ML20198H459

Forwards Declassified Matl Re Amend 42 to PVNGS Physical Security Plan,Submitted 970318.Encl Submitted in Order to Facilitate Noticing of Requested Amend in Fr

ML20198H459
Person / Time
Site:	Palo Verde
Issue date:	09/09/1997
From:	James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-04009-JML-A, 102-4009-JML-A, NUDOCS 9709180086
Download: ML20198H459 (4)

Text

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Commamaw. mens,ma Luns 10CFR50.90 James M. Levine TEL (602)39M300 Mail Staton 7002 Palo Verde Nuclear Senior V.co President r AX (602)39M077 P O Box $2034 Generating Staton Nuclear Phoenix, AZ 85072-2034 102-04009-JMUAKK/ RAS September 9,1997 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station: P1-37 Washington, DC 20555 0001

Reference:

Letter 102-03901-JMUAKK/ RAS, PVNGS Physical Security Plan, Amendment 42, March 18,1997

Subject:

Palo Verde Nuclear Generating Station (PVNGS) i Units 1,2, and 3 Docket Nos. STN 50 528/529/530 Non Safeguards Enclosure from PVNGS Physical Security Plan, Amendment 42 On March 18,1997, Arizona Public Service Company (APS) submitted a request to the NRC to amend the PVNGS Physical Security Plan (Amendment 42).

In order to facilitate noticing of the requested amendment in the Federal Realster, APS has declassified the "No Significant Hazards Consideration Determination" from the previously submitted amendment request. The declassified materialis attached.

Should you have questions regarJing this submittal, please contact Scott A. Bauer at (602)393 5978.

Sincerely,,

JML/AKK/ RAS /mah (F

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Attachment cc:

E. W. Merschoff K. E. Perkins I

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K. M. Thomas PVNGS Sr. Resident 9709180086 970909 hDR ADOCK 0500 0

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i ATTACHMENT i

"NO SIGNIFICANT HAZARDS CONSIDERATION 4

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PVNGS PHYSICAL SECURITY PLAN AMENDMENT 42 i

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NQJIGNIFICANT HAZARDS CONSIDERATION DEIERMINATIOJ The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with a proposed amendment would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated;

2. Create the possibility of 1 new or different kind of accident from any accident previously evaluated; or

3. Involve a significant reduction in a margin of safety.

A discussion of these standards as they relate to this amendment request follows:

Standard 1: Does the proposed change involve a sign lficant increase in the probability or consequences of an accident previously evaluated?

The proposed changes do not significantly increase the probability or consequences of an accident previously evaluated. The " accident" as it relates to the Security Plan would have to be an impact to the Design Basis Threat (DBT) postulated for PVNGS. This change does not decrease the overall security systems (as described in paragraph's (b) through (h) of 10 CFR 73.55) ability to protect PVNGS with the objective of high assurance against the DBT of radiological sabotage as stated in 73.1 (a). This change does not delete or contradict any regulatory requirements.

The applicable design basis threat is described in 10CFR73.1. Based on that threat, the probability of an external determined violent assault by stealth, or deceptive actions, of several persons is unaffected by the requested changes to the search requirements. Similarly, an internal threat of an insider, including an employee (in any position) is no more likely to occur as a result of the search techniques. The probability of an attack with a four-wheel drive land vehicle bomb is unaffected. Theft or diversion of formula quantities of strategic special nuclear material is a threat of removal from the inside of the protected area, which is not within the scope of this change that only affects searches of material entering the protected area.

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i Standard 2: Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

The possibility of an accident of a new or different kind has not been created because the DBT (as described in the Security Plan and 10CFR73.1) would not be changed as a result of these changes. The changes supplement regulatory -

i requirements and commitments already described in the PVNGS Physical Security Plan.

Standard 3: Does the proposed change involve a significant reduction in a margin of safety?

The proposed changes do not involve a significant reduction in a margin of safety.

These changes to the personnel, material and package search criteria are not specifically considered in the basis for any margin of safety. The DBT considers inside assistance by a knowledgeable individual, however, these changes would not assist this individual in either sabotage or theft of nuclear material.

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