Letter Sequence Request |
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MONTHYEARML1002607162010-01-22022 January 2010
Request for Exemption from Physical Security Requirements (Redacted)
Project stage: Request
ML1006007132010-03-16016 March 2010
Exemption from the Requirements of 10 CFR Part 73, Section 73.55 Implementation Deadline for Physical Security Plans
Project stage: Approval
2010-01-22
[Table View] |
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Category:Exemption from NRC Requirements
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ML19281D7402020-01-0606 January 2020
Exemption from 10 CFR 50.54(w)(1) - Onsite Property Damage Insurance
ML19282A0362020-01-0606 January 2020
Exemption from 10 CFR 140.11(a)(4) - Primary and Secondary Liability Insurance
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Letter, Exemption from 10 CFR 140.11(a)(4) - Primary and Secondary Liability Insurance and Amendment No. 14 to Indemnity Agreement No. B-48
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Letter, Partial Exemption from Record Retention Requirements of 10 CFR 50.71(c), 10 CFR 50.59(d)(3), and 10 CFR 50 Appendix B
ML19088A0502019-03-25025 March 2019
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ML19088A1272019-03-25025 March 2019
(PNPS) - Request for Exemption from 10 CFR 140.11 (a)(4)
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Response to Request for Additional Information - Exemption from the Requirements of 10CFR50.47 and Appendix E to 10CFR50
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Pilgrim Nuclear Power Station - FRN, Exemption from Specific Provisions in 10 CFR 73.55 Related to Suspension of Security Measures for Licensed Senior Operator or Certified Fuel Handler (CAC No. MF9274)
ML1006007132010-03-16016 March 2010
Exemption from the Requirements of 10 CFR Part 73, Section 73.55 Implementation Deadline for Physical Security Plans
ML1002607162010-01-22022 January 2010
Request for Exemption from Physical Security Requirements (Redacted)
ML0813603262008-06-0909 June 2008
Exemption from the Schedule Requirements of 10 CFR 50.75(f)(3)
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Request for Exemption from the Schedule Requirements of 10 CFR 50.75(f)(3)
ML0225505592002-09-12012 September 2002
Exemption from Requirements of 10 CFR Part 20, Section 20.1003 Definition of Total Effective Dose Equivalent (TEDE)
2022-08-29
[Table view]
Category:Letter
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Annual Radioactive Effluent Release Report, January 1 Through December 31, 2022
L-23-004, HDI Annual Occupational Radiation Exposure Data Reports - 20222023-04-24024 April 2023
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Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities
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[Table view] |
Text
Entergy Nuclear Operations, Inc.
EPilgrim Entew600 Nuclear Power Station Rocky Hill Road Plymouth, MA 02360 Kevin H. Bronson Site Vice President January 22, 2010 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555
SUBJECT:
Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station Docket 50-293 License No. DPR-35 Request for Exemption from Physical Security Requirements (Redacted)
LETTER NUMBER: 2.10.008
Dear Sir or Madam:
In accordance with the requirements of 10 CFR 73.5, Entergy Nuclear Operations Inc., (ENO) requests the Nuclear Regulatory Commission (NRC) approve an exemption from specific requirements of 10 CFR Part 73, "Physical Protection of Plants and Materials" for the Pilgrim Nuclear Power Station (PNPS). The requested exemption would extend the compliance date for implementation of certain new security requirements issued by the NRC in a Final Rule dated March 27, 2009 (74 FR 13926).
Pursuant to the Final Rule, the new security requirements must be implemented by March 31, 2010. ENO has evaluated these new requirements and determined that most requirements can be implemented by the required date. However, specific parts of the new requirements will require additional time to implement since they involve upgrades to the existing security system. These upgrades involve physical modifications that include
]. Attachment 1 to this letter provides additional details regarding the specific provisions of the Rule for which an exemption is requested, project milestones, and an Environmental Assessment. Attachment 2 provides a site layout sketch illustrating the new secure owner controlled area (SOCA) boundary.
ENO is requesting an extension from the March 31, 2010, implementation date to September 15, 2010, for these specific requirements based on the time required to design, procure equipment, install the necessary modifications, and considerations of impediments to construction such as material delivery dates as shown on the implementation table in , Table 2, Project Milestones.
hO(C g(
Entergy Nuclear Operations, Inc. Letter Number: 2.10.008 Pilgrim Nuclear Power Station Page 2 PNPS's current security program and the new security requirements scheduled to be implemented by March 31, 2010, will provide continued assurance of public health and safety and common defense and security.
ENO requests approval of this schedular exemption request by March 23, 2010, to otherwise allow time to prepare and implement compensatory measures if the exemption is not granted.
The proposed schedular exemption is requested to be effective upon issuance.
The information provided in the attachments to this letter is considered Security-Related Information associated with physical protection of PNPS, as described in 10 CFR 2.390(d)(1).
Accordingly, ENO requests that the information provided in the attachments be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. A version of this letter edited for public disclosure, ENO Letter Number 2.10.008, is signed and submitted to the NRC on this date.
There are no new commitments made in this letter.
If you have any questions or require additional information, please contact Mr. Joseph Lynch, Licensing Manager, at 508-830-8403.
Kevin H. Bronson Site Vice President : Request For Exemption From Physical Security Requirements : PNPS Site Layout Sketch MJG/mg cc:
Mr. Samuel J. Collins, Regional Administrator Mr. James S. Kim, Project Manager U.S. Nuclear Regulatory Commission, Region I Plant Licensing Branch I-1 475 Allendale Road Division of Operator Reactor Licensing King of Prussia, PA 19406-1415 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Senior Resident Inspector One White Flint North O-8C2 Pilgrim Nuclear Power Station 11555 Rockville Pike Rockville, MD 20852
Attachment 1 Request For Exemption From Physical Security Requirements (Redacted Version)
(5 pages)
Attachment 1 Request For Exemption From Physical Security Requirements A. Background The Nuclear Regulatory Commission (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. Entergy Nuclear Operations Inc., (ENO) has evaluated these new requirements and determined that most requirements can be implemented within the implementation period. However, ENO has also determined that implementation of certain specific requirements will require additional time beyond March 31, 2010.
ENO has approved a plan, for physical modifications, [ ]. The analysis phase has been completed and the design phase for the modifications and security equipment additions are well under way. Installation will be completed by September 15, 2010.
B. PNPS Security System Upgrade The scope of work to meet the new security requirements of 10 CFR 73.55 includes but is not limited to the following major items:
[ ]
Due to the scope of the design, procurement, installation activities, and equipment delivery schedules as shown on the implementation table in Attachment 1, Table 2, Project Milestones, completion of one of the new requirements contained in 10 CFR 73.55 will require additional time beyond March 31,2010.
With approval of this exemption request, the Part 73 provisions required to be implemented by March 31, 2010 will be completed except for the proposed exemption described in Section C below. This item, subject of the request for an exemption, will be implemented by September 15, 2010. PNPS will then be in full compliance with the Final Rule.
Page 1 of 5
Attachment 1 Request For Exemption From Physical Security Requirements C. Proposed Exemptions ENO requests a schedular exemption, from the compliance date only, for the item listed in this section. PNPS's current security program and the new 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 or property or the common defense and security in accordance with 10 CFR 73.5.
[ ]
D. Basis for Proposed Exemption Entergy Nuclear Operations Inc., (ENO) requests a schedular exemption from
] for the Pilgrim Nuclear Power Station (PNPS). The request for an exemption from the March 31, 2010, implementation date to September 15, 2010, is based on the [ ].
Using established processes, the duration (study, design, construction, testing, turnover) of a project of this magnitude is typically 18 -24 months. The 12-month implementation period challenged this timeframe significantly. The challenge is further complicated by the delivery times for additional equipment needed to fully meet the section of the Rule specified in this request. PNPS 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 work activities associated with the physical modifications.
[ ]
Table 1 summarizes the specific exemption requested, the basis for the exemption, and the scheduled completion date for the installation of the necessary modification. The scheduled completion date has been developed based on current information, delivery schedules and anticipated impediments to construction. These dates are not considered to be regulatory commitments.
Table 2 provides a list of activities, composite milestones for those activities and a reference to individual Engineering Changes (ECs) addressed by the composite milestones.
Individual completion dates may change as designs are finalized and construction proceeds. Therefore, these dates are not considered to be regulatory commitments.
Page 2 of 5
Attachment 1 Request For Exemption From Physical Security Requirements Environmental Assessment ENO is requesting an exemption for PNPS in accordance with 10 CFR 73.5, "Specific Exemptions". The requested exemption is schedular in nature and would defer the compliance date for one specific provision of 10 CFR 73.55 from March 31, 2010, to September 15, 2010. The proposed exemption is needed to allow additional timne for the design and installation of security modifications.
PNPS's current security program and the new requirements that will be implemented by March 31, 2010, will provide continued assurance of public health and safety and common defense and security.
Deferral of the compliance date for one specific provision of 10 CFR 73.55 is a schedular change only and therefore does not result in any physical changes to structures, systems or components or land use at PNPS. 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,
" any land disturbance.
==
Conclusion:==
There is no significant radiological environmental impact associated with the proposed schedular exemption. The proposed exemption will not affect non-radiological plant effluents nor any historical sites.
Page 3 of 5
Attachment 1 Request For Exemption From Physical Security Requirements Table 1 Exemption Summary
[ ]
The date provided is a best estimate based on information available at the time the schedule was developed and may change as designs are finalized and construction proceeds.
Therefore, this date is not considered to be a regulatory commitment.
Page 4 of 5
Attachment 1 Request For Exemption From Physical Security Requirements Table 2 PROJECT MILESTONES
[ ]
The dates provided are best estimates based on information available at the time the schedule was developed and may change as designs are finalized and construction proceeds.
Therefore, these dates are not considered to be regulatory commitments.
Page 5 of 5 Site' Plan (1 Page)
Site Plan
[ ].