RA-09-019, Request for Exemptions from Physical Security Requirements
| ML093370140 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/30/2009 |
| From: | Duncan R Carolina Power & Light Co, Progress Energy Carolinas, Progress Energy Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RA-09-019 | |
| Download: ML093370140 (16) | |
Text
Attachment 1 to this letter contains WSECURITY-RELATED INFORMATION -WITHHOLD 10 CFR 73.5 UNDER 10 CFR 2.390.
PO Box 1551 Upon removal of Attachment 1 411 Fayetteville Street Mall this letter is uncontrolled.
Raleigh NC 27602 Serial: RA-09-019 November 30, 2009 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / LICENSE NO. DPR-23 REQUEST FOR EXEMPTIONS FROM PHYSICAL SECURITY REQUIREMENTS Ladies and Gentlemen:
In accordance with the requirements of 10 CFR 73.5, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., requests the Nuclear Regulatory Commission (NRC) approve exemptions from specific requirements of 10 CFR Part 73, "Physical Protection of Plants and Materials." The exemptions requested would extend the compliance due date for H. B. Robinson Steam Electric Plant, Unit No. 2, for certain measures required by the revised rule.
The NRC issued a Final Rule for revised security requirements in the Federal Register dated March 27, 2009. Pursuant to the Final Rule, the revised security requirements must be implemented by March 31, 2010. CP&L has performed an extensive evaluation of the Final Rule and will achieve compliance with a vast majority of the revised rule by the March 31, 2010, compliance date.
CP&L has determined, however, that implementation of two specific provisions of the Final Rule will require more time to implement because they involve upgrades to the security system that require significant physical modifications (e.g., the relocation of certain security assets to a new security building that will be constructed, and the addition of uinterruptable power supplies). Therefore, additional time beyond the March 31, 2010, date is requested to complete these security modifications. Additional details regarding the specific provisions of the rule for which exemptions are requested, and the length of the exemptions are provided in .
This letter contains the following attachments:
" Attachment 1: Exemption Request for the H. B. Robinson Steam Electric Plant, Unit No. 2 (Contains Security-Related Information - Withhold Under 10 CFR 2.390)
" Attachment 2: Redacted Version of Exemption Request for the H. B. Robinson Steam Electric Plant, Unit No. 2 As noted above, Attachment 1 contains security-related information associated with the physical protection of H. B. Robinson Steam Electric Plant, Unit No. 2, as described in 10 Attachment 1 to this letter contains SECURITY-RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390. (,. (
Upon removal of Attachment 1 this letter is uncontrolled.
United States Nuclear Regulatory Commission RA-09-019 Page 2 CFR 2.390(d)(1). Accordingly, CP&L requests that the information contained in be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390.
This letter contains no regulatory commitments.
If you should have any questions regarding this submittal, please contact Ed O'Neil, Director
- Nuclear Protective Services, at (919) 546-2151.
I declare under penalty of perjury that the foregoing is true and correct. Executed on November 30, 2009.
\4 R. .J. uncan 11 Vice President, Nuclear Operations Progress Energy, Inc.
RJD/dbm Attachments:
- 1. Exemption Request for the H. B. Robinson Steam Electric Plant, Unit No. 2 (Contains Security-Related Information - Withhold Under 10 CFR 2.390)
- 2. Redacted Version of Exemption Request for the H. B. Robinson Steam Electric Plant, Unit No. 2 c: J. Wiggins, USNRC Director - Nuclear Security and Incident Response L. Reyes, USNRC Regional Administrator - Region II USNRC Resident Inspector - HBRSEP, Unit No. 2 T. Orf, NRR Project Manager -HBRSEP, Unit No. 2 Attachment 1 to this letter contains SECURITY-RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390.
Upon removal of Attachment 1 this letter is uncontrolled.
Attachment 2 Redacted Version of Exemption Request for the H. B. Robinson Steam Electric Plant, Unit No. 2
United States Nuclear Regulatory Commission Attachment 2 to RA-09-019 Page 1 of 13 H.B. Robinson Steam Electric Plant, Unit No. 2 Docket No. 50-261 / License No. DPR-23 Request for Exemption from Specific Provisions in 10 CFR 73.55 A. Background The NRC recently issued a Final Rule for revised security requirements in the Federal Register dated March 27, 2009. Pursuant to 10 CFR 73.55(a)(1) of the Final Rule, the revised security requirements in 10 CFR 73.55 must be implemented by March 31, 2010.
Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., has completed an extensive evaluation of these new requirements. This evaluation included a new comprehensive blast analysis for each of Progress Energy's four nuclear sites. The comprehensive blast analysis included consideration of equipment necessary to maintain the four required alarm station functions, consideration of explosives as allowed by the Design Basis Threat (DBT), and research of construction records to determine exact wall construction. Additionally, as resolutions to identified vulnerabilities were evaluated, CP&L's internal adversary team was consulted to assure that thorough resolutions were chosen.
As a result of this extensive evaluation, CP&L has determined that the H.B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, site will be in compliance with the vast majority of the requirements in the Final Rule within the brief implementation period. Significant efforts are being expended to comply with the revised rule requirements in the Final Rule. These efforts include: implementation of the new safety/security interface requirements, revising and implementing the Training and Qualification Plan in accordance with the new requirements, revising and implementing the new increased drill and exercise requirements, and resolving the major logistical challenges involved with the increased number of drills and exercises involving the adversary team and Multiple Integrated Laser Engagement System (MILES) gear. To address some of the logistical challenges, Progress Energy plans to centrally control the MILES gear and is voluntarily adopting the Department of Energy standards for issuance of the MILES gear for drills and exercises.
However, CP&L has determined that implementation of two specific parts of the revised requirements will require additional time because they involve significant physical upgrades
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to the HBRSEP, Unit No. 2, security system. These significant physical modifications will
{ benefit the HBRSEP, Unit No. 2, defensive strategy beyond the minimum requirements necessary to meet the new security requirements.
Prior to the issuance of the Final Rule, CP&L had embarked on several significant security improvement initiatives to enhance the fleet's protective strategy, replace aging security
United States Nuclear Regulatory Commission to RA-09-019 Page 2 of 13 equipment, and standardize security systems across the company's four nuclear sites. At HBRSEP, Unit No. 2, this involves the construction of a new firing range (complete),
replacing the intrusion detection systems, acting as a lead plant for subterranean barriers, and modernizing the alarm stations, none of which are directly associated with the Final Rule.
Upon review of the Final Rule, CP&L reordered the work and added two projects necessary to achieve compliance with the Final Rule. These projects are:
The projects listed above, are a series of significant modifications which, once completed, will provide a robust defensive posture beyond that which would be achieved through minimum compliance with the Final Rule. See Table 1 below for project milestone schedules.
B. Proposed Exemptions CP&L requests exemptions, from the implementation date only, for the two items listed below. CP&L will maintain the current HBRSEP, Unit No. 2, site protective strategy in accordance with the current Physical Security Plan. The current HBRSEP, Unit No. 2, site protective strategy has been approved by the NRC staff as providing a high assurance for the protection of the facility and public from the effects of radiological sabotage. Accordingly, the requested exemption to defer compliance with provisions of 10 CFR 73.55 until December 30, 2010, "will not endanger life or property or the common defense and security, and are otherwise in the public interest."
Item 1
United States Nuclear Regulatory Commission to RA-09-019 Page 3 of 13 Item 2
United States Nuclear Regulatory Commission to RA-09-019 Page 4 of 13 C. Basis for Exemptions CP&L is seeking exemption from the March 31, 2010, compliance date to December 30, 2010, for two provisions listed in 10 CFR 73.55 as discussed in Section B. HBRSEP, Unit No. 2, management has approved the plan to install the new building and new backup power system, and to relocate the equipment. These projects include several significant plant modifications:
A schedule for these projects is summarized in Table 1 below which shows critical milestones.
United States Nuclear Regulatory Commission to RA-09-019 Page 5 of 13 These plant modifications are significant in scope involving the construction of new facilities, extensive design and procurement efforts, and work with high voltage cabling and the personnel safety risk associated with such work. These modifications warrant a thorough review of the safety security interface and must be coordinated with the Spring 2010 refueling outage. All of these efforts require careful design, planning, procurement, and implementation efforts as discussed below.
Design work has begun for these modifications; however, the designs are currently in the early stages. Therefore, there are many details that have yet to be carefully worked out to support procurement, construction, and operation. The selection of the engineering firm is complete and the detailed design package for these projects is in progress. CP&L has expedited the processes to this point by sole sourcing the blast analysis, conceptual design work, and detailed design work, thus eliminating the time that would have been required to move through the competitive bidding process.
United States Nuclear Regulatory Commission to RA-09-019 Page 6 of 13 Due to space limitations inside the PA and the need to construct the new security building during the Spring 2010 refueling outage, the location for the new building was selected to The new security building will be constructed of reinforced concrete in a way that will withstand a single act and be located away from the PA barrier. Substantial time is needed to complete the design to the point where building construction can begin. This includes not only the design of the building, but also the design of the {
} and the design of the duct banks that will be necessary to support the equipment that will be installed in the building. These designs must be integrated to assure that the new security building can adequately support the functions and equipment that will be located within it. Approximately four months are needed to complete the designs to the point where construction of the building can be started. Plans call for procurement activities and site preparation activities to begin once the design reaches the 30 percent phase.
{ } and construction of the large { }
reinforced concrete structure are major construction projects within the PA. Construction of the new building is a prominent portion of the critical path for completing the projects to
{
} Underground interferences such as underground power, communications, and piping systems that could disrupt plant operations will first have to be identified and relocated from the area before the foundation and building shell can be constructed.
Construction inside the PA must be carefully planned and controlled to minimize impacts on plant operations and/or refueling outage activities. Construction of the new building will span the Spring 2010 refueling outage resulting in additional logistical challenges involving personnel and material movements in and around the PA. Approximately five and a half months are scheduled for preparing the site and constructing the large building foundation and reinforced concrete shell. The building shell must be completed {
}
A large number of cables must be routed to the new security building as a result of the systems that will be located in the building. Therefore, a new underground duct bank section must be installed to connect the new security building to the existing duct banks. A
United States Nuclear Regulatory Commission to RA-09-019 Page 7 of 13 portion (approximately 50 feet) of the new underground duct bank route crosses the site's heavy haul path which will be used for the movement of several extremely heavy loads (e.g.,
main generator rotor, feed water heaters, main transformer) during the Spring 2010 refueling outage. Construction of this portion of the duct bank cannot be completed in time to assure a safe load path for the heavy loads that will be moved during the refueling outage.
Therefore, excavation and construction of this portion of the new duct bank cannot start until after the heavy loads have been moved.
Excavation and trenching in the PA is a slow process which typically involves hand excavating the surface and then vacuuming away the loose dirt to prevent the inadvertent severance of underground power, communications, and piping systems that could disrupt plant operations. This work involves considerable personnel safety risk and, therefore, must be carefully planned and executed since the wires, duct banks, and conduits involved carry high voltage cabling from various plant loads. The condition of the underground cabling and duct bank must be determined before the detailed design work can be completed.
United States Nuclear Regulatory Commission Attachment 2 to RA-09-019 Page 8 of 13 CP&L believes those security facilities that are in or near the interior areas of the PA are the most effective throughout the range of contingencies for which we must prepare.
{
} will ensure that HBRSEP, Unit No. 2, is compliant with the single act requirements, and also position security resources in an area well protected from a variety of other threats. The new facility will also be available for future plans {
} to further improve HBRSEP, Unit No. 2's, protective strategy.
Summa As indicated above, CP&L is expending a great deal of effort in the design and planning phases of these projects to ensure a sound safety-security interface.
" Operating experience from the implementation of previous security orders has shown that decisions made within a compressed schedule to meet an aggressive deadline may create unintended consequences that have long-term adverse impacts on the site.
- Additional time will provide for better planning and execution to better assure personnel safety and a sound safety-security interface throughout the projects.
These modifications will provide several long term security benefits for HBRSEP, Unit No. 2.
A central location within the PA {
} will improve the defensive position of these assets and ensure protection from single act vulnerabilities.
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United States Nuclear Regulatory Commission to RA-09-019 Page 9 of 13 CP&L believes that the additional time necessary to complete this project is warranted based on the strengthened security posture that will be achieved through the implementation of these projects.
CP&L believes that the significant scope of the modifications and the time necessary to safely construct and test the modifications justify an exemption to the March 31, 2010, compliance date of the Final Rule. Therefore, CP&L believes that our actions are in the best interest of protecting public health and safety through the security changes that will be instituted.
D. Environmental Assessment Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., is requesting an exemption for H.B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, in accordance with 10 CFR 73.5, "Specific exemptions." The requested exemptions would defer the compliance date from March 31, 2010, as specified in 10 CFR 73.55(a)(1), to December 30, 2010, for two specific provisions of 10 CFR 73.55.
The proposed action is needed to allow additional time for the design and installation of security modifications that are expected to provide long term benefits in security posture and capabilities. In lieu of full compliance with the two provisions of 10 CFR 73.55, as revised on March 27, 2009, CP&L will maintain the current HBRSEP, Unit No. 2, site protective strategy in accordance with the current Physical Security Plan. The current HBRSEP, Unit No. 2, site protective strategy has been approved by the NRC staff as providing a high assurance for the protection of the facility and public from the effects of radiological sabotage.
Deferral of compliance from March 31, 2010, to December 30, 2010, for two provisions of 10 CFR 73.55 is a compliance date change only and, therefore, does not result in any physical changes to structures, systems, and components (SSCs) or land use at HBRSEP, Unit No. 2. Therefore, the deferral of the compliance date does not involve:
" any change to the types, characteristics, or quantities of non-radiological effluents discharged to the environment.
" any changes to liquid radioactive effluents discharged to the environment.
United States Nuclear Regulatory Commission to RA-09-019 Page 10 of 13
- any changes to gaseous radioactive effluents discharged to the environment.
- any change in the type or quantity of solid radioactive waste generated.
" any change in occupational dose under normal or Design Basis Accident (DBA) conditions.
" any change in the public dose under normal or DBA accident conditions.
" any land disturbance.
Conclusion There is no significant radiological environmental impact associated with the proposed exemption. The proposed exemption will not affect any historical sites nor will it affect non-radiological plant effluents.
United States Nuclear Regulatory Commission Attachment 2 to RA-09-019 Page 1 Iof 13 Table 1: Project Schedule Milestones*
I-
- The dates and sequences provided in this milestone schedule are best estimates based on information available at the time the schedule was developed and may change as designs are finalized and construction proceeds. Therefore, these dates and sequences are not considered to be regulatory commitments.
United States Nuclear Regulatory Commission to RA-09-019 Page 12 of 13 Figure 1: Conceptual Design of Proposed Security Building
United States Nuclear Regulatory Commission to RA-09-019 Page 13 of 13 Figure 2: Proposed Location of New Security Building