ML042610299

Final Response to Requests for Additional Information Palo Verde Nuclear Generating Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program

ML042610299
Person / Time
Site:	Palo Verde
Issue date:	09/03/2004
From:	Overbeck G Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Security and Incident Response
References
102-05148-GRO/SAB/DGM
Download: ML042610299 (3)

Text

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OCFR73.45 Gregg R. Overbeck Mail Station 7602 Palo Verde Nuclear Senior Vice President TEL (623) 393-5148 P.O. Box 52034 Generating Station Nuclear FAX (623) 393-6077 Phoenix, AZ 85072-2034 102-05148-GRO/SAB/DGM September 3, 2004 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Reference:

1) Order dated April 29, 2003, Requiring Compliance with Revised Design Basis Threat ("Order EA-03-086" or "Order")

2) Letter 102-05098-GRO/RAS, dated 04/28/2004, G. R. Overbeck to NRC, Supplemental Response to the April 29, 2003, Orders to Palo Verde Nuclear Generating Station (PVNGS)

3) Letter dated 08/24/2004, Scott A. Morris, NRC to G. R. Overbeck, Clarification of Vehicle Search Criteria

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3 Docket No. STN 50-528; 50-529; 50-530 License No. NPF-41; NPF-51; NPF-74 Final Response to Requests for Additional Information re: Palo Verde Nuclear Generating Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program.

Dear Sirs:

The NRC issued an Order dated April 29, 2003, requiring compliance with revised Design Basis Threat ("Order EA-03-086" or "Order', Reference 1) and other security related Orders (collectively "Orders") for the Palo Verde Nuclear Generating Station.

Order EA-03-086 imposes license conditions on nuclear power plants licensed pursuant to the Atomic Energy Act of 1954 and Title 10 of the Code of Federal Regulations.

Section Ill.A of the Order requires licensees to revise their physical security plans and safeguards contingency plans to provide protection against the revised design basis threat (DBT) set forth in Attachment 2 to the Order.Section III.A also requires licensees to revise the security force training and qualification plan to implement the revised DBT.

These revised plans, along with an implementation schedule, were required to be submitted to the Commission for review and approval no later than April 29, 2004.

ENCLOSURE(S) CONTAIN(S)

SAFEGUARDS INFORMATION UPON SEPARATION THIS PAGE IS DECONTROLLED

SAFEGUARDS INFORMATION U. S. Nuclear Regulatory Commission Final Response to Requests for Additional Information re: Palo Verde Nuclear Generating Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program.

Page 3 cc:

B. S. Mallett M. B. Fields N. L. Salgado NRC Region IV Regional Administrator NRC NRR Project Manager (without enclosures)

NRC Senior Resident Inspector for PVNGS ENCLOSURE(S) CONTAIN(S)

SAFEGUARDS INFORMATION UPON SEPARATION THIS PAGE IS DECONTROLLED SAFEGUARDS INFORMATION

SAFEGUARDS INFORMATION U. S. Nuclear Regulatory Commission Final Redponse to Requests for Additional Information re: Palo Verde Nuclear Generating Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program.

Page 2 In accordance with the Order and 10CFR § 50.4, APS submitted this Supplemental Response (Reference 2) on April 28, 2004.

The NRC requested additional changes during a telephone conversation with Mr. B.

Benney, NRC on August 31, 2004, in order to complete its evaluation based on its review of the Palo Verde Nuclear Generating Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program.

Enclosed find Revision 0 of the Palo Verde Nuclear Generating Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program incorporating the changes resulting from the above telephone conversation.

APS proposes the alternative approach provided by the NRC staff for Section 9.4.1.1 per the August 24, 2004 letter (Reference 3). The NRC staff has determined that the alternative achieves the same high assurance objective as intended by the regulations, and that the overall system performance provides an equivalent level of protection against radiological sabotage that would be provided by paragraphs (c)(3) and (c)(4) of the Code of Federal Regulations (10 CFR) Section 73.55.

If you have questions regarding this submittal, please contact Daniel G. Marks, Section Leader, Regulatory Affairs, at (623) 393-6492.

Arizona Public Service Company makes no commitments in this letter.

The material enclosed herewith contains Safeguards Information as defined by 10 CFR 73.21 and its disclosure to unauthorized individuals is prohibited by Section 147 of the Atomic Energy Act of 1954, as amended.

Sincerely, GRO/SAB/DGM/dgm

Enclosures:

1)

Revision 0 of the Palo Verde Nuclear Generating Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program ENCLOSURE(S) CONTAIN(S)

SAFEGUARDS INFORMATION UPON SEPARATION THIS PAGE IS DECONTROLLED SAFEGUARDS INFORMATION