ML20070E467

Comment Opposing Petition for Rulemaking PRM-73-9 Re Upgrading Design Basis Threat for Radiological Sabotage of Nuclear Reactors.Recommends That NRC Deny Petition to Increase Design Basis Threat for Security

ML20070E467
Person / Time
Site:	Midland
Issue date:	02/26/1991
From:	Vanhoof E CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-56FR3228, RULE-PRM-73-9 56FR3228-00022, 56FR3228-22, ERV-91-22, NUDOCS 9103060014
Download: ML20070E467 (2)

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'91 11AR -4 P 3 S teuw cua POWERING sarm s~n MKN0GAN'S PROGRESS cennt onicu: 1945 West Patnall Road. Jackson. Mi 49201 517) 769 1 45; February 26, 1991 ERV 91-22 Mr Samuel J Chilk Secretary Att: Docketing and Service Branch US Nuclear Regulatory Commission Washington, DC 205S5-RE: NUCLEAR CONTROL INSTITUTE AND THE COMMITTEE TO BRIDGE THE GAP:

PETITION FOR RULEMAKING - UPGRADING THE DESIGN BASIS THREAT FOR RADIOLOGICAL SAB0TAGE OF NUCLEAR REACTORS (56 FED RfC 3228 --JANUARY 29,1991)

REQUEST FOR COMMENTS

Dear Mr Chilk:

Consumers Power Company has reviewed comments made by NUMARC concerning the Petition for Rulemaking to Upgrade the Design Basis Threat for Radiciogical Sabotage of Nuclear Reactors and concurs with these comments.

In particular, the Company has maintained close contact with local law enforrament agencies near its two nuclear power plants and has practiced' quick response to a threat of physical sabotage with backup from these agencies.

In addition to local

-law enforcement agencies, the Company has = drilled with State and Federal agencies for-rapid backup to any physical threat of sabotage.

'The defense-in-depth philosophy used so effectively in providing safety in nuclear plant operations is also used against physical sabotage threats.

The protection of vital equipment is inherent _in nuclear plant design.

Hardened concrete structures provide this protection which is backed up by security-

systems of fences, lights, cameras and warning systems.

In addition, physical bar_riers both natural: and man-made emplaccalents-protect approaches to the plants.

9103060014 910226 PDR PHM 73-9 PDR A C%tS ENERGYCOMPANY 0

l The Big Rock Nuclear Plant has operated for close to 30 years and Palisades for nearly 20 years with no threats of physical sabotage.

Available intelligente does not substantiate the development of a physical sabotage threat in the future as proposed by the petitioner even considering the Middle East situation.

In vtew of the above, it is recommended that the NRC deny the petition to increase the design basis threat for security.

Respectflilly,

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