ULNRC-06844, Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification

Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification

ML23341A184
Person / Time
Site:	Callaway
Issue date:	12/07/2023
From:	Witt T Ameren Missouri, Union Electric Co
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML23342A158	List: ML23341A190 ULNRC-06844, Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification
References
ULNRC-06844
Download: ML23341A184 (1)

Text

?AI11erefl Callaway Plant MISSOURi December 7, 2023 ULNRC-06844 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 73.5 Ladies and Gentlemen:

DOCKET NUMBERS 50-483 & 72-1045 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

RENEWED FACILITY OPERATING LICENSE NPF-30 REQUEST FOR EXEMPTION FROM SPECIFIC REQUIREMENTS IN 2023 SECURITY RULE, ENHANCED WEAPONS, FIREARMS BACKGROUND CHECKS, AND SECURITY EVENT NOTIFICATIONS On March 14, 2023, the Nuclear Regulatory Commission (NRC) published for notice in the federal Register, final Rule, Enhanced Weapons, firearms Background Checks, and Security Event Notifications. This final rule became effective April 13, 2023, with a compliance date ofJanuary 8, 2024.

In response to the publication of the final rule, Ameren Missouri (Union Electric) performed a gap analysis to compare the new rule against current requirements, NRC endorsed documents, and other guidance documents published by the NRC. Ameren Missouri also evaluated the broad impact across multiple organizations and the change management scope.

In accordance with 1 0 CfR 73 .5, Ameren Missouri is requesting an exemption for Callaway Plant (as well as the Independent Spent Fuel Storage Installation (ISfSI) located at the Callaway Plant site) from the specific requirements in 10 CFR Part 73, Subpart T, Security Notifications, Reports, and Recordkeeping, 1 0 CfR 73 1 200(a) through 1 0 CfR 73 1200(t), Notification of Physical Security Events, 1 0 CfR 73 1 205(a)(1) through 1 0 CfR 73 1 205(e), Written follow-up Reports of Physical Security Events, 10 CfR 73.1210(a)(1) through 10 CfR 73.1210(h), Recordkeeping of Physical Security Events, and 10 CfR 73 121 5(a) through 1 0 CFR 73 121 5(0, Suspicious Activity Reports, until the later of December 3 1 2024, or 1 80 days after publication of the final Regulatory Guides.

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ULNRC-06844 December 7, 2023 Page2of4 Ameren Missouri is also requesting an exemption from using the definitions for the terms Contraband and Time of Discovery as recently revised in 1 0 CFR 73 .2, Definitions, until the later of December 3 1, 2024, or 1 80 days after publication of the final Regulatory Guides. The exemption would not apply to the definitions of those terms that were in effect prior to the issuance of the 2023 revisions.

Ameren Missouri is not requesting an extension to the compliance date for specific requirements in Title 1 0 of the Code of Federal Regulations (1 0 CFR) Part 73 Subpart B, Enhanced Weapons, Preemption, and firearms Background Checks, described in 1 0 CFR 73 1 5, Authorization for Use of Enhanced Weapons and Preemption of Firearms Laws, and 1 0 CFR 73 1 7, firearm Background Checks for Armed Security Personnel.

Based on NRCs projected timeline for completion ofrevision to the applicable Regulatory Guides associated with this final rule, and the time necessary for Ameren Missouri to go through the change management processes adequately to include the number of training weeks that will be required, Ameren Missouri is requesting a new compliance date of December 3 1 2024, or 1 80 days after publication of final Regulatory Guides, whichever is later.

The attachment to this letter provides the justification and rationale for the exemption request. The requested exemption from the specific requirements in 1 0 CfR Part 73 is permissible under 10 CfR 73 .5 because it is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security.

Ameren Missouri requests approval ofthis exemption by January 4, 2024.

This letter does not contain new commitments.

Ifthere are any questions, please contact Em Smith at 3 14-225-17 11.

Sincerely, Todd A. Witt Manager, Regulatory Affairs

Enclosure:

Justification for Exemption Request from Specific Requirements in the 2023 Security Rule, Enhanced Weapons, firearms Background Checks, and Security Event Notifications

ULNRC-06844 December 7, 2023 Page3of4 cc: Mr. John Monninger Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard . -Jft:.)

Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office . .

U.S. Nuclear Regulatory Commission . -

8201 NRC Road Steedman, MO 65077 .

Mr. M. Chawla Project Manager, Callaway Plant Office of Nuclear Reactor Regulation .

U. S Nuclear Regulatory Commission Mail Stop O8B1A Washington, DC 20555-0001

ULNRC-06844 December 7, 2023 Page4of4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6500 West Freeway, Suite 400 FortWorth,TX 76116 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Other Situations ULNRC Distribution:

F. M. Diya K. C. Scott W. A. Witt B. L. Jungmann B. Brown T. A. Witt T. B. Elwood NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Ms. Kathleen McNelis (Public Service Commission)

Ms. Claire Eubanks (Public Service Commission)