ML20003G875
| ML20003G875 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 03/16/1981 |
| From: | Mccorkle G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Dawson D GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8105040093 | |
| Download: ML20003G875 (2) | |
Text
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DISTRIBUTION:
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Manager, Licensing and Transportation Region III
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.s 175 Curtner Avenue RG? age C
,4g San Jose, California 95125 R
Gentlemen:
p This refers to your request for clarification of the phrase, "... test of the safeguards system", as contained in 10 CFR 73.40(d); and as discussed in your letter of August 5,1980. This will also confirm the various te'.ephone conversations pertaining to this subject; the latest of which were between your Mr. H. A. Rogers and Mr. O. F. Smith of the NRC staff on February 23 and 26, 1981.
As discussed and agreed upon during the referenced telephone conversations, tne revision of License Condittorr 1.2A, as originally requested in your above-referenced letter, is not necassary. The following explanation should adequately clarify the vaguaness of the phrase in question and provida the necessary guidance for compliance with the " testing" require-ments of 10 CFR 73.40(d).
The primary objective of your annual review and audit should be to assure the capability to respond to safeguards contingencies. To accomplish t
this, it is not necessary to test all components and subsystems of the safeguards system. The extent to wnTch the system should be tested will vary from time to time; and should be detennined based upon current information, acquired through a continuing evaluation of the strengths and weaknesses of the physical security program. Such cond itions are usually confirmed through direct observations and the results of inspec-tiens and reviews conducted by other individuals (either your represen-tatives or those of the NRC) since the last annual review and audit. For instance, the confirmation of a current, written agreement or understand-ing with the local law enforcement authorities (LLEA) and a testing of '
the comunication links (radio and telephone) between the LLEA and the site will satisfy the "...connitments established for response by local law enforcement authorities." However, if local circumstances dictate the need to illustrate the capability of the essential response forces (to include the LLEA), you tay conclude that such an exercise is appro-priate. When such a determination is mde, the involvement of LLEA or 810504 0 693
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2-General Electric Company other off-site personnel, over and above comitments previously agreed to, should be initiated only with their advance notification and consent.
Likewise, other components of the rafeguards system may be tested, to varying degrees, as warranted by local circumstances.
In surinary, there is no standard checklist to be applied to the testing of the safeguards system. The regulation, by design, allows considerable flexibility for application to local conditions. By employment of those measures which are deemed to be necessary to achieve the primary objec-tive of the annual review and audit, as stated above, the testing require-ments of 10 CR 73.40(d) can be satisfied.
Sincerely,
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" Original Signed by G.W. McCorkle" George W. McCorkle, Chief Physical Security Licensing Branch Division of Safeguands, NMSS l
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