ML20205M455

Forwards Rev to Physical Security Plan.Use of Adpro Device Will Be Accompanied by Security Force Member Direct Observation of Zones Until Performance Study Rept Completed & Evaluated.Rev Withheld (Ref 10CFR2.790 & 73.21)

ML20205M455
Person / Time
Site:	Limerick
Issue date:	10/31/1988
From:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8811030099
Download: ML20205M455 (4)

Text

i I PHILADELPHI A ELECTRIC COM PANY 2301 MARKET STREET P.O. BOX 8699 PHILADELFMI A. PA 19101 (215) sas soo

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......m October 31, 1988 Docket Nos. 50-352 50-353 Mr. W. T. Russell, Administrator Region I U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Dear Mr. Russell:

Enclosed are an original and three copies of a Revision to the Physical Security Plan for Limerick Generating Station consisting of page changes dated October, 1988 and a Summary of Plan Revisions. The revisions to the Plan include changes made in response to comments received from the NRC ir, a letter dated August 4, 1988 from R. R. Bellamy, Chief Facilities Radiological Safety and Safeguards Braauh. The revisions also reflect the insettion of changes to the Plan proposed in December, 1987 which were approved by the NRC in a letter dated August 3, 1988 from Richard J. Clark, Project Manager. The December, 1987 proposed revisions included a proposed impler.1ntation schedule. The enclosed revisions includ2 an implementation schedule which reflects the effective date of the license amendment which approved the proposed revisions.

An extension of the due date for this submittal was granted by E. D. Sylvester on September 8, 1988. The enclosed changes to the Physical Security Plan will not decrease the safeguards effectiveness of the Plan.

Please note that the use of the Adpro device discut on page 3-4 will be accompar.ied by a security force member's direct observation of the zones until the performance study report has been completed and evaluated. A copy of the report will be provided to the NRC. Additionally, it must be recognized that records retention commitments made relative to the recently 3CCf 7bh~ lY G811030099 esto33

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Mr. W. T. Russell, Administraf or October 31, 1988 Region I Page 2 of 2 revised 10 CFR 73.55 and 73.70 (53 Fed. Reg. 19240), which became effective as of July 26, 1988, will be implemented as follows:

1) In cases where previous commitments in the Plan were Jess than those required by the new regulation, the records will be accumulated beginning July 26, 1988.

Therefore, if the previous commitment only required one year of the records retention and the new regulation requires three years, the newly required three years of documentation will be available for audit as of July 26, 1990;

2) In cases where previous commitments were equal to or ,

greater than those required by the new regulation, the required documentation will be available for audit immediately.

_In accordance with 10 CFR 2.790 and 10 CFR 73.21 of the Commissi'on3.9 regulations, it is hereby requested that the enclosed revisiorr. to the Plan be withheld f rom public disclosure. An affidavit which supports this request for nondisclosure is attached.

Very truly yours, Enclosures cc: Addressee (2 Copies)

COH ONWEALTH OF PENNS)1VANIA  :

ss.

COUN1Y 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 License NPF-39 for Limerick Unit 1 and is authorized to execute this affidavit; 2.- ik has reviewed the revisions to the Physical Security Plan dated October, 1988, and the Summary thereof (heroinafter the "Revision") aad knows the contents thereof. The Revision will not reduce the safeguards effectiveness ci the Plan;

3. The Revision which is sought to La withheld from public disclosure contains aetails relating to the Physical Security Plan for Limerick Station;

! 4. The 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 conf 1 der.tial and

. proprietary information, and; i

It Page 2

5. The Revision should be c nsidered by the NRC as confidential and proprietary information and-be withheld from public. disclosure on the grounds that it contains Safeguards Infomation, it contains details relating to the physical security plans of a licensed facility, it contains detailed infomation which could be used to compromise the safety and security of the facility, such disclosure is not required in the public interest and such disclosure would adversely affect the interests of Philadelphia Electric Company.

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u Vice Presi3bnt Subscribed and sworn to before me this Snr day of Oer- 1988.

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