ML101310227

Response to April 8, 2010, Request for Additional Information Regarding Security Assessments, for the Review of the PVNGS License Renewal Application

ML101310227
Person / Time
Site:	Palo Verde
Issue date:	04/29/2010
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06176-DCM/GAM
Download: ML101310227 (6)

Text

A subsidiary of Pinnacle West Capital Corporation 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 102-06176-DCM/GAM April 29, 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 Response to April 8, 2010, Request for Additional Information Regarding Security Assessments, for the Review of the PVNGS License Renewal Application By letter dated April 8, 2010, the Nuclear Regulatory Commission staff issued a request for additional information (RAI) related to the PVNGS license renewal application (LRA). contains Arizona Public Service Company's response to the April 8, 2010, RAI.

APS makes no commitments in this letter. Should you need further information regarding this submittal, please contact Russell A. Stroud, Licensing Section Leader, at (623) 393-5111.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on

-/

/0 (d te)

Sincerely, DCM/RAS/GAM/GAT A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway Comanche Peak-Diablo Canyon

• Palo Verde

• San Onofre

• South Texas

• Wolf Creek

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Response to April 8, 2010, Request for Additional Information Regarding Security Assessments, for the Review of the PVNGS License Renewal Application Page 2

Enclosure:

Response to April 8, 2010, Request for Additional Information Regarding Security Assessments, for the Review of the PVNGS License Renewal Application cc:

E. E. Collins Jr.

J. R. Hall L. K. Gibson R. I. Treadway L. M. Regner D. M. Drucker G. A. Pick Doug Huyck Beth Mizuno NRC Region IV.Regional Administrator NRC NRR Project Manager NRC NRR Project Manager NRC Senior Resident Inspector for PVNGS NRC License Renewal Safety Project Manager NRC License Renewal Environmental Project Manager NRC Region IV (electronic)

NRC NRC

ENCLOSURE Response to April 8, 2010, Request for Additional Wnformation Regarding Security Assessments, for the Review of the PVNGS License Renewal Application

Enclosure Response to April 8, 2010, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI Introduction In order to complete its evaluation and address the risk associated with security/terrorist events, the staff has determined additional information is needed regarding plant-specific evaluations and mitigative measures completed. The staff requests the following information be provided. Please note that no classified information, safeguards information, or Sensitive Unclassified Non-Safeguards Information (SUNSI) is requested or to be provided:

NRC Request (a)

a. A listing of the significant security-related assessments performed subsequent to the events of 09/11/2001. Significant assessments performed by/for Arizona Public Service Company (e.g., self assessments, contractor assessments), industry (e.g.,

Electric Power Research Institute (EPRI), Nuclear Energy Institute (NEI)), and government (e.g., U.S. Nuclear Regulatory Commission and Department of Homeland Security) should be included in the listing.

Arizona Public Service Company's Response to Request (a)

A number of significant security related assessments were performed for the Palo Verde Nuclear Generating Station (PVNGS) subsequent to September 11, 2001. These' assessments were performed internally by Arizona Public Service Company (APS), the Department of Homeland Security (DHS), and the Nuclear Regulatory Commission (NRC).

An assessment of PVNGS was performed in 2005 that evaluated the station beyond the NRC's Design Basis Threat, and evaluated the resulting offsite consequences.

The NRC performed an inspection November 18, 2008, on the Interim Compensatory Measures associated with the mitigation strategies of an aircraft threat (10 CFR 50.54(hh)).

The PVNGS Emergency Preparedness Organization conducted an integrated response drill involving a hostile action at PVNGS on December 10, 2009.

Additional significant security assessments for PVNGS included NRC inspections conducted subsequent to September 11, 2001 in the following areas:

" Baseline Inspections

" Temporary Instructions (Material Control and Accounting, and Interim Compensatory Measures)

" Physical Security Reports and Investigative Reports Supplemental Inspections

• Closeout Inspection (Interim Compensatory Measures)

" Force on Force Inspections 1

Enclosure Response to April 8, 2010, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC Request (b)

b. A summary of the key results and findings from the assessments identified in item (a) above, including the results of any offsite consequence assessment for security-related events.

Arizona Public Service Company's Response to Request (b)

The areas of key findings associated with the assessments of the PVNGS security program have been discussed with the NRC staff. It was mutually concluded that these findings are Sensitive Unclassified Non-Safeguards Information (SUNSI) that will therefore not be provided in this submittal as specified in the RAI.

NRC Request (c)

c. A summary or listing of the enhancements to plant hardware, personnel, or procedures as a result of the assessments.

Arizona Public Service Company's Response to Request (c)

Enhancements were made in the areas listed below as a result of the assessments identified in the response to request (a). The enhancements included changes, modifications, or additions to plant hardware, personnel, or procedures.

Plant Hardware Physical Barriers Security Post and Structures Access Control Devices Access Requirements Searches Surveillance and Monitoring Personnel Equipment Communications Maintenance, Testing and Calibration of Security Equipment Compensatory Measures Personnel Training for PVNGS non-Security Personnel Training for Security Personnel General Weapons Procedures Work Hour Controls & Fatigue Large Aircraft Threats Physical Security Plan 2

Enclosure Response to April 8, 2010, Request for Additional Information for the Review of the PVNGS License Renewal Application Safety/Security Interface Training and Qualification Plan Safeguards Contingency Plan Cyber Security Plan Law Enforcement Response Plan Independent Spent Fuel Storage Facility Security Program Deliberate Acts Emergency Plan Emergency Plan Implementing Procedures.

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