ML100190140
| ML100190140 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear, 05000386  |
| Issue date: | 01/14/2010 |
| From: | Walsh K Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| OCAN011003 | |
| Download: ML100190140 (6) | |
Text
Entergy Operations, Inc.
En tegy 1448 SR. 333 Russellvine, AR 72802 Tel 479-858-3110 Kevin T. Walsh Vice President, Operations Arkansas Nuclear One OCAN01 1003 January 14, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Request for Exemption from Physical Security Requirements (Redacted)
Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6
Dear Sir or Madam:
In accordance with the requirements of 10CFR73.5, Entergy Operations, Inc. (Entergy) requests the NRC approve an exemption from specific requirements of 1 OCFR Part 73, "Physical Protection of Plants and Materials," for Arkansas Nuclear One (ANO). The requested exemption extends the compliance date for the implementation of certain new security requirements issued by NRC in a final rule dated March 27, 2009 (74FR13926).
Pursuant to the final rule, the new security requirements must be implemented by March 31, 2010. Entergy has evaluated these new requirements and determined that the majority can be implemented by the March 31, 2010, compliance date. However, specific parts of the new requirements require more time to implement since they involve significant upgrades to the security system. These changes involve physical modifications that include
]. The attachment to this letter provides additional details regarding the specific provisions of the rule for which an exemption is requested, as well as an environmental assessment.
Entergy requests an extension from the March 31, 2010, implementation date to October 31, 2010, for all but one of the requirements and to August 31, 2011, for full compliance, based on the delayed delivery of [
] caused by limited vendor resources and subsequent installation and testing time requirements. Entergy's current security program and the new security requirements being implemented by March 31, 2010, provide continued assurance of public health and safety and common defense and security.
Entergy requests approval of this exemption request by March 15, 2010, in order to avoid being in non-compliance with 10CFR73.55. The proposed exemption is requested to be effective upon issuance.
A security-related version of this letter requesting withholding from public disclosure (OCAN011001) was signed and mailed to the NRC on January 14, 2010.
~DoI
1 14 OCAN01 1003 Page 2 of 2 There are no new commitments contained in this submittal. If you have any questions or require additional information, please contact David Bice at 479.858.5338.
Sincere'ly, KTW/nbm
Attachment:
Request for Exemption from Physical Security Requirements cc:
Mr. Elmo Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS 0-8 B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852
Attachment to OCAN01 1003 Request for Exemption from Physical Security Requirements
Attachment to OCAN01 1003 Page 1 of 3 Request for Exemption from Physical Security Requirements A. Background The NRC issued a final rule for new security requirements in the Federal Register dated March 27, 2009. Pursuant to I OCFR73.55(a)(1) of the final rule, the new security requirements are required to be implemented by March 31, 2010. Entergy has evaluated these new requirements and determined that most can be implemented by the required date; however, Entergy has determined that implementation of specific requirements requires additional time beyond March 31, 2010.
Entergy has approved a plan to [
]. The study phase has been completed and the design phase for the [
] has begun. [
] Installation and testing requires several months; therefore, partial implementation [
] is expected by October 31, 2010, with full implementation [
] expected by August 31, 2011.
B. ANO Security Computer System Upgrade
] Due to the amount of procurement and installation activities, several of the new requirements contained in 10CFR73.55 require additional time beyond March 31, 2010.
These items, as described in Section C below, are expected to be implemented by October 31, 2010, for all but one item, with full implementation by August,31, 2011.
C. Proposed Exemption Entergy requests an exemption for ANO, from the compliance date only, for the items listed in this section. ANO's current security program and the new requirements being implemented by March 31, 2010, provide continued assurance of public health and safety and common defense and security. Accordingly, the requested exemption is authorized by law and does not endanger life or property or the common defense and security in accordance with 1 OCFR73.5.
Item 1 Regulation
[
]
Issue
[
]
Item 2 Re-gulation
[I
Attachment to OCAN01 1003 Page 2 of 3 Issue I ]
Item 3 Regulation
[I]
Issue
[ ]
Item 4 Regulation I I Issue Conclusion In lieu of full compliance with these provisions of 10CFR73.55, Entergy is maintaining the ANO site protective strategy in accordance with the ANO Security Plan. The ANO site protective strategy has been approved by the NRC staff as providing a high assurance for the protection of the facility and public from the effects of radiological sabotage. Therefore, Entergy's current security program and the other new security requirements being implemented by March 31, 2010, provide continued assurance of public health and safety and common defense and security.
D. Basis for Proposed Exemption Entergy is requesting a schedule exemption from [
]. The basis for requesting an exemption of the March 31, 2010, date to October 31, 2010, for all but one of the provisions, and August 31, 2011, for final compliance, is based on installation of [
]to address the new Part 73 rule requirements.
[I ] Entergy is continuing efforts to implement the remaining new Part 73 requirements identified in the March 27, 2009, Federal Register Notice (final rule) and associated Regulatory Guides issued in July 2009, by March 31, 2010.
The following is a more detailed description of the modification activities associated with the t ].
I ]
Attachment to OCAN01 1003 Page 3 of 3 The following table provides the project milestone schedule for the [
] associated with the exemption requested. These milestones represent a schedule that is driven to comply with the new Part 73 requirements. The milestone schedule has been developed based on currently available information.
Milestone Schedule
[I]
E. Environmental Assessment Entergy is requesting an exemption for ANO in accordance with 1 OCFR73.5, "Specific Exemptions." The requested exemption is schedule-driven in nature and would defer the compliance date for these specific provisions of 10CFR73.55 from March 31, 2010, to October 31, 2010, for all but one of the provisions, and August 31, 2011, for final compliance.
The proposed exemption is needed to allow additional time for the design and installation of security modifications.
ANO's current security program and the new requirements being implemented by March 31, 2010, provide continued assurance of public health and safety and common defense and security.
Deferral of the compliance date for these specific provisions of 1 OCFR73.55 is a schedule change only and, therefore does not result in any physical changes to structures, systems, components, or land use at ANO. The deferral of the compliance date does not involve:
any change to the types, characteristics, or quantities of non-radiological effluents discharged to the environment, any change to liquid or gaseous radioactive effluents discharged to the environment, any change in the type or quantity of solid radioactive waste generated, any change in occupational dose under normal or design basis accident conditions, any change in the public dose under normal or design basis accident conditions,
- or any land disturbance.
Conclusion There is no significant radiological environmental impact associated with the proposed schedule exemption. The proposed exemption does not affect non-radiological plant effluents or any historical sites.