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| number = ML100680530
| number = ML100680530
| issue date = 03/08/2010
| issue date = 03/08/2010
| title = Palisades - Redacted Supplement to Request for Exemption from Physical Security Requirements
| title = Redacted Supplement to Request for Exemption from Physical Security Requirements
| author name = Schwartz C J
| author name = Schwartz C
| author affiliation = Entergy Nuclear Operations, Inc
| author affiliation = Entergy Nuclear Operations, Inc
| addressee name =  
| addressee name =  
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| document type = Letter
| document type = Letter
| page count = 10
| page count = 10
| project =
| stage = Supplement
}}
}}


=Text=
=Text=
{{#Wiki_filter:March 8, 2010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nuclear Inc. Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Christopher J. Schwarz Site Vice President 10 CFR 73.5  
{{#Wiki_filter:Nuclear           Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Christopher J. Schwarz Site Vice President March 8, 2010                                                    10 CFR 73.5 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001


==SUBJECT:==
==SUBJECT:==
Redacted Supplement to Request for Exemption from Physical Security Requirements Palisades Nuclear Plant Docket 50-255 License No. DPR-20  
Redacted Supplement to Request for Exemption from Physical Security Requirements Palisades Nuclear Plant Docket 50-255 License No. DPR-20


==Dear Sir or Madam:==
==Dear Sir or Madam:==
In accordance with the requirements of 10 CFR 73.5, Entergy Nuclear Operations, Inc. (ENO) requested the Nuclear Regulatory Commission (NRC) approve an exemption from specific requirements of 10 CFR Part 73, "Physical Protection of Plants and Materials," for the Palisades Nuclear Plant by extending the deadline for the , implementation of new security requirements issued by NRC in a Final Rule dated March 27, 2009 (74 FR 13926). The request for exemption was submitted on January 14, 2010 (inadvertently dated January 14, 2009). January 28, 2010, during a teleconference, the NRC requested that supplemental information be provided.
 
The NRC specified during the call that a redacted version the supplemental response would not be required.
In accordance with the requirements of 10 CFR 73.5, Entergy Nuclear Operations, Inc.
ENO submitted the supplemental information in a security-related version of this letter on February 16, 2010. On March 8, 2010, in a follow-up call, the NRC did request a redacted version. This letter provides the requested redacted version of the supplemental response.
(ENO) requested the Nuclear Regulatory Commission (NRC) approve an exemption from specific requirements of 10 CFR Part 73, "Physical Protection of Plants and Materials," for the Palisades Nuclear Plant by extending the deadline for the             ,
Attachment 1 contains the requested information.
implementation of new security requirements issued by NRC in a Final Rule dated March 27, 2009 (74 FR 13926). The request for exemption was submitted on January 14, 2010 (inadvertently dated January 14, 2009).
ENO is no longer requesting exemption from [ ] or [ ]. Attachment 2 was updated to provide the correct exemptions and dates being requested.
January 28, 2010, during a teleconference, the NRC requested that supplemental information be provided. The NRC specified during the call that a redacted version the supplemental response would not be required. ENO submitted the supplemental information in a security-related version of this letter on February 16, 2010. On March 8, 2010, in a follow-up call, the NRC did request a redacted version. This letter provides the requested redacted version of the supplemental response. contains the requested information. ENO is no longer requesting exemption from [         ] or [     ]. Attachment 2 was updated to provide the correct exemptions and dates being requested. In addition, Table 2 in Attachment 2 was revised to reflect new milestone dates based on current information. Attachment 3 was updated with the correct date being requested.
In addition, Table 2 in Attachment 2 was revised to reflect new milestone dates based on current information.
 
Attachment 3 was updated with the correct date being requested.
Page 2 This letter identifies no new commitments and makes no revisions to existing commitments.
Page 2 This letter identifies no new commitments and makes no revisions to existing commitments.
Sincerely, cjs/bed Attachment 1 : Attachment 2: Attachment 3: Supplement to Request for Exemption from Physical Security Requirements Basis for Proposed Exemption Environmental Assessment cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC 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 (ENO) has evaluated these new requirements for the Palisades Nuclear Plant (PNP) and determined that many can be implemented by the required date. However, ENO has also determined that implementation of some specific requirements will require additional time beyond March 31,2010. ENO is in the process of [ ]. Delays have been experienced with the ], with the [ ]. Once the [ needed for [ In addition, the [ Due to [ ]. The proposed location of the [ provided in Attachment 2, Table 3. ], time will be ] is required to be [ ] in some areas. ]. ] is ENO is effecting these modifications in order to improve security protective strategies, address equipment obsolescence, and meet the requirements of the revised regulation.
Sincerely, cjs/bed :         Supplement to Request for Exemption from Physical Security Requirements :          Basis for Proposed Exemption :          Environmental Assessment cc:   Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
Modifications to the [ ] and installation of the [ ] and the [ ] are expected to be completed by August 31, 201 PNP Security System Upgrade Description Major upgrades to achieve compliance with 10 CFR 73.55 include, but are not limited to: Page 1 of 4 Due to the [ ] , and in consideration of [ ], completion of some of the new requirements contained in 10 CFR 73.55 will require additional time beyond March 31, 2010. Description of Modifications at Risk of Meeting Implementation Date A new[ ] is being installed.
 
The new [ ] is an [ ]. Attachment 2, Table 1, provides the current schedule for [ ]. Installation of the [ ] is necessary to accommodate  
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 (ENO) has evaluated these new requirements for the Palisades Nuclear Plant (PNP) and determined that many can be implemented by the required date. However, ENO has also determined that implementation of some specific requirements will require additional time beyond March 31,2010.
[ ], which will be necessary to [ ]. This is based upon [ ]. In addition, the [ ] in some areas. [ ] will be required to be installed in areas where these [ ] are made. These actions are necessary to offset the [ Table 2, provides the current schedule for [ Attachment 2, Table 3, depicts the [ ], in conjunction with other [ ]. Attachment 2, ]. ] and [ ] in progress.
ENO is in the process of [
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 exemptions described in Section C, below. These items, subject to the request for an exemption, will be implemented by August 31,2010, as discussed above. PNP will then be in full compliance with the Final Rule. Page 2 of 4 C. Proposed Exemptions ENO requests an exemption, from the implementation deadline only, for the items listed below. PNP'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.
                                          ]. Delays have been experienced with the
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. Please note that PNP is no longer requesting exemptions for [ ] and [ ]. Regulation  
                    ], with the [
] states: ]. ]. Page 3 of 4
                  ]. Once the [                                               ], time will be needed for [
]. Regulation  
                          ].
] states: ]. ]. Regulation  
In addition, the [                 ] is required to be [          ] in some areas.
] states: ]. ]. Page 4 of 4 Entergy Nuclear Operations, LLC (ENO) is requesting a schedular exemption from [ ], for the Palisades Nuclear Plant (PNP). The request for an exemption from the March 31,2010, implementation date to August 31, 2010, is based on the [ ] and [ ] to meet the revised requirements.
Due to [
Using established processes, the duration (study, design, construction, testing, turnover and training) of a project of this magnitude is typically 18 -24 months. The 12-month implementation period challenged this time frame significantly.
                                                        ].
Although work is continuing on these [ ], it is likely that completion will be further complicated by 1) [ ], and 2) [ ]. ENO 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. Tables 1 and 2 provide the project milestone schedules for the [ ] associated with the specific exemptions requested.
The proposed location of the [                                                     ] is provided in Attachment 2, Table 3.
The schedules take into consideration anticipated impediments to [ ], which may delay [ ]. It also considers delays in the [ ]. Table 3 provides a [ the [ ], in conjunction with other [ Page 1 of 3 ] and ] in progress.
ENO is effecting these modifications in order to improve security protective strategies, address equipment obsolescence, and meet the requirements of the revised regulation. Modifications to the [         ] and installation of the [
dates below are estimates, with the exception of the August 31,2010, end date. Table 1 -Schedule Milestones for [ ] Milestone Scheduled Completion Date [ ] March 5, 2010 [ ] April 23, 2010 [ ] April 23, 2010 [ ] April 26, 2010 [ ] June 4, 2010 [ ] June 7,2010 [ ] July 2,2010 [ ] July 23,2010 [ ] August 30, 2010 [ ] August 31, 2010 Table 2 -Schedule Milestones for [ ] Milestone Scheduled Completion Date [ ] February 19, 2010 [ ] May 7,2010 [ ] May 10, 2010 [ ] June 18, 2010 [ ] June 21,2010 [ ] July 30,2010 [ ] August 2, 2010 [ ] August 20, 2010 [ ] August 31, 2010 Page 2 of 3 G z :s: 0 J: (/) G Z 0:: C I M C0 -0 C0 Q) 0') CCS 0..
    ] and the [                               ] are expected to be completed by August 31, 201 PNP Security System Upgrade Description Major upgrades to achieve compliance with 10 CFR 73.55 include, but are not limited to:
ENO is requesting an exemption for PNP in accordance with 10 CFR 73.5, "Specific Exemptions." The requested exemption is schedular in nature, and would defer the compliance date for three specific provisions of 10 CFR 73.55 from March 31,2010, to August 31, 2010. The proposed exemption is needed to [ ] . PNP'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.
Page 1 of 4
 
Due to the [                                                                               ],
and in consideration of [
                                      ], completion of some of the new requirements contained in 10 CFR 73.55 will require additional time beyond March 31, 2010.
Description of Modifications at Risk of Meeting Implementation Date A new[                       ] is being installed. The new [         ] is an [
                                                                                        ]. , Table 1, provides the current schedule for [
            ].
Installation of the [             ] is necessary to accommodate [
                  ], which will be necessary to [
    ]. This is based upon [
                                                                  ].
In addition, the [                                               ] in some areas. [
          ] will be required to be installed in areas where these [                 ] are made. These actions are necessary to offset the [
                                                                          ]. Attachment 2, Table 2, provides the current schedule for [                                     ]. , Table 3, depicts the [                                     ] and [
                ], in conjunction with other [             ] in progress.
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 exemptions described in Section C, below. These items, subject to the request for an exemption, will be implemented by August 31,2010, as discussed above. PNP will then be in full compliance with the Final Rule.
Page 2 of 4
 
C. Proposed Exemptions ENO requests an exemption, from the implementation deadline only, for the items listed below. PNP'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. Please note that PNP is no longer requesting exemptions for [                     ] and [
                        ].
Regulation
                      ] states:
                                  ].
                                                                        ].
Page 3 of 4
 
                ].
Regulation
            ] states:
                          ].
                              ].
Regulation
          ] states:
                                        ].
                      ].
Page 4 of 4
 
Entergy Nuclear Operations, LLC (ENO) is requesting a schedular exemption from [
                                                                                            ], for the Palisades Nuclear Plant (PNP). The request for an exemption from the March 31,2010, implementation date to August 31, 2010, is based on the [
                                                                          ] and [
                                                            ] to meet the revised requirements.
Using established processes, the duration (study, design, construction, testing, turnover and training) of a project of this magnitude is typically 18 - 24 months. The 12-month implementation period challenged this time frame significantly. Although work is continuing on these [               ], it is likely that completion will be further complicated by 1) [
                      ], and 2) [
                                  ].
ENO 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.
Tables 1 and 2 provide the project milestone schedules for the [                 ] associated with the specific exemptions requested. The schedules take into consideration anticipated impediments to [                                                     ], which may delay [
    ]. It also considers delays in the [                                               ].
Table 3 provides a [                                                                       ] and the [                                   ], in conjunction with other [       ] in progress.
Page 1 of 3
 
dates below are estimates, with the exception of the August 31,2010, end date.
Table 1 - Schedule Milestones for [           ]
Milestone                                               Scheduled Completion Date
[     ]                                                 March 5, 2010
[     ]                                                 April 23, 2010
[     ]                                                 April 23, 2010
[     ]                                                 April 26, 2010
[     ]                                                 June 4, 2010
[     ]                                                 June 7,2010
[     ]                                                 July 2,2010
[     ]                                                 July 23,2010
[     ]                                                 August 30, 2010
[     ]                                                 August 31, 2010 Table 2 - Schedule Milestones for [         ]
Milestone                                         Scheduled Completion Date
[     ]                                           February 19, 2010
[     ]                                           May 7,2010
[     ]                                           May 10, 2010
[     ]                                           June 18, 2010
[     ]                                           June 21,2010
[     ]                                           July 30,2010
[     ]                                           August 2, 2010
[     ]                                           August 20, 2010
[     ]                                           August 31, 2010 Page 2 of 3
 
G z
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0 J:
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~
Q) 0')
CCS 0:: 0..
C I
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ENO is requesting an exemption for PNP in accordance with 10 CFR 73.5, "Specific Exemptions." The requested exemption is schedular in nature, and would defer the compliance date for three specific provisions of 10 CFR 73.55 from March 31,2010, to August 31, 2010. The proposed exemption is needed to [
                                                  ].
PNP'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 is a schedular change only, and therefore, does not result in any physical changes to structures, systems or components or land use at PNP. The deferral of the compliance date does not involve:
Deferral of the compliance date is a schedular change only, and therefore, does not result in any physical changes to structures, systems or components or land use at PNP. 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 the types, characteristics, or quantities of non-radiological effluents discharged to the environment,
Line 50: Line 139:
* any change in occupational dose under normal or design basis accident conditions,
* 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 change in the public dose under normal or design basis accident conditions,
* any land disturbance.  
* any land disturbance.


==
==
Conclusion:==
Conclusion:==


There is no significant radiological environmental impact associated with the proposed schedular exemption.
There is no significant radiological environmental impact associated with the proposed schedular exemption. The proposed exemption will not affect non-radiological plant effluents or any historical sites.
The proposed exemption will not affect non-radiological plant effluents or any historical sites. Page 1 of 1}}
Page 1 of 1}}

Latest revision as of 03:33, 12 March 2020

Redacted Supplement to Request for Exemption from Physical Security Requirements
ML100680530
Person / Time
Site: Palisades Entergy icon.png
Issue date: 03/08/2010
From: Schwartz C
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML100680530 (10)
v • d • e


Text

Nuclear Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Christopher J. Schwarz Site Vice President March 8, 2010 10 CFR 73.5 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Redacted Supplement to Request for Exemption from Physical Security Requirements Palisades Nuclear Plant Docket 50-255 License No. DPR-20

Dear Sir or Madam:

In accordance with the requirements of 10 CFR 73.5, Entergy Nuclear Operations, Inc.

(ENO) requested the Nuclear Regulatory Commission (NRC) approve an exemption from specific requirements of 10 CFR Part 73, "Physical Protection of Plants and Materials," for the Palisades Nuclear Plant by extending the deadline for the ,

implementation of new security requirements issued by NRC in a Final Rule dated March 27, 2009 (74 FR 13926). The request for exemption was submitted on January 14, 2010 (inadvertently dated January 14, 2009).

January 28, 2010, during a teleconference, the NRC requested that supplemental information be provided. The NRC specified during the call that a redacted version the supplemental response would not be required. ENO submitted the supplemental information in a security-related version of this letter on February 16, 2010. On March 8, 2010, in a follow-up call, the NRC did request a redacted version. This letter provides the requested redacted version of the supplemental response. contains the requested information. ENO is no longer requesting exemption from [ ] or [ ]. Attachment 2 was updated to provide the correct exemptions and dates being requested. In addition, Table 2 in Attachment 2 was revised to reflect new milestone dates based on current information. Attachment 3 was updated with the correct date being requested.

Page 2 This letter identifies no new commitments and makes no revisions to existing commitments.

Sincerely, cjs/bed : Supplement to Request for Exemption from Physical Security Requirements : Basis for Proposed Exemption : Environmental Assessment cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

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 (ENO) has evaluated these new requirements for the Palisades Nuclear Plant (PNP) and determined that many can be implemented by the required date. However, ENO has also determined that implementation of some specific requirements will require additional time beyond March 31,2010.

ENO is in the process of [

]. Delays have been experienced with the

], with the [

]. Once the [ ], time will be needed for [

].

In addition, the [ ] is required to be [ ] in some areas.

Due to [

].

The proposed location of the [ ] is provided in Attachment 2, Table 3.

ENO is effecting these modifications in order to improve security protective strategies, address equipment obsolescence, and meet the requirements of the revised regulation. Modifications to the [ ] and installation of the [

] and the [ ] are expected to be completed by August 31, 201 PNP Security System Upgrade Description Major upgrades to achieve compliance with 10 CFR 73.55 include, but are not limited to:

Page 1 of 4

Due to the [ ],

and in consideration of [

], completion of some of the new requirements contained in 10 CFR 73.55 will require additional time beyond March 31, 2010.

Description of Modifications at Risk of Meeting Implementation Date A new[ ] is being installed. The new [ ] is an [

]. , Table 1, provides the current schedule for [

].

Installation of the [ ] is necessary to accommodate [

], which will be necessary to [

]. This is based upon [

].

In addition, the [ ] in some areas. [

] will be required to be installed in areas where these [ ] are made. These actions are necessary to offset the [

]. Attachment 2, Table 2, provides the current schedule for [ ]. , Table 3, depicts the [ ] and [

], in conjunction with other [ ] in progress.

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 exemptions described in Section C, below. These items, subject to the request for an exemption, will be implemented by August 31,2010, as discussed above. PNP will then be in full compliance with the Final Rule.

Page 2 of 4

C. Proposed Exemptions ENO requests an exemption, from the implementation deadline only, for the items listed below. PNP'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. Please note that PNP is no longer requesting exemptions for [ ] and [

].

Regulation

] states:

].

].

Page 3 of 4

].

Regulation

] states:

].

].

Regulation

] states:

].

].

Page 4 of 4

Entergy Nuclear Operations, LLC (ENO) is requesting a schedular exemption from [

], for the Palisades Nuclear Plant (PNP). The request for an exemption from the March 31,2010, implementation date to August 31, 2010, is based on the [

] and [

] to meet the revised requirements.

Using established processes, the duration (study, design, construction, testing, turnover and training) of a project of this magnitude is typically 18 - 24 months. The 12-month implementation period challenged this time frame significantly. Although work is continuing on these [ ], it is likely that completion will be further complicated by 1) [

], and 2) [

].

ENO 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.

Tables 1 and 2 provide the project milestone schedules for the [ ] associated with the specific exemptions requested. The schedules take into consideration anticipated impediments to [ ], which may delay [

]. It also considers delays in the [ ].

Table 3 provides a [ ] and the [ ], in conjunction with other [ ] in progress.

Page 1 of 3

dates below are estimates, with the exception of the August 31,2010, end date.

Table 1 - Schedule Milestones for [ ]

Milestone Scheduled Completion Date

[ ] March 5, 2010

[ ] April 23, 2010

[ ] April 23, 2010

[ ] April 26, 2010

[ ] June 4, 2010

[ ] June 7,2010

[ ] July 2,2010

[ ] July 23,2010

[ ] August 30, 2010

[ ] August 31, 2010 Table 2 - Schedule Milestones for [ ]

Milestone Scheduled Completion Date

[ ] February 19, 2010

[ ] May 7,2010

[ ] May 10, 2010

[ ] June 18, 2010

[ ] June 21,2010

[ ] July 30,2010

[ ] August 2, 2010

[ ] August 20, 2010

[ ] August 31, 2010 Page 2 of 3

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0 J:

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~

Q) 0')

CCS 0:: 0..

C I

M

ENO is requesting an exemption for PNP in accordance with 10 CFR 73.5, "Specific Exemptions." The requested exemption is schedular in nature, and would defer the compliance date for three specific provisions of 10 CFR 73.55 from March 31,2010, to August 31, 2010. The proposed exemption is needed to [

].

PNP'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 is a schedular change only, and therefore, does not result in any physical changes to structures, systems or components or land use at PNP. 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 or any historical sites.

Page 1 of 1

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