ML20138K072

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Comment Opposing Proposed Rule 10CFR73 Re Physical Protection of Plants & Matls
ML20138K072
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 05/02/1997
From: Medling E
SOUTHERN CALIFORNIA EDISON CO.
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR7721, RULE-PR-73 62FR7721-00004, 62FR7721-4, NUDOCS 9705120121
Download: ML20138K072 (2)


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w ffS DOCMETED USNRC Southem Califomia Edison Company 7/ MAY -8 AU :58 BAN CLEMENTE, CALIFORNIA 92674-0128 0FFICE OF SECRETARYm,,m~.

May 2, 1997 00CKETlHG & SERVICE-~=

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BRANCH

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l Secretary, U.S. Nuclear Regulatory Commission DOCKET MBER Attn: Docketing and Service Branch PROPOSED RULE $ M (M F# pgG Washington, D.C.

20555-0001

Subject:

Southern California Edison (Edison) Comments on Proposed Changes to 10 CFR Part 73, ' Physical Protection of Plants and Materials,"

(62 Fed. Reg. 34, pg. 7721-7725, February 20,1997)

Gentlemen:

In the subject Federal Register Notice, NRC solicited comments on proposed rulemaking regarding nuclear power plants physical security requirements.

These changes were identified by NRC as marginal to safety, redundant, or no longer effective, and as reducing the regulatory burden on licensees without compromising physical protection.

This proposed rule would eliminate the requirement for escort of licensee-owned vehicles entering the protected area (PA) for work-related purposes provided that these vehicles are driven by licensee employees who a unescorted access.

At San Onofre Nuclear Generating Station (SONGS), ar.d many other nuclear power plants, most vehicles entering the PA are driven by contract employees who undergo the same security screening as licensee employees.

Consequently, the proposed change, as written, would not provide the reduction in regulatory burden intended by the proposed change.

Edison recommends that the last sentence of 10CFR73.55(d)(4) be revised as follows:

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" Escort is not required for licensee-owned vehicles entering the

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protected area driven by site workers having unescorted access."

Since contract employees are subjected to the same security requirements as regular employees, this change would not cause any reduction in security effectiveness as compared to the original proposed change.

120007 g51 121 970502 73 62FR7721 ppg D5/0

-O Docketing ar.d Service Branch t i'

Should you have any questions, please contact Marty Speer at 714-368-6251.

i Sincerely, I

a cc:

E. W. Merschoff, Regional Administrator, NRC Region IV K. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 j

M. K. Webb, NRC Project Manager, San Onofre Unit 1 L. C. Carson, Regional Project Inspector, San Onofre Unit 1

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,S. S. Bajwa, Section Chief, Decommissioning Section l

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