ML20210J086

Requests NRC Approval of Exemption from Certain Requirements of 10CFR73, Physical Protection of Plants & Matls, by 990921.Exemption Is Needed to Support Scheduled 991001 Implementation of Plant Sf Ni.Encl Withheld,Per 10CFR73.21

ML20210J086
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	07/30/1999
From:	Krich R COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9908040186
Download: ML20210J086 (3)

Text

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.. Commonwealth Edison Company 1400 Opus Pizcc Downers Grove, IL 60515 5701 I . -

, SAFEGUARDS INf0RMAil0N l

~ NO. 2 '

4 July 30,1999 '

U.S. Nuclear Regulatory Commission ATfN: Document Control Desk Washington, DC 20555 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 i NRC Docket Nos. 50-295 and 50-304

Subject:

Request for Exemption from Certain Requirements of 10 CFR 73

Reference:

NRC letter," Certification of Permanent Cer, nation of Power Operation and Permanent Removal of Fuel from the Reactor for Zion Nuclear Power Station, Units 1 and 2," dated May 4,1998 Pursuant to 10 CFR 73.5, " Specific Exemptions," we are requesting NRC approval of an exemption from certain requirements of 10 CFR 73, " Physical Protection of Plants and Materials." in the referenced letter, the NRC acknowledged that, pursuant to 10 CFR 50.82(a)(2), " Termination of License,"

the 10 CFR 50 licenses for Zion Nuclear Power Station (ZNPS), Units 1 and 2, no longer authorize operation of the reactors or em.olacement or retention of fuel in the reactor vessels. In this condition, ZNPS poses a significantly reduced risk to public health and safety. Commensurate with this reduction in risk, we are planning to replace our current security plan for ZNPS with the attached proposed Defueled Physical Security Plan (Attachment 1).

The proposed Defueled Physical Security Plan modifies the existing ZNPS physical protection system and security organization in light of the substantially reduced radiological risk posed by ZNPS. The radiological consequences of the analyzed design basis accidents cannot exceed 10 CFR 100, " Reactor Site Criteria," limits or the Environmental Protection Agency Protective Action Guides.

The potential for a release, due to radiological sabotage, exceeding the exposure limits contained in 10 CFR 100 is remote.

l 9908040186 990730 PDR ADCCK 05000295 F PDR SAFEGUARDS INFORMATION Ud(1C 85 Attachment 1 Contains Safeauards Information NO. 2 Upon Separation This Paae is Decontrolled A Unicom Company dI1 I u

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- July 30,1999 comed U.S. Nucl=r Regulatory Commission SAFEGUARDS INFORMATION

.Page 2 NO. 2 j ,

The attached plan does not result in a decrease in safeguards effectiveness.

However, the attached plan does not meet all the requirements of 10 CFR 73.

l Therefore, in accordance with 10 CFR 73.5, we are requesting an exemption from l certain requirements of 10 CFR 73 regarding the physical protection system and the security organization. Attachment 2, " Exemption Request," identifies the specific requirements in the regulations that are the subject of the exemption request and contains the associated justifications. As explained in Attachment 2, the NRC may grant the requested exemption since it would be authorized by law, would not endanger life or property or the common defense and security, and would otherwise be in the public interest. The proposed Defueled Physical Security Plan, which reflects changes being made pursuant to 10 CFR 50.54(p),

conditions of Licenses,"is attached to aid the NRC in its review and evaluation of our exemption request.

The attached plan has been reviewed and approved in accordance with the Commonwealth Edison Quality Assurance Program.

i We are requesting NRC approval of the exemption by September 21,1999. The exemption is needed to support the scheduled October 1,1999, implementation of the ZNPS spent fuel nuclear island which simplifies the cooling and support infrastructure for the spent fuel pool.

Attachment 1 contains Safeguards Information that must be protected from public disclosure pursuant to 10 CFR 73.21, " Requirements for the Protection of l

Safeguards Information."

If you have any questions about this letter, please contact Mr. P. R. Simpson at (630) 663-7971.

Respectfully,

. . or R. M. Krich Vice President- Regulatory Services Attachments: (1) Zion Nuclear Power Station Proposed Defueled Physical l

Security Plan (SAFEGUARDS INFORMATION)

(2) Exemption Request cc: Regional Administrator- NRC Region 111 (two copies) f Attachment 1 Contains Safeauards Information SAFEGUARDS INFORMATION Upon Separation This Pace is Decontrolled E2 m

f-Comed SAFEGUARDS INFORMATION

. NO. 2 '

l bec: NRC Project Manager, NRR - Zion Nuclear Power Station (w/o Attachment 1) l Decommissioning Branch Chief- NRC Region lli (w/o Attachment 1) ,

Office of Nuclear Facility Safety -IDNS (w/o Attachment 1)

Vice President - Regulatory Services (w/o Attachment 1)

Licensing Director - Zion /Dresden Unit 1 Decommissioning (w/o Attachment 1)

NGG Security Director (w/o Attachment 1) i Nuclear Oversight Manager- Zion Nuclear Power Station (w/o Attachment 1) l Manager of Energy Practice -Winston and Strawn (w/o Attachment 1) ,

Comed Document Control Desk - Licensing (hard copy) (w/o Attachment 1)

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Comed Document Control Desk - Licensing (electronic copy) (w/o Attachment 1) )

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Attachment 1 Contains Safeauards Information i Upon Separation This Pace is Decontrolled

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