ML103360283

Redacted Version of Exemption Request from Specific Provision in 10 CFR 73.55

ML103360283
Person / Time
Site:	Robinson
Issue date:	09/30/2010
From:	Progress Energy Carolinas
To:	Office of Nuclear Reactor Regulation
References
RA-10-021
Download: ML103360283 (20)

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 0-021 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 (( 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 (( 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}}