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{{#Wiki_filter:Attachment 2 Redacted Version of Exemption Request for the H. B. Robinson Steam Electric Plant, Unit No. 2 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 10-021 Page 1 of 19 H.B. Robinson Steam Electric Plant, Unit No. 2 Docket No. 50-261 / License No. DPR-23 Request for Exemption from a Specific Provision in 10 CFR 73.55 A. Background The NRC 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 were to be implemented by March 31, 2010. Carolina Power& Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., 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 thefour required alarm station functions, consideration of explosives as allowed by the DesignBasis Threat (DBT), and research of construction records to determine exact wall construction.
{{#Wiki_filter:Attachment 2 Redacted Version of of Exemption Request for the H. B. Robinson Steam Electric Plant, Unit No.
Additionally, as resolutions to identified vulnerabilities were evaluated, CP&L's internal adversary team was consulted to assure that thorough resolutions were selected.As a result of the extensive evaluation, CP&L determined that the H.B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, site would be in compliance with the vast majority of the requirements in the Final Rule within the brief implementation period. Significantefforts were and are being expended to comply with the revised rule requirements in the Final Rule. These efforts included:
No.22
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, ProgressEnergy centrally controls the MILES gear and has voluntarily adopted the Department ofEnergy standards for issuance of the MILES gear for drills and exercises.
 
However, CP&L previously determined that implementation of two specific parts of the revised requirements would require additional time because they involve significant physical upgrades to the HBRSEP, Unit No. 2, security system.
Commission United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 11 of Page    of 19 19 H.B. Robinson Steam Steam Electric Plant, Unit No. No.22 Docket No. 50-261 50-261 / License No. DPR-23 Request       Exemption from a Specific Provision Request for Exemption                        Provision in 10 CFR 73.55
These changes are significant physical modifications that will benefit the HBRSEP, Unit No. 2, defensive strategy beyond the minimum requirements necessary to meet the new security requirements.
 
Primarily,{d)(}Upon review of the Final Rule, CP&L identified two projects necessary to achieve 1 United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 1 of 19 H.B. Robinson Steam Electric Plant, Unit No.2 Docket No. 50-261 / License No. DPR-23 Request for Exemption from a Specific Provision in 10 CFR 73.55 A. Background The NRC 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 were to be implemented by March 31, 2010. Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., completed an extensive evaluation ofthese new requirements.
===Background===
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.
A. Background The NRC issued a Final Rule for revised security requirements in the Federal Register dated March 27,2009.
Additionally, as resolutions to identified vulnerabilities were evaluated, CP&L's internal adversary team was consulted to assure that thorough resolutions were selected.
27, 2009. Pursuant to 10 CFR 73.55(a)(1) 73.55(a)(1) of the Final Rule, the revised revised security requirements in 10 CFR 73.55 were to be implemented implemented by March March 31,31, 2010. Carolina PowerPower
As a result ofthe extensive evaluation, CP&L determined that the H.B. Robinson Steam Electric Plant (HBRSEP), Unit No.2, site would be in compliance with the vast majority of the requirements in the Final Rule within the brief implementation period. Significant efforts were and are being expended to comply with the revised rule requirements in the Final Rule. These efforts included:
    & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc.,
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 centrally controls the MILES gear and has voluntarily adopted the Department of Energy standards for issuance of the MILES gear for drills and exercises.
completed an extensive evaluation evaluation of  these new requirements. This evaluation included a ofthese comprehensive blast analysis for each of Progress Energy's four nuclear sites. The new comprehensive comprehensive blast analysis included comprehensive                    included consideration of equipment equipment necessary necessary to maintain the four required required alarm station functions, consideration consideration of explosives explosives as allowed by the Design Basis Threat (DBT), and research of construction records to determine determine exact exact wall construction. Additionally, as resolutions to identified vulnerabilities vulnerabilities were evaluated, adversary team was consulted CP&L's internal adversary               consulted to assure that thorough resolutions resolutions were selected.
However, CP&L previously determined that implementation of two specific parts ofthe revised requirements would require additional time because they involve significant physical upgrades to the HBRSEP, Unit No.2, security system. These changes are significant physical modifications that will benefit the HBRSEP, Unit No.2, defensive strategy beyond the minimum requirements necessary to meet the new security requirements.
As a result ofthe of the extensive evaluation, CP&L determined determined that the H.B. Robinson Steam Electric Plant (HBRSEP), Unit No. No.2,2, site would be in compliance compliance with the vast majority of      of the requirements requirements in the Final Rule within the brief implementation implementation period. Significant efforts were and are being expended expended to comply with the revised rule requirements in the Final Rule. These efforts included: implementation implementation of the new safety/security safety/security interface interface requirements, revising and implementing implementing the Training         Qualification Plan in accordance Training and Qualification              accordance with the new requirements, requirements,  revising and implementing implementing  the new   increased increased   drill and exercise requirements, and resolving resolving the major logistical challenges involved involved with the increased increased number of drills and exercises   involving exercises involving  the adversary adversary team   and Multiple   Integrated Multiple Integrated LaserLaser Engagement System (MILES) gear. To address some of the logistical Engagement                                                        logistical challenges, challenges, Progress Energy centrally controls controls the MILES gear and has voluntarily adopted the Department of          of Energy standards for issuance of the MILES gear for drills and exercises.
Primarily, Upon review of the Final Rule, CP&L identified two projects necessary to achieve ) (d)(l)
However, CP&L previously       determined that implementation previously determined        implementation of two specific specific parts ofthe of the revised requirements would require additional time because they involve significantsignificant physical upgrades to the HBRSEP, Unit No. No.2,2, security system. These changes changes are significant physical modifications modifications that will benefit the HBRSEP, Unit No.        2, defensive
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 2 of 19 compliance with the Final Rule.
{d)(}
These projects were: (d)(1)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 regulation.
No.2,   defensive strategy beyond the minimum minimum requirements necessary to meet the new securitysecurity requirements.
Compliance with the above listed rule provisions was the subject of the November 30, 2009, (Reference
requirements. Primarily,
: 1) exemption request which was approved by the NRC on March 3, 2010, (Reference 2). CP&L has determined that additional time, beyond that previously approved by the NRC in Reference 2, will be required to achieve compliance with one of the two items. Compliance with { } has been delayed due to the complexity of (d)(1)the work, the complexity of the design and associated analysis; and the increased scope of underground duct banks and buried conduit that must be constructed.
                                                                                                            ) (d)(l) 1 Upon review of the Final Rule, CP&L identified two projects necessary to achieve
 
Regulatory Commission United States Nuclear Regulatory     Commission to 10-021 Page 22 of Page    of 19 19 compliance with the Final Rule. These projects were:
compliance (d)(1)
(d)(l)
The projects listed above, are a series of significant significant modifications modifications which, once completed, will provide a robust defensive posture beyond that which would be achievedachieved through through compliance with the regulation.
minimum compliance Compliance with the above listed rule provisions was the subject of the November 30, 2009, Compliance (Reference 1)
(Reference  1) exemption request which was approved by the   the. NRC on March 3, 3, 2010, (Reference 2). CP&L has determined (Reference                  determined that additional additional time, beyond beyond that previously  approved previously approved by the NRC in Reference Reference 2, will be required to achieve compliance compliance with one of the two Compliance with {
items. Compliance                                   } has been delayed due to the complexity of     (d)(1)
(d)(l) the work, the complexity of the design and associated analysis; and the increased scope of      of underground duct banks and buried conduit that must be constructed.
constructed.
See Table 1 below for project milestone schedules.
See Table 1 below for project milestone schedules.
B. Proposed Exemption CP&L requests an exemption, from the implementation date only, for the item 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 high assurance for the protection of the facility and public from the effects of radiological sabotage.
Exemption B. Proposed Exemption CP&L requests an exemption, from the implementation implementation date only, for the item listed below.
Accordingly, the requested exemption to defer compliance with one provision of 10 CFR 73.55 until September 16, 2011, "will not endanger life or property or the common defense and security, and are otherwise in the public interest." (d)(1)-J United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 2 of 19 compliance with the Final Rule. These projects were: 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 regulation.
CP&L will maintain the current HBRSEP, Unit No.2,    No. 2, site protective protective strategy in accordance accordance with the current current Physical Security Plan. The current HBRSEP, Unit No.2,  No. 2, site protective strategy has been approved by the NRC staff as providing high assurance for the protection protection of the facility and public from the effects of radiological radiological  sabotage. Accordingly, Accordingly, the exemption to defer compliance with one provision requested exemption                                      provision of 10 CFR 73.55 until September    16, 2011, September 16,2011,     "will not endanger endanger  life or property property or the common defense and security, and security,  and are are otherwise otherwise in the public interest.
Compliance with the above listed rule provisions was the subject of the November 30, 2009, (Reference
interest." "
: 1) exemption request which was approved by the. NRC on March 3, 2010, (Reference 2). CP&L has determined that additional time, beyond that previously approved by the NRC in Reference 2, will be required to achieve compliance with one of the two (d)(l) items. Compliance with { } has been delayed due to the complexity of (d)(l) the work, the complexity of the design and associated analysis; and the increased scope of underground duct banks and buried conduit that must be constructed.
(d)(1)
See Table 1 below for project milestone schedules.
(d)(l)
B. Proposed Exemption CP&L requests an exemption, from the implementation date only, for the item 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 high assurance for the protection of the facility and public from the effects of radiological sabotage.
                                                                                                      -J
Accordingly, the requested exemption to defer compliance with one provision of 10 CFR 73.55 until September 16,2011, "will not endanger life or property or the common defense and security, and are otherwise in the public interest. " (d)(l)
 
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 3 of 19 C. Basis for Exemption CP&L is seeking an exemption from the previously approved December 30, 2010, compliance date to September 16, 2011, for one provision listed in 10 CFR 73.55 as discussed in Section B. HBRSEP, Unit No. 2, management has approved the plan toperform the modifications necessary to achieve full compliance with the provision.
United States Nuclear Regulatory Regulatory Commission Commission to 10-021 Page 33 of Page    of 19 19
This plan has been aggressively pursued, with significant effort expended in order to meet the 2010 date previously approved; however, a number of issues have significantly hampered the ability to move forward with the plan as described in Reference
                                                                                                          . (d)(1)
: 1. These issues will be discussed in detail below.The following issues have delayed the work to this point, and/or impacted the projected schedule:
(d)(l)
the complexity of the design and construction of the projects which lead to unforeseen scope growth; a better understanding of the time necessary for transition and testing for the new systems; and due to a fire in an electrical switchgear room, the spring refueling outage was extended beyond that originally anticipated when schedules were first developed.
C. Basis for Exemption Exemption CP&L is seeking an exemption from the previously previously approved December December 30, 2010, 2010, compliance date to September 16,2011, compliance                        16, 2011, for one provision listed in 10 CFR 73.55 as discussed in Section Section B. HBRSEP, Unit No.2,No. 2, management management has approved the plan to necessary to achieve full compliance perform the modifications necessary                      compliance with the provision. ThisThis plan has been aggressively pursued, with significant effort effort expended in order to meet the 2010 date previously previously approved; however, a number number of issues have significantly    hampered significantly hampered the ability ability to move forward with the plan plan as described described in Reference Reference 1.1. These issues will be discussed in detail below.
These issues were revealed as the design evolved from the conceptual state to a point where discovery is now 90 percent complete.Proiect Overview The work necessary to achieve full compliance includes several significant plant modifications. A summary of the physical modifications required includes:.(d)(1)I(d)(1)United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 3 of 19 C. Basis for Exemption
The following issues have delayed delayed the work to this point, and/or impacted the projected projected schedule: the complexity schedule:      complexity ofthe of the design design and construction of the projects which lead to unforeseen scope scope growth; a better understanding understanding of the time necessary necessary for transition and testing for the new systems; and due to a fire in an electrical electrical switchgear switchgear room, the spring anticipated when schedules were first refueling outage was extended beyond that originally anticipated                              first developed. These issues were revealed revealed  as the design  evolved  from  the conceptual conceptual  state  to a point where where discovery is now 90 percent percent complete.
{ CP&L is seeking an exemption from the previously approved December 30, 2010, compliance date to September 16,2011, for one provision listed in 10 CFR 73.55 as discussed in Section B. HBRSEP, Unit No.2, management has approved the plan to perform the modifications necessary to achieve full compliance with the provision.
Proiect Overview Project  Overview The work necessary necessary to achieve full compliance compliance includes several several significant plant modifications. A summary summary ofthe of the physical  modifications physical modifications required includes:
This plan has been aggressively pursued, with significant effort expended in order to meet the 2010 date previously approved; however, a number of issues have significantly hampered the ability to move forward with the plan as described in Reference
{                                                                                                        I(d)(
: 1. These issues will be discussed in detail below. The following issues have delayed the work to this point, and/or impacted the projected schedule:
                                                                                                        } (d)(J)
the complexity ofthe design and construction of the projects which lead to unforeseen scope growth; a better understanding of the time necessary for transition and testing for the new systems; and due to a fire in an electrical switchgear room, the spring refueling outage was extended beyond that originally anticipated when schedules were first developed.
 
These issues were revealed as the design evolved from the conceptual state to a point where discovery is now 90 percent complete.
United States Nuclear Regulatory Commission United                                Commission  to 10-021 Page 4 of 19 (d)()
Project Overview The work necessary to achieve full compliance includes several significant plant modifications.
(d)(l)
A summary ofthe physical modifications required includes: (d)(l) } (d)(J)
A schedule for these projects is summarized summarized in Table 1 which shows critical milestones.
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 4 of 19 (d)()A schedule for these projects is summarized in Table 1 which shows critical milestones.
It is essential essential to work these projects together because:
It is essential to work these projects together because: These plant modifications are significant in scope involving the construction of newfacilities, extensive design and procurement efforts, and work with high voltage cabling and the personnel safety risk associated with such work. These modifications warranted thorough review of the safety security interface and had to be coordinated with the Spring 2010 refueling outage. All of these efforts require careful design, planning, procurement, and implementation efforts as discussed below.The design work is approximately 65 percent complete at this point. Although the majority of the designs are not 100 percent complete, they have progressed to the point where discovery is now 90 percent complete. CP&L has been working very closely with the engineering vendor preparing the detailed design packages for these projects, and has called upon industry experts for third party reviews for certain aspects to ensure a quality design meeting all regulations.
(d)(1)
Construction inside the PA had to be carefully planned and controlled to minimize impacts (d)(1)United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 4 of 19 A schedule for these projects is summarized in Table 1 which shows critical milestones.
(d)(l)
It is essential to work these projects together because: 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 warranted thorough review of the safety security interface and had to be coordinated with the Spring 2010 refueling outage. All of these efforts require careful design, planning, procurement, and implementation efforts as discussed below. The design work is approximately 65 percent complete at this point. Although the majority of the designs are not 100 percent complete, they have progressed to the point where discovery is now 90 percent complete.
These plant modifications are significant in scope involving the construction construction of new new facilities, extensive design and procurement procurement    efforts, and work  with high voltage cabling and the personnel safety risk associated with such work. These modifications modifications warranted warranted thorough review review  of the safety security  interface  and  had to be coordinated coordinated with the Spring Spring 2010 refueling outage. All of these efforts efforts require require careful careful design, planning, procurement, procurement, and implementation implementation efforts as discussed below.
CP&L has been working very closely with the engineering vendor preparing the detailed design packages for these projects, and has called upon industry experts for third party reviews for certain aspects to ensure a quality design meeting all regulations.
approximately 65 percent complete The design work is approximately                    complete at this point. Although Although the majority of the designs are not 100 percent complete, they have progressed to the point where discovery is now 90 percent percent complete. CP&L has been working very closely with the engineering vendor preparing the detailed design packagespackages for these projects, and has called called upon industry experts experts for third party reviews for certain certain aspects to ensure a quality design meeting all regulations.
Construction inside the P A had to be carefully planned and controlled to minimize impacts (d)(l) (d)(l)
Construction inside the P  PAA had to be carefully carefully planned planned and controlled to minimize minimize impacts
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 5 of 19 on plant operations and refueling outage activities.
 
Minimal construction activities spanned the extended Spring 2010 refueling outage resulting in additional logistical challenges involving personnel and material movements in and around the PA.HBRSEP, Unit No. 2, shut down on Sunday March 28, 2010, following a fire in an electrical switchgear room. Due to significant fire related damage, the planned refueling outage was started three weeks early. The refueling outage extended from a scheduled 35 days to 113 days due to the additional activities required to recover from the March 2 8 th event. The Part 73 compliance project plan called for stopping all project work, with the exception of{ }~~, during the outage to ensure that safety and the(d(1 outage were not impacted by project activities, such as closing roads and relocating outage equipment for excavation of duct banks.The March 28 thevent and the decision to start the refueling outage three weeks early causedlimited availability of project construction and engineering resources during this, period.Construction of underground duct banks and manholes was substantially delayed due to unavailability of work areas because of outage activities. This resulted in not completing
United States Nuclear Regulatory Regulatory Commission Commission to 10-021 Attachment         10-021 Page 5 of 19 Page        19 operations and refueling on plant operations                        outage activities. Minimal refueling outage                              construction activities Minimal construction        activities spanned spanned the extended Spring 2010 refueling outage resulting in additional logistical challenges        challenges involving personnel and materialmaterial movements in and around the P          PA.
*some scheduled pre-outage activities. Much of the site and project engineering resources were reassigned to event recovery and the refueling outage earlier than planned, which caused delays in the processing of Engineering Change (EC) packages. This had a ripple effect throughout the project schedule causing construction activities to slip by approximately five weeks. (d)( 1)Extending the unit outage prevented some of the Part 73 Project activities from being worked as scheduled.
A.
The outage was completed on July 19, 20 10. This eight week extension resulted in a five week delay in beginning excavation of duct banks / manholes and their subsequent installation, due to lack of available, resources and/or outage equipment in the way of project work areas. The outage extension also resulted in EC design review milestones to be delayed 2 months due to unavailability of site engineering resources.(d)( 1)Due to space limitations inside the PA and the need to construct the{}during the Spring 2010 refueling outage, the location {}was selected to ()1 minimize interferences with the refueling outage. The location selected was occupied by a{ } were removed from (d)( 1)the site in mid-January and construction personnel removed the last portions of the concrete sections from the site in mid-March.
HBRSEP, Unit No.2,   No. 2, shut down down on Sunday March 28,2010,28, 2010, following a fire in an electrical electrical significant fire related switchgear room. Due to significant switchgear                                          related damage, the planned        refueling outage was planned refueling started three three weeks early. The refueling outage                                  scheduled 35 outage extended from a scheduled          35 days to th 113 days due to the additional activities          required to recover activities required      recover from the March 2288th        event. The compliance project Part 73 compliance        project plan called        stopping all project called for stopping                                      exception of project work, with the exception        of
This allowed personnel to lay out the { (d)(1)United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 5 of 19 on plant operations and refueling outage activities.
{            {                                      }~~,during the outage
Minimal construction activities spanned the extended Spring 2010 refueling outage resulting in additional logistical challenges involving personnel and material movements in and around the P A. HBRSEP, Unit No.2, shut down on Sunday March 28,2010, following a fire in an electrical switchgear room. Due to significant fire related damage, the planned refueling outage was started three weeks early. The refueling outage extended from a scheduled 35 days to 113 days due to the additional activities required to recover from the March 28 th event. The Part 73 compliance project plan called for stopping all project work, with the exception of { }, during the outage to ensure that safety and the outage were not impacted by project activities, such as closing roads and relocating outage equipment for excavation of duct banks. The March 28 th event and the decision to start the refueling outage three weeks early caused limited availability of project construction and engineering resources during this period. Construction of underground duct banks and manholes was substantially delayed due to unavailability of work areas because of outage activities.
                                                        },             outage to ensure that safety safety and the(d(1 the     (d)(l) were not impacted outage were          impacted by project activities, activities, such as closing                  relocating outage closing roads and relocating        outage equipment for excavation equipment          excavation of duct banks.
This resulted in not completing . some scheduled pre-outage activities.
th The March 28thevent                  decision to start the refueling outage three weeks event and the decision                                                weeks early    caused early caused availability of project limited availability                  construction and engineering project construction          engineering resources during this  this,period.
Much of the site and project engineering resources were reassigned to event recovery and the refueling outage earlier than planned, which caused delays in the processing of Engineering Change (EC) packages.
period.
This had a ripple effect throughout the project schedule causing construction activities to slip by approximately five weeks. { } Extending the unit outage prevented some ofthe Part 73 Project activities from being worked as scheduled.
underground duct banks and manholes Construction of underground Construction                                                                substantially delayed manholes was substantially        delayed due to unavailability of work areas unavailability                areas because of outage activities.
The outage was completed on July 19,2010. This eight week extension resulted in a five week delay in beginning excavation of duct banks / manholes and their subsequent installation, due to lack of available resources and/or outage equipment in the way of project work areas. The outage extension also resulted in EC design review milestones to be delayed 2 months due to unavailability of site engineering resources.
activities. This                      completing This resulted in not completing pre-outage    activities.
Due to space limitations inside the P A and the need to construct the { } during the Spring 2010 refueling outage, the location { } was selected to minimize interferences with the refueling outage. The location selected was occupied by a { } were removed from. the site in mid-January and construction personnel removed the last portions of the concrete sections from the site in mid-March.
    *some scheduled pre-outage activities.
This allowed personnel to layout the { (d)(l) (d)(1) (d)(1) (d)(1 ) (d)(1) (d)(1)
  . some                                            Much    of the site  and project  engineering    resources engineering resources reassigned to event recovery were reassigned                                      refueling outage earlier recovery and the refueling               earlier than planned,     which planned, which caused delays in the processing of Engineering Engineering Change (EC) packages.packages. This had a ripple throughout the project effect throughout                    schedule causing construction project schedule                              activities to slip by construction activities            by approximately five weeks. {
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 6 of 19} and install dewatering wells around the excavation (d)(1)area.Due to the water table in the area, the area must be continually dewatered to prevent flooding of the excavated area. Following substantial rainfalls, construction delays areincurred while the area is dewatered and dried out.
approximately                                                                                                      (d)( 1)
Site preparation/excavation for the{ } took approximately three months. Excavation and (d)(1)trenching in the PA is a slow process which typically involves hand excavating or air lancing 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.
(d)(1)
This work involves considerable personnel safety risk and, therefore, must be carefully planned and executed since the wires, duct banks, and conduits involved could carry high voltage cabling from various plant loads.(d)(1)Originally selected to minimize the impact to the plant and reduce construction time, the decision { } has proven to have had an adverse impact onthe schedule.
                                                  }
Although the off-site { } fabrication has progressed, delivery has been delayed due to the design issues encountered, particularly with the analytical blast analysis and structural analysis effort. The blast analysis and structural analysis for the { } (d)(1)were more complex than originally anticipated and required significantly more time to complete than expected. This analytical effort has gone through several iterations to assess the { } against the DBT and new { (d)(1)}During the week of August 9, 2010, a team of Progress Energy personnel met with{ } vendor and engineering vendor personnel to resolve the issues with the analysis. (d)(1)This meeting achieved a path forward for successfully completing the analysis and moving forward with { } Therefore, CP&L (d)(1)is moving forward with the installation of a { (d)(1)} at HBRSEP, Unit No. 2.The contract for the { } required the (d)(1){ } vendor to provide design drawings, calculations, and blast certificates that met United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 6 of 19 } and install dewatering wells around the excavation (d)(l) area. Due to the water table in the area, the area must be continually dewatered to prevent flooding of the excavated area. Following substantial rainfalls, construction delays are incurred while the area is dewatered and dried out. Site preparation/excavation for the { . } took approximately three months. Excavation and trenching in the PAis a slow process which typically involves hand excavating or air lancing 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.
Extending the unit outage Extending                outage prevented prevented some of      the Part 73 Project activities ofthe                    activities from being scheduled. The outage was completed worked as scheduled.                                                    19, 20 10. This eight completed on July 19,2010.                  eight week week resulted in a five week delay in beginning extension resulted extension                                            beginning excavation excavation of duct banks / manholes manholes subsequent installation, due to lack of available and their subsequent                                                                and/or outage equipment available, resources and/or              equipment in the way of project project work areas. The outage extension  extension also resulted in EC design review  review milestones milestones to be delayed                            unavailability of site delayed 2 months due to unavailability            site engineering engineering resources.
This work involves considerable personnel safety risk and, therefore, must be carefully planned and executed since the wires, duct banks, and conduits involved could carry high voltage cabling from various plant loads. Originally selected to minimize the impact to the plant and reduce construction time, the decision { } has proven to have had an adverse impact on the schedule.
(d)( 1)
Although the off-site { } fabrication has progressed, delivery has been delayed due to the design issues encountered, particularly with the analytical blast analysis and structural analysis effort. The blast analysis and structural analysis for the { } were more complex than originally anticipated and required significantly more time to complete than expected.
(d)(1) limitations inside the P Due to space limitations                    PA A and the need to construct        the{}
This analytical effort has gone through several iterations to assess the { } against the DB T and new { } During the week of August 9, 2010, a team of Progress Energy personnel met with . { } vendor and engineering vendor personnel to resolve the issues with the analysis.
construct the  {                          }
This meeting achieved a path forward for successfully completing the analysis and moving forward with { } Therefore, CP&L is moving forward with the installation of a { } at HBRSEP, Unit No.2. The contract for the { } required the { } vendor to provide design drawings, calculations, and blast certificates that met . (d)(l) (d)(l) (d)(l) (d)(l) (d)(l) (d)(l) (d)(l) (d)(l) (d)(l)
(d)(1 )
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 7 of 19 the required codes and standards.
refueling outage, the location {{}was during the Spring 2010 refueling                                                              } was selected selected to   ()1 minimize    interferences with the refueling outage. The location minimize interferences                                                location selected selected was occupied occupied by a
After review of the vendor's calculation and blast certification, additional blast and structural analyses were required to verify the performance of the structures.
{                      {                                                              }} were removed removed from.
The design products required several rounds of comments and resolution between the engineering firm preparing the required change documents and the { }vendor's engineers.
from    (d)( 1)
The number of iterations was unforeseen and caused delays {}CP&L expected the { } vendor to have an engineering capability that would support the practices common to nuclear utility design efforts; but, the { } vendor was not prepared for the level of review and oversight that was required and provided for nuclear projects by CP&L. The engineering vendor responsible to design the equipment
(d)(1) the site in mid-January            construction personnel mid-January and construction           personnel removed the last portions of the concrete  concrete sections from the site in mid-March.
{} was tasked to prepare the designs
mid-March. This allowed personnelpersonnel to laylayout out the {                      (d)(1)
{} The effort was complicated because the
(d)(1)
{ } design was outside of the engineering vendor's scope. The iterative process created by vendors working together was much more significant and lengthy than expected due to the complexity of the designs resulting in further delays.The { } have been fabricated at the vendor's facility.
 
A Progress Energy team inspected the vendor's fabrication facility on July 22, 2010, and found several items that were not built to requirements which had to be corrected.
United                                Commission United States Nuclear Regulatory Commission  to 10-021 Page 6 of 1919
Additionally, the {(d)(1)(d)(1)(d)(1)(d)(1)(d)(1)(d)(1)I> (d)(1)As a result of the issues discussed above, {September 2010 to early March 2011.A large number of cables must be routed to {} completion has slipped from mid-(d)(1)} Therefore, new underground duct bank (d)(1)United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 7 of 19 the required codes and standards.
                                                  } and install dewatering wells around the excavation excavation      (d)(1)
After review of the vendor's calculation and blast certification, additional blast and structural analyses were required to verify the performance of the structures.
(d)(l) area.
The design products required several rounds of comments and resolution between the engineering firm preparing the required change documents and the { } vendor's engineers.
Due to the water table in the area, the area must be continually dewatereddewatered to prevent prevent flooding of the excavated excavated area. Following substantial substantial rainfalls, construction delays are incurred while the area is dewatered and dried out. Site preparation/excavation preparation/excavation for the
The number of iterations was unforeseen and caused delays { } CP&L expected the { } vendor to have an engineering capability that would support the practices common to nuclear utility design efforts; but, the { } vendor was not prepared for the level of review and oversight that was required and provided for nuclear projects by CP&L. The engineering vendor responsible to design the equipment
{.                                   }} took approximately three months. Excavation and         and         . (d)(1)
{ } was tasked to prepare the designs { } The effort was complicated because the { } design was outside of the engineering vendor's scope. The iterative process created by vendors working together was much more significant and lengthy than expected due to the complexity of the designs resulting in further delays. The { } have been fabricated at the vendor's facility.
(d)(l) trenching in the PAisPA is a slow process which typically                        excavating or air lancing typically involves hand excavating              lancing the surface and then vacuuming away the loose dirt to prevent the inadvertent severance      severance ofof communications, and piping systems that could disrupt plant underground power, communications, operations. This work involves considerable personnel personnel safety risk and, therefore, must be carefully planned and executed executed since the wires, duct banks, and conduits involved could carry high voltage cabling from various plant loads.
A Progress Energy team inspected the vendor's fabrication facility on July 22,2010, and found several items that were not built to requirements which had to be corrected.
(d)(1)
Additionally, the { As a result of the issues discussed above, { September 2010 to early March 2011. A large number of cables must be routed to { } } completion has slipped from mid-} Therefore, new underground duct bank (d)(l ) (d)(l ) (d)(l ) (d)(l) (d)(l ) (d)(l) (d)(l) (d)(l) (d)(l )
(d)(l)
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 8 of 19 sections must be installed to connect security equipment to { } As (d)(1)the design progressed from the conceptual stage, the full complexity of the project was realized and the need for additional cabling with identified.
Originally selected selected to minimize the impact to the plant and reduce construction time, the decision {                                         } has proven to have had an adverse impact on              (d)(l)
The original schedule called for an evaluation of existing duct banks for routing cables to and from { }. Locating available conduits to pull new cable back to the (d)(1){ } became an issue. Approximately 32 security pull boxes and manholes were inspected around the site for spare conduits.
Although the off-site {{
Pairs of manholes were opened, spare or unused conduits were identified and evaluated for use, and abandoned cables were identified and removed to free up conduits.
the schedule. Although                                }} fabrication has progressed, delivery delivery has been been delayed due to the design issues encountered, encountered, particularly particularly with the analytical analytical blast analysis structural analysis effort. The blast analysis and structural analysis for the {
As the existing duct banks were examined,many more than expected were found to be too full for use. Additionally, as duct bankconstruction progressed, unexpected underground obstructions were found that required duct bank routes to be revised. Therefore, new duct banks and routings had to be designed andconstructed that were not originally planned.The initial design called for 16 duct banks (approximately 2100 linear feet) and 11 manholes.
and structural                                                                                          }}    (d)(1)
The current design now calls for 22 duct banks (approximately 3185 linear feet) and 14 manholes, and approximately 3000 linear feet of direct buried conduit, a significant scope increase.
(d)(l) were more complex than originally anticipated                          significantly more time to anticipated and required significantly complete than expected. This analytical effort has gone through several iterations to assess complete the {{                                }} against the DB DBT  T and new {{                                        (d)(1)
Approximately 1515 linear feet of duct banks and ten manholes have beeninstalled through the end of August 2010. Refer to Figure 3 for pictures of recent duct bank construction.
(d)(l)
During installation of duct banks / manholes in the heavy haul road it was determined that the manholes specified in the design would not be able to withstand the crane weight.Redesign and fabrication of the new heavy haul manholes caused a four week slip in the construction schedule.
                                  }}
The heavy haul road is the only road that can be used by the equipment hatch crane to enter the radiological control area and remove the containmentbuilding equipment hatch
During the week of August 9, 2010, a team    team of Progress Energy personnel met with
/ shielding to support a unit refueling outage.Duct bank construction is only approximately 50 percent complete at this time. It is not expected that the duct banks will be completed at the time the { } (d)(1)arrives onsite. As stated above, excavation and trenching in the PA is a slow process that must be carefully planned and executed to assure personnel and nuclear safety.(d)(1)United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 8 of 19 sections must be installed to connect security equipment to { } As (d)(l) the design progressed from the conceptual stage, the full complexity of the project was realized and the need for additional cabling with identified.
  .{          }
The original schedule called for an evaluation of existing duct banks for routing cables to and from { }. Locating available conduits to pull new cable back to the (d)(l) { } became an issue, Approximately 32 security pull boxes and manholes were inspected around the site for spare conduits.
                }  vendor and  engineering engineering  vendor                  resolve the issues with the analysis.
Pairs of manholes were opened, spare or unused conduits were identified and evaluated for use, and abandoned cables were identified and removed to free up conduits.
personnel to resolve personnel                                                (d)(1)
As the existing duct banks were examined, many more than expected were found to be too full for use. Additionally, as duct bank construction progressed, unexpected underground obstructions were found that required duct bank routes to be revised. Therefore, new duct banks and routings had to be designed and constructed that were not originally planned. The initial design called for 16 duct banks (approximately 2100 linear feet) and 11 manholes.
(d)(l)
The current design now calls for 22 duct banks (approximately 3185 linear feet) and 14 manholes, and approximately 3000 linear feet of direct buried conduit, a significant scope increase.
This meeting achieved achieved a path forward for successfully successfully completing the analysis and moving forward with     {                                                                 }} Therefore,    CP&L Therefore, CP&L        (d)(1)
Approximately 1515 linear feet of duct banks and ten manholes have been installed through the end of August 2010. Refer to Figure 3 for pictures of recent duct bank construction.
(d)(l) is moving forward with the installation of a {                                                              (d)(1)
During installation of duct banks / manholes in the heavy haul road it was determined that the manholes specified in the design would not be able to withstand the crane weight. Redesign and fabrication of the new heavy haul manholes caused a four week slip in the construction schedule.
(d)(l)
The heavy haul road is the only road that can be used by the equipment hatch crane to enter the radiological control area and remove the containment building equipment hatch / shielding to support a unit refueling outage. Duct bank construction is only approximately 50 percent complete at this time. It is not expected that the duct banks will be completed at the time the { } (d)(l) arrives onsite. As stated above, excavation and trenching in the PAis a slow process that must be carefully planned and executed to assure personnel and nuclear safety. (d)(l)
              }} at HBRSEP, Unit No.2.
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 9 of 19 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.
No. 2.
The new facility will also be available for future plans {} to further improve HBRSEP, Unit No. 2's, protective strategy.(d)(1)(d)(1)(d)(1)See Table 1 below for project milestone schedules.
The contract for the {                                                                }} required the       (d)(1)
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 9 of 19 CP &L believes those security facilities that are in or near the interior areas of the P A 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.
(d)(l)
See Table 1 below for project milestone schedules. (d)(l) (d)(l) (d)(l)
{{          }
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 10 of 19 Summar 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.
                }  vendor to provide provide design    drawings,    calculations, drawings, calculations,    and  blast certificates certificates that met
* Operating experience from the implementation of previous security orders, at Progress Energy facilities as well as in the industry, 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 optimum planning and execution to better assurepersonnel industrial safety and a sound safety-security interface throughout the project.These modifications will provide several long term security benefits for HBRSEP, Unit No. 2.* A central location within the PA for {} will improve the defensive position of these assetsand ensure protection from single act vulnerabilities.* A central location within the PA for { } will greatly enhance the (d)(1)defensive posture of the station from threats beyond that which is required for the single act.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 additional time beyond the previouslyapproved compliance date. 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.
 
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 10 of 19 Summary 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.
United States Nuclear Regulatory United                  Regulatory Commission Commission  to 10-021 Page 77 of Page    of 19 19 the required required codes codes and standards. After review review of the vendor's vendor's calculation calculation and blast certification, additional blast and structural analyses were required to verifyverify the performance performance of the structures. The design products required several several rounds of comments comments and resolution resolution between the engineering engineering firm preparing preparing the required change documents documents and the {              }}  (d)(1))
* Operating experience from the implementation of previous security orders, at Progress Energy facilities as well as in the industry, 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.
(d)(l unforeseen and caused delays {{
* Additional time will provide for optimum planning and execution to better assure personnel industrial safety and a sound safety-security interface throughout the project. These modifications will provide several long term security benefits for HBRSEP, Unit No. 2.
vendor's engineers. The number of iterations was unforeseen
* A central location within the P A for { } will improve the defensive position of these assets and ensure protection from single act vulnerabilities.
                                                          }}                                               (d)(1))
* A central location within the P A for { } will greatly enhance the defensive posture of the station from threats beyond that which is required for the single act. 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.
(d)(l expected the {
CP&L believes that the significant scope of the modifications and the time necessary to safely construct and test the modifications justify additional time beyond the previously approved compliance date. 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)(l) (d)(l)
CP&L expected                    } vendor to have an engineering engineering capability capability that would support (d)(1))
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 11 of 19 D. Temporary Compliance Measures Considered in Lieu of a Second ExemptionCP&L considered other options for achieving temporary compliance with the one provision of the Final Rule by the previously approved compliance date before seeking this exemption.
(d)(l the practices practices common to nuclear nuclear utility design efforts; but, the {           } vendor was notnot prepared for the level of review review  and oversight oversight  that  was  required required  and provided provided  for  nuclear projects by CP&L. The engineering engineering vendor vendor responsible responsible to design the equipment {
Options considered are discussed below. However, for the reasons provided below, these temporary compliance measures were rejected.(d)(1)United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 11 of 19 D. Temporary Compliance Measures Considered in Lieu of a Second Exemption CP&L considered other options for achieving temporary compliance with the one provision of the Final Rule by the previously approved compliance date before seeking this exemption.
                            } was tasked to prepare the designs {                                           (d)(1)
Options considered are discussed below. However, for the reasons provided below, these temporary compliance measures were rejected. (d)(l)
(d)(l)
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 12 of 19 (d)( 1)United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 12 of 19 (d)(1 )
              } The effort was complicated because the {                      } design was outside outside ofof engineering vendor's scope. The iterative process created by vendors working together the engineering                                                                              together significant and lengthy than expected due to the complexity of the designs was much more significant resulting in further delays.
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 13 of 19 (d)(1)United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 13 of 19 (d)(l)
The {                          }} have been fabricated at the vendor's vendor's facility. A Progress          (d)(1))
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 14 of 19 (d)(1)E. 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 September 16, 2011, for one provision 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.
(d)(l Energy team inspected inspected the vendor's fabrication fabrication facility on July 22,    2010, and found several 22,2010, items that were not built to requirements which had to be corrected. Additionally, the {
In lieu of full compliance with the provision 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 highassurance for the protection of the facility and public from the effects of radiological sabotage.Deferral of compliance from March 31, 2010, to September 16, 2011, for the provision 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." 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.
(d)(1)
* any change in the public dose under normal or DBA accident conditions.
(d)(l)
                                                                                        }I (d)(l)
                                                                                                            > (d)(1)
As a result of the issues discussed above, {              } completion has slipped from mid-            (d)(1)
(d)(l)
September 2010 to early March March 2011.
2011.
A large number of cables must be routed to {{
(d)(1))
(d)(l
                                                    } Therefore, Therefore, new underground underground duct bank
 
Commission United States Nuclear Regulatory Commission  to 10-021 Page 88 of Page      19 of 19 installed to connect security equipment sections must be installed                        equipment to {                            } As (d)(1)
(d)(l) progressed from the conceptual stage, the full complexity the design progressed                                          complexity of the project was realized and the need for additional additional cabling cabling with identified.
schedule called for an evaluation of existing duct banks for routing cables to The original schedule and from {{                        }. Locating available conduits to pull new cable back to the
                                        }.                                                           (d)(1)
(d)(l)
{                                      issue. Approximately
                            } became an issue,   Approximately 32 security pull boxes and inspected around the site for spare conduits. Pairs of manholes were opened, manholes were inspected identified and evaluated for use, and abandoned cables were spare or unused conduits were identified identified and removed to free up conduits. As the existing duct banks were examined, expected were found to be too full for use. Additionally, as duct bank many more than expected construction progressed, unexpected construction                              underground obstructions unexpected underground    obstructions were found that required duct Therefore, new duct banks and routings had to be designed and bank routes to be revised. Therefore, constructed that were not originally planned.
constructed The initial design called for 16 duct banks (approximately 2100 linear feet) and 11  11 manholes. The current design now calls for 22 duct banks (approximately (approximately 3185 linear feet) approximately 3000 linear feet of direct buried conduit, a significant and 14 manholes, and approximately Approximately 1515 linear feet of duct banks and ten manholes have been scope increase. Approximately                                                              been installed through the end of August 2010. Refer to Figure 3 for pictures of recent duct bank bank construction.
During installation                    manholes in the heavy haul road it was determined installation of duct banks / manholes                                  determined that the manholes specified in the design would not be able to withstand the crane weight.
Redesign and fabrication of the new heavy haul manholes manholes caused caused a four week slip in the construction schedule. The heavy haul road is the only road that can be used by the construction equipment hatch crane to enter the radiological control area and remove the containment equipment equipment hatch / shielding to support a unit refueling building equipment                                        refueling outage.
Duct bank construction construction is only approximately        percent complete at this time. It is not approximately 50 percent expected that the duct banks will be completed at the time the {{
expected                                                                                    }     (d)(1)
(d)(l) arrives onsite. As stated above, excavation and trenching in the PAis PA is a slow process that must be carefully planned and executed to assure personnel personnel and nuclear safety.
(d)(1)
(d)(l)
 
United States Nuclear Regulatory Regulatory Commission Commission  to 10-021 Attachment Page Page 99 of 19 of 19 (d)(1)
(d)(l)
CP&L CP  &L believes those security facilities that are in or near the interior areas of the P PAA are the most effective effective throughout the range of contingencies contingencies for which we must prepare.
{{                                                                                                    (d)(1)
(d)(l)
                            } will ensure that HBRSEP, HBRSEP, Unit No.No.2,2, is compliant with the single act requirements, and also position security security resources resources in an area well protected protected from a variety of other threats. The new facility will also be available for future plans {{                 (d)(1)
(d)(l)
                                    }} to further improve HBRSEP, Unit No. 2's, protective strategy.
See Table Table 1 below for project milestone schedules.
 
United States States Nuclear Nuclear Regulatory Regulatory Commission Commission  to 10-021 Attachment Page Page 10  of 19 10 of  19 Summar Summary As indicated above, CP&L is expending expending a great deal of effort in the design and planning phases of these projects to ensure a sound safety-security safety-security interface.
interface.
        **  Operating experience experience from the implementation implementation of previous security orders, at Progress Energy Energy  facilities as well  as in the industry, has shown that decisions made within a compressed compressed schedule schedule to meet an aggressive deadline may create unintended unintended consequences consequences that have long-term adverse adverse impacts on the site.
        **  Additional time will provide for optimum planning and executionexecution to better assure personnel industrial safety and a sound personnel                            sound safety-security safety-security interface throughout the project.
These modifications modifications will provide provide several long term security benefits for HBRSEP, Unit No. 2.
        **  A central central location within the P PA A for {
(d)(l)
                                              } will improve improve the defensive position position of these assets and ensure protection from single act vulnerabilities.
        **  A central central location within the P PA A for {                          } will greatly greatly enhance enhance the (d)(1)
(d)(l) defensive defensive posture of the station from threats threats beyond beyond that which which is required for the single act.
CP&L believes believes that the additional time necessary necessary to complete complete this project project is warranted based on the strengthened strengthened security posture that will be achieved achieved through the implementation implementation of of these projects.
CP&L believes believes that the significant scope scope of the modifications and the time necessary to safely construct and test the modifications modifications justify justify additional time beyond the previously previously compliance date. Therefore, approved compliance            Therefore, CP&L believes believes that our actions are in the best interest of protecting protecting public health  and   safety through  the security security changes that will be instituted.
 
States Nuclear United States          Regulatory Commission Nuclear Regulatory  Commission Attachment  to 10-021 10-021 Page  11 of Page 11  of 19 19 D. Temporary    Compliance Measures Temporary Compliance                Considered in Lieu of Measures Considered                Second Exemption of aa Second  Exemption considered other CP&L considered    other options for achieving            compliance with the one provision temporary compliance achieving temporary                            provision of the Final Rule Rule by the  previously approved the previously            compliance date approved compliance        before seeking date before seeking this exemption.
Options  considered are discussed below. However, for the Options considered                                                    provided below, these the reasons provided temporary compliance temporary              measures were rejected.
compliance measures (d)(1)
(d)(l)
 
United States Nuclear Regulatory Regulatory Commission Commission  to 10-021 Page 12 Page 12 of 19 of 19 (d)( 1))
(d)(1
 
United United States Nuclear Nuclear Regulatory Regulatory Commission Commission Attachment 2 to 10-021 Page Page 13 of 19 (d)(1)
(d)(l)
 
United States Nuclear Regulatory Commission Commission  to 10-021 Attachment Page 14 of 1919 (d)(1)
(d)(l)
E. Environmental Environmental Assessment Assessment Carolina Power & Light Company Carolina                      Company (CP&L), now doing business as Progress Energy Inc., is requesting an exemption Carolinas, Inc.,
Carolinas,                          exemption for H.B. Robinson Steam Electric Plant (HBRSEP),
(HBRSEP),     Unit  No.
No.2,2, in accordance accordance                      "Specific exemptions."
with 10 CFR 73.5, "Specific      exemptions." The requested                                    compliance date from March 31, exemptions would defer the compliance requested exemptions                                                          31, 2010, as specified in 10 CFR 73.55(a)(1),
73.55(a)(1),  to  September  16,  2011, 16,2011,  for one provision  of  10        73.55. The CFR 73.55.
proposed action is needed to allow additional time for the design and installation of security modifications that are expected to provide long term benefits modifications                                              benefits in security security posture and compliance with the provision of 10 CFR 73.55, as revised on capabilities. In lieu of full compliance                                                          on March  27, 2009, CP&L will maintain the current HBRSEP, March 27,2009,                                                    Unit  No.
No.2, 2, site protective Security Plan. The current HBRSEP, Unit accordance with the current Physical Security strategy in accordance No. 2, site protective strategy has been approved by the NRC staff as providing a high No.2, assurance for the protection of the facility and public from the effects of radiological assurance sabotage.
Deferral      compliance from March 31, Deferral of compliance                                                  2011, for the provision of September 16, 2011, 31, 2010, to September                                  of therefore, does not result in any 10 CFR 73.55 is a compliance date change only and, therefore, physical changes to structures, systems, and components (SSCs) or land use at HBRSEP, Unit No. 2. Therefore, No.2.                    deferral of the compliance Therefore, the deferral          compliance date does not involve:
        *" any change change to the types, characteristics, characteristics, or quantities of non-radiological non-radiological effluents effluents discharged to the environment.
        *" any changes changes to liquid radioactive radioactive effluents discharged discharged to the environment.
        *" any changes changes to gaseous radioactive radioactive effluents effluents discharged discharged to the environment.
        *" any change change in the type or quantity of solid radioactive waste generated.
generated.
        *" any change change in occupational 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.
* any land disturbance.
Conclusion There is no significant radiological environmental impact associated with the proposed exemption.
Conclusion Conclusion*
The proposed exemption will not affect any historical sites nor will it affect non-radiological plant effluents.
environmental impact associated with the proposed There is no significant radiological environmental                                     proposed exemption will not affect any historical sites nor will it affect exemption. The proposed exemption non-radiological plant effluents.
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 14 of 19 E. 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 September 16,2011, for one provision 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.
n,on-radiological
In lieu of full compliance with the provision 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 September 16, 2011, for the provision 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:
Commission United States Nuclear Regulatory Commission to 10-021 Page 15 Page  15 of of 19 19 F.  
* 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.
* 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 n,on-radiological plant effluents. (d)(l)
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 15 of 19 F.  


==References:==
==References:==
: 1. Progress Energy letter from R.
: 1. Progress Energy letter from R. J. Duncan II to the Nuclear Regulatory Regulatory Commission Commission Document Control Desk titled, Request for for Exemptions from Physical Exemptions from    Physical Security Security Requirements," dated November 30, 2009 Requirements,"
J. Duncan II to the Nuclear Regulatory Commission Document Control Desk titled, Request for Exemptions from Physical Security Requirements," dated November 30, 2009 2. Nuclear Regulatory Commission letter from Tracy J. Orf to Eric McCartney titled, H. B.Robinson Steam Electric Plant, Unit No. 2 -Exemption From the Requirements of 10 CFR Part 73, Section 73.55 (TA C No. ME2816), dated March 3, 2010 United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 15 of 19 F.
Nuclear Regulatory Commission letter from Tracy
: 2. Nuclear                                            J. Orfto Tracy 1. Orf to Eric McCartney McCartney titled, H. B.
Robinson Steam Electric Plant, Unit No.                 From the Requirements No.22 - Exemption From         Requirements of of 10 CFR Part Part 73, Section 73.55 (TAC (TA C No. ME2816), dated March No. ME2816),          March 3,2010 3, 2010


==References:==
United States Nuclear Nuclear Regulatory Regulatory Commission Commission Attachment to 10-021 Page 16 of 19 Table 1: Project   Schedule Milestones **
: 1. Progress Energy letter from R. J. Duncan II to the Nuclear Regulatory Commission Document Control Desk titled, Request for Exemptions from Physical Security Requirements," dated November 30, 2009 2. Nuclear Regulatory Commission letter from Tracy 1. Orfto Eric McCartney titled, H. B. Robinson Steam Electric Plant, Unit No.2 -Exemption From the Requirements of 10 CFR Part 73, Section 73.55 (TAC No. ME2816), dated March 3,2010 United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 16 of 19 Table 1: Project Schedule Milestones  
Project Schedule (d)(l)
** 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.
* The dates The  dates and and sequences sequences provided  in this provided in this milestone milestone schedule schedule are are best best estimates based on estimates based      information on information
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 16 of 19
* available at the time the schedule schedule was developed developed  and may change change  as designs are finalized and construction construction proceeds. Therefore, these dates and sequences sequences are not considered considered to be regulatory commitments.
* Table 1: Project Schedule Milestones
 
* 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.
United States Nuclear Regulatory Commission Regulatory Commission  to 10-021 Attachment Page 17 of 19 Figure 1: Design of { } (d)(l (d)(1))
Therefore, these dates and sequences are not considered to be regulatory commitments. (d)(l)
(d)(1)
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 17 of 19 Figure 1: Design of { (d)(1)(d)(1)United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 17 of 19 Figure 1: Design of { } (d)(l ) (d)(l)
(d)(l)
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 18 of 19 Figure 2: Location of
 
{ (d)(1)(d)(1)United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 18 of 19 Figure 2: Location of { } (d)(l) (d)(l)
Regulatory Commission United States Nuclear Regulatory Commission to 10-021 Attachment Page 18 of 19 Figure 2: Location of {{ } (d)(1)
United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 19 of 19 Figure 3: Recent Duct Bank Construction Major East -West Duct Bank Under Construction One Set of Manholes in PreviouslyCompleted Duct Bank United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 19 of 19 Figure 3: Recent Duct Bank Construction Major East -West Duct Bank Under Construction One Set of Manholes in Previously Completed Duct Bank}}
(d)(l)
(d)(1)
(d)(l)
 
United States Nuclear Nuclear Regulatory Regulatory Commission Commission Attachment to 10-021 Page 19 of 19 Figure 3: Recent Duct Bank Construction Construction Major East - West Duct Bank Under Construction Construction One Set of Manholes in Previously Previously Completed Duct Bank}}

Revision as of 05:40, 13 November 2019

Redacted Version of Exemption Request from Specific Provision in 10 CFR 73.55
ML103360283
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 09/30/2010
From:
Progress Energy Carolinas
To:
Office of Nuclear Reactor Regulation
References
RA-10-021
Download: ML103360283 (20)
v • d • e


Text

Attachment 2 Redacted Version of of Exemption Request for the H. B. Robinson Steam Electric Plant, Unit No.

No.22

Commission United States Nuclear Regulatory Commission Attachment 2 to 10-021 Page 11 of Page of 19 19 H.B. Robinson Steam Steam Electric Plant, Unit No. No.22 Docket No. 50-261 50-261 / License No. DPR-23 Request Exemption from a Specific Provision Request for Exemption Provision in 10 CFR 73.55

Background

A. Background The NRC issued a Final Rule for revised security requirements in the Federal Register dated March 27,2009.

27, 2009. Pursuant to 10 CFR 73.55(a)(1) 73.55(a)(1) of the Final Rule, the revised revised security requirements in 10 CFR 73.55 were to be implemented implemented by March March 31,31, 2010. Carolina PowerPower

& Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc.,

completed an extensive evaluation evaluation of these new requirements. This evaluation included a ofthese comprehensive blast analysis for each of Progress Energy's four nuclear sites. The new comprehensive comprehensive blast analysis included comprehensive included consideration of equipment equipment necessary necessary to maintain the four required required alarm station functions, consideration consideration of explosives explosives as allowed by the Design Basis Threat (DBT), and research of construction records to determine determine exact exact wall construction. Additionally, as resolutions to identified vulnerabilities vulnerabilities were evaluated, adversary team was consulted CP&L's internal adversary consulted to assure that thorough resolutions resolutions were selected.

As a result ofthe of the extensive evaluation, CP&L determined determined that the H.B. Robinson Steam Electric Plant (HBRSEP), Unit No. No.2,2, site would be in compliance compliance with the vast majority of of the requirements requirements in the Final Rule within the brief implementation implementation period. Significant efforts were and are being expended expended to comply with the revised rule requirements in the Final Rule. These efforts included: implementation implementation of the new safety/security safety/security interface interface requirements, revising and implementing implementing the Training Qualification Plan in accordance Training and Qualification accordance with the new requirements, requirements, revising and implementing implementing the new increased increased drill and exercise requirements, and resolving resolving the major logistical challenges involved involved with the increased increased number of drills and exercises involving exercises involving the adversary adversary team and Multiple Integrated Multiple Integrated LaserLaser Engagement System (MILES) gear. To address some of the logistical Engagement logistical challenges, challenges, Progress Energy centrally controls controls the MILES gear and has voluntarily adopted the Department of of Energy standards for issuance of the MILES gear for drills and exercises.

However, CP&L previously determined that implementation previously determined implementation of two specific specific parts ofthe of the revised requirements would require additional time because they involve significantsignificant physical upgrades to the HBRSEP, Unit No. No.2,2, security system. These changes changes are significant physical modifications modifications that will benefit the HBRSEP, Unit No. 2, defensive

{d)(}

No.2, defensive strategy beyond the minimum minimum requirements necessary to meet the new securitysecurity requirements.

requirements. Primarily,

) (d)(l) 1 Upon review of the Final Rule, CP&L identified two projects necessary to achieve

Regulatory Commission United States Nuclear Regulatory Commission to 10-021 Page 22 of Page of 19 19 compliance with the Final Rule. These projects were:

compliance (d)(1)

(d)(l)

The projects listed above, are a series of significant significant modifications modifications which, once completed, will provide a robust defensive posture beyond that which would be achievedachieved through through compliance with the regulation.

minimum compliance Compliance with the above listed rule provisions was the subject of the November 30, 2009, Compliance (Reference 1)

(Reference 1) exemption request which was approved by the the. NRC on March 3, 3, 2010, (Reference 2). CP&L has determined (Reference determined that additional additional time, beyond beyond that previously approved previously approved by the NRC in Reference Reference 2, will be required to achieve compliance compliance with one of the two Compliance with {

items. Compliance } has been delayed due to the complexity of (d)(1)

(d)(l) the work, the complexity of the design and associated analysis; and the increased scope of of underground duct banks and buried conduit that must be constructed.

constructed.

See Table 1 below for project milestone schedules.

Exemption B. Proposed Exemption CP&L requests an exemption, from the implementation implementation date only, for the item listed below.

CP&L will maintain the current HBRSEP, Unit No.2, No. 2, site protective protective strategy in accordance accordance with the current current Physical Security Plan. The current HBRSEP, Unit No.2, No. 2, site protective strategy has been approved by the NRC staff as providing high assurance for the protection protection of the facility and public from the effects of radiological radiological sabotage. Accordingly, Accordingly, the exemption to defer compliance with one provision requested exemption provision of 10 CFR 73.55 until September 16, 2011, September 16,2011, "will not endanger endanger life or property property or the common defense and security, and security, and are are otherwise otherwise in the public interest.

interest." "

(d)(1)

(d)(l)

-J

United States Nuclear Regulatory Regulatory Commission Commission to 10-021 Page 33 of Page of 19 19

. (d)(1)

(d)(l)

C. Basis for Exemption Exemption CP&L is seeking an exemption from the previously previously approved December December 30, 2010, 2010, compliance date to September 16,2011, compliance 16, 2011, for one provision listed in 10 CFR 73.55 as discussed in Section Section B. HBRSEP, Unit No.2,No. 2, management management has approved the plan to necessary to achieve full compliance perform the modifications necessary compliance with the provision. ThisThis plan has been aggressively pursued, with significant effort effort expended in order to meet the 2010 date previously previously approved; however, a number number of issues have significantly hampered significantly hampered the ability ability to move forward with the plan plan as described described in Reference Reference 1.1. These issues will be discussed in detail below.

The following issues have delayed delayed the work to this point, and/or impacted the projected projected schedule: the complexity schedule: complexity ofthe of the design design and construction of the projects which lead to unforeseen scope scope growth; a better understanding understanding of the time necessary necessary for transition and testing for the new systems; and due to a fire in an electrical electrical switchgear switchgear room, the spring anticipated when schedules were first refueling outage was extended beyond that originally anticipated first developed. These issues were revealed revealed as the design evolved from the conceptual conceptual state to a point where where discovery is now 90 percent percent complete.

Proiect Overview Project Overview The work necessary necessary to achieve full compliance compliance includes several several significant plant modifications. A summary summary ofthe of the physical modifications physical modifications required includes:

{ I(d)(

} (d)(J)

United States Nuclear Regulatory Commission United Commission to 10-021 Page 4 of 19 (d)()

(d)(l)

A schedule for these projects is summarized summarized in Table 1 which shows critical milestones.

It is essential essential to work these projects together because:

(d)(1)

(d)(l)

These plant modifications are significant in scope involving the construction construction of new new facilities, extensive design and procurement procurement efforts, and work with high voltage cabling and the personnel safety risk associated with such work. These modifications modifications warranted warranted thorough review review of the safety security interface and had to be coordinated coordinated with the Spring Spring 2010 refueling outage. All of these efforts efforts require require careful careful design, planning, procurement, procurement, and implementation implementation efforts as discussed below.

approximately 65 percent complete The design work is approximately complete at this point. Although Although the majority of the designs are not 100 percent complete, they have progressed to the point where discovery is now 90 percent percent complete. CP&L has been working very closely with the engineering vendor preparing the detailed design packagespackages for these projects, and has called called upon industry experts experts for third party reviews for certain certain aspects to ensure a quality design meeting all regulations.

Construction inside the P PAA had to be carefully carefully planned planned and controlled to minimize minimize impacts

United States Nuclear Regulatory Regulatory Commission Commission to 10-021 Attachment 10-021 Page 5 of 19 Page 19 operations and refueling on plant operations outage activities. Minimal refueling outage construction activities Minimal construction activities spanned spanned the extended Spring 2010 refueling outage resulting in additional logistical challenges challenges involving personnel and materialmaterial movements in and around the P PA.

A.

HBRSEP, Unit No.2, No. 2, shut down down on Sunday March 28,2010,28, 2010, following a fire in an electrical electrical significant fire related switchgear room. Due to significant switchgear related damage, the planned refueling outage was planned refueling started three three weeks early. The refueling outage scheduled 35 outage extended from a scheduled 35 days to th 113 days due to the additional activities required to recover activities required recover from the March 2288th event. The compliance project Part 73 compliance project plan called stopping all project called for stopping exception of project work, with the exception of

{ { }~~,during the outage

}, outage to ensure that safety safety and the(d(1 the (d)(l) were not impacted outage were impacted by project activities, activities, such as closing relocating outage closing roads and relocating outage equipment for excavation equipment excavation of duct banks.

th The March 28thevent decision to start the refueling outage three weeks event and the decision weeks early caused early caused availability of project limited availability construction and engineering project construction engineering resources during this this,period.

period.

underground duct banks and manholes Construction of underground Construction substantially delayed manholes was substantially delayed due to unavailability of work areas unavailability areas because of outage activities.

activities. This completing This resulted in not completing pre-outage activities.

  • some scheduled pre-outage activities.

. some Much of the site and project engineering resources engineering resources reassigned to event recovery were reassigned refueling outage earlier recovery and the refueling earlier than planned, which planned, which caused delays in the processing of Engineering Engineering Change (EC) packages.packages. This had a ripple throughout the project effect throughout schedule causing construction project schedule activities to slip by construction activities by approximately five weeks. {

approximately (d)( 1)

(d)(1)

}

Extending the unit outage Extending outage prevented prevented some of the Part 73 Project activities ofthe activities from being scheduled. The outage was completed worked as scheduled. 19, 20 10. This eight completed on July 19,2010. eight week week resulted in a five week delay in beginning extension resulted extension beginning excavation excavation of duct banks / manholes manholes subsequent installation, due to lack of available and their subsequent and/or outage equipment available, resources and/or equipment in the way of project project work areas. The outage extension extension also resulted in EC design review review milestones milestones to be delayed unavailability of site delayed 2 months due to unavailability site engineering engineering resources.

(d)( 1)

(d)(1) limitations inside the P Due to space limitations PA A and the need to construct the{}

construct the { }

(d)(1 )

refueling outage, the location {{}was during the Spring 2010 refueling } was selected selected to ()1 minimize interferences with the refueling outage. The location minimize interferences location selected selected was occupied occupied by a

{ { }} were removed removed from.

from (d)( 1)

(d)(1) the site in mid-January construction personnel mid-January and construction personnel removed the last portions of the concrete concrete sections from the site in mid-March.

mid-March. This allowed personnelpersonnel to laylayout out the { (d)(1)

(d)(1)

United Commission United States Nuclear Regulatory Commission to 10-021 Page 6 of 1919

} and install dewatering wells around the excavation excavation (d)(1)

(d)(l) area.

Due to the water table in the area, the area must be continually dewatereddewatered to prevent prevent flooding of the excavated excavated area. Following substantial substantial rainfalls, construction delays are incurred while the area is dewatered and dried out. Site preparation/excavation preparation/excavation for the

{. took approximately three months. Excavation and and . (d)(1) (d)(l) trenching in the PAisPA is a slow process which typically excavating or air lancing typically involves hand excavating lancing the surface and then vacuuming away the loose dirt to prevent the inadvertent severance severance ofof communications, and piping systems that could disrupt plant underground power, communications, operations. This work involves considerable personnel personnel safety risk and, therefore, must be carefully planned and executed executed since the wires, duct banks, and conduits involved could carry high voltage cabling from various plant loads. (d)(1) (d)(l) Originally selected selected to minimize the impact to the plant and reduce construction time, the decision { } has proven to have had an adverse impact on (d)(l) Although the off-site Template:The schedule. Although fabrication has progressed, delivery delivery has been been delayed due to the design issues encountered, encountered, particularly particularly with the analytical analytical blast analysis structural analysis effort. The blast analysis and structural analysis for the { and structural }} (d)(1) (d)(l) were more complex than originally anticipated significantly more time to anticipated and required significantly complete than expected. This analytical effort has gone through several iterations to assess complete the {{ }} against the DB DBT T and new {{ (d)(1) (d)(l) 

                                 }}

During the week of August 9, 2010, a team team of Progress Energy personnel met with 

  .{           }
               }  vendor and   engineering engineering   vendor                  resolve the issues with the analysis.

personnel to resolve personnel (d)(1) (d)(l) This meeting achieved achieved a path forward for successfully successfully completing the analysis and moving forward with { }} Therefore, CP&L Therefore, CP&L (d)(1) (d)(l) is moving forward with the installation of a { (d)(1) (d)(l) 

             }} at HBRSEP, Unit No.2.

No. 2. The contract for the { }} required the (d)(1) (d)(l) {{ } 

               }  vendor to  provide provide design    drawings,    calculations, drawings, calculations,    and  blast certificates certificates that met

United States Nuclear Regulatory United Regulatory Commission Commission to 10-021 Page 77 of Page of 19 19 the required required codes codes and standards. After review review of the vendor's vendor's calculation calculation and blast certification, additional blast and structural analyses were required to verifyverify the performance performance of the structures. The design products required several several rounds of comments comments and resolution resolution between the engineering engineering firm preparing preparing the required change documents documents and the { }} (d)(1)) (d)(l unforeseen and caused delays Template:Vendor's engineers. The number of iterations was unforeseen (d)(1)) (d)(l expected the { CP&L expected } vendor to have an engineering engineering capability capability that would support (d)(1)) (d)(l the practices practices common to nuclear nuclear utility design efforts; but, the { } vendor was notnot prepared for the level of review review and oversight oversight that was required required and provided provided for nuclear projects by CP&L. The engineering engineering vendor vendor responsible responsible to design the equipment { 

                            } was tasked to prepare the designs {                                           (d)(1)

(d)(l) 

             } The effort was complicated because the {                       } design was outside outside ofof engineering vendor's scope. The iterative process created by vendors working together the engineering                                                                               together significant and lengthy than expected due to the complexity of the designs was much more significant resulting in further delays.

The { }} have been fabricated at the vendor's vendor's facility. A Progress (d)(1)) (d)(l Energy team inspected inspected the vendor's fabrication fabrication facility on July 22, 2010, and found several 22,2010, items that were not built to requirements which had to be corrected. Additionally, the { (d)(1) (d)(l) 

                                                                                       }I (d)(l)
                                                                                                           > (d)(1)

As a result of the issues discussed above, { } completion has slipped from mid- (d)(1) (d)(l) September 2010 to early March March 2011. 2011. A large number of cables must be routed to {{ (d)(1)) (d)(l 

                                                   } Therefore, Therefore, new underground underground duct bank

Commission United States Nuclear Regulatory Commission to 10-021 Page 88 of Page 19 of 19 installed to connect security equipment sections must be installed equipment to { } As (d)(1) (d)(l) progressed from the conceptual stage, the full complexity the design progressed complexity of the project was realized and the need for additional additional cabling cabling with identified. schedule called for an evaluation of existing duct banks for routing cables to The original schedule and from {{ }. Locating available conduits to pull new cable back to the 

                                       }.                                                            (d)(1)

(d)(l) { issue. Approximately 

                            } became an issue,    Approximately 32 security pull boxes and inspected around the site for spare conduits. Pairs of manholes were opened, manholes were inspected identified and evaluated for use, and abandoned cables were spare or unused conduits were identified identified and removed to free up conduits. As the existing duct banks were examined, expected were found to be too full for use. Additionally, as duct bank many more than expected construction progressed, unexpected construction                              underground obstructions unexpected underground     obstructions were found that required duct Therefore, new duct banks and routings had to be designed and bank routes to be revised. Therefore, constructed that were not originally planned.

constructed The initial design called for 16 duct banks (approximately 2100 linear feet) and 11 11 manholes. The current design now calls for 22 duct banks (approximately (approximately 3185 linear feet) approximately 3000 linear feet of direct buried conduit, a significant and 14 manholes, and approximately Approximately 1515 linear feet of duct banks and ten manholes have been scope increase. Approximately been installed through the end of August 2010. Refer to Figure 3 for pictures of recent duct bank bank construction. During installation manholes in the heavy haul road it was determined installation of duct banks / manholes determined that the manholes specified in the design would not be able to withstand the crane weight. Redesign and fabrication of the new heavy haul manholes manholes caused caused a four week slip in the construction schedule. The heavy haul road is the only road that can be used by the construction equipment hatch crane to enter the radiological control area and remove the containment equipment equipment hatch / shielding to support a unit refueling building equipment refueling outage. Duct bank construction construction is only approximately percent complete at this time. It is not approximately 50 percent expected that the duct banks will be completed at the time the {{ expected } (d)(1) (d)(l) arrives onsite. As stated above, excavation and trenching in the PAis PA is a slow process that must be carefully planned and executed to assure personnel personnel and nuclear safety. (d)(1) (d)(l)

United States Nuclear Regulatory Regulatory Commission Commission to 10-021 Attachment Page Page 99 of 19 of 19 (d)(1) (d)(l) CP&L CP &L believes those security facilities that are in or near the interior areas of the P PAA are the most effective effective throughout the range of contingencies contingencies for which we must prepare. {{ (d)(1) (d)(l) 

                            } will ensure that HBRSEP, HBRSEP, Unit No.No.2,2, is compliant with the single act requirements, and also position security security resources resources in an area well protected protected from a variety of other threats. The new facility will also be available for future plans {{                 (d)(1)

(d)(l) 

                                    }} to further improve HBRSEP, Unit No. 2's, protective strategy.

See Table Table 1 below for project milestone schedules.

United States States Nuclear Nuclear Regulatory Regulatory Commission Commission to 10-021 Attachment Page Page 10 of 19 10 of 19 Summar Summary As indicated above, CP&L is expending expending a great deal of effort in the design and planning phases of these projects to ensure a sound safety-security safety-security interface. interface. 

       **   Operating experience experience from the implementation implementation of previous security orders, at Progress Energy Energy  facilities as well  as in the industry, has shown that decisions made within a compressed compressed schedule schedule to meet an aggressive deadline may create unintended unintended consequences consequences that have long-term adverse adverse impacts on the site.
       **   Additional time will provide for optimum planning and executionexecution to better assure personnel industrial safety and a sound personnel                            sound safety-security safety-security interface throughout the project.

These modifications modifications will provide provide several long term security benefits for HBRSEP, Unit No. 2. 

       **   A central central location within the P PA A for {

(d)(l) 

                                              } will improve improve the defensive position position of these assets and ensure protection from single act vulnerabilities.
       **   A central central location within the P PA A for {                          } will greatly greatly enhance enhance the (d)(1)

(d)(l) defensive defensive posture of the station from threats threats beyond beyond that which which is required for the single act. CP&L believes believes that the additional time necessary necessary to complete complete this project project is warranted based on the strengthened strengthened security posture that will be achieved achieved through the implementation implementation of of these projects. CP&L believes believes that the significant scope scope of the modifications and the time necessary to safely construct and test the modifications modifications justify justify additional time beyond the previously previously compliance date. Therefore, approved compliance Therefore, CP&L believes believes that our actions are in the best interest of protecting protecting public health and safety through the security security changes that will be instituted.

States Nuclear United States Regulatory Commission Nuclear Regulatory Commission Attachment to 10-021 10-021 Page 11 of Page 11 of 19 19 D. Temporary Compliance Measures Temporary Compliance Considered in Lieu of Measures Considered Second Exemption of aa Second Exemption considered other CP&L considered other options for achieving compliance with the one provision temporary compliance achieving temporary provision of the Final Rule Rule by the previously approved the previously compliance date approved compliance before seeking date before seeking this exemption. Options considered are discussed below. However, for the Options considered provided below, these the reasons provided temporary compliance temporary measures were rejected. compliance measures (d)(1) (d)(l)

United States Nuclear Regulatory Regulatory Commission Commission to 10-021 Page 12 Page 12 of 19 of 19 (d)( 1)) (d)(1

United United States Nuclear Nuclear Regulatory Regulatory Commission Commission Attachment 2 to 10-021 Page Page 13 of 19 (d)(1) (d)(l)

United States Nuclear Regulatory Commission Commission to 10-021 Attachment Page 14 of 1919 (d)(1) (d)(l) E. Environmental Environmental Assessment Assessment Carolina Power & Light Company Carolina Company (CP&L), now doing business as Progress Energy Inc., is requesting an exemption Carolinas, Inc., Carolinas, exemption for H.B. Robinson Steam Electric Plant (HBRSEP), (HBRSEP), Unit No. No.2,2, in accordance accordance "Specific exemptions." with 10 CFR 73.5, "Specific exemptions." The requested compliance date from March 31, exemptions would defer the compliance requested exemptions 31, 2010, as specified in 10 CFR 73.55(a)(1), 73.55(a)(1), to September 16, 2011, 16,2011, for one provision of 10 73.55. The CFR 73.55. proposed action is needed to allow additional time for the design and installation of security modifications that are expected to provide long term benefits modifications benefits in security security posture and compliance with the provision of 10 CFR 73.55, as revised on capabilities. In lieu of full compliance on March 27, 2009, CP&L will maintain the current HBRSEP, March 27,2009, Unit No. No.2, 2, site protective Security Plan. The current HBRSEP, Unit accordance with the current Physical Security strategy in accordance No. 2, site protective strategy has been approved by the NRC staff as providing a high No.2, assurance for the protection of the facility and public from the effects of radiological assurance sabotage. Deferral compliance from March 31, Deferral of compliance 2011, for the provision of September 16, 2011, 31, 2010, to September of therefore, does not result in any 10 CFR 73.55 is a compliance date change only and, therefore, physical changes to structures, systems, and components (SSCs) or land use at HBRSEP, Unit No. 2. Therefore, No.2. deferral of the compliance Therefore, the deferral compliance date does not involve: 

       *" any change change to the types, characteristics, characteristics, or quantities of non-radiological non-radiological effluents effluents discharged to the environment.
       *" any changes changes to liquid radioactive radioactive effluents discharged discharged to the environment.
       *" any changes changes to gaseous radioactive radioactive effluents effluents discharged discharged to the environment.
       *" any change change in the type or quantity of solid radioactive waste generated.

generated. 

       *" any change change in occupational 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 Conclusion* environmental impact associated with the proposed There is no significant radiological environmental proposed exemption will not affect any historical sites nor will it affect exemption. The proposed exemption non-radiological plant effluents. n,on-radiological

Commission United States Nuclear Regulatory Commission to 10-021 Page 15 Page 15 of of 19 19 F.

References:

1. Progress Energy letter from R. J. Duncan II to the Nuclear Regulatory Regulatory Commission Commission Document Control Desk titled, Request for for Exemptions from Physical Exemptions from Physical Security Security Requirements," dated November 30, 2009 Requirements,"

Nuclear Regulatory Commission letter from Tracy

2. Nuclear J. Orfto Tracy 1. Orf to Eric McCartney McCartney titled, H. B.

Robinson Steam Electric Plant, Unit No. From the Requirements No.22 - Exemption From Requirements of of 10 CFR Part Part 73, Section 73.55 (TAC (TA C No. ME2816), dated March No. ME2816), March 3,2010 3, 2010

United States Nuclear Nuclear Regulatory Regulatory Commission Commission Attachment to 10-021 Page 16 of 19 Table 1: Project Schedule Milestones ** Project Schedule (d)(l)

  • The dates The dates and and sequences sequences provided in this provided in this milestone milestone schedule schedule are are best best estimates based on estimates based information on information
  • available at the time the schedule schedule was developed developed and may change change as designs are finalized and construction construction proceeds. Therefore, these dates and sequences sequences are not considered considered to be regulatory commitments.

United States Nuclear Regulatory Commission Regulatory Commission to 10-021 Attachment Page 17 of 19 Figure 1: Design of { } (d)(l (d)(1)) (d)(1) (d)(l)

Regulatory Commission United States Nuclear Regulatory Commission to 10-021 Attachment Page 18 of 19 Figure 2: Location of {{ } (d)(1) (d)(l) (d)(1) (d)(l)

United States Nuclear Nuclear Regulatory Regulatory Commission Commission Attachment to 10-021 Page 19 of 19 Figure 3: Recent Duct Bank Construction Construction Major East - West Duct Bank Under Construction Construction One Set of Manholes in Previously Previously Completed Duct Bank}}

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