ML20086R461

Requests for Exemption from 10CFR73.55 to Eliminate from Security Plan Requirement to Continuously Staff Duplicate Alarm Station.Description of Proposed Physical Security Plan Changes & Other Supporting Info Encl.Encls Withheld

ML20086R461
Person / Time
Site:	Cook
Issue date:	07/19/1995
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1206, NUDOCS 9507310147
Download: ML20086R461 (3)

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July 19, 1995 AEP:NRC:1206'

'I Docket Nos.: 50-315 50-316 i

U. S. Nuclear Regulatory Commission b

ATTN:

Document Control Desk l

Washington, D. C.

20555 Gentlemen:

Donald C. Cook Nuclear Plant Units 1 and 2 I

APPLICATION FOR EXEMPTION FROM 10 CFR 73.55 DUPLICATE ALARM STATION STAFFING REQUIREMENT This letter is our application, pursuant to 10 CFR 73.5,'for an exemption from 10 CFR 73.55(e)(1) and other sections of 10 CFR 73.

Specifically, the request is to eliminate from the Donald C. Cook Nuclear-Plant security plan the requirement to continuously staff the duplicate alarm station.

If this exemption request is approved, an amendment to the Donald C. Cook Nuclear Plant Modified i

Amended Security Plan will be required under 10 CFR 50.90.

Our proposed determination of no significant hazards consideration performed pursuant to 10 CFR 50.92 is contained in Attachment 1,

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with justification for the request for exemption from 10 CFR 73.55(e)(1). A description'of the proposed physical security plan changes, our analysis concerning the effectiveness of the security plan, and our justification for the exemption are also contained in.

The details of the specific changes to the physical security plan, with the existing sections affected and with the proposed changed sections -are contained in Attachment 2.

In accordance with 10 CFR 73.5, this exemption is justifiable since (1) no law specifically requires that NRC regulations mandate a

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continuously manned duplicate alarm station and the Commission is authorized to grant exemptions to 10 CFR 73 requirements, (2) it will not endanger life or property or the common defense, (3) it is in the public interest, (4) the underlying purpose of the rule will be served, (5) continued compliance results in undue hardship and cost from excess staffing expenses compared to nuclear plants in other nations, and (6) the duplicate alarm station equipment will be maintained operable, in case it is needed for contingencies.

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.nclosure COntains 5AFEGUARDS INFORMATION UpOn Separation This Page is Dec0ntrollej;l U. S. Nuclear Regulatory Commission AEP:NRC:1206' Page 2 In addition, this is a cost beneficial' licensing action (CBLA) submittal and represents a large dollar value CBLA item.

The lifetime cost savings associated with this CBLA are approximately

$5,379,770, as detailed in Attachment 3.

These proposed changes have been reviewed and approved by the Cook Nuclear Site Vice President / Plant Manager and the Plant Nuclear Safety Review Committee.

Please acknowledge receipt of this

letter, which contains safeguards information, by signing and returning the enclosed safeguards information transmittal form to D.

J.

Ashley, Cook-Nuclear Plant, One Cook Place, Bridgman, Michigan 49106.

In accordance with 10 CFR 73.21, it is requested that the subject transmittals be withheld from public disclosure and not placed in the Public Document Room.

Please contact us if you have any questions concerning this exemption request.

Sincerely, CL t

E. E. Fitzpatrick Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS !*#3 DAY OF

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tiotary Public My Commission Expires: J M 00 eh Attachments 1

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A. A. Blind G. Charnoff H. J. Miller NFEM Section Chief I

NRC Resident Inspector Bridgman J. R. Padgett l

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4 U. S. Nuclear' Regulatory Connaission

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S. J. Brewer /D.'H Malin/K. J. Toth/L. M. Smart U. M. Hodge ' Bridgman J. A. Kobyra/S. H. Steinhart/S. P. Hodge D. R. Mihalik J. B. Shinnock W. ~ G. Smith, Jr.

-l J. S.-Wiebe J. B. Hickman, NRC - Washington, D.C.

PRONET DC-N-6015.1 i

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