View source for DCL-22-069, Independent Spent Fuel Storage Installation, Revision to License Amendment Request 22-01, Request for Approval of Alternative Security Measures for Early Warning System

{{Adams
| number = ML22251A295
| issue date = 09/09/2022
| title = Independent Spent Fuel Storage Installation, Revision to License Amendment Request 22-01, Request for Approval of Alternative Security Measures for Early Warning System
| author name = Peck A
| author affiliation = Pacific Gas &amp; Electric Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS, NRC/NRR
| docket = 05000275, 05000323, 07200026
| license number = DPR-080, DPR-082, SNM-2511
| contact person = 
| case reference number = DCL-22-069
| package number = ML22251A294
| document type = Letter type:DCL
| page count = 7
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Security-Related Information - Withhold under 10 CFR 2.390 Pacific Gas and Electric Company*
Adam S. Peck                       Diablo Canyon Power Plant Site Vice President                Mail code 104/5/507 P.O. Box 56 Avila Beach, CA 93424 805.545.6675 Internal: 691.6675 PG&E Letter DCL-22-069                                                                                                10 CFR 50.90 10 CFR 73.55(r)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Diablo Canyon Units 1 and 2 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Materials License No. SNM-2511, Docket No. 72-26 Diablo Canyon Independent Spent Fuel Storage Installation Revision to License Amendment Request 22-01 Request for Approval of Alternative Security Measures for Early Warning System References 1: NRC Letter DIABLO CANYON POWER PLANT - SECURITY BASELINE INSPECTION REPORT 05000275/2021404 AND 05000323/2021404, dated January 13, 2022 2: PG&E Letter DCL-22-010,  License Amendment Request 22-01, Request for Approval of Alternate Security Measures for Early Warning System, dated February 16, 2022 (ADAMS Accession No. ML22048A526) 3: PG&E Letter DCL-22-044, Supplement to License Amendment Request 22-01 Request for Approval of Alternative Security Measures for Early Warning System, dated June 20, 2022 (ADAMS Accession No. ML22173A135)

==Dear Commissioners and Staff:==

Pursuant to 10 CFR 50.90, Pacific Gas and Electric Company (PG&E) hereby submits this revision to the proposed amendment to Facility Operating License Nos. DPR-80 and DPR-82 for Diablo Canyon Power Plant Units 1 and 2, respectively, submitted in Reference 2. The enclosed revised license amendment request (LAR) requests NRC A me m b e r of   the      STARS     (Strategic         Teaming      and       Resource         Sharing)  Alliance C a l l a wa y
* D i a b l o C a n y o n
* P a l o V e r d e
* W o l f C r e e k THE ATTACHMENT 2 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF ATTACHMENT 2 TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED

Security-Related Information - Withhold under 10 CFR 2.390 Document Control Desk                                                                       PG&E Letter DCL-22-069 Page 2 approval in accordance with 10 CFR 73.55(r) of proposed alternative security measures for the implementation of an Early Warning System.
This revision supersedes the evaluation of the proposed changes, detailed description, technical evaluation, and assessment of the proposed alternative security measures contained in Reference 2. The no significant hazards consideration evaluation and environmental consideration evaluation contained in Reference 2 are not impacted by this revision since the scope of the change is not revised. This revision has incorporated information contained in the Supplement to Reference 2 submitted in Reference 3, and addressed comments provided by the staff during the audit conducted August 2 and August 3, 2022.
This submittal contains security-related information and is being protected pursuant to 10 CFR 2.390. The affected attachment has been identified and marked to reflect it contains security-related information.
The Attachment 1 to the Enclosure provides a summary of the proposed changes and the applicable regulatory requirements. The Attachment 2 to the Enclosure (Security-Related Information) includes an evaluation of the proposed changes, including a detailed description, technical evaluation, and assessment of the proposed alternative security measures. PG&E requests approval of this revised LAR within four months to address the two NRC findings of very low security significance (Green), identified in Security Inspection Report 2021404 (Reference 1), in an expeditious manner. PG&E requests the license amendment be made effective upon NRC issuance and to be implemented within 90 days from the date of issuance.
PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this submittal.
Pursuant to 10 CFR 50.91, PG&E is sending a copy of this proposed amendment to the California Department of Public Health.
If you have any questions or require additional information, please contact James Morris, Regulatory Services Manager, at 805-545-4609.
I state under penalty of perjury that the foregoing is true and correct.
A me m b e r of   the      STARS     (Strategic         Teaming      and     Resource        Sharing) Alliance C a l l a wa y
* D i a b l o C a n y o n
* P a l o V e r d e
* W o l f C r e e k THE ATTACHMENT 2 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ATTACHMENT 2 TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED

Security-Related Information - Withhold under 10 CFR 2.390 Document Control Desk                                                                        PG&E Letter DCL-22-069 Page 3 Sincerely, September 8, 2022 Adam S. Peck                                                                                                     Date Site Vice President kjse/51134627 Enclosure cc:        Diablo Distribution cc/enc (without Enclosure Attachment 2)
Mahdi O. Hayes, NRC Senior Resident Inspector Samson S. Lee, NRR Project Manager Scott A. Morris, NRC Region IV Administrator Gonzalo L. Perez, Branch Chief, California Department of Public Health A  me m b e r of   the      STARS     (Strategic         Teaming      and     Resource        Sharing) Alliance C a l l a wa y
* D i a b l o C a n y o n
* P a l o V e r d e
* W o l f C r e e k THE ATTACHMENT 2 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ATTACHMENT 2 TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED

Security-Related Information - Withhold under 10 CFR 2.390 Enclosure PG&E Letter DCL-22-069 Evaluation of the Proposed Change

==Subject:==
Revision to License Amendment Request 22-01, Request for Approval of Alternative Security Measures for Early Warning System
: 1.       

==SUMMARY==
DESCRIPTION (uncontrolled)
: 2.       APPLICABLE REGULATORY REQUIREMENTS (uncontrolled)
: 3.       REFERENCES (uncontrolled)
ATTACHMENTS:
: 1.       Summary Description, Applicable Regulatory Requirements, Reference
: 2.       Summary Description, Detailed Description, Technical Evaluation and Assessment of Alternative Security Measures for Detection and Assessment Systems, Regulatory Evaluation, Precedent, References (Security-Related Information)
THE ATTACHMENT 2 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ATTACHMENT TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED

Security-Related Information - Withhold under 10 CFR 2.390 Enclosure Attachment 1 PG&E Letter DCL-22-069 EVALUATION
: 1.      

==SUMMARY==
DESCRIPTION This license amendment request is for NRC approval in accordance with 10 CFR 73.55(r) of proposed alternative security measures for the implementation of an Early Warning System (EWS) with respect to the 10 CFR 73.55(e), (i), (n), and (o) requirements.
The Diablo Canyon Power Plant (DCPP) EWS is comprised of barriers and a separate Intrusion Detection System (IDS). It is designed to supplement the Protected Area (PA) barrier and IDS, and to provide delay and early indication of unauthorized entry into areas of the Owner Controlled Area (OCA) adjacent to the PA. This allows a more rapid security response and a more effective and efficient use of security personnel, equipment, and programs. Detection at the EWS has been used to develop responder timelines, and as a result, the EWS is considered required to meet the requirements of 10 CFR 73.55(b).
A limited capability version of the EWS was initially developed and installed at DCPP in 2005 to supplement the PA barrier and IDS in certain locations. At that time, no specific NRC guidance was in place to address the use of a system that supplemented the required PA system (i.e., PA barrier and IDS). However, the EWS was installed, maintained, and tested, and was credited in the responder timelines analysis. In 2011, DCPP developed and installed a more advanced EWS which was put into operation in 2013. The EWS is maintained and tested to meet the guidance in Regulatory Guide 5.44, Revision 3, Perimeter Intrusion Alarm Systems.
The EWS supplements the PA barrier and IDS, and as a result has the potential to introduce activities that would interfere with alarm station operators assigned duties, which is prohibited by 73.55(d)(2)(ii) and 73.55(i)(4)(ii)(C). As a result, the EWS was designed and implemented to minimize these concerns.
Although no formal NRC guidance has been issued on these systems, based on various NRC correspondences, EWSs that must meet the requirements of 10 CFR 73.55(b) must also meet the applicable requirements for barriers and IDS set forth in 10 CFR 73.55(e), (i), (n) and (o). Additionally, the licensee Physical Security Plan (PSP) must describe the intended function of the EWS, how the EWS is designed, constructed and equipped to perform the intended function, personnel duties and responsibilities, the equipment components and systems used provide the capability to perform the intended function, communication and information transmission methodologies, EWS maintenance and testing, and appropriate measures taken to maintain and restore the EWS function in the event of failure/degradation. The DCPP PSP was revised in accordance with 10 CFR 50.54(p) to include the EWS in August 2016.
1 THE ATTACHMENT 2 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ATTACHMENT TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED

Security-Related Information - Withhold under 10 CFR 2.390 Enclosure Attachment 1 PG&E Letter DCL-22-069 In order to ensure a common understanding of the applicable requirements and implementation of the EWS, Pacific Gas and Electric Company (PG&E) is requesting NRC review and approval of the proposed alternative security measures in accordance with 10 CFR 50.90.
The Attachment 2 to the Enclosure of this letter provides the proposed alternative security measures, the technical basis for each proposed alternative security measure, and the assessment that they meet the same performance objectives of the 10 CFR 73.55(i) requirements and provide a level of protection that is at least equal to that which would otherwise be provided by the 10 CFR 73.55(i) requirements.
The no significant hazards consideration evaluation and environmental consideration evaluation provided in Attachment 1 to the Enclosure of PG&E Letter DCL-22-010, License Amendment Request 22-01, Request for Approval of Alternate Security Measures for Early Warning System, dated February 16, 2022 (ADAMS Accession No. ML22048A526), continues to be applicable to this revision since the scope of the requested change is not revised.
: 2.      APPLICABLE REGULATORY REQUIREMENTS 10 CFR 73.55(i)(1), Detection and assessment systems, requires the licensee shall establish and maintain intrusion detection and assessment systems that satisfy the design requirements of 10 CFR 73.55(b) and provide, at all times, the capability to detect and assess unauthorized persons and facilitate the effective implementation of the licensees protective strategy.
10 CFR 73.55(i)(2) requires that intrusion 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.
10 CFR 73.55(i)(3)(iv) requires the licensee ensures detection and assessment systems, alarm devices to include transmission lines to annunciators are tamper indicating and self-checking.
73.55(i)(4)(ii)(C) requires the licensee shall not permit any activities to be performed within either alarm station that would interfere with an alarm station operators ability to execute assigned duties and responsibilities.
10 CFR 73.55(i)(4)(ii)(F) requires the licensee ensures an alarm station operator cannot change the status of a detection point or deactivate a locking or access control device at 2
THE ATTACHMENT 2 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ATTACHMENT TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED

Security-Related Information - Withhold under 10 CFR 2.390 Enclosure Attachment 1 PG&E Letter DCL-22-069 a protected or vital area portal, without the knowledge and concurrence of the alarm station operator in the other alarm station.
10 CFR 73.55(i)(4)(ii)(G) requires the licensee ensures operators in both alarm stations are knowledgeable of the final disposition of all alarms.
10 CFR 73.55(r) Alternative measures state:
(1) The Commission may authorize an applicant or licensee to provide a measure for protection against radiological sabotage other than one required by this section if the applicant or licensee demonstrates that:
(i) The measure meets the same performance objectives and requirements specified in paragraph (b) of this section.
(2) The licensee shall submit proposed alternative measure(s) to the Commission for review and approval in accordance with &sect;&sect; 50.4 and 50.90 of this chapter before implementation.
(3) In addition to fully describing the desired changes, the licensee shall submit a technical basis for each proposed alternative measure. The basis must include an analysis or assessment that demonstrates how the proposed alternative measure provides a level of protection that is at least equal to that which would otherwise be provided by the specific requirement of this section.
Regulatory Guide 5.44, Revision 3, Perimeter Intrusion Alarm Systems describes the functions of perimeter intrusion detection methods that are acceptable to the NRC.
Sections 1.4, Tamper protection, and 1.5 System line supervision, provide guidance for meeting the requirements of 10 CFR 73.55(i)(3)(iv). The guidance, in part, states that all signal lines connecting detection devices to alarm stations should be supervised. If the processing electronics are separated from the sensor elements and are --    not located within the detection area of the sensor elements, the signal lines linking the sensors to the processing electronics should also be supervised.
: 3.      REFERENCE
: 1.      Regulatory Guide 5.44, Revision 3, Perimeter Intrusion Alarm Systems, October 1997.
3 THE ATTACHMENT 2 TO THE ENCLOSURE OF THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. THIS INFORMATION MUST BE PROTECTED ACCORDINGLY. UPON REMOVAL OF THE ATTACHMENT TO THE ENCLOSURE, THIS LETTER IS DECONTROLLED}}