ML19009A099

From kanterella
Jump to navigation Jump to search
Interim Storage Partners, LLC - Partial Response to RAI Part 1, Physical Security, Including Revision 3 of the Physical Security Plan, Guard Training and Qualification Plan
ML19009A099
Person / Time
Site: Consolidated Interim Storage Facility
Issue date: 01/07/2019
From: Sanchez E
Consolidated Interim Storage Facility
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
MML19114A230 List:
References
E-53364
Download: ML19009A099 (12)
v • d • e


Text

INTERIM STORAGE

.PARTNERS January 7, 2019 E-53364 Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852

Subject:

Partial Response to RAI Part 1, Physical Security, including Revision 3 of the Physical Security Plan, Guard Training and Qualification Plan, Docket 72-1050

Reference:

1. * - L~tter from John-Chau Nguyen (NRC) to Elicia Sanchez (ISP),

lnterir:n Storage Partners' License Application to Com,truc;;t and Operate the Waste Control Specialists Consolidated Interim Storage

. * ---Eacilit¥,-Andr.ews-County, Texas~cket-bJo.J2-1050 - Fits+/---

.. -* *_-_:*~-=~-~-:--.~_-:-:.~~ *-* - *_ **: *-. : Req~u~srror:.A:aai1fo*11ai-intofrnat1or-il'art f(PhysrcaFS.eoi:irtW;:*cratea *-

: *****:-~:-=*:* :::

_____________ --------------------** _.... ________

  • November 6, 2018_(E-51587}_____________ _ _________ ---------------------------------- _________
  • ___
  • _____ _
    • ---_***.. _. -------* ____ -______ --- _---- 2*~-. :-*cefler from J. -scoff Kirl<"(WCS1 to Mark"Lcffriba-fcf{f\\f~ense*--... _. *':~---:-

Application to Construct and Operate a Consolidated Interim Storage

- Facilit~rfor'Spenrr,.Juclear FuelTn~Ancfrews;County, Texat*-bocket72-1050, dated April 28, 2016 Interim Storage Partners (ISP) hereby files this partial response to the Request for Additional Information (RAI) Part 1, Physical Security documented in the attachments to the NRC letter dated November 6, 2018 (Reference 1) to support continued NRC review of the April 28, 2016 WCS License application requesting authorization to construct and operate a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas (Reference 2).

Contained in this submittaJ are responses to seventeen (17) of the twenty-eight (28)

RAls attached to Reference 1.

  • Safeguards Information When separated from Safeguards Information enclosure(s), this document is d~controlled provided the_ transmittal document d9es not otherwise warrant protection from the unauthorized disclosure.

P.O. Box 1129

  • interimstoragepartners.com 300 I
JH5SZ/p fo1t-15S

Safeguards Information Document Contrpl Desk E-53364

. Page 2 of 4 ISP and its team have determined that in order to provide complete and high quality responses to ttie balance of the RAls, we will need additional time to conclude the required responses. We would also like to schedule a meeting with NRC staff to discuss the remaining RIAs. Following that meeting, ISP will provide a schedule for completing *our responses to the RAls.

This submittal contains the following enclosures:

  • provides responses to the RAls items (SGI).
  • is Revision 3 of the Physical Security Plan (SGI)

\\

  • contains Revision 3 of the Training and Qualification Plan (SGI)
  • cc:>nt~ins revised MOUs and changed SAR pages (Public)

Physical Secur:ity Plan and Guard Training and Qualification Plan changes are tracked and indicated by revision bars in Revision 3 of these documents.

No changes we,~e req1;.1ired to the Safeguards Co,ntingency Plan, therefore the current

\\

  • revision for this,:document remains Revision 2. All of the documents included in the attachment arEln,arkecf as Safeguards Information and must be withheld from Linauthorizeu**df~*c1dsu~e* parsw.r,t to 10* CFR ?3::~2::-~:-:*** -----** --* * - * **:*-.* -~ ::*--;--:~

ISP requests that ~ c9py of all correspondence regardjrig this matter be direclly mailed to Mr. Jack Boshoven, Chief Engineer CISF Licensing :Eind Engineering; at 713q*

Minstrel Way, $.uite 300, Coh,imbia, MD 21045.

Should you hay~ any questions regarding this submittal, please contact Mr. Jack

Besh~~Ae:-aHft:<fr.9tG-6956,~t-jaekl,esheven@oranO;group.

.... --~......:.-~.:....* :c..:..... :./....*.,::.. ::...*

~= -

Safeguards Information

-*- **-* ~--*--* ---*..

When separated from Safeguards Information enclosure(s), this document is decontrolled provided the transmittal document does not otherwise warrant protection from the unauthorized disclosure.

Safeguards Information Document Control Desk I certify under penalty of perjury that the foregoing is true and correct.

Sincerely,

~~~y Elicia B. Sanchez,.

Chief Financial Officer

  • Interim Storage Partners LLC E-53364 Page 3 of 4 I certify the above names person appeared before me and execut~d this document on this ~day of.le.!,~ a:>.(~ ~Dl-ol ~

LANA TULL.

~Public

'i Notary PubUc, State ot Texas i

Mv CommlssiOn Expires December 01, 2019 cc:

John (Chau) Nguyen (NRC SFM) - Letter Only Jeff Isakson, ISP/TN Americas - Letter Only Jack Boshoven, ISP/TN Americas -Letter Only Safeguards Information When separated from Safeguards Information enclosure(s), this document is decontrolled provided the-transmittal document does not otherwise warrant protection from the unauthorized disclosure.

Document Control Desk

Enclosures:

1. RAI Responses (SGI)

Safeguards Information E-53364 Page 4 of 4

2. PSP-100 WCS CISF Physical Sec.urity Plan Revision 3 Effective Date 1/4/19 (SGI)
3. STW-700 WCS CISF Training and Qualification Plan Revision 3 Effective Date 1/4/19 (SGI)
4. MOUs and changed SAR pages (Public)

Safeguards Information When separated from Safeguards Information enclosure(s), this document is decontrolled provided the transmittal document does not otherwise warrant protection from the unauthorized disclosure. *

/

  • (Public)
  • WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 3.4.2 Design Criteria for Other SSCs Not Important-to-Safety The-classification of SSCs allows the application of design criteria in a graded manner. The system classifies SSCs by function in order to apply the appropriate

<;lesign criteria. Design criteria for NITS buildings and structures are discussed in this section.

The design criteria for SSCs classified as NITS, but that have importance t_o operations, such as transport vehicles, fire detection and suppression systems, security systems, radiation monitoring systems, and temperature monitoring systems, are addressed in subsequent chapters of this SAR. These SSCs are designed in accordance with their applicable codes and standards.

The WCS CISF radiation monitors are classified as NITS. The radiation monitors are not used to prevent or mitigate any credible accidents. The WCS CISF will utilize several types of radiation monitors including area monitors, thermo luminescent dosimeters.(TLD), portable hand held monitors, personnel dosimetry, and portable airborne monitors. The use of several different types of monitors ensures that redundant methods are in place to detect high radiation conditions and provide warning for on.site personnel.

The temperature monitoring system where used is classified as NITS. The purpose of the temperature monitoring system is to provide continuous surveillance of each cask's temperature to ensure proper operation. The temperature monitoring system is designed so that a monitor failure would result in a loss of signal to the monitoring computer. The loss of signal would initiate an alarm informing security personnel of a potential cask temperature problem. Security personnel would then contact operations personnel. In place of temperature monitoring, regular visual inspection for inlet and outlet blockage to. ensure that the overpacks remain operable may b~ implemented.

3.4.2.2 Conventional Quality WCS CISF SSCs not designated as ITS are considered to be of conveptional quality.

Conventional quality SSCs are designed and constructed in accordance with commercial standards as described below. The design of conventional.structures conforms with the requirements of ACI 318 [3.:6] for concrete and the AISC Manual of Steel Construction [3-7] for structural steel.

Page 3-24

WCS Consolidated Interim Stor~ge Facility Safety Analysis Report Revision 3 Interim Table 3-5 Quality Assurance Classification of Structures, Systems, and Components as Utilized at the WCS ClSF(I)

Important-To-Safety Not Important-To-Safety Classification Category A Facility Infrastructure SNF Canister Security and Administration Building Storage Pads (NUHOMS Storage Overpacks)

Classification Category B Overhead Building Cranes Storage Overpacks Overhead Building Crane Lifting Devices Canister Transfer System Electrical Power Vertical Cask Transporter

~

Classification Category C Facility Lighting Storage Pads (Vertical Concrete Storage NUHOMS Cask Transfer Trailer overpacks)

Cask Handling Building Radiation Monitors Temperature Monitoring System Treated as Category C Communication System Derailer (See Note 2)

Fire Protection System

  • CAS (See Note 2)

Potable Water System Securi_ty Lighting (See Note 2)

Sanitary Waste/Septic Systems Security Cameras (See Note 2)

Facility Roads Security Alarm Systems (See Note 2)

Railroad Line Components Backup Electric Power (Generators) (See Note 2)

Associated Support Equipment Notes:

(1) Quality Assurance Classifications for each of the Storage Systems SSCs are addressed in Table 3-4.

(2) Treated as ITS Category C with the exception 10 CFR Part 21 does not apply.

I Page 3-34 I

I

MEMORANDUM OF UNDERSTANDING.

. BETWEEN THE CARLSBAD MEDICAL CENTER AND WASTE CONTROL SPECIALISTS LLC AND INTERIM STORAGE PARTNERS LLC The purpose of this Memorandum of Understanding is to provide for the cooperation and coordination between the Carlsbad Medical Center and Waste Control Specialists LLC (WCS) and Interim Storage Partners LLC (ISP).

WCS operates a fully permitted and licensed hazardous and low level radioactive waste treatment,.storage and disposal facility. ISP operates a licensed Consolidated Interim Storage Facility (WCS CISF) for Spent Nuclear Fuel. In the event of an emergency, there is a potential need for. hospital medical services for citizens who may be employed by, contracted by, or visiting the facility.

Therefore, during the construction, operations and decommissioning of the WCS waste treatment, storage and disposal facilities and WCS CISF in Andrews County, the following is agreed*to:

1. The Carlsbad Medical Center agrees to work with WCS/ISP i!l coordinating emergency plans and procedures for assistance during the construction, operation and decommissioning phases of the WCS/WCS CISF facilities in Andrews County.
2. In the event of an emergency at the facility, the Carlsbad Medical Center Medical Center will coordinate with WCS/ISP and local emergency response organizations to establish hospital medical services as
  • I needed.
3. ltatany-time the *Carlsbad-Medical* Center, in*their judgment;* determines* they do-not"have-the
  • resources to respond tci the request for services from WCS/ISP due to other obligations or events, the Carlsbad Medical Center will be held harmless of any consequences.
4. The Carlsbad Medical Center will be invited to participate in joint training and emergency preparedness drills and exercises.
5. All Carlsbad Medical Center equipment property and personnel will remain under the operational

_:c;...c.oc..c..ntrol of their. re~~9tive unit~--*------

  • 6, **TIJis-~greement wi.11 J:>.e *rE;iyi§.We~Levery* five ye~rs;.. *l;ither p~rty m_ay terminate_ th.is ~greE;iment with a *. - *** -:::~*

ninety day written notice to the other party..

In witness whereof, the parties have executed this Memorandum of Understanding on the date indicated.

Name (print)

Signature Title Waste. Control Specialists LLC Date:

Name (print)

Signature Title Interim Storage Partners LLC

. Date:

Name (print)

Signatu*re Title Carlsbad Medical Center Date:

MEMORANDUM OF UNDERSTANDING BETWEEN THE CITY OF ANDREWS ANQ WASTE CONTROL SPECIALISTS LLC AND INTERIM STORAGE PARTNERS LLC The purpose of this Memorandum pf Understanding is to provide for the cooperation and coordination between the City of Andrews and Waste Ccfr1~rol Specialists LLC (WCS) and Interim Storage Partners LLC (ISP).

WCS operates a fully permitted and licensed hazardous and low level radioactive waste treatment, storage and disposal facility. ISP operates a licehs~d Consolidated Interim Storage Facility for Spent Nuclear Fuel. In the.

event of an emergency, arid the po_teritial need for services, the City of Andrews will respond to the facility and provide Primary Fire Fighting Services, Emergency Medical Services and Police services should they be

-neieded at the facility.

Therefore, during the construction,* operations and decommissioning of the WCS waste treatment, storage and disposal facilities and the WCS C1$F i_ri Andrews County, the following is agreed to: *

1. The City of Andrews agrees to worKwith WCS/ISP in coordinating emergency plans and procedures for assistance-during* the construction, operation and decommissioning phases of the WCS/WCS CISF facilities ih Andrews County.
2. In the event of an emergency-at the facility, the City of Andrews will coordinate with WCS/ISP to establish Police, Emergency Medical and Fire Fighting Services as needed at the facility. Once on-scene, the City of Andrews will° have jurisdiction as the Primary Emergency Authority for Fire Fighting Services. When present on-sqehei the Andrews County Sheriff's Office will coordinate any police

__ response_as the_Primary_Emergency_Authority for Law_Enf_a[cemenLA.separate WCS_.::-_Police

. Department MOU exists..

3. At the request of the City of Andrew$, and subjecrto the approval of WCS, WCS trained respO!lders and equipment will respond to an emergency event in s*upport and at the direction of the City of Andrews.
4. If at any *ume City of Andrews, in tt:ieir judgment, determines *they do not have the resources to respond to the request for services from WCS/ISP due to other obligations or events, the City of Andrews will be held harmless of any consequei_nces.

~-5~-:§tty:'Qfj\\l"lcf~'!Vs--~itt~ir.,_yi~cHQ-:Pt:ir.titjpat~~oJ1roirr!~mer:g~r.eiR~f~dness-drillsand exercises.*.

~

. _ __ _ __ __ 6._ All. City of Andrews equipment _pJQ~erty and _personnel will remain under_ the operational control of their

.... * * *-::*:- ::: *-__ : reSf)eclive-agency.*.-.: =: __.:... :::.::._:=.:..::_-=-=-:::..:__:_.-__ *.. :: *. *-.: * -:*:_.:_:::::._.:-~:-::.:::_:_:*.:::.:*-i:::::::::*: * :;.::_:::::.-_ ~.::_~::_ -. -

  • --- -*-* -- - - ?-;--This-agreement-will-be reviewed-every-five-years. Either-partymay-terminate this-agreement with a nin_etyd.~y written notice to th~ P1h_~rparty..

In witness whereof, th!;! parties have executed this Memorandum of Understanding on the date indicated.

Name (print)

Signature Title Waste Control Specialists LLC Date:

Name (print)

Signature Title Interim Storage Partners LLC Date:

Name (print)

Signature Title City of Andrews Date:

.MEMORANDUM OF UNDERSTANDING BETWEEN EUNICE FIRE AND RESCUE AND WASTE CONTROL SPECIALISTS LLC AND INTERIM STORAGE PARTNERS LLC The purpose of this Memorandum of Understanding is to provide for the cooperation and coordination between the Eunice Fire and Rescue and Waste Control Specialists* LLC (WCS) and Interim. Storage Partners

. LLC (ISP)..

WCS operates a fully permitted and licensed hazardous and low level radioactive waste treatment, storage and *

  • disposal facility. ISP operates a licensed Consolidated.Interim Storage Facility for Spent Nuclear Fuel. In the event of an emergency, and the potential need for services, Eunice Fire and Rescue will respond to the facility and provide Emergency Medical and Fire Fighting Services should they be needed at the facility.

t Therefore, during the construction, operations and decommissioning of the WCS waste treatment, storage and disposal facilities and the WCS CISF in Andrews County, the following is agreed to:

1. Eunice Fire and Rescue agree~ to work with WCS/ISP in coordinating emergency plans and procedures for assistance during the construction, operation and decommissioning phases of the WCS/WCS CISF facilities in Andrews County.
  • . 2. In the event of an emergency at the facility, Eunice Fire and Rescue will coordin~te with WCS/ISP to provide Fire Fighting and Emergency Medical Services as needed at the facility. Once on-scene, the City of Andrews will have jurisdiction as the Primary Emergency Authority for Fire Fighting Services.
3. If at any time Eunice Fire and Rescue, in their judgment, determines they do not have the resources to respond to the *request for services from WCS/ISP due to other obligations or events, Eunice Fire and.

-Rescue will be held harmless of any consequences. *

4. At the request of Eunice Fire and Rescue, and subject to the approval of WCS, WCS trained responders and equipment will respond to an emergency event in support of and at the direction of Eunice Fire and Rescue.
5. Eunice Fire and Rescue will be invited to participate in joint training and emergency preparedness drills
  • and exercises.
6. All Eunice Fire and Rescue equipment property and personnel will remain undedhe operational control of their respective age,:icy.
7. This agreement will be reviewed every five years. Either party may terminate this agreement with a ninety day written notice to the other party.

In witness whereof, the parties have executed this Memorandum of Understanding on the date indicated.

Name (print)

Signature Title Waste Control Specialists LLC Date:

Name (print)

Sign.ature Title

, Interim Storage Partners LLC Date:

Name (print)

Signature Title Eunice Fire and Rescue Date:

MEMORANDUM OF UNDERSTANDING BETWEEN THE LEA REGIONAL MEDICAL CENTER AND WASTE CONTROL SPECIALISTS LLC AND INTERIM STORAGE PARTNERS LLC The purpose of this Memorandum of Understanding is to provide for the cooperation and coordination between the Lea Regional Medical Center and Waste Control Specialists LLC (WCS) and Interim Storage Partners LLC (WCS).

WCS operates a fully permftted and licensed hazardous and low level radioactive waste treatment, storage and disposal facility. ISP operates a licensed Consolidated Interim Storage Facility for Spent Nuclear Fuel. In the event of an emergency, there is a potential need for hospital medical services for citizens who may be employed by, contracted by, or visiting the facility.

Therefore, during the construction, operations and decommissioning of the WCS waste treatment, storage and disposal fa.cilities and the WCS CISF in Andrews County, the following is agreed to:

1. The Lea Regional Medical Center agrees to work with WCS/ISP in coordinating emergency plans and procedures for assistance during the construction, operation and decommissioning phases of the WCS/WCS CISF facilities in Andrews County.
2. In the event of an emergency at the facility, the Lea Regional Medical Center will coordinate with WCS/ISP and local emergency response organizations to establish hospital medical services as needed.
3. If at any time the Lea Regional Medical Center, in their judgment, determi!"les they do not have the resources to respond to the request for services from WCS due to other obligations or events, the Lea Regional Medical Center will be held harmless of any consequences.
4. The Lea Regional Medical Center will be invited to participate in joint training and emergency preparedness drills and exercises.
5. All Lea Regional Medical Center equipment property and personnel will remain under the operational control of their respective unit(s).
6. This agreeme:nt will be reviewed every five years. Either party may term*inate this agreement with a ninety day written notice to the other party.

In witness whereof, the parties have executed this Memorandum of Understanding on the date indicated.

l Name (print)

Signature Title Waste Control Specialists LLC

  • Date:

Name (print)

Signature Title Interim Storage Partners LLC Date:

Name (print).

Signature Title Lea Regional Medical Center Date:

I

MEMORANDUM OF UNDERSTANDING BETWEEN THE PERMIAN REGIONAL MEDICAL CENTER AND WASTE CONTROL SPECIALISTS LLC AND INTERIM

. STORAGE PARTNERS lLC The purpose of this Memorandum of Understanding is to provide for the cooperation and coordination between the Permian Regional Medical Center and Waste Control Specialists LLC (WCS) and Interim Storage Partners I*

LLC (ISP).. *.

WCS operates a fully permitted and licensed hazardous and low level radioactive waste treatment, storage arid*

disposal facility. ISP operates a licensed Consolidated Interim Storage Facility.for Spent Nuclear Fuel. In the event of an emergency, there is a potential need for hospital medical services for citizens who may be employed by, contracted by, or visiting the facility.

Therefore, during the construction, operations and decommissioning of the WCS waste treatment, storage and disposal facilities and the WCS CISF in Andrews County, the following is agreed to:

.~

1. The Permian Regional Medical Center agrees to wqrk with WCS/ISP in coordir;iating emergency plans and procedures for assistance during the construction, operation and decommissioning phases of the WCS/WCS CISF facilities in Andrews County.
2. In the event of an emergency at the facility, the Permian Regional Medical Center will coordinate with WCS/ISP and local emergency response organizations to establish hospital medical services as needed.

Q

3. If at any time-tne*-Permian Region-al*Me-dical'Center,.in theirJudgment, determines*they*cto-not have the resources to re~porid to the request for services from WCS due to other obligations or events, the Permian Regional Medical Center will be held harmless of any consequences.
4. The Permian.Regional Medical Center will be invited to participate in joint training and emergency preparedness drills and exercises.
5. All Pern:iiari Regional Medical Center equipment property and personnel will remain under' the operational c...911Jrol qt their respective un_lli._s__L__ *
6. This agreem~tJ.t.Will be.r~viewed ~v~ry-flve years; E;it_h_e_r -pa-.. rt-y--rn.~y-terminate.this *agr~~rnentwith~a--~-1 ninety day written notice to the other party..

In witness whereof, _the partie.s have executed this Memorandum of Understanding on the date indicated.

Name (print)

Signature Title Waste Control Specialists LLC Date:

Name (print)

Signature Title Interim Storage Partners LLC

  • Date:

Name (print)

Signature Title Permian Regional Medical Center Date:.

Retrieved from "https://kanterella.com/w/index.php?title=ML19009A099&oldid=4941217"