ML100120657

Request for Exemption from Physical Security Requirements

ML100120657
Person / Time
Site:	Susquehanna
Issue date:	01/08/2010
From:	Rausch T S Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6594
Download: ML100120657 (18)

Text

0 0 0 Timothy S. Rausch PPL Susquehanna, LLC Sr. Vice President

& Chief Nuclear Officer 769 Salem Boulevard

] D -Berwick, PA 18603 p Tel. 570.542.3445 Fax 570.542.1504 tsrausch@pplweb.com TM JAN 0 8 2010 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OPI-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION REQUEST FOR EXEMPTION FROM PHYSICAL SECURITY REQUIREMENTS Docket Nos. 50-387 PLA-6594 and 50-388

References:

1) 1OCFR73.55 Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors against Radiological Sabotage.2) PLA-6583, Mr. T. S. Rausch (PPL), to Document Control Desk (USNRC),"Susquehanna Steam Electric Station Request for Exemption from Physical Security Requirements," dated December 3, 2009.This letter revises and replaces the exemption request submitted in PLA-6583, dated December 3, 2009 (Reference 2).In accordance with the requirements of 10CFR73.5, PPL Susquehanna, LLC (PPL)requests the Nuclear Regulatory Commission (NRC) approve an exemption from the specific requirements of 10CFR73, "Physical Protection of Plants and Materials," for Susquehanna Steam Electric Station (SSES) Units 1 and 2 by extending the implementation deadline for certain security requirements issued by NRC in a Final Rule dated March 27, 2009 (74FR 13926).Pursuant to the Final Rule, the new security requirements must be implemented by March 31, 2010. PPL has evaluated these new requirements and determined that many can be implemented by the required date. PPL has determined, however, that implementation of specific parts of the new requirements will require more time to implement since they are significant physical changes involving or requiring:

1) specific parts that are proving to be long lead time items, 2) specialized industry expertise whose availability is being challenged by the significant demand for a limited resource, or 3) a major interface with the plant for installation that must be carefully planned and implemented to avoid impact to the plant protective strategy. Document Control Desk PLA-6594 PPL is requesting an exemption from the March 31, 2010 implementation date for those requirements itemized in Attachment

1. Specifically, extensions are requested until October 29, 2010 for two requirements and until July 31, 2011 for one other requirement.

Attachment 1 also includes the justification for the requested exemptions.

The milestone schedule for accomplishing the subject work is contained in Attachment

2. Attachment 2 also identifies the regulatory commitments.

Attachment 3 is the environmental assessment.

Attachments 1 and 2 have been redacted to delete security related information.

The security related information has been replaced with "[ ]". A security related version of this letter (PLA-6593) was signed and submitted to the NRC on this date.PPL has determined that our current security program, along with the new security requirements that will be-implemented by March 31, 2010, will provide continued assurance of public health and safety and common defense and security.

Accordingly, the requested exemption is authorized by law and will not endanger life, property, or the common defense and security in accordance with 10CFR73.5.

PPL requests approval of this exemption request by February 27, 2010to otherwise allow time to prepare and implement compensator y measures if the exemption is not granted.The proposed exemptions are requested tO be effective, upon issuance.Should you have any questions or require additional information, please contact Mr. Michael H. Crowthers, Manager-Nuclear Regulatory Affairs, at (610) 774-7766.Sincerely, Attachment 1: Description of Exemption Items (Redacted Version)Attachment 2: Milestone Schedule/Regulatory Commitments (Redacted Version)Attachment 3: Environmental Assessment Copy: Mr. S. J. Collins, NRC Regional Administrator Mr. P. W. Finney, NRC Resident Inspector Mr. R. R. Janati, DEP/BRP Mr. A. Patel, NRC Sr. Resident Inspector Mr. B. K. Vaidya, NRC Project Manager Document Control Desk PLA-6594 cc: J. M. Helsel R. E. Smith M. R. Sleigh M. H. Crowthers P. A. Horn (SRC)T. VanVreede T. A. Gorman C. E. Manges, Jr.T. G. Wales (DBD)NRA Files DCS NUCSB3 NUCSA4 NUCNG GENPL4 NUCSB2 GENPL5 GENPL5 NUCSA4 GENPL5 GENPL4 GENPL4 Attachment 1 to PLA-6594 Description of Exemption Items (Redacted Version)

Attachment 1 to PLA-6594 Page 1 of 7 INTRODUCTION The NRC issued a Final Rule for new security requirements in the Federal Register dated March 27, 2009. Per the Final Rule, new security requirements must be implemented by March 31, 2010.This attachment provides a description of each item for which an exemption from the March 31, 2010 implementation date is requested along with the associated justification.

Each of the items involves one or more of the following situations: " The item requires specific parts that are proving to be long lead time items." The item requires specialized industry expertise whose availability is being challenged by the significant demand for a limited resource.* The item involves a major interface with the plant for installation that must be carefully planned and implemented to avoid impact to the plant protective strategy.Impacts to the plant protective strategy are particularly significant during the period leading up to and throughout the upcoming Unitl refueling outage when our Extended Power Uprate Project, including a major digital upgrade adding an Integrated Control System, is being installed.

The EPU Project provides significant plant challenges with the number of contract personnel that will be required to accomplish the work during the outage. The large number of site contract personnel in-processing each day, which will be significantly beyond that experienced during a normal refueling outage, will require the full attention of Nuclear Security.PPL requests an exemption, from the implementation deadline only, for the three items listed below. PPL has determined that our current security program, along with the new security requirements that will be implemented by March 31, 2010, will provide continued assurance of public health and safety and common defense and security.

Accordingly, the requested exemption is authorized by law and will not endanger life, property, or the common defense and security in accordance with 10CFR73.5.

DESCRIPTION OF SPECIFIC PROPOSED EXEMPTIONS Item#1: r ]Regulatory Reciuirement:

[ I Attachment 1 to PLA-6594 Page 2 of 7 Description of Issue:[ ] Additional time is required to fully implement this modification.

Exemption Requested:

Extend the completion for this aspect of compliance with the requirements of [from March 31, 2010 until October 29, 2010.Justification for Exemption:

The justification for this request for an exemption is based on a combination of equipment availability, the critical nature of the design change, and the critical nature of the tie-in of the new design into the existing systems. The specific details are as follows: Long lead-time equipment required to implement this modification cannot be assured to be available to support full implementation by March 31, 2010.Specifically, o The equipment

[ ] required to implement this plant change are long-lead time procurements.

Estimated lead. times. for this equipment have increased significantly from the preliminary estimates of 5 to 7 weeks to 10 to 12 weeks when the purchase orders were placed. As an increasing number of licensees pursue this type of equipment, these delivery times are expected to increase.o Additionally, due to the critical nature of this equipment

[ ], factory acceptance/post-modification testing will be required upon completion of fabrication/installation.

Positive results for this testing cannot be assumed.Test failures would further delay the implementation schedule.

Attachment 1 to PLA-6594 Page 3 of 7* The addition of [ ] for this application is a significant change requiring a thorough engineering evaluation to assure that all critical aspects of the design are completely understood and factored into the final design. For example, [] was conducted to identify [ ]. An engineering review revealed the presence of [ ] that could impact the long term performance of the [ ]. The addition of equipment and related design to [ ] was required to resolve this issue. The additional time would avoid expediting the engineering change process and ensure a thorough evaluation prior to finalizing the design.* [I ]. Compensatory Security Measures will be required while [ ]. This will require the full attention of the Security Force Resources.

To be most effective, the Security Force demands described below associated with the upcoming Unit 1 outage should not be performed simultaneously with this work.* In mid-January 2010, pre-outage preparation work will begin for the Unit 1 refueling outage. This Unit 1 refueling outage involves the completion of an: Extended Power Uprate Project, including ajmajor digital system upgrade adding a new Integrated Control System. From mid-January through early April 2010, a significant number of additional contract personnel will be onsite.Daily in-processing for this outage period will be significantly greater than for a normal refueling outage. An outage of this m-agnitude will require the full attention of the Security Force beyond that experienced during a normal refueling outage.Finally, system testing and personnel training must be performed before this change can be considered to be fully implemented.

This exemption request is limited to extending the compliance date to provide an [ ]. Changes to other provisions and requirements including maintaining

[ ] is not included in this request.

Attachment 1 to PLA-6594 Page 4 of 7 Item #2: r 1 Regulatory Requirements:

[1]Description of Issue:[ ]. Additional time is required to complete installation of [ ] required to meet the new rule requirements.

Exemption Requested:

Extend the completion for this aspect of compliance with the requirements of [from March 31, 2010 until October 29, 2010.Justification for Exemption:

The justification for this request for an exemption is based on a combination of the.specific location where this work must be performed, the critical nature and availability of the resources required to perform the design .change, and the critical nature ýof the tie-in of the new design into the existing systems. The specific details are as follows:

Attachment 1 to PLA-6594 Page 5 of 7* [i ] for this application is a specialized change requiring the availability of engineering personnel qualified to perform the design. The vendor design engineering group used for this type of work at PPL Susquehanna, LLC (PPL)is currently being employed by approximately one-half of the licensees for similar type work. The limited availability of this required resource is affecting our ability to complete the vendor design engineering and procurement in the time frame originally established in the vendor design engineering contract.Following completion of the vendor design, PPL must integrate the vendor design into an engineering change package. Following the issuance of the engineering change package field engineering application design and installation work planning must be completed.

The mission success of the installation and the worker safety during installation depends on the quality of design and work planning.

Vendor delays have challenged the ability to adequately and safely complete the design and planning, in time to support installation prior to the upcoming Unit 1 refueling outage.* The installation of this modification involves [! ]. To avoid an impact to Security Personnel monitoring plant access during the.heavy period for the outage will require [ ] to be suspended beginning in mid-January of 2010.Based on the factors described above, the installation of this change cannot be completed prior to mid-January 2010.In mid-January of 2010, pre-outage preparation work will begin for the Unit 1 refueling outage. This Unit 1 outage involves the completion of an Extended Power Uprate Project, including a major digital upgrade adding a new Integrated Control System. From mid-January through early April of 2010, a significant number of additional contract personnel will be onsite. Daily in-processing for this outage period will be significantly greater than for a normal refueling outage. An outage of this magnitude will require the full attention of the Security Force beyond that experienced during even a normal refueling outage.Finally, system testing and personnel training must be performed before this change can be considered to be fully implemented.

Attachment 1 to PLA-6594 Page 6 of 7 This exemption request is limited to extending the compliance date to [ ].During the extension period, the [ ] will continue to be performed by [ ].These modifications will provide [ ]. All other [ ] and are not included in this request.Item #3: [ I Regulatory Requirements:

[ ]Description of Issue:[ ]. Additional time is required to complete [ ] and achieve full compliance with all aspects of the new rule.

Attachment 1 to PLA-6594 Page 7 of 7 Exemption Requested:

Extend the completion for this aspect of compliance with the requirements of [from March 31, 2010 until July 31, 2011.Justification for Exemption:

The justification for this request for an exemption is based on a combination of the critical nature and availability of the resources required to perform the design change and the critical nature of the tie-in of the new design into the existing systems. The specific details are as follows:[ ]" The design required to adequately address the requirements of [ ] cannot be effectively integrated into [ ]. [ ]. Additionally, the [ ] is based on [ ], whereas the new design is based on [ ]. To effectively transfer [ ], a major upgrade to the [ ] is required.

The upgrade will [ ]. Once the existing [is completed, the [ ] can be integrated into [ ] and [ ] will meet the requirements of [ ]." To accomplish this major system upgrade, many of the factors described above for achieving compliance with the requirements of [ ] apply. Additionally, since this change will impact the [ ] for the security system, it must be comprehensively and diligently designed, meticulously planned and very carefully installed and tested to avoid an [ ]." During the period of time between achieving compliance with the requirements of [ ] ( i.e. October 29, 2010) and achieving compliance with the requirements of [ ] (i.e. July 31, 2011) the affected area of the [ ] can be[ ] by personnel in the [ ] with the [ ] for meeting the design requirements of [ ] in the [ ]. [ ] will be received in the [ ], but[ ]is completed and the [ ] are integrated into [ ]. [ ] in the [ ] is required to comply with [ ]. This exemption request is specifically limited to extending the compliance date to provide [ ]. [ ] is adequate to meet the requirements and thus is not included in this request.

Attachment 2 to PLA-6594 Milestone Schedule/Regulatory Commitments (Redacted Version)

• Attachment 2 to PLA-6594 Page 2 of 2 List of Regulatory Commitments The following table identifies the regulatory commitments in this document.

Any other statements in this submittal represent intended or planned actions, are provided for informational purposes, and are not considered to be regulatory commitments.

Regulatory commitments Due date/event Compliance with [ ] Achieved October 29, 2010 Compliance with [ ] Achieved October 29, 2010 Compliance with [ ] Achieved July 31, 2'011 Attachment 3 to PLA-6594 Environmental Assessment Attachment 3 to PLA-6594 Page 1 of 3 1. Describe any change to the types, characteristics, or quantities of nonradiological effluents discharged to the environment as a result of the proposed exemptions.

PPL Response: There are no expected changes in the types, characteristics, or quantities of nonradiological effluents discharged to the environment associated with these proposed exemptions.

This application is associated with implementation of security changes.These security changes will not result in changes to the design basis requirements for the structures, systems, and components (SSCs) at the Susquehanna Steam Electric Station (SSES) that function to limit the release of-non-radiological effluents during and following postulated accidents.

All the SSCs associated with limiting the release of offsite non-radiological effluents will therefore continue to be able to perform their functions, and as a result; there is no significant non-radiological effluent impact. There are no materials or chemicals introduced into the plant that could affect the characteristics or types of non-radiological effluents.

In addition, the-method of operation of nonradiological waste systems will not be affected by these proposed exemptions.

2. Describe any changes to liquid radioactive effluents discharged as a result, of the proposed exemptions.

PPL Response: There are no expected changes to the liquid radioactive effluents discharged as a result of these proposed exemptions.

The proposed exemptions will not interact to produce any different quantity or type of radioactive material in the reactor coolant system. These proposed exemptions will not result in changes to the design basis requirements for the SSCs at SSES that function to limit the release of liquid radiological effluents during and following postulated accidents.

All the SSCs associated with limiting the release of liquid radiological effluents will therefore, continue to be able to perform their functions, and as a result, there is no significant liquid radiological effluent impact.3. Describe any changes to gaseous radioactive effluents discharged as a result of the proposed exemptions.

PPL Response: There are no expected changes to the gaseous radioactive effluents discharged as a result of this exemption.

The proposed exemptions will not interact to produce any different quantity or type of radioactive material in the reactor coolant system. These proposed exemptions will not result in changes to the design basis requirements for the SSCs at SSES that function to limit the release of gaseous radiological effluents during and following postulated accidents.

All the SSCs associated with limiting the release of Attachment 3 to PLA-6594 Page 2 of 3 gaseous radiological effluents will therefore, continue to be able to perform their functions, and as a result, there is no significant gaseous radiological effluent impact.4. Describe any change in the type or quantity of solid radioactive waste generated as a result of the proposed exemptions.

PPL Response: These proposed exemptions will not result in changes to the design basis requirements for the structures, systems, and components (SSCs) at SSES that function to limit the release of solid waste during and following postulated accidents.

All the SSCs associated with limiting the release of solid radioactive waste will therefore continue to be able to perform their function.

Radiation surveys will be performed in accordance with plant radiation protection procedures on excavated dirt that could be contaminated, such as inside the protected area or radiation control areas, that will be disposed of offsite.5. What is the expected change in occupational dose as a result of the proposed exemptions under normal and design basis accident conditions?

PPL Response: Under normal power operation there would be no expected radiological impact on either the workforce or the public. There are no other expected changes in normal occupational operating doses. Control room dose is not impacted by the proposed security changes and would not impact occupational dose.6. What is the expected change in the public dose as a result of the proposed exemptions under normal and DBA accident conditions?

PPL Response: Dose to the public will not be changed by the proposed security changes during normal operations.

As noted in Items 2, 3 and 4 above, there is no basis to contemplate an increased source of liquid, gaseous or solid radiological effluents that could contribute to increased public exposure during normal operations and DBA conditions.

The proposed exemptions do not impact systems used during normal operation or systems used to detect or mitigate a DBA.

Attachment 3 to PLA-6594 Page 3 of 3 7. What is the impact to land disturbance for the proposed exemptions?

PPL Response: The activities related to the proposed exemptions are potentially subject to local zoning and environmental permitting requirements.

The need for permitting for each proposed activity is determined on a case-by-case basis by consulting with the Salem Township zoning authority and County Conservation District.

With respect to cultural resource protection concerns, all of the subject activities are being conducted within the plant Protected Area, the entirety of which is formally classified as "disturbed" by the Pennsylvania Historical Museum Commission; therefore, none of the proposed activities require additional cultural resource protection considerations.

==

Conclusion:==

There are no significant radiological environmental impacts associated with the proposed security change at SSES. Additionally, the proposed changes will not affect non-radiological plant effluents