Letter Sequence Supplement |
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EPID:L-2023-LLE-0082, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation (Approved, Closed) |
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MONTHYEARML23341A0222023-11-15015 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation Project stage: Request ML24121A0732024-04-16016 April 2024 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information Project stage: Supplement ML24136A2432024-05-24024 May 2024 Independent Spent Fuel Storage Installation - Exemption from Select Requirements of Title 10 of the Code of Federal Regulations Part 73 Project stage: Approval 2024-04-16
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Category:Letter
MONTHYEARML24351A1792024-12-11011 December 2024 Independent Spent Fuel Storage Installation (ISFSI) - Nuclear Liability Insurance Coverage ML24291A2742024-10-17017 October 2024 (Dpc), Submittal of La Crosse Boiling Water Reactor (LACBWR) Quality Assurance Program Description (QAPD) Revision 32 ML24249A3202024-09-0404 September 2024 Quality Assurance Program Application to Transportation Activities Pursuant to 10 CFR 71.101(f) IR 07200046/20244012024-07-23023 July 2024 Independent Spent Fuel Storage Installation – NRC Security Inspection Report 07200046/2024401 IR 05000409/20240012024-07-17017 July 2024 NRC Inspection Report 05000409/2024001(DRSS); 07200046/2024001(DRSS) ML24193A1152024-07-0909 July 2024 Intent to Implement NAC-MPC CoC No. 1025, Amendment No. 7, Revision 1 ML24136A2432024-05-24024 May 2024 Independent Spent Fuel Storage Installation - Exemption from Select Requirements of Title 10 of the Code of Federal Regulations Part 73 ML24121A0732024-04-16016 April 2024 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information ML24058A1222024-02-27027 February 2024 Independent Spent Fuel Storage Installation (ISFSI) Annual Radiological Environmental Operating Report, and Changes to the Off-Site Dose Calculation Manual for 2023 ML24045A1612024-01-25025 January 2024 LACBWR ISFSI Submittal 10 CFR 50.59 and 10 CFR 72.48 Report of Changes, Tests, and Experiments ML24045A1592024-01-25025 January 2024 LACBWR ISFSI Submittal of Decommissioning Plan and Post Shutdown Decommissioning Activities Report ML24031A6432023-12-20020 December 2023 Independent Spent Fuel Storage Installation (ISFSI) - Nuclear Liability Insurance Coverage ML23341A0222023-11-15015 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23192A1082023-06-14014 June 2023 Possession-Only License DPR-45 - New Chief Nuclear Officer Selected ML23192A0612023-06-14014 June 2023 Possession-Only License DPR-45 - Formal Announcement of New ISFSI Manager ML23137A1552023-05-0202 May 2023 Possession-Only License DPR-45 - Financial Statement and Auditors Report ML23130A1202023-05-0202 May 2023 Transmittal of Financial Statement and Auditors Report ML23115A1712023-04-0404 April 2023 ISFSI - Nuclear Liability Insurance Coverage ML23115A1742023-04-0303 April 2023 Independent Spent Fuel Storage Installation, Adoption of Amendment 7 of NAC MPC Certificate of Compliance No. 72-1025 and Canister Registration ML19009A1542023-03-15015 March 2023 LACBWR License Transfer Conforming Amendment Issuance ML23074A0552023-03-13013 March 2023 Decommissioning Funding Status Report for Shutdown Reactor ML23066A3232023-03-0707 March 2023 Energysolutions, LLC, Notification of Closing of Transaction ML23076A0402023-03-0606 March 2023 Notification of License Transfer Date from Lacrossesolutions, LLC to Dairyland Power Cooperative ML23060A0732023-02-27027 February 2023 Annual Radiological Environmental Operating Report ML23055A0282023-02-24024 February 2023 Completion of License Termination Activities and Release of Remaining Class 1 Survey Units from Possession Only License No. DPR-45 ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML23033A0682023-01-26026 January 2023 Proof of Financial Protection ML23024A0122023-01-26026 January 2023 Letter to Energysolutions Transmitting Threshold Determination for Merger/Restructuring IR 05000409/20220012022-12-27027 December 2022 NRC Inspection Report No. 05000409/2022001(DRSS) ML22321A3132022-12-0808 December 2022 LACBWR License Transfer Order Fifth Extension Letter ML22335A0852022-11-23023 November 2022 Request for Extension of Order Approving Transfer of the License for the La Crosse Boiling Water Reactor from Lacrossesolutions, LLC, to Dairyland Power Cooperative ML22297A0042022-10-20020 October 2022 Response to October 14, 2022 Request for Additional Information for Class 1 Excavation and Basement Survey Units ML22285A0782022-10-13013 October 2022 NRC Analysis of Energy Solutions Decommissioning Funding Status Report Docket No. 50-409 ML22278A0282022-10-12012 October 2022 Request for Confirmatory Information Letter Re to the Review of the Class 1 Survey Units ML22269A3902022-09-0707 September 2022 Response to July 5, 2022 Request for Additional Information for Class 1 Excavation and Basement Survey Units ML22230A8012022-08-16016 August 2022 Request for Extension of Order Approving Transfer of the License for the La Crosse Boiling Water Reactor from Lacrossesolutions, LLC, to Dairyland Power Cooperative ML22223A0712022-07-28028 July 2022 Response to June 5, 2022 Request for Additional Information for Class 1 Survey Areas ML22224A1172022-07-14014 July 2022 Possession-Only License DPR-45 Chief Nuclear Officer Selected ML22224A1372022-07-12012 July 2022 Quality Assurance Program Description (Oapd), Revision 31 ML22203A0932022-07-11011 July 2022 Changes to the La Crosse Boiling Water Reactor (LACBWR) ISFSI Physical Security Plan IR 07200046/20224012022-06-0101 June 2022 (Decommissioning) - Independent Spent Fuel Storage Installation Security Inspection Report 07200046/2022401 ML22122A2302022-05-24024 May 2022 Approval to Release Class 2 and Class 3 Survey Units from the Part 50 License ML22146A2002022-05-24024 May 2022 Submittal of Quality Assurance Program Changes ML22123A0822022-04-25025 April 2022 Possession-Only License DPR-45 - Financial Statement and Auditors Report ML22068A2102022-04-20020 April 2022 Issuance of Amendment No. 77 Approving Independent Spent Fuel Storage Installation Emergency Plan, Revision 40 ML22108A0562022-03-28028 March 2022 Decommissioning Funding Plan for Independent Spent Fuel Storage Installation ML22084A0092022-03-22022 March 2022 Annual Property Insurance Status Report ML22077A0132022-03-15015 March 2022 Report on Status of Decommissioning Funding for Shutdown Reactor ML22069A1282022-03-0808 March 2022 Lacrossesolutions, LLC, La Crosse Boiling Water Reactor (LACBWR) Annual Radiological Environmental Operating Report, Supplemental Letter ML22062B0362022-02-28028 February 2022 Annual Radiological Environmental Operating Report 2024-09-04
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARML24121A0732024-04-16016 April 2024 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information ML15128A2672015-04-21021 April 2015 Independent Spent Fuel Storage Installation - Response to Apparent Violations in IR 07200046/2014001 and 05000409/2014008 (EA-15-026) ML15107A4552015-04-0606 April 2015 Dairyland Power Coopertive Regarding Apparent Violations Referenced in NRC Inspection Report for 07200046/2014001 ML0635501462006-12-0808 December 2006 Reply to a Notice of Violation Identified in NRC Inspection Report 050-00409-06-03 2024-04-16
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Jeremy Browning Chief Nuclear Officer DAIRYlAND POWER COOPERATIVE April 16, 2024 In reply, please refer to LAC-14548 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 la Crosse Boiling Water Reactor Independent Spent Fuel Storage Installation NRC Docket Nos. 50-409 and 72-046
SUBJECT:
Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information
REFERENCE:
Letter, J. Browning (Dairyland Power Cooperative) to NRC, "Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation," dated November 15, 2023, ML23341A022.
By letter dated November 15, 2023 (Referen::e), Dairyland Power Cooperative submitted a request for La Crosse Boiling Water (LACBWR) Independent Spent Fuel Storage Installation (ISFSI) for exemption from the compliance date of January 8, 2024, for the new security rule, "Enhanced Weapons, Firearms Background Checks, and Security Event Notifications."
During review of the exemption request it was noted that additional information would be required to provide clarification for the request. On April 2, 2024, a clarification call was conducted with the NRC and the LACBWR ISFSI staff, to discuss supplemental information that would be required for the request. This letter and attachment serve as a supplement to provide the additional information, by providing a revised Section C "Considerations For Exemption".
If you have any questions, please contact Mr. Marty Moe, ISFSI Manager, at (608) 689-4263.
There are no new commitments being made to the U.S. Nuclear Regulatory Commission by this letter.
~1)~
Jeremy Browning Chief Nuclear Officer Dairyland Power Cooperative A Touchstone Energy* Cooperative ~
3200 East Ave. 5.
- 608-787-1420 fax* www.dalrylandpower.com Dairyland Power Cooperative Is an equal opportunity provider and employer.
lAC-14548 Page 2of2 JRB:MGM:tco Enclosure DAIRYlAND POWER COOPERATIVE Revised Section C "Considerations For Exemption" cc:
Bernard White NRC Project Manager Tilda Lui NRC Project Manager Eugenio Bonano Region Ill Security Jack Giessner Regional Administrator Yoira Diaz Sanabria Kristina Banovac NRC Project Manager Vince Williams NRC NSIR Security
~o.e Willis NRC NSIR Security Division of Fuel Management A Touchstone Energy* Cooperative 1't~ -
3200 East Ave. S.
- 608-787-1420 fax* www.dalrvlandpower.com Dairyland Power Cooperative is an equal opportunity provider and employer.
LAC-14548 Attachment C. CONSIDERATIONS FOR EXEMPTION As highlighted in the selected examples above, DPC was moving towards a compliance date of January 8, 2023, without full clarity on key parts of the final rule would result in an inadequate implementation. Unknown success path towards compliance of the final rule, as written, in current code language; along with the conflict and confusion the published, publicly available, stated positions of the NRC, are key elements for this request. DPC would find themselves in a situation where the modification to security plans and procedures would be required at least twice, based on interpretation of this new rule. DPC is requesting the following considerations be taken into account during review of this request:
DPC will continue to utilize the Corrective Action Program to document Conditions Adverse to Regulatory Compliance which includes Security related items, which will not change in the interim until the new compliance date.
DPC will continue to comply with security event reporting, as it existed prior to March 2023, in 10 CFR 73. 71, "Reporting of Safeguards Events," as well as appendix G to part 73 "Reportable Safeguards Events" which will not change in the interim until the new compliance date.
DPC will use the definition of Contraband and Time of Discovery as defined in NEI 03-12 revision 7 which will not change in the interim until the new compliance date.
DPC is currently capable of making voluntary reports of suspicious activities, and this will not change in the interim until the new compliance date.
DPC believes the burden associated with rework is unnecessary while we await final clarity with publication of associated Regulatory Guides. Several examples of where rework will be required are:
o Revisions of associated procedures/processes, job aids, training materials and lesson plans that are used to describe and elaborate on reporting requirements.
o The re-training of impacted ISFSI personnel with updated information contained within the revised guidance documents:
Security Regulatory/Compliance Emergency Response Radiation Protection