NRC-09-0081, Supplemental Information Re the Request for Exemption from Physical Security Requirements

Supplemental Information Re the Request for Exemption from Physical Security Requirements

ML100040010
Person / Time
Site:	Fermi
Issue date:	12/23/2009
From:	Plona J DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-09-0081
Download: ML100040010 (15)

Text

Joseph H.

Joseph H. Plona Plona Site Vice President President 6400 N.

N.Dixie Highway, Newport, MI 48166 Tel: 734.586.5910 Fax: 734.586.4172 Security-Related

, DYE DTE Energy*

Energy-Information - Withhold Under 10 CFR 2.390 Security-Related Information 2.390 10 CFR 73.5 73.5 December 23, 2009 23,2009 NRC-09-0081

u. S. Nuclear U. Regulatory Commission Nuclear Regulatory Attention:

Attention: Document Control Desk Desk Washington Washington DC D C 20555-0001

References:

1) 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) Detroit Edison Letter to the NRC, "Request "Request for Exemption from Physical Security Requirements,"

Requirements," NRC-09-0059, NRC-09-0059, dated November 19, 2009

Subject:

Supplemental Information Regarding the Request Supplemental Information Request For Exemption Exemption from Physical Physical Security Requirements Reguirements In Reference 2, Detroit Edison requested an exemption exemption from the compliancecompliance date of 10 10 CFR 73.55(a)(1) 73.55(a)(1) for implementing certain requirements requirements of the fina110 final 10 CFR 73.55 rule, "Requirements for Physical "Requirements Physical Protection of Licensed Activities in Nuclear Power Reactors Against Against Radiological Sabotage." In two telephone conversations Radiological Sabotage." between conversations between NRC staff and Detroit Edison personnel personnel on December December 2, and December 14, 2009, the NRC requested clarifications to the information provided in Reference 2. The requested some clarifications requested clarifications have been incorporated requested clarifications incorporated in the enclosures enclosures to this letter.

letter. The specific changes include numbering modifications listed for compliance numbering modifications compliance with the new rule in both Enclosures Enclosures 1 and 2,2, referencing referencing the specific section section of the rule for which the exemption is requested and revising the description description of one of the modifications.

modifications. of this letter provides the physical and programmatic programmatic security information information to support this exemption request. Enclosure Enclosure 2 contains a schedule showing showing milestones for each of the security modifications required to implement implement the new rule. Enclosures 1 and 2 of this letter replace Enclosures Enclosures 1 and 2 of Reference information Reference 2. The information provided provided in Enclosures 1 and 2 is considered security-related considered security-related information associated associated with the physical physical protection of Fermi 2, as described in 10 CFR 2.390(d)(1). 2.390(d)(1).

Enclosures 1 and 2 contain contain Security Related Information Information -

Withhold under 10 CFR 2.390. Upon Separation, the cover cover letter and Enclosures Enclosures 3, 4 and 5 are DECONTROLLED.

DECONTROLLED. SDO\

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, Security-Related Security-Related Information Information Withhold Under 10 CFR2.390 CFR 2.390 USNRC NRC-09-0081 Page 2 Accordingly, Detroit Edison requests that the information information provided in Enclosures Enclosures 1 and 2 of this letter be withheld from public disclosure in accordance disclosure accordance with the provisions of of CFR 2.390. Enclosure 10 CFR Enclosure 3 contains contains the Environmental Environmental Assessment Assessment as provided provided in Reference 2. Enclosures Enclosures 4 and 5 are non-proprietary non-proprietary versions of Enclosures 1 and 2.

Enclosures 4 and 5 of Reference Enclosures 4 and 5 of this letter replace EnClosures Reference 2.

There are no new commitments commitments included in this document.

Should you have any questions or require additional additional information, please contact Mr.

Rodney W. Johnson of my staff at (734) 586-5076.

586-5076.

Sincerely, Enclosures

1. Request for Exemption

1. Exemption from Physical Security Security Requirements (Security Related Requirements (Security Information Information - Withhold Withhold Under Under 10 CFR CFR 2.390)

2. Schedule of Milestones for Security Modifications Modifications (Security (Security Related Information Information -

Withhold Under Under 10 CFR 2.390) 2.390)

Environmental Assessment

3. Environmental Assessment Non-Proprietary Version of Enclosure 1

4. Non-Proprietary

5. Non-Proprietary Non-Proprietary Version of Enclosure 2 cc: NRC Project Manager Manager NRC Resident Office Office Reactor Reactor Projects Projects Chief, Branch 4, Region Region III Regional Administrator, Region III III Supervisor, Electric Operators, Supervisor,Electric Operators, Michigan Public Service Commission*

Michigan Commission [w/o Enclosures 1 and 2]

.Enclosures Enclosures 1 and 2 contain Security Related Information Information -

Withhold under 10 CFR 2.390. Upon Separation, the cover letter and Enclosures 3, 4 and 5 are DECONTROLLED.

Enclosur~s 3,4 DECONTROLLED.

Enclosure 3 to Enclosure NRC-09-0081 NRC-09-0081 Request Request for Exemption Security Plan Exemption from Physical Security Plan r Environmental Assessment Environmental Assessment Enclosures 1 and 2 contain Security Related Information -

cover Withhold under 10 CFR 2.390. Upon Separation, the cover Enclosures 3, letter and Enclosures letter are DECONTROLLED.

3, 4 and 5 are

-1'"

\)

-' Enclosure Enclosure 33 to NRC-09-008l NRC-09-0081 Page 1 Request for Exemption from Physical Security Plan Request Environmental Assessment Environmental Assessment

1. Describe Describe any change change to the types, characteristics, characteristics, or quantities of non-radiological non-radiological effluents discharged discharged to the environment environment as a result of the proposed proposed exemption.

Response

There are no expected expected changes changes in the types, characteristics, characteristics, or quantities quantities of non-radiological effluents discharged to the environment associated with the proposed effluents discharged proposed exemption.

exemption. This application application is associated associated with implementation implementation of security changes. These security security changes changes will not result resu,lt in changes changes to the design design basis requirements for the structures, systems, and components components (SSCs) at Fermi 2 that function to limit the release release of non-radiological effluents during and following postulated postulated accidents. All the SSCs associated with limiting the release of of offsite non-radiological non-radiological effluents effluents will therefore therefore continue continue to be able to perform perform their functions, and as a result; there is no significant non-radiological effluent impact. There are no materials or significant non-radiological chemicals introduced chemicals introduced into the plant that could affect the characteristics characteristics or types of non-radiological radiological effluents. In addition, the method of operation of non-radiological non-radiological waste systems will not be affected affected by this exemption.

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

Response

There are no expected expected changes changes to the liquid radioactive discharged as a result of this radioactive effluents discharged exemption. The proposed security changes will not interact to produce interact produce any different quantity or or type of radioactive radioactive material in the reactor coolantcoolant system. These security changeschanges will not result in in changes changes to the design design basis requirements for the SSCs at Fermi 2 that function to limit the release of liquid radiological ofliquid radiological effluents effluents during during and following postulated accidents.

accidents. All the SSCs associated associated with limiting-the release of liquid radiological ofliquid radiological effluents will therefore, therefore, continue to be able to perform perform their functions, and as a result, there is no liquid radiological radiological effluent impact.

3.

3. Describe Describe any changes changes to gaseous radioactive effluents discharged radioactive effluents discharged as a result of the proposed proposed exemption.

Response

Response:

There are There are no no expected expected changes to the gaseous radioactive discharged as a result of this radioactive effluents discharged exemption. The proposed security security changes changes will not interact to produce any different quantity quantity or or type of radioactive material material in the reactor coolant system. These security changes will not result in changes in changes to requirements for the SSCs at Fermi 2 that function to limit the to the design basis requirements release of gaseous radiological effluents during and following postulate0--iccidents.

postulat~5h.ccidents. All the SSCs SSCs r-------------------------------------~~/-

Enclosures 1 and 2 contain Enclosures contain Security Informad___~

Security Related Inforimati--°'

Withhold under 10 CFR 2.390. Upon Separation, Separation, the cover cover letter and Enclosures Enclosures 3, 3, 4 and 5 are DECONTROLLED.

DECONTROLLED.

"\,

'\ I j Enclosure 3 to Enclosure NRC-09-0081 Page 2 Page limiting-the release of gaseous associated with limiting-the gaseous radiological radiological effluents effluents will therefore, therefore, continue continue to be able to perform their functions, and as a result, there is no significant gaseous radiological effluent impact impact.

4. Describe any change in the type or quantity of solid radioactive radioactive waste generated generated as a result of of the proposed exemption.

Response

These security changes will not result in changes to the design basis requirements requirements for the components (S structures, systems, and components SCs)

(SSCs) at Fermi 2 that function to limit the release of solid associated with limiting the postulated accidents. All the SSCs associated waste during and following postulated release of solid radioactive release radioactive waste will therefore continue continue to be able to perform perform their function.

Radiation Radiation surveys will be performed performed in accordance accordance with plant radiation radiation protection procedures on protection procedures on excavated dirt, such as inside the protected area or radiation control areas, that will be disposed excavated disposed of offsite. Any contaminated contaminated dirt will be handled in accordance accordance with plant procedures. Fermi 2 has a radiation survey program and procedures to handle any contaminated excavated excavated soil that is protected area or radiation control areas. Therefore, these security changes inside the protected changes will not radioactive waste generated.

changes to the type or quantity of solid radioactive result in changes

5. What is the expected change in occupational dose as a result of the proposed exemption

5. What is the expected change in occupational dose as a result of the proposed exemption under normal and design basis accident accident conditions?

conditions?

Response

Under normal power operation operation there would be no expected expected radiological impact on the workforce.

There are no other expected changes changes in normal occupational operating doses. Control room dose occupational changes. Therefore, is not impacted by the proposed security changes. changes will not Therefore, these security changes result in changes changes in occupational occupational dose as a result of the proposed proposed exemption.

Enclosures 1 and 2 contain Security Enclosures Security Related Information -

Withhold Separation, the cover Withhold under 10 CFR 2.390. Upon Separation, cover 3, 4 and 5 are DECONTROLLED.

letter and Enclosures 3, DECONTROLLED.

Enclosure 3 to NRC-09-0081 Page 3

6. What is the expected expected change change in the public dose as a result of the proposed proposed change under normal and Design Basis Accident Accident conditions?

Response

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

operations. As noted in items 2, 33 and 4 above above there is no basis to contemplate contemplate an increased increased source of liquid, gaseous or solid radiological radiological effluents that could contribute contribute to increased public exposure exposure during normal operations operations and DBA conditions. The proposed proposed security changes do not impact systems used during normal operation nor systems used to detect or mitigate a DBA.

7. What is the impact to land disturbance for the proposed proposed security changes?

Response

The proposed security security changes changes include installation installation of a new Protected Area fence and relocating approximately 500 feet of Protected approximately Protected Area Area fence away from the Protected Area Area access portal.

Installation Installation of a new Protected Area fence is taking place close to the existing existing fence, inside inside the current current isolation isolation zone. The isolation isolation zone was previously disturbed disturbedbyby construction construction activities.

The 500 feet of Protected Protected Area Area fence being being relocated relocated is being placed in a pre-existing parking lot; previously previously disturbed property. The remainder of the modifications remainder ofthe modifications will be performed performed inside the Protected Protected Area.

There There will be no impacts to historical historical and cultural cultural resources because the security changes changes are to be made in previously disturbed areas. No changes to the National Pollution Discharge Elimination Elimination System permit are needed. There will not be an effect on the aquatic aquatic or terrestrial habitat in the vicinity of the plant, or to threatened, endangered, or protected species under the Endangered Species Endangered Species Act. There will be no impacts to essential fish habitat covered by the Magnuson-Steven's Act. There will be no impact to the air or ambient air quality.

Magnuson-Steven's Fermi 22 has a procedure procedure in place to address land disturbances.

disturbances. The procedure requires a Environmental Excavation Environmental Excavation Permit and a Excavated Excavated Material Management Management Plan.

Conclusion:

There is no significant radiological environmental impact associated with the proposed radiological environmental proposed security changes at Fermi 2. These proposed proposed changes changes will not affect any historical historical sites nor will they non-radiological plant effluents.

affect non-radiological Enclosures Enclosures 1 and 2 contain contain Security Security Related Information Information -

Withhold under 10 CFR 2.390. Upon Separation, cover Separation, the cover letter and Enclosures 3, 3, 4 and 5 are DECONTROLLED.

DECONTROLLED.

Enclosure 4 NRC-09-0081 NRC-09-0081 Non-Proprietary Non-Proprietary Version of Enclosure 1 Enclosures Enclosures 1 and 22 contain contain Security Related Related Information Information--

Withhold under 10 CFR 2.390. Upon Separation, the covercover letter and Enclosures Enclosures 3, 4 and 55 are DECONTROLLED.

DECONTROLLED.

Endosure 44 to Enclosure to NRC-09-0081 NRC-09-0081 Page 1 Page Request for Exemption Request Exemption fromfrom Physical Physical Security Security Requirements Requirements Overview:

Overview:

Detroit Edison Detroit Edison is requesting requesting an exemption from the compliance compliance date of 10 CFR 73.55(a)(1) 73.55(a)(1) until May 31, May 31, 2011. basis for requesting 2011. The basis exemption is the need for completion requesting an exemption completion of significant of significant physical modifications physical modifications to comply with with the new 10 CFR 73 While some of the 73 rule requirements. While required by the 10 CFR 73 rule scope required work scope rule change requirements will be change requirements completed by March be completed 31, March 31, 2010, some 2010, modifications will some modifications will require additional time to complete.

require additional complete.

Prior to the 10 10 CFR CFR 73 rule change, Detroit Edison recognized current Fermi recognized that the current Fermi 2 security security system and system and infrastructure infrastructure required upgrades upgrades to meet industry standards, standards, enhance enhance the site's strategy and to replace aging security protective strategy equipment. The plan security equipment. upgrade the security plan to upgrade security system was system was approved approved by plant management completion date management in April 2008 with an original completion date of of 2011. [

August 2011.

]

Following publication Following publication of the 10 CFR change, additional work scope CFR 73 rule change, identified above scope was identified above and beyond and beyond the original security security system upgrade plans. [

system upgrade resources into the 10 CFR 73 rule compliance and significant resources Detroit Edison is investing significant continuing upgrade continuing upgrade of the existing existing security system. The proposed proposed schedule represents represents a significant amount of physical physical work and accounts accounts for the Fermi 2 organizational organizational capacity capacity required to address the scope, complexity, and integration of the 10 CFR 73 rule change required change security modifications and the planned security upgrade modifications.

modifications implementation of the 10 CFR 73 rule change and continuing security system Throughout implementation compensatory upgrade activities, the Fermi 2 security routines, response capability and compensatory measures, when applied, will be managed and coordinated in accordance accordance with the approved Fermi 2 Physical Physical Security Plan. There will be no compromise to the Fermi 2 Physical Security Plan.

Enclosures 11 and 2 contain Security Related Information -

Withhold under 10 CFR 2.390. Upon Separation, the cover cover and Enclosures 3, 4 and 5 are DECONTROLLED.

letter and to Enclosure to NRC-09-0081 NRC-09-0081 Page 2 Security Security Upgrades Upgrades Approved Approved for Implementation Implementation Prior to the March March 27, 2009 Federal 27,2009 Federal Register Register Notice:

While realizing that the 10 CFR 73 rule changes While realizing changes have have a higher priority priority for workflow, workflow, upgrades upgrades to the Fermi 22 security system will continue continue to be designed designed and implemented implemented in coordination coordination with modifications modifications required for compliance compliance with the new rule.

. [

Modifications Required for Compliance with the New Rule to be completed by March Modifications 31, 2010 March 31, 2010

• 1

]I Enclosures 11 and 2 contain Security Related Information -

Withhold under 1010 CFR 2.390. Upon Separation, the cover letter and Enclosures 3, 44 and 5 are DECONTROLLED.

to NRC-09-0081 Page 3 Detroit Edison is requesting requesting an exemption from the compliance compliance date of 10 CFR 73.55(a)(1) 73.55(a)(1) for the following requirements:

Modifications Required for Compliance Modifications Compliance with the New Rule that Extend Beyond March 31, 31, 2010 2010 II I

Enclosures Enclosures 1 and 2 contain contain Security Related Information Information -

Withhold Withhold under 10 CFR 2.390. Upon Separation, Separation, the cover letter and Enclosures Enclosures 3, 3, 4 and 5 are DECONTROLLED.

DECONTROLLED.

to NRC-09-0081 Page 4 The following was taken into consideration consideration in order to create create the Fermi Fermi 2 schedule schedule for completion of the modifications modifications supporting the 10 CFR 73 rule change:

• " Fermi 2 security routines, response capability compensatory measures, capability and compensatory measures, when applied, will be managed and coordinated coordinated in accordance accordance with the approved Fermi 2 Physical Security Security Plan. There There will be no compromise compromise to the Fermi 2 Physical Physical Security Security Plan.

• " The organizational organizational capacity capacity required to address address the scope, scope, complexity, complexity, and integration ofof the 10 CFR 73 rule change security modifications modifications and planned security upgrade modifications.

modifications.

]

• A phased approach is used in scheduling security modifications scheduling security modifications to equipment in order to address the limitations of taking redundant equipment out of service service for both alarm stations.

• " Security involvement Security involvement to in-process in-process outage workers and to provide for normal security security functions during during the upcoming upcoming fourteenth refueling ou~age planned to start in the fall of refueling outage of 2010.

4* Contingencies have been built into the schedule to accommodate complications Contingencies complications due to construction and weather construction weather issues.

A schedule showing milestones for each of the security modifications is provided in Enclosure security modifications Enclosure 2.

Enclosures I1 and 2 contain Security Related Information -

Withhold under 10 CFR 2.390. Upon Separation, the cover cover 3, 4 and 5 are DECONTROLLED.

letter and Enclosures 3, to NRC-09-0081 Page 5 Summary:

Detroit Edison requests an exemption exemption from the March 31, 31, 2010 date, required by 10 CFR 73'55(a)(1),

73.55(a)(I), to May 31, 2011 31,2011 in order to implement physical modifications modifications addressing the new requirements.

rule requirements.

Throughout implementation implementation of the upgrades and 10 CFR 73 rule implementation implementation activities, Fermi 2 security routines, response response capability capability and compensatory compensatory measures, measures, when applied, will wilibe be accordance with the approved Fermi 2 Physical Security Plan. There managed in accordance There will be no no compromise to the Fermi 2 Physical Security Plan.

Enclosures 1 and 2 contain Security Security Related Information -

Withhold under 10 CFR 2.390. Upon Separation, the cover letter and Enclosures 3, 4 and 5 are DECONTROLLED.

DECONTROLLED.

Enclosure Enclosure 5 NRC-09-0081 NRC-09-0081 Enclosure 2 Non-Proprietary Version of Enclosure Non-Proprietary Enclosures 11 and 2 contain Security Related Information -

Withhold Under 10 CFR 2.390. Upon Separation, the cover 3, 4 and letter and Enclosures 3,4 DECONTROLLED.

and 5 are DECONTROLLED.

Enclosure 5 to Enclosure NRC-09-0081 Page 1 Page Schedule of Milestones for Security Security Modifications Modifications Modifications Required for Compliance Modifications Required Compliance with the New Rule to be completed completed by March 31, 31, 2010 2010 II

]

Detroit Edison is requesting an exemption exemption from the compliance compliance date of 10 CFR 73.55(a)(1) 73.55(a)(1) for the following requirements:

requirements:

Modifications Modifications Required Required for Compliance Compliance with the New Rule that Extend Beyond March 31, 31, 2010 2010 Index Numbers used in this enclosure match the numbers used in Enclosure 1. 1.

II I

Enclosures 1 and 2 contain Security Related Enclosures Related Information -

Withhold under 10 CFR 2.390. Upon Separation, the cover Enclosures 3, letter and Enclosures 3, 4 and 55 are DECONTROLLED.

Enclosure 5 to NRC-09-0081 Page 2 I

Enclosures 1 and 22 contain contain Security Security Related Related Information Information -

Withhold Withhold under 10 CFR 2.390. Upon Separation, the covercover letter and Enclosures Enclosures 3, 3, 4 and 55 are DECONTROLLED.

DECONTROLLED.