ML20196F139

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Forwards Revs to Physical Security Plan.Revs Withheld (Ref 10CFR2.790 & 73.21)
ML20196F139
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 12/08/1988
From: Gallagher J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Russell W
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8812120206
Download: ML20196F139 (4)


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c cU tbs-13, o1l PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A, PA 19101 (ass) sai soot

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December 8, 1988 Docket Nos. 50-277 50-278 Mr. W. T.

Russell, Administrator Region I U.S. Nuclear Regulatory Commission ATTN: Document Control DJsk Washington, DC 20555

Reference:

August 25, 1988 letter, R. E. Martin (NRC) to William M. Alden (PECo)

Dear Mr. Russell:

This letter transmita to the NRC Document Control Desk, in accordance with 10 CPR 50.54(p)(1), an orig)nal and three copies of a Revision to the Physical Security Plan for Peach Bottom Atomic Power Station consisting of page changes dated December 1988 and a Summary of Plan Revisions.

The Revisions to the Plan reflect the insertion of changes to the Plan proposed in December, 1987 which wera approved by the NRC as documented in the referenced letter.

The revisions include an implementation schedule which conforms to the schedule proposed in December 1987.

The revised Plan also includes changes to conform records retention requirements with current regulations, and other changes as detailed in the Summary of Plan Revisions.

These changes have been discussed with E. D.

Sylvester of your staff.

In a related matter, we wo'ald like to point out that records retention commitments made pursuant to the recently revised 10 CPR 73.55 and 73.70 (53 Ped. Reg. 19240), which became effective on July 26, 1988, will be implemented as follows:

1)

In cases where previous commitments in the Plan were for shorter retention periods than those required by 3

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.Mr. W. T. Russell, Administrator December 8, 1988 Region I Page 2 of 2 the new regulation, accumuls'.lon of additional records began on July 26, 1988.

Therefore, if the previous commitment on.1.y required one year of records retention and the new regulation requires three years, three years of documentation will be available for audit on and after July 26, 1990; 2)

In cases where previous commitments were equal to or greater than those required by the new regulation, the required documentation is now available for audit.

In accordance with 10 CPR 2.790 and 10 CFR 73.21 of the Commission's regulations, it is hereby requested that the enclosed revisions to the Plan be withheld from public disclosure.

An affidavit which supports this request for nondisclosure is attached.

Very truly yours, Enclosures cc Addressee (2 Copies)

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COMMONWEALTH OF PENNSYLVANIA ss.

COUNTY OF PHILADELPHIA J. W. Gallagher, being first duly sworn, deposes and states that:

1.

He is Vice President of Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for Peach Botton Atomic Power Station, Units 2 & 3, respectively, and is authorized to execute this affidavit; 2.

He has reviewed the revisions to the Physical Security Plan dated December 1988, and the Summary thereof (hereinafter the "Revision") and knows the contents thereof.

The Revision will not reduce the safeguards effectiveness of the Plan; 3.

The Revision which is sought to be withheld from the public disclosure contains details relating to the Physical Security Plan for Peach Botton Atomic Power Station; 4.

Tho information set forth in the Revision has been treated as confidential and proprietary information and has been withheld from public disclosure by Licensee in accordance with Licensee's practice of treating all information dealing with the details of security plans as confidential and proprietary information, and; e

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The Revision should be considered by the NRC as confidential and proprietary information and be withheld from public disclosure on the grounds that it contains Safegeerds Information, it contains details relating to the phyvical security plaris of a licensed facility, it contains detailed information which could be used to comproniae the safety and security of the facility, such disclosure is not required in the public inte-6 and such disclosure would adversely affect the interests c Philadelphia Electric Company.

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%$0//-4 VVice President Subscribed and sworn to before me this 6" day of December, 1988.

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