ML19347F291
| ML19347F291 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 05/05/1981 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Stoltz T Office of Nuclear Reactor Regulation |
| References | |
| TAC-43702, NUDOCS 8105180271 | |
| Download: ML19347F291 (2) | |
Text
s j SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, Box 1s830, sacramento, Califomia 95813; (916) 452-3211 p
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_ ' 4;l k %w' y,G 1991 DIRECTOR OF NUCLEAR REACTOR REGULATION 6
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J ATTENTION: JOHN STOLTZ, CHIEF Wir y
US NUCLEAR REGULATORY COMMISSION
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,3 C0CKET 50-312, RANCl!0 SEC0 NUCl. EAR GENERATING STATION, UNIT 1 We have received Federal Register, Vol. 46, No.12, dated Monday, January 19, 1981, Rules and Regulations. This amendment lists 10 CFR 73.71 (c) which has an effective date of April 6, 1981.
The introductory sentence of 73.71 (c) states, "Each licensee under either a specific or general license shall..." We have discussed 73.71 (c) with our licensing engineer and we have been Informed that Rancho Seco Nuclear Generating Power Plant has a Class 3 license for commercial and industrial facilities. We cannot determine if 73.71 (c) applies to Rancho Seco.
Additionally, we are unsure if the District should commit to Regulatory Guide 5.62, " Reporting of Physical Security Events", because of the previously noted concern.
A second concern with Regulatory Guide 5.62, dated February 1981, is the apparent contradiction between two sections. Sectiot. B, " Loss of Physical Security Effectiveness", subsection 3, paragraph 2, states that a major loss of security effectiveness that has been properly compensated for, is considered a moderate event and must be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
%ction 1 on the same page (5.62-2), "A Moderate loss of Physical Secucity Effective-ness", in part defines a moderate loss of physical secuni.y effectiveness as any event listed under a major loss of phy! al security effect.veness, f
that has been procerly compensated for in a timely manner and needs only to be logged in iicensee's recceds.
(Re: Table 1, page 5.62-3).
It is unclear how to handle a loss of security effectiveness in view of the contradictions mentioned above.
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i John Stoltz
~ May 5, 1981 It has been our interpretation that safeguard procedural violations without malicious intent need only to tue logged in the licensee's records. For example, an individual enters a vital area in which he had been recenti; authorized to enter, but who's authorization had been terminated without his knowledge.
Because of the centradictions mentioned, the District would like your office to confirm our interpretation of reporting times for safeguard procedural' violations without malicious intent.
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ktb John J. Mattimoe Assistant General Manager and Chief Engineer cc:
R.H. Engelken, Director Region V, Office of Inspection and Enforcement US Nuclear Regulatory Coie::assion Walnut Creek Plaza, Iuite 202 1900 North California Blvd.
Walnut Crsss, CA 94596
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