ML21070A192

Independent Spent Fuel Storage Installation - Supplemental Response to NRC Order EA-20-103, Issuance of .Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access

ML21070A192
Person / Time
Site:	Three Mile Island, 07200077
Issue date:	02/16/2021
From:	Orth T Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
EA-20-103
Download: ML21070A192 (4)

Text

{{#Wiki_filter:Three M_lle Island Nuclear Station, Unit 1 Exelon Generation 441 S. P.0. Box 480 Middleto wn, PA 170~7 Submittal Contains Security-Related Information - Withhold Under 10 CFR 2.390

                                                                                              .EA-20-103 72.4 TMl-21-008 February 16, 2021 U.S. Nuclear Regulatory Commission 1

ATTN:* Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards. Washir:igtqn, DC 20555-0001 Three Mile Island Nuclear Station, Uf!it 1 Renewed Facility License No. DPR-50 NRC Docket No. 50-289 and 72-077

Subject:

Supplemental Response to NRC Order EA-20-103, "Issuance of .Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access at the Three Mile Island Generating Station lnd~pendent Spent Fuel Storage Installation"

References:

(1) NRC Order EA-20-103, "Issuance of Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access at the Three Mile Island Generating Station Independent Spent Fuel Storage Installa tion/ dated August 27, 2020 (ADAMS ML20224A121) (2) Response to NRC Order EA-20-103, "Issuance of Order for Implementation of *Additional Security Measures and Fingerprinting for Unescorted Access at the Three Mile Island Generating Station Independent Spent Fuel Storage Installation," dated September 15,. 2020 (ADAMS ML20259A196) .I (3) Supplemental Response to NRC Order EA-20-103, "Issuance of Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access at the Three Mile Island Generating Station Independent Spent Fuel Storage Installation," dated Janµary 28, 2021 (ADAMS ML21036A023) Pursuant to NRC Order EA-20-103 (Reference 1) (ASM Order) for Three Mile Island Generating Station, Unit 1 (TMl-1), Exelon Generation Company, LLC 20-day response required by Sections 111.B and 111.C of the Order (Refere (Exelon) provided the c J .11 J DD Tf

   .3, Exelon provided a detailed response to Attachments 1 and 2 of the TMl-1 ASM        O;:J4 :5 SZ~

nce 2). In Reference SE.CURITY-RELATED INFORM ATION- WITHH OLD ATTACHMENT UNDER 10 CFR 2.390 ;Jf'f-S 5 2L) fl/Lit f\Jl':-{SS

TMl-21-008 February 16, 2021 U.S. Nuclear Regulatory Commission Supplemental Response to EA-20-103 1 Page2 which included the revised TMI Security Plan, Training and Qualification Plan, Safeguards Contingency Plan (Security Plan), associated analysis, and supporting documentation. The revised Security Plan (Revision 24) provided in the January 28, 2021 submit tal (Reference 3), has been internally reviewed and approved by Exelon prior to submit tal. Exelon has detennined in accordance with 10 CFR 50.54(p)(2) that the revision does not decrease the safeguards effectiveness of the Security Plan and as such does not require Nuclear Regulatory Commission (NRG) review and approval. 01 The purpose of this letter is to clarify the intent the supplemental informa tion provided in in Reference 3, and to request the NRG to review the infonnation provide d to support its evaluation that Exelon has met the necessary conditions and require ments in the ASM Order in such a manner that the NRG may make its determination that TMl-1 is in compliance with the ASM Order requirements. Additionally, Exelon has finalized the TMI Integrated Response Plan ISFSI that was provided as a draft document in Attachment 5 of Reference 3. The Attachm ent to this letter provides the Exelon approved ISFSI Integrated Response Plan and replaces the draft

• document in Reference 3 in its entirety.

As required by the ASM Order, Exelon must meet the following conditio ns prior to placing spent fuel in the Independent Spent Fuel Storage Installation (ISFSI):

• Demonstrate the ability to comply with the required ASMs as outline d in these documents no later than 365 days from the date of this Order or 90 days before the first day that spent fuel is initially placed in the ISFSI, whichever occurs first.
• Implement the ASM requirements.
• Receive written verification from the NRG (specifically from the Office of Nuclear Material Safety and Safeguards) that Exelon has adequately demon strated compliance with the ASM requirements.

In order to support the planned spent fuel transfer to the ISFSI, Exelon is requesting that the NRG complete its review and provide written verification that TMI is in compliance with the ASM Order by September 17, 2021. The enclosed Attachment is considered sensitive, unclassified (non-sa feguard) infonnation in accordance with 10 CFR 2.390, 'Public inspections, exemptions, reques ts for withholding,' paragraph (d)(1). As such, Exelon requests that the infonnation contain ed in the attachment be withheld from public disclosure. Upon separation of the attachm ent this cover letter contains no Security-Related information. This letter does not contain any regulatory commitments.

TMl-21-008 February 16, *2021 U.S. Nuclear Regulatory Commission Supplemental Response to EA-20-103 Page3 Should you have any questions concerning this letter, please contact Mr. Daniel Kenny at (717) 948-8855. . Respectfully, Trevor L. Orth Site Decommissioning Director Three Mile Island Nuclear Station, Unit 1

Attachment:

Implementing and Supporting Documentation - Withhold per 10 CFR 2.390 - TMI Integrated Response Plan ISFSI (Official Use Only-:- Law Enforcement Sensitive) cc: w/o attachment Regional Administrator - NRC Region I Project Manager, NMSS - Three Mile Island, Unit 1 Decommissioning, ISFSI and Reactor Health Physics Branch, NRC Region I

• Director, Bureau of Radiation Protection - PA Department of Environmental Resources

TMl-21-008 February 16, 2021 U.S. Nuclear Regulatory Commission Supplemental Response to EA-20-103 Page 4 bee: VP Nuclear Security, Licensing and Regulatory (Cantera) VP License Renewal and Decommissioning Sr. Manager, Decommissioning Director - Licensing and Regulatory Affairs - (East) Sr. Manager - Licensing and Regulatory Affairs - (East) Licensing Records Commitment Tracking Coordinator - KSA 3-E C. Smith - TMI L. Holden - Cantera P. Simpson - Cantara M. Kunz wiler- Cantara D. Pallansch - Cantara W. Trump - Kennett Square}}