ML20035A031
| ML20035A031 | |
| Person / Time | |
|---|---|
| Issue date: | 03/23/1993 |
| From: | Marcus G Office of Nuclear Reactor Regulation |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20034D486 | List: |
| References | |
| NUDOCS 9303230275 | |
| Download: ML20035A031 (9) | |
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March 23, 1993 MEMORANDUM FOR: Document Control Desk Document Management Branch Division of Information Support Services Office of Information Resources Management FROM:
Gail H. Marcus, Chief Generic Communications Branch Division of Operating Reactor Support Office of Nuclear Reactor Reguiation
SUBJECT:
DOCUMENTS ASSOCIATED WITH THE PROPOSED GENERIC LETTER REGARDING THE TECHNICAL SPECIFICATION CONTROL REQUIREMENTS FOR EMERGENCY AND SECURITY PLANS The Technical Specification Branch has prepared a draft generic letter regarding modification of the technical specification requirements for emergency and security plans. The Committee to Review Generic Requirements (CRGR) has reviewed and endorsed this draft genieric letter. The Generic Communications Branch (0GCB) is preparing to publish the draft generic letter in the Federal Reaister for public comment.
By copy of this memorandum we are providing the enclosed documents to the Public Document Room.
The enclosures are (1) the draft generic letter as approved by the CRGR and (2) the CRGR Review Package.
We request that you provide us with the Nuclear Documents System accession number for this memorandum so that we can include this information in the Federal Reaister notice. This information can be provided to the listed contact by telephone.
Y un/C.wd Gail H. Marcus, Chief Generic Communications Branch Division of Operating Reactor Support Office of Nuclear Reactor Regulation
Enclosures:
As Stated CONTACT: Don Kirkpatrick, NRR SO4-1849 9303230275 930323
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(DRAFT) 10:
ALL HOLDERS OF OPERATING LICENSES FOR NUCLEAR POWER REACTORS
SUBJECT:
MODIFICATION OF THE TECHNICAL SPECIFICATION ADMINISTRATIVE CONTROL REQUIREMENTS FOR EMERGENCY AND SECURITY PLANS (Generic Letter 93- )
The U.S. Nuclear Regulatory Commission (NRC) is issuing this guidance for changes to technical specifications (TS) to (1) remove the audit of the emergency and security plans and implementing procedures from the' list of responsibilities of the company nuclear audit and review group and (2) remove the review of the emergency and security plans from the list of responsibil-ities of the unit review group.
Parts 50 and 73 of Title 10 to the Code of Federal Reaulations (10 CFR) include provisions that are sufficient to address these requirements (See Enclosure 1).
Also this guidance will allow licensees to (3) relocate the requirements for the unit review group to review procedures, and procedure changes, for the implementation of the emergency and security plans.
The NRC developed this line-item TS improvement in response to a proposal by the Duke Power Company to amend the operating licenses of its plants. contains sample technice.1 specification requirements that have been marked to show the requirements that may be removed.
Licensees should retain these audit and review activities in a manner that fully satisfies the regulatory requirements that are summarized in Enclosure 1.
Although the TS change removes requirements that are specific with regard to providing a plant operations perspective in the review and audit of emergency and security plans and implementing procedures, the NRC staff is not suggesting that licensees remove or reduce this perspective when satisfying the regulatory requirements for these activities.
Licensees that plan to adopt this line-item TS improvement are encouraged to propose TS changes consistent with the enclosed guidance.
NRC project managers will review the amendment requests to verify that they conform to the guidance.
Please contact your project managar or the contact indicated herein if you have questions on this matter.
Any action by licensees to propose technical specification changes in accordaace with the guidance of this generic letter is voluntary and, therefore, not a backfit under 10 CFR 50.109. The following information, although not requested under the provisions of 10 CFR 50.54(f), would help the NRC to evaluate licensees' costs to propose TS changes in accordance with this generic letter.
1.
The licensee's time and costs to prepare the amendment request.
2.
An estimate of the licensee's long-term cost or savings as a result of this TS change.
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I Generic Letter 93- [
i This request is covered by Office of Management and Budget Clearance Number 3150-0011, which expires June 30, 1994. The estimated average number of burden hours is 40 person hours per licensee response, including those needed to assess the new recommendations, search data sources, gather and analyze the data, and prepare the required letters.
Send comments regarding this burden i
estimate or any other aspect of this collection of information, including i
suggestions for reducing this burden, to the Information and Records i
Management Branch (MNBB 7714), Division of Information Support Services, Office of Information and Resource Management, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 and to Ronald Minsk, Office of Information j
and Regulatory Affairs (3150-0011), NE08-3019, Office of Management and Budget, Washington, D.C. 20503.
j Sincerely, i
James G. Partlow Associate Director for Projects
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Office of Nuclear Reactor Regulation
Enclosure:
As stated i
Contact:
Tom Dunning, NRR l
(301) 504-1189 f
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Generic Letter 93-A Summary of Regulatory Requirements for Emergency and Security Plans in Title 10 to the Code of Federal Regulations Emeroency Plan i
Section 50.54(q) includes the following statement:
A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the
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standards in s 50.47(b) and the requirements in Appendix E of this part.
1 Section V, " Implementing Procedures," of Appendix E to Part;50 includes the l
following statement:
i No less than 180 days prior to the scheduled issuance of an operating i
license for a nuclear power reactor or a license to possess-nuclear i
material the applicant's detailed implementing procedures for its emergency plan shall be submitted to the Commission as specified in 9 50.4.
Licensees who are authorized to operate a nuclear power facility shall submit any changes to the emergency plan or. procedures to the Commission, as specified in s 50.4, within 30 days of such changes.
_j Section 50.54(t) includes the following statement:
A nuclear power reactor licensee shall provide for the development, revision, implementation, and maintenance of its emergency preparedness program.
To this end, the licensee shall provide for a review of its emergency preparedness program at least every 12 months by persons who have no direct responsibility for implementation of the emergency preparedness program. The review shall include an evaluation for -
adequacy of interfaces with State and local governments and of licensee drills, exercises, capabilities, and procedures. The results of the i
review, along with recommendations for improvements, shall be documented, reported to the licensee's corporate and plant management, and retained for a period of five years.
Security Plan Section 50.54(p)(1) includes the following statement:
The licensee shall prepare and maintain safeguards contingency plan 1
procedures in accordance with Appendix C of Part 73 of this chapter for effecting the actions and decisions contained in the Responsibility.
Matrix of the safeguards contingency plan.
j Section 50.54(p)(3) includes the following statement:
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The licensee shall provide for the development, revision, implementation and maintanence (sic) of its safeguards contingency plan. -To this end,.
the licensee shall provide for a review at least every 12 months of the safeguards ' contingency plan by individuals independent of both security-l k
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Generic Letter 93-Enclosure 1 i
program management and personnel who have direct responsibility for implementation of the security program. The review must include a i
review and audit of safeguards contingency procedures and practices....
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The results of the review and audit, along with recommendations for i
improvements, must be documented, reported to the licensee's corporate i
and plant management, and kept available at the plant for inspection for a period of two years.
l Section 73.40(a) includes the following statement:
Each licensee shall provide physical protection against radiological sabotage and against theft of special nuclear material at fixed sites where licensed activities are conducted.
i Section 73.40(b) includes the following statement:
l Each licensee...shall prepare a safeguards contingency plan in 1
accordance with the criteria set forth in appendix C of this part.
The licensee shall retain the current plan as a record until the Commission terminates the license for which the plan was developed and, if any portion of the plan is superseded, retain the superseded material for three years after each change. The plan becomes effective and must be I
followed by the licensee 30 days after approval by the Commission.
i Section 73.40(c)' includes the following statement:
j Prior to the plan becoming effective, the.icensee shall have:
.l Section 73.40(c)(2) includes the following statement:
Detailed procedures developed according to appendix C to this part available at the licensee's site. The licensee shall retain a copy of the current procedures as a record until the Commission. terminates the license for which the procedures were developed and, if any portion of-the procedures is superseded, retain the superseded material for three' years after each change.
j Section 73.40(d) includes the following statement:
The licensee shall provide.for the implementation, revision, and a
maintenance of this safeguards contingency plan. To this end, the i
licensee shall provide for a review at least every twelve months' of the
'I safeguards contingency plan by individuals independent of both security j
program management and personnel who have direct responsibility for implementation of the security program. The review must include a review and audit of safeguards contingency procedures and practices....
The results of the review and audit, along with recommendations for improvements must'be. documented, reported to the licensee's corporate and plant management, and kept available at the plant for inspection for a period of three years from the date of the review or audit.
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I Generic Letter 93-Enclosure 1 I
.Section 73.55(b)(3) includes the folluwing statement:
The licensee shall have a management system to provide for the development, revision, implementation, and enforcement-of security procedures. The system shall include f
Section 73.55(b)(3)(i) includes the following statement:
Written security procedures that document the structure of the' security l
organization and detail the duties of guards, watchmen, and other i
individuals responsible for security. The licensee shall maintain a copy of the current procedures as a record until the Commission terminates each license for which the procedures were developed and, if
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any portion of the procedure is superseded, retain the superseded material for three years after each change.
Section 73.55(b)(3)(ii) includes the following statement:
I Provisions for written approval of these procedures and any revisions to the procedures by the individual with overall-responsibility for the i
security function. The licensee shall retain each written approval as 'a j
record for three years from the date of the approval.
Section 73.55(g)(4) includes the following statement:
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The security program shall be reviewed at least every 12 months by i
individuals independent of both security management and security supervision. The review shall include a review and audit of
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security procedures and practices.... The results of the review audit and evaluation along with recommendation for corrections and improvements, if any, shall be documented, reported to the
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licensee's plant management and to corporate management at least one level higher than that having responsibility for. the day to day plant operation.
Section 73.56(g)(1) includes the following statement:
Each licensee shall audit its access authorization program within 12 months of _the effective date of implementation of this program and at-l least every 24 months thereafter to ensure that the requirements of this -
section are satisfied.
Section 73.56(g)(2). includes the following statement:
j Each licensee who accepts the access-authorization program of a contractor or vendor as provided _for by paragraph (a)(4) of this section shall have access to records and shall audit contractor or vendor programs every 12 months to ensure that the requirements of this section
.l are satisfied.
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t Geheric Letter 93-Enclosure 1 I
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Section 73.56(h)(2) includes the following statement:
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-i Each licensee shall retain records of results of audits, resolution of the audit findings and corrective actions for three years.
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Ge'neric Letter 93-i t
Model Technical Specifications Administrative Control Requirements t
for Security and Emergency Plans 1
(Modified as shown)
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r The following model technical specifications are derived from the
" Standard Technical Specifications for Westinghouse Pressurized Water Reactors," NUREG-0452, Revision 4a.
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6.5.1 IUNIT REVIEW GROUP (URGil i
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RESPONSIBILITIES 6.5.1.1 through 6.5.1.5 (No change,)
6.5.1.6 The [URG) shall be responsible for:
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- a. through h.
(#o change.)
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Review of the Security Plan and implementing procedurc; :.nd--sdniMal ef recommended change; to the [ Company !!uclear Review and Audi+
Group]; Not used.
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Review of the Emergency Plan and implementing procedure; con submittal i
of reccmmended change; to the [ Company !!uclear Retiew and 1444t Croup];
Not used.
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- k. and 1.
(No change.)
6.5.2 ICOMPANY NUCLEAR REVIEW AND AUDIT GROUP (CNRAG)1 6.5.2.1 through 6.5.2.7 (No change.)
f AUDITS F
6.5.2.8 Audits of unit activities shall be performed under the cognizance of I
the [CNRAG). These audits shall encompass.
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- a. through d.
(No change.)
i e.
The Security Plan and implementing procedure; at least once per-24 months-Not used, j
f.
The. Emergency Plan and implementing procedures at least ence per 24 =cnth;.
Not used.
- g. through j.
(No change.)
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- Deleted sections are noted as "Not used" to avoid renumbering sections.
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t Gdneric letter 93-Eaclosure 2 i
6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented, and maintained covering-the activities referenced below:
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- a. and b.
(No change.)
c.
Security Plan implementation.
Not used.
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d.
Emergency Plan implementatica.
tJot used.
- e. through g.
(No change.)
6.8.2 Each procedure of Specification 6.8.1, and change thereto, shall be i
reviewed by the [URG) and shall be approved by the [ Plant Superintendent]
prior to implementation and reviewed periodically as set forth in administra-tive procedures.
(No change.)
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t The requriements of Specifications 6.5.1.6 for items i and j, 6.8.1 for items c and d, and the provisions of Specification 6.8.2 are to be relocated to the security and emergency plans as applicable.
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