ML24022A149
| ML24022A149 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/17/2024 |
| From: | Morgan M Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML24022A149 (16) | |
Text
An EDISON INTERNATIONAL Company SAFEGUARDS INFORMATION January 17, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Docket Nos. 50-206, 50-361, 50-362 and 72-41 Revision 4 to the Physical Security Plan Mark Morgan Manager Nuclear Regulatory Affairs 10 CFR 50.54(p)
San Onofre Nuclear Generating Station, Units 2 and 3, and Independent Spent Fuel Storage Installation
Dear Sir or Madam:
Southern California Edison (SCE) has made changes to the Physical Security Plan (PSP), for San Onofre Nuclear Generating Station (SONGS) that SCE has determined do not decrease the safeguards effectiveness of this plan.
On November 27, 2023, SCE issued Revision 4 to the [ISFSI-Only] Physical Security Plan (PSP), Training and Qualification Plan (T&Q) and Safeguards Contingency Plan (SCP), collectively referred to as the Security Plan. The changes in Revision 4 are speeific te-the-PSP-and do not impact the T&Q or SCP. -SCE-has-determined that the changes in Revision 4 to the Security Plan do not decrease the safeguards effectiveness ofthe~PSP. In accordance with 10 CFR 50.54(p)(2); a copy of the 50.54(p) evaluation of these changes is provided as Enclosure 1 for your information. contains a line-in/line-out copy of Section 3.2, Section 22.1.3, and Appendix A (affected pages only).. Enclosure 3 contains a clean copy of Section 3.2, Section 22.1.3, and Appendix A (affected pages only). Enclosure 4 contains a complete copy of the new Rev1s1on 4 of the S-ONGS Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan.
There are no new regulatory commitments made by this letter or its enclo_sures.
Note that Enclosures* 2, 3 & 4 to this letter contain Safeguards Information. This letter a "7 I_
may be decontrolled upon separation from its enclosures.
- J Ajj J l-Y
- :,
SAFEGUARDS INFORMATION Note: Enclosures 2, 3 & 4 to this letter contains "SAFEGUARDS INFORMATION."
-:--""Tms letter may be "Decontrolled" upon separatiori*trcimEhclosures 2, 3 & 4.
If you have any questions regarding this matter, please contact me at (949) 368-627 4.
Sincerely, Enclosures
- 1. Screening Criteria - Security Licensing Documents
- 2. Physical Security Plan Changed Pages, Line-in/Line-out Version for Section 3.2, Section 22.1.3, and Appendix A (SGI)
- 3. Physical Security Plan Changed Pages, Clean Version for Section 3.2, Section 22.1.3, and Appendix A (SGI)
- 4. SONGS Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan, Revision 4 (SGI) cc:
R. Kellar, NRC Region IV, Branch Chief, Plant Support Branch Note: Enclosures 2, 3 & 4 to this letter contains "SAFEGUARDS INFORMATION."
This letter may be "Decontrolled" upon separation from Enclosures 2, 3 & 4.
ENCLOSURE 1 SCREENING CRITERIA-SECURITY LICENSING DOCUMENTS Assessment of Acceptability of 10 CFR 50.54(p)
Physical Security Plan Changes, Revision 4 Page 1 of 14 ENCLOSURE 1 DOES NOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERATION ENCLUSURES 2, 3 & 4 CONTAIN SGI AND MUST BE PROTECTED ACCORDINGLY
50.54(p) Report for PSP, Revision 4, Section 3.2, Preemption Authority SECTION / TITLE Physical Security Plan (PSP), Revision 4, Section 3.2, Preemption Authority PROPOSED COMMITMENT:
- The PSP, Section 3.2, Preemption Authority, has been updated to remove the reference to NRC Order EA-13-092. Text describing measures for meeting the requirements of Order EA-13-092,
-"Issuance of Order Designating an Interim Class of NRC Licensed Facilities That are Eligible to Apply to the Commission for Authorization to use the Authority Granted Under the Provisions of Section 161A of the Atomic Energy Act of 1954," has also been updated (deleted). This update was an administrative change to align the PSP with the requirements of 10 CFR 73.15 and 10 CFR 73.17. The requirements reflected in the deleted text for meeting the requirements of the Order (and 73.15 / 73: 17) remain in place and are described in Station procedures.
A copy of the Line-in/Line-out changes that shows deleted text and new text is provided in.
IMPACT ON EFFECTIVENESS OF A GENERIC PLAN:
- 1. o Yes I No
- 2. Yes I No Does this change delete or contradict any regulatory requirement?
Rationale: A review of the changes in the PSP, Section 3.2, against the requirements contained in 1 O CFR 73.55 was conducted to determine if the PSP would still meet the associated regulatory requirements if the changes were implemented. The review determined that the proposed changes to the SONGS Security Plan, which includes the Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan, continue to meet the requirements of 10 CFR 73.55.
See Attachment 1, Table 1, for additional details.
Would the change decrease the level of Security system performance as described in paragraphs (a) through (r), of 1 O CFR 73.55 to protect with the objective of high assurance against the applicable design basis threat of radiological sabotage as stated in 10 CFR 73.1 (a)?
Rationale: This update was an administrative change to align the PSP with the requirements of 10 CFR 73.15 and 73.17. A review of the changes in the PSP, Section 3.2, against the performance r:equirements of paragraphs (a) through (r) of 10 CFR 73.55 was conducted to ensure the changes would continue to provide a high assurance against the applicable design basis threat of radiological sabotage as stated in 1 O CFR 73.1 (a). No decrease in the level of Security system performance was identified during the review of paragraphs (a) through (r) of 73.55.
See Attachment 1, Table 1, for additional details.
Page 2 of14 ENCLOSURE 1 DOES NOT CONTAIN SGI AND 15 "DECONTROLLED" UPON SEPERATION ENCLUSURES 2, 3 & 4 CONTAIN SGI AND MUST BE PROTECTED ACCORDINGLY
50.54(p) Report for PSP, Revision 4, Section 3.2, Preemption Authority
- 3. Yes I No D NIA The change described in Section 3.2 of the PSP does not result in a reduction of SONGS capability to detect and assess threats up to and including the design basis threat of radiological sabotage or make appropriate notifications to the Local Law Enforcement Agency (LLEA).
This change does not address any committed number of Armed Security Officers or the protective strategy. As such, there is no decrease in the effectiveness of the security plan or protective* strategy as a result of this change. The security plan continues to provide high assurance through the effective implementation of the site protective strategy.
An assessment of Security documents and other licensee documents impacted by this change was conducted. This change impacts the PSP, Section 3.2. No impact to the T&Q, SCP or other licensee documents was identified. Editorial updates to some Station procedures to remove references to NRC Order EA-13-092 and replaced with references to 1 O CFR 73.15 and 7~.17 was required to align with this change.
Procedures updated include:
SEC-26, Personnel Screening Programs for Unescorted Access, Safeguards Information Access, Preemption Authority, and.
Quantities of Radioactive Material For any licensee that has NRG-approved Security Plan commitments as alternatives to one or more of the requirements of 10 CFR 73.55 (Alternative Measures): Does this change decrease the level of Security system performance needed to protect with the objective of high assurance against the design basis threat of radiological sabotage as stated in 1 O CFR 73.1 (a)?
Rationale: The SONGS [ISFSI Only] Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan, Revision 0, was approved in accordance with 10 CFR 50.90 and includes NRG-approved Alternative Measures. This change does not impact or change an NRG-approved Alternative Measure._
Page 3 of 14 ENCLOSURE 1 DOES NOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERATION ENCLUSURES 2, 3 & 4 CONTAIN SGI AND MUST BE PROTECTED ACCORDINGLY
50.54(p) Report for PSP, Revision 4, Section 22.1.3, Temporary Suspension of Security Measures - Reporting SECTION / TITLE Physical Security Plan (PSP), Revision 4, Section 22.1.3, Temporary Suspension of Security Measures - Reporting PROPOSED COMMITMENT:
The PSP, Section 22.1.3, Temporary Suspension of Security Measures - Reporting, has been updated. The change reflects a minor editorial update to replace references to 10 CFR 73.71 with 10 CFR 73.1200.
A copy of the Line-in/Line-out changes that shows the deleted text and new text is provided in.
IMPACT ON EFFECTIVENESS OF A GENERIC PLAN:
. 1. D Yes I No
- 2. D Yes I No Does this change delete or contradict any regulatory requirement?
Rationale: A review of the chc1nges in the PSP, Section 22.1.3, against the requirements contained in 1 O CFR 73.55 was conducted to determine if the PSP would still meet the associated regulatory requirements if the changes were implemented. The review determined that the proposed changes to the SONGS Security Plan, which includes the Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan, continue to meet the requirements of 1 O CFR 73.55.
See Attachment 1, Table 2 for additional details.
Would the change decrease the level of Security system performance as described in paragraphs (a) through (r), of 1 O CFR 73.55 to protect with the objective of high assurance against the applicable design basis threat of radiological sabotage as stated in 1 O CFR73.1 (a)?
Rationale: This update was an administrative change to align the PSP with new CFR requirements reflected in 10 CFR 73.1200. A review of the changes in the PSP, Section 22.1.3, against the performance requirements of paragraphs (a) through (r) of 10 CFR 73.55 was conducted to ensure the changes would continue to provide a high assurance against the applicable design basis threat of radiological sabotage as stated in 10 CFR 73.1 (a). No decrease in the level of Security system performance was identified during the review of paragraphs (a) 'through (r) of 73.55. See Attachment 1, Table 2, for additional details.
The change described in Section 22.1.3 of the PSP does not result in a reduction of SONGS capability to detect and assess threats up to and including the design basis threat of radiological sabotage or make appropriate notifications to the Local Law Enforcement Agency (LLEA).
This change does not address any committed number of Armed Security Officers or the protective strategy. As such, there is no decrease in the effectiveness of the security plan or protective strategy as a result of this change. The security plan continues to provide high assurance through the effective implementation of the site protective strategy.
Page 4 of 14 ENCLOSURE 1 DOES NOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERATION ENCLUSURES 2, 3 & 4 CONTAIN SGI AND MUST BE PROTECTED ACCORDINGLY
50.54(p) Report for PSP, Revision 4, Section 22.1.3, Temporary Suspension of Security Measures - Reporting
- 3. Yes I No D N/A An assessment of Security documents and other licensee documents impacted by this change was conducted. This change impacts the PSP, Section 22.1.3. No impact to the T&Q, SCP or other licensee documents was identified. Editorial updates to som*e Station procedures to remove
- references to 10 CFR 73.71 (and Appendix G) and replace with references to 10 CFR 73.1200 was required to align with this change.
Procedures updated include:
SEC-1, Security SEC-15, Notifications, Reporting and Loggable Events For any licensee that has NRG-approved Security Plan commitments as alternatives to one or more of the requirements of 10 CFR 73.55 (Alternative Measures): Does this change decrease the level of Security system performance needed to protect with the objective of high assurance against the design basis threat of radiological sabotage as
- stated in 10 CFR 73.1(a)?
Rationale: The SONGS [ISFSI Only] Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan, Revision 0, was approved in accordance with 10 CFR 50.90 and includes NRG-approved Alternative Measures. This change does not impact or change an NRC-approved Alternative Measure.
Page 5 of 14 ENCLOSURE 1 DOES NOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERATION ENCLUSURES 2, 3 & 4 CONTAIN SGI AND MUST BE PROTECTED ACCORDINGLY
50.54(p) Report for PSP, Revision 4, Appendix A, Glossary of Terms*and Acronyms SECTION / TITLE Physical Security Plan (PSP), Revision 4, Appendix A, Glossary of Terms and Acronyms PROPOSED COMMITMENT:
The PSP, Revision 4, Appendix A, Glossary of Terms and Acronyms, has been updated.
The change reflects minor editorial changes to the definitions of Contraband and Discovery (Time Of) [i.e., Time of Discovery], to align with updated definitions in 10 CFR 73.2.
A copy of the Line-in/Line-out changes that shows the deleted text and new text is provided in.
IMPACT ON EFFECTIVENESS OF A GENERIC PLAN:
- 1. D Yes If No
- 2. D Yes If No Does this change delete or contradict any regulatory requirement?
Rationale: A review of the changes in the PSP, Appendix A, against the requirements contained in 10 CFR 73.55 was conducted to determine if the PSP would still meet the associated regulatory requirements if the changes were.implemented. The review determined that the proposed changes to the SONGS Security Plan, which includes the Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan, continue to meet the requirements of 1 O CFR 73.55.
_See Attachment 1, Table 3 for additional details.
Would the change decrease the level of Security system performance as described in paragraphs (a) through (r}, of 10 CFR 73.55 to protect with the objective of high assurance against the applicable design basis threat of radiological sabotage as stated in 10 CFR 73.1 (a)?
Rationale: This update was an editorial change to align the PSP with new CFR definitions for Contraband and Discovery (Time Of) [i.e., Time of Discovery] reflected in 10 CFR 73.2. A review of the changes in the PSP, Appendix A, against the performance requirements of paragraphs (a) through (r) of 10 CFR 73.55 was conducted to ensure the changes would continue to provide a high assurance against the ap*plicable design basis threat of radiological sabotage as stated in 1 O CFR 73.1 (a). No decrease in the level of Security system performance was identified during the review of paragraphs (a) through (r) of 73.55. See Attachment 1, Table 3, for additional details.
The change described in Appendix A of the PSP does not result in a reduction of SONGS capability to detect and assess threats up to and including the design basis threat of radiological sabotage or make appropriate notifications to the Local Law Enforcement Agency (LLEA).
This change does not address any committed number of Armed Security Officers or the protective strategy. As such, there is no decrease in the effectiveness of the security plan or protective strategy as a result of this change. The security plan continues to provide high assurance through the effective implementation of the site protective strategy.
Page 6 of 14 ENCLOSURE 1 DOES NOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERATION ENCLUSURES 2, 3 & 4 CONTAIN SGI AND MUST BE PROTECTED ACCORDINGLY
50.54(p) Report for PSP, Revision 4, Appendix A, Glossary of Terms and Acronyms
- 3. : Yes I No NIA An assessment of Security documents and other licensee documents impacted by this change was conducted. This change impacts Appendix
. A of the PSP. No impact to the T&Q, SCP or other licensee documents
- was identified. Editorial updates to some Station procedures to align with the updated definitions were required to implement this change.
Procedures updated include: _
SEC-4, Searches (Vehicle, Personnel, and Material) Escort and Protected Area Access SEC-15, Notifications, Reporting and Loggable Events Note: Aspects of the Contraband definition that address national security information or classified Restricted Data (RD) are not applicable to SONGS and have been omitted from the SONGS definition.
For any licensee that has NRG-approved Security Plan commitments as alternatives to one or more of the requirements of 1 O CFR 73.55 (Alternative Measures): Does this change decrease the level of Security system performance needed to protect with the objective of high assurance against the design basis threat of radiological sabotage as stated in 10 CFR 73.1 (a)?
Rationale: The SONGS [ISFSI Only] Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan, Revision 0, was approved in accordance with 10 CFR 50.90 and includes NRC'-approved Alternative Measures. This change does not impact or change an NRC-approved Alternative Measure.
Page 7 of14 ENCLOSURE 1 DOES NOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERATION ENCLUSURES 2, 3 & 4 CONTAIN SGI AND MUST BE PROTECTED ACCORDINGLY L
50.54(p) Report for PSP, Revision 4, Conclusion CONCLUSION:
The changes performed under 1 O CFR 50.54(p) to the SONGS Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan, as described above in Section 3.2, Section 22.1.3, and Appendix A were evaluated to determine if the aggregate effect of the changes resulted in a reduction of SONGS capability to detect and assess threats up to and including the design basis threat of radiological sabotage or make the appropriate notification to LLEA.
The evaluation concluded the changes do not decrease the level of Security system performance needed to protect with the objective of high assurance against the design basis threat of radiological sabotage as stated in 1 O CFR 73.1 (a). The changes to Section 3.2, Section 22.1.3, and Appendix A repr~sent editorial/administrative changes to align the PSP with new CFR guidance and its associated references.
Page 8 of 14 ENCLOSURE 1 DOES NOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERATION ENCLUSURES 2, 3 & 4 CONTAIN SGI AND MUST BE PROTECTED ACCORDINGLY
50.54(p) Report for PSP, Revision 4, Attachment 1, Table 1 - Table 1: 10 CFR 73.55 Paragraphs (a) Through (r), PSP Section 3.2, Preemption Authority Note: 73.55 paragraphs impacted are highlighted in Green.
Results: No impacts identified. The changes to Section 3.2, Preemption Authority, are not associated with the requirements of 10 CFR 73.55.
Introduction Results: No impact identified. SONGS continues to maintain compliance with 73.55(a).
General Performance Objectives and Requirements Results: No impact identified. SONGS continues to maintain compliance with 73.55(b).
Security Plan Results: No impact identified. SONGS continues to maintain compliance with 73.55(c).
Security Organization Results: No impact identified. SONGS continues to maintain compliance with 73.55(d).
Physical Barriers Results: No impact identified. SONGS continues to maintain compliance with 73.55(e).
Target Sets (N/A)
SONGS ISFSI does not contain target sets.
Access Controls Results: No impact identified. SONGS continues to maintain compliance with 73.55(g).
Search Programs Results: No impact identified. SONGS continues to maintain compliance with 73.55(h).
Detection and Assessment Systems Results: No impact identified. SONGS continues to maintain compliance with 73.55(i).
Communication Requirements Results: No impact identified. SONGS continues to maintain compliance with 73.550).
Response Requirements Results: No impact identified. SONGS continues to maintain compliance with 73.55(k).
MOX Facilities (N/A SONGS ISFSI does not contain MOX fuel.
Page 9 of 14 ENCLOSURE 1 DOES NOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERATION ENCLUSURES 2, 3 & 4 CONTAIN SGI AND MUST BE PROTECTED ACCORDINGLY
50.54(p) Report for PSP, Revision 4, Attachment 1, Table 1 10 CFR 73.55(m)
Security Program Reviews Results: No impact identified. SONGS continues to maintain compliance with 73.55(m).
Maintenance, Testing and Calibration Results: No impact identified. SONGS continues to maintain compliance with 73.55(n).
Compensatory Measures
.Results: No impact identified. SONGS continues to maintain compliance with 73.55(0).
Suspension of Security Measures Results: No impact identified. SONGS continues to maintain compliance with 73.55(p).
Records Results: No impact identified. SONGS continues to maintain compliance with 73.55(q).
Alternative Measures Results: No impact identified. SONGS continues to maintain compliance with 73.55(r).
Page 10 of 14 ENCLOSURE 1 DOES NOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERATION ENCLUSURES 2, 3 & 4 CONTAIN SGI AND MUST BE PROTECTED ACCORDINGLY
50.54(p) Report for PSP, Revision 4, Attachment 1, Table 2 -Table 2: 10 CFR 73.55 Paragraphs (a) Through (r), PSP Section 22.1.3, Temporary Suspension of Security Measures - Reporting Note: 73.55 paragraphs impacted are highlighted in Green.
Results: Editorial impacts identified. The changes to Section 22.1.3, Temporary Suspension of Security Measures - Reporting, are associated with the requirements of 10 CFR 73.55(p).
Introduction Results: No impact identified. SONGS continues to maintain compliance with 73.55(a) 10 CFR 73.55(b)
General Performance Objectives and Requirements Results: No impact identified. SONGS continues to maintain compliance with 73.55(b).
Security Plan Results: No impact identified. SONGS continues to maintain compliance with 73.55(c).
Security Organization Results: No impact identified. SONGS continues to maintain compliance with 73.55(d).
Physical Barriers Results: No impact identified. SONGS continues to maintain compliance with 73.55(e).
Target Sets (N/A)
SONGS ISFSI does not contain target sets.
Access Controls Results: No impact identified. SONGS continues to maintain compliance with 73.55(9).
- Search Programs Results: No impact identified. SONGS continues to maintain compliance with 73.55(h).
Detection and Assessment Systems Results: No impact identified. SONGS continues to maintain compliance with 73.55(i).
Communication Requirements Results: No impact identified. SONGS continues to maintain compliance with 73.550).
Response Requirements Results: No impact identified. SONGS continues to maintain compliance with 73.55(k).
MOX Facilities (N/A SONGS ISFSI does not contain MOX fuel.
Page 11 of 14 ENCLOSURE 1 DOES NOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERA TION ENCLUSURES 2, 3 & 4 CONTAIN SGI AND MUST BE PROTECTED ACCORDINGLY
50.54(p) Report for PSP, Revision 4, Attachment 1, Table 2 10 CFR 73.55(m)
Security Program Reviews Results: No impact identified. SONGS continues to maintain compliance with 73.55(m).
Maintenance, Testing and Calibration Results: No impact identified. SONGS continues to maintain compliance with 73.55(n).
Compensatory Measures Results: No impact identified. SONGS continues to maintain compliance with 73.55(0).
10 CFR 73:55(p)
Suspension of Security Measures Resuits: The changes represent minor editorial updates to CFR references within the PSP, Section 22.1.3, to align with 10 CFR 73.1200. SONGS continues to maintain compliance with 73.55(p).
Records Results: No impact identified. SONGS continues to maintain compliance with 73.55(q).
Alternative Measures Results: No impact identified. SONGS continues to maintain compliance with 73.55(r).
Page 12 of 14 ENCLOSURE 1 DOES NIOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERATION ENCllJSURES-"2;~3 & 4 CONTAIN SGI AND MUST BE PROTIECTED~CCORDINGLY
50.54(p) Report for PSP, Revision 4, Attachment 1, Table 3 - Table 3: 10 CFR 73.55 Paragraphs (a) Through (r), PSP Appendix A, Glossary of Terms and Acronyms Note: 73.55 paragraphs impacted are highlighted in Green.
Results: Editorial impacts identified. The updates to Appendix A do not directly impact requirements stated in 10 CFR 73.55. Requirements for the handling and discovery of Contraband are associated with the requirements of 10 CFR 73.55(9).
10 CFR 73.55(a) 10.CFR 73.55(b) 10 CFR 73.55(c) 10 CFR 73.55(d) 10 CFR 73.55(e) 10 CFR 73.55(f) 10 CFR 73.55(g)
Introduction Results: No impact identified. SONGS continues to maintain compliance with 73.55{a)
General Performance Objectives and Requirements Results: No impact identified. SONGS continues to maintain compliance with 73.55(b).
Security Plan Results: No impact identified. SONGS continues to maintain compliance with 73.55(c).
Security Organization Results: No impact identified. SONGS continues to maintain compliance with 73.55(d).
Physical Barriers Results: No impact identified. SONGS continues to maintain compliance with 73.55{e).
Target Sets (N/A)
SONGS ISFSI does not contain target sets.
Access Controls Results: The definition of Contraband, as defined in Appendix A, has been updated tb align with 10 CFR 73.2. The change in definition includes disease causing agents as an example of other dangerous materials. This change has been accounted for in Station procedures as
-applicable:-There are no adverse-impacts-as a result of this' change and S0NGS*continues to maintain compliance with 73.55(g).
10 CFIR. 73.55(11)
- Search*Programs Results: No impact identified. SONGS continues to maintain compliance with 73.55{h).
Detection and Assessment Systems Results:-:No impact identified. SONGS continues to maintain compliance with 73,55(i).
Communication Requirements Results: No impact identified. SONGS continues to maintain compliance with 73.550).
. Page 13 of 14 ENCLOSURE 1 DOES NOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERATION
~NClUSURES 2, 3 & 4 CONTAIN SGI AND MUST BE PROTECTED AeCORDINGL Y
50.54{p) Report for PSP, Revision 4, Attachment 1, Table 3 10 CFR 73.55(k)
Response Requirements Results: No impact identified. SONGS continues to maintain compliance with 73.55(k).
MOX Facilities (N/A SONGS ISFSI does not contain MOX fuel.
Security Program Reviews Results: No impact identified. SONGS continues to maintain compliance with 73.55(m).
Maintenance, Testing and Calibration Results: No impact identified. SONGS continues to maintain compliance with 73.55(n).
Compensatory Measures Results: No impact identified. SONGS continues to maintain compliance with 73.55(0).
Suspension of Security Measures Results: No impact identified. SONGS continues to maintain compliance with 73.55(p).
Records Results: No impact identified. SONGS continues to maintain compliance with 73.55(q).
Alternative Measures Results: No impact identified. SONGS continues to maintain compliance with 73.55(r).
ENCLOSURE 1 DOES NOT CONTAIN SGI AND IS "DECONTROLLED" UPON SEPERATION
'ENCtUSURES 2, 3 & 4 CONTAIN SGI AND MUST J3E'PROTECTED ACCORDINGLY