ML20235U560

Advises That Oct 1988 Rev to Plant Physical Security Plan Consistent W/Provisions of 10CFR50.54(p) & Acceptable Pending Mod of Section 11.5 Re Definition of Annual. Feb 1989 Rev to Be Resubmitted to Rectify Problem Areas

ML20235U560
Person / Time
Site:	Limerick
Issue date:	02/27/1989
From:	Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8903090261
Download: ML20235U560 (4)

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E REOloNI 418 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406 FEB 2 7.1989' Docket No. 50-352/50-353 Philadelphia Electric Company ATTN: Mr. C..A. McNeill Executive Vice President-Nuclear 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:

This is in response to your letters of July 29 and October 31, 1988, regarding changes to the Limerick Generating Station Physical Security Plan, identified as the February 1989 Revision.and the October 1988 Revision, respectively.

The February 1989 Revision contains your plan changes for integrating Unit 2 into the Limerick security program as an operating unit. The October 1988

. Revision incorporates the NRC-approved changes necessitated by the L.

- Miscellaneous Amendments, and other, minor administrative. changes.

We have reviewed the changes contained in the October 1988 Revision and have determined that all but.one change is consistent with the provisions of 10 CFR 50.54(p) and, therefore, considered acceptable.

The unacceptable change invdives.the definition of " annual" in Section 11.5.of the plan.

This change would permit security. program audits and guard force requalifications to be extended to as much as 13 months. This is contrary to 10 CFR 73.55 which requires audits and requalifications at a frequency not to exceed 12 months.

This change should be modified to be consistent with the requirements of 10 CFR 73.55 and a corrected page should be submitted to this office within 30 days of

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receipt of this letter.

l We have also reviewed the changes in the February 1989 Revision and have determined that, because this revision was developed prior to the October 1988 Revision, certain inconsistencies and ambiguities exist between the two revisions which require resolution before the February 1989 Revision can be accepted. Those changes were discussed with Mr. P. Supplee of your staff who stated that the identified problem areas would be rectified and that the revision would be resubmitted.

The enclosures to your letters are being withheld from public disclosure since they contain Safeguards Information which must be protected in accordance with 10 CFR 73.21.

E. D. Sylvester (215-337-5308) is our contact should there by any questions concerning these matters.

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4 Philadelphia Electric Company 2

The response directed by this letter is not subject to the clearance pro-cedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

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- Ronald R. Bellamy, C ief Far.ilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards cc:

See Next Page 0

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i Philadelphia Electric' Company 3

cc:

Troy B. Conner, Jr., Esquire Mr. Robert Gramm Conner and Wetterhahn Senior Resident Inspector 1747 Pennsylvania Ave., N.W.

U.S Nuclear Regulatory Commission Washington, D. C.

20006 P. O. Box 596 Pottstown, Pennsylvania 19464 Mr. Charles Mengers S7-1 Philadelphia Electric Company Mr. Ted Ullrich 2301 Market Street Manager - Unit 2 Startup Philadelphia, Pennsylvania 19101 Limerick Generating Station P. O. Box A Mr. David Honan N2-1 Sanatoga, Pennsylvania 19464 Philadelphia Electric Company 2301. Market Street Mr. John Doering Philadelphia, Pennsylvania 19101 Superintendent-Operations Limerick Generating Station Mr. Grahm M. Leitch, Vice President P. O. Box A Limerick Generating Station Sanatoga, Pennsylvania 19464 Post Office Box A Sanatoga, Pennsylvania 19464 Thomas Gerusky, Director Bureau of Radiation Protection PA Dept. of Environmental Resources P. O. Box 2063 Harrisburg, Pennsylvania 17120 l

Governor's Office of State Planning and Development ATTN:

Coordinator, Pennsylvania Mr. Thomas Kenny State Clearinghouse Senior Resident Inspector P. O. Box 1323 US Nuclear Regulatory Commission Harrisburg, Pennsylvania 17102.

P. O. Box 596 Pottstown, Pennsylvania 19464 Mr. Philip J. Duca Superintendent-Technical Mr. Joseph W. Gallagher Limerick Generating Station Vice President, Nuclear Services P. O. Box A Philadelphia Electric Company Sanatoga, Pennsylvania 19464 2301 Market Street Philadelphia, Pennsylvania 19101 Mr. John S. Kemper Senior Vice President-Nuclear Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

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Chief, NRR/RSGB Document Control Desk (Official Record Copy) - RID Code RG01, Region I Docket Room (w/ concurrence)

Region I Licensing File (w/ concurrence)

Region I Safeguards Files (with concurrences)

Region I Section Chief DRP-2A

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