Amy Christine" <ACCHAMBE@southernco.com>
Tracking Status: None Post Office: MN2PR09MB5084.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 6074 8/10/2023 5:14:00 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: