ML100550875

Exemption Request for 10 CFR 73.55 Implementation - Update

ML100550875
Person / Time
Site:	Palo Verde
Issue date:	02/16/2010
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06131-DCM/CJS
Download: ML100550875 (4)

Text

10 CFR 73.5 LA P A subsidiaryof Pinnacle West CapitalCorporation Dwight C. Mims Mail Station 7605 Palo Verde Nuclear Vice President Tel. 623-393-5403 P.O. Box 52034 Generating Station Regulatory Affairs and Plant Improvement Fax 623-393-6077 Phoenix, Arizona' 85072-2034 102-06131-DCM/CJS February 16, 2010 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Exemption Request for 10 CFR 73.55 Implementation - Update By letter number 102-06111, dated December 21, 2009, Arizona Public Service Company (APS) applied for an exemption from the schedule requirement of 10 CFR Part 73, Physical Protectionof Plants and Materials, paragraph 73.55(a)(1) for PVNGS Units 1, 2, and 3, pursuant to 10 CFR 73.5. The new rule, 10 CFR 73.55, published March 27, 2009, effective May 26, 2009, with a full implementation date of March 31, 2010, requires licensees to protect, with high assurance, against radiological sabotage by designing and implementing comprehensive site security plans.

As a result of updated project information and clarifications obtained during a conference call with the NRC staff on February 2, 2010, APS hereby updates its exemption request. Specifically, APS continues to request an exemption until December 17, 2010, for constructing the Protected Area Security Extension (PASE) structure. In addition, APS withdraws the exemption request for an improved uninterruptible power supply (UPS), and instead requests that an exemption be provided until June 30, 2010, for the installation and testing of certain solar powered light standards. The Attachment to this letter provides a summary schedule for these activities.

The APS current and new physical protection program that will be implemented by March 31, 2010, continue to provide high assurance of public health and safety.

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. APS requests the exemption by March 12, 2010, to support implementation in the PVNGS security program by March 31, 2010.

The site areas physically impacted by the modifications. are relatively small, when compared to the overall PVNGS site. The modifications will be implemented in areas A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak 0 Diablo Canyon

• Palo Verde 0 San Onofre

• South Texas 0 Wolf Creek AmtZ'4

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Exemption Request for 10 CFR 73.55 Implementation - Update Page 2 previously disturbed by site construction activities. This request is confined to implementation schedules for two provisions of 10 CFR 73.55 and, as such, is an administrative relief. Accordingly, the proposed exemption should result in a finding of no significant impact, pursuant to 10 CFR 51.32. Specifically, the proposed action, as revised, will not significantly increase the probability or consequences of accidents. No changes are being made in the types of effluents that may be released offsite. There is no significant increase in the amount of any effluent released offsite. There is no significant increase in occupational or public radiation exposure. Therefore, there are no significant radiological environmental impacts associated with the proposed action.

With regard to potential non-radiological impacts, the proposed action, as revised, does not have a potential to affect any historic sites. It does not affect non-radiological plant effluents and has no other environmental impact. Therefore, there are no significant non-radiological environmental impacts associated with the proposed action.

Denial of the application for exemption would result in no change in current environmental impacts. Thus the environmental impacts of the proposed action and the alternative action (i.e., the "no-action" alternative) are similar.

The action does not involve the use of any different resources than those previously considered in the Final Environmental Statement for the Palo Verde Nuclear Generating Station, Units 1,2, and 3, NUREG-0841, dated February 1982.

No commitments are being made by this letter. Should you need further information regarding this exemption request, please contact Russell A. Stroud, Licensing Section Leader, at (623) 393-5111.

Sincerely, DCMITNW/CJS/gat

Attachment:

Summary Project Schedule cc:

E. E. Collins Jr. NRC Region IV Regional Administrator J. R. Hall NRC NRR Project Manager K. S. Brooks Sr. Physical Security Inspector, RIV/DRS/PSB R. I. Treadway NRC Senior Resident Inspector for PVNGS

Attachment Summary Project Schedule

Attachment Summary Project Schedule Protected Are"'S'uiifty n Project Activity Target Completion Date Solar Light Standards Design Input Document Development Complete Final Design March 19, 2010 Procurement March 31, 2010 Planning and Implementation May 7, 2010 Verification Testing and Turnover June 30, 2010 PASE Facility Final PASE Design April 2, 2010 Procurement of PASE Facility and Equipment April 30, 2010 PASE Planning and Implementation November 12, 2010 PASE Verification Testing and Turnover December 17, 2010

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