ML24318C482
| ML24318C482 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/05/2024 |
| From: | Samson Lee Plant Licensing Branch IV |
| To: | Gerfen P Pacific Gas & Electric Co |
| Lee S, 301-415-3168 | |
| References | |
| EPID L-2024-LLA-0048, EPID L-2024-LLE-0016 | |
| Download: ML24318C482 (1) | |
Text
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION December 5, 2024 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 THE EARLY WARNING SYSTEM (EPID L-2024-LLA-0048 AND EPID L-2024-LLE-0016)
Dear Paula Gerfen:
By letter dated April 15, 2024 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML24108A111), Pacific Gas and Electric Company (PG&E, 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 the early warning system (EWS) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 73.55(r). By the same letter, the licensee also submitted an exemption request from 10 CFR 73.55(e)(9)(vi)(A) for the EWS in accordance with 10 CFR 73.5.
Based on its review of the LAR and exemption request, the U.S. Nuclear Regulatory Commission (NRC, the Commission) staff determined that, to complete its review of the exemption request, it needs a response to the enclosed request for additional information (RAI).
The NRC staff may have additional RAIs. The NRC staff held a draft RAI clarification call with the licensee staff on December 5, 2024. The licensee staff requested, and the NRC staff agreed, to an RAI response by January 16, 2025.
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, NRC may deny PG&Es application for amendment under the provisions of 10 CFR Section 2.108, Denial of application for failure to supply information. Please contact me if circumstances result in the need to revise the agreed upon response date.
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; non-public)
- 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 VERSION)
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 EXEMPTION REQUEST FROM (U) 10 CFR 73.55(e)(9)(vi)(A) 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 April 15, 2024 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML24108A111), Pacific Gas and Electric Company (PG&E, 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 the early warning system (EWS) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 73.55(r). By the same letter, the licensee also submitted an exemption request from 10 CFR 73.55(e)(9)(vi)(A) for the EWS in accordance with 10 CFR 73.5. Based on its review of the LAR and exemption request, the U.S. Nuclear Regulatory Commission (NRC, the Commission) staff determined that, to complete its review of the exemption request, it needs a response to its requests for additional information (RAIs) in section 2.0 below.
2.0 (U) REQUEST FOR ADDITIONAL INFORMATION (U) RAI-1 (U) Regulatory Basis (U) The regulation at 10 CFR 73.1(a)(1) states that the design basis threat (DBT) of radiological sabotage includes:
(U) (i) A determined violent external assault, attack by stealth, or deceptive actions, including diversionary actions, by an adversary force capable of operating in each of the following modes: A single group attacking through one entry point, multiple groups attacking through multiple entry points, a combination of one or more groups and one or more individuals attacking through multiple entry points, or individuals attacking through separate entry points, with the following attributes, assistance and equipment:
(U) (A) Well-trained (including military training and skills) and dedicated individuals, willing to kill or be killed, with sufficient knowledge to identify specific equipment or locations necessary for a successful attack;
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION (U) RAI-3 (U) Regulatory Basis (U) The regulation at 10 CFR 73.1(a)(1) states that the DBT of radiological sabotage includes:
(U) (i) A determined violent external assault, attack by stealth, or deceptive actions, including diversionary actions, by an adversary force capable of operating in each of the following modes: A single group attacking through one entry point, multiple groups attacking through multiple entry points, a combination of one or more groups and one or more individuals attacking through multiple entry points, or individuals attacking through separate entry points, with the following attributes, assistance and equipment:
(U) (A) Well-trained (including military training and skills) and dedicated individuals, willing to kill or be killed, with sufficient knowledge to identify specific equipment or locations necessary for a successful attack; (U) (B) Active (e.g., facilitate entrance and exit, disable alarms and communications, participate in violent attack) or passive (e.g., provide information), or both, knowledgeable inside assistance; (U) (C) Suitable weapons, including hand-held automatic weapons, equipped with silencers and having effective long range accuracy; (U) The regulation at 10 CFR 73.55(e)(3) requires that Physical barriers must:
(U) (i) Be designed and constructed to:
(U) (A) Protect against the design basis threat of radiological sabotage; (U) (B) Account for site-specific conditions; and (U) (C) Perform their required function in support of the licensee physical protection program, (U) (ii) Provide deterrence, delay, or support access control.
(U) (iii) Support effective implementation of the licensees protective strategy.
(U) The regulation at 10 CFR 73.55(e)(9)(i) requires that, Vital equipment must be located only within vital areas, which must be located within a protected area so that access to vital equipment requires passage through at least two physical barriers, except as otherwise approved by the Commission and identified in the security plans.
ML24318C483 (Non-Public)
ML24318C482 (Public)
- via email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NSIR/DPCP/RSB/BC NAME SLee PBlechman AMarshall DATE 11/13/2024 11/14/2024 11/11/2024 OFFICE NRR/DORL/LPL4/BC(A)
NRR/DORL/LPL4/PM NAME TNakanishi SLee DATE 12/5/2024 12/5/2024