ML20035B469
| ML20035B469 | |
| Person / Time | |
|---|---|
| Issue date: | 03/23/1993 |
| From: | Marcus G Office of Nuclear Reactor Regulation |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9304020018 | |
| Download: ML20035B469 (14) | |
Text
March 23, 1992 n.
MEMORANDUM FOR:
Document Control Desk Document Management Branch Division of Information Support Services Office of Information Resources Mana;,ement FROM:
Gail H. Marcus, Chief Generic Communications Branch Division of Operating Reactor Support l
Office of Nuclear Reactor Regulation t
SUBJECT:
DOCUMENTS ASSOCIATED WITH THE PROPOSED GENERIC LETTER r
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 generic 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 l
are (1) the draft generic letter as approved by the CRGR and (2) the CRGR Review Package.
l t
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 l
Federal Reaister notice.
This information can be provided to the listed contact by telephone, i
/S/
Gail H. Marcus, Chief i
Generic Communications Branch Division of Operating Reactor Support Of' ice of Nuclear Reactor Regulation
Enclosures:
As Stated CONTACT: Don Kirkpatrick, NRR 504-1849 Dist ribution w/
Enclosures:
DKirkpatrick, NRR OGCB R/F l
Central Files PDR Distribution w/o
Enclosures:
p g
SWeiss, NRR-TDunning, NRR WRickley, NRR DORS R/F d
0Kirkpatrick, R/F g
fl}lX ' '
OGCB: DORS:NRR BC/0GCB: DORS:NRR DKirkpatrick GHMarcus g r' /
03/M/93 D gf93 UN w
DOCUMENT NAME:
T k.
hih[ h[]
Y b E
/
9304020018 930323
] W " 'C R v -
b
['>R RECI\\
UNITED STATES e
7,g g
NUCLEAR REGULATORY COMMISSION
{
qp o
c WASHINGTON, D.C. 20555
'S9 (DRAFT)
T0:
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 plins.
The NRC developed this line-item TS improvement in response to a propos11 by the Duke Power Company to amand the operating licenses of its plants. contains sample technical 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 manager or the contact indicated herein if you have questions on this matter.
Any action by licensees to propose technical specification changes in accordance 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 tht-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.
4A 1.
Generic Letter 93-.
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 l
data, and prepare the required letters.
Send comments regarding this burden l
estimate or any other aspect of this collection of information, including I
suggestions for reducing this burden, to the Information and Records 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 l
and Regulatory Affairs (3150-0011), NE0B-3019, Office of Management and l
Budget, Washington, D.C. 20503.
Sincerely, James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosure:
As stated
Contact:
Tom Dunning, NRR (301) 504-1189 l
l l
l l
l l
p l
Generic Lette t
A Summary of Regulatory Requirements for Emergency and Security Plans i
in Title 10 to the Code of Federal Regulations l
p Emeroency Plan i
l Section 50.54(q) includes the following statement:
I A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the i
standards in s 50.47(b) and the requirements in Appendix E of this part.
.l Section V, " Implementing Procedures," of Appendix E to Part 50 includes the following statement:
l No less than 180 days prior to the scheduled issuance of an operating
[
license for a nuclear power reactor or a license to possess nuclear material the applicant's detailed implementing procedures for its emergency plan shall be submitted to the _ Commission as specified in s 50.4.
Licensees who are authorized to operate a ~ lear power l
facility shall submit any changes to the emergency. an or procedures to j
the Commission, as specified in 6'50.4, within 30 days of such changes.
t Section 50.54(t) includes the following statement:
A nuclear power reactor licensee shall provide for the development, l
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 month's by persons who i
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'procedurcs.
The results of the
-l review, along with recommendations for improvements, shall be 4
documented, reported to the licensee's corporate and plant management, and retained for a period of five years.
j i
Security Plan l
Section 50.54(p)(1) includes the following statement:
The licensee shall prepare and maintain safeguards contingency plan i
procedures in accordance with Appendix C of Part 73 of this chapter for i
effecting the actions and decisions contained in the Responsibility Matrix of the safeguards contingency plan.
I Section 50.54(p)(3) includes the following statement.
1 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 l
safeguards contingency plan by individuals independent of both security l
o
I-l/i Generic Letter 93.-
2- -
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 two years.
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.
Section 73.40(b) includes the following statement:
Each licensee...shall prepare a safeguards contingency plan in 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 followed by the licensee 30 days after approval by the Commission.
Section 73.40(c) includes the following statement:
Prior to the plan becoming effective, the licensee shall have:
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.
Section 73.40(d) includes the following statement:
The licenses shall provide for the implementation, revision, and maintenance of this safeguards contingency plan..To this end, the licensee shall provide for a review at least every twelve months of the safeguards contingency plan by individuals independent of both security 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.
i l
Generic Letter 93-Enclosure 1.
1 Section 73.55(b)(3) includes the following statement:
The licensee shall have a management system to provide for the j
development, revision, implementation, and enforcement of security procedures. The system shall include:
Section 73.55(b)(3)(i) includes _the following statement:
Written security procedures that document the structure of the security organization and detail the duties of guards, watchmen, and other l
individuals responsible for security.
The licensee shallimaintain a copy of the current procedures as a record until the Commission terminates each license for which the procedures were_ developed and, if any portion of the procedure is superseded, retain the. superseded j
material for three years after each change.
j Section 73.55(b)(3)(ii) includes-the following statement:
l i
Provisions for written approval of _these procedures.and any revisions to the procedures by the individual with overall responsibility for the security function.
The licensee shall retain each written approval as a-i record for three years from the date of the approval.
l Section 73.55(g)(4) includes the following statement:
The security program shall be reviewed at least evary 12 months-by individuals independent of both security managemeni and security i
supervision. The review shall include a review and audit:of security procedures and practicesL... The results of the review audit and evaluation along with recommendation for corrections and improvements, if any, shall be documented, reported to the 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 least every 24 months thereafter to ensure'that the requirements of this i
section are satisfied.
Section.73.56(g)(2) includes the following statement:
{
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 onsure that the requirements of this sectior, are satisfied.
i f.:
oir b
y r-
.. ~..
l P
3 4
Generic Letter 93-
-4.
r
'h 4
i I
Section 73.56(h)(2) includes the following statement:
Each licensee shall retain records of results of _ audits, resolution of the audit findings and corrective actions for three years.
j f':
r t
l
.i l
l i
?
i
?
1 I
i i
L 4
t e
i b
I i
i I
b 4
?
I tt Generic Letter 93-1 Model Technical Specifications Administrative Controlf Requirements for Security and Emergency Plans (Modified as shown) 1 The following model technical specifications-are derived from the
" Standard Technical Specifications for Westinghouse Pressurized Water I
Reactors," NUREG-0452, Revision 4a.
b 6.5.1 IUNIT REVIEW GROUP (URGil RESPONSIBILITIES i
6.5.1.1 through 6.5.1.5 (No change.)
[
6.5.1.6 The [URG] shall be responsible for:
r
- a. through h.
(No change.)
i.
Review of the Security Plan and implementing procedure: and submittal h emmended change; to the [ Company "uclear Review and Audi+
Croup];
Not used.
- j.
Rc.icw cf the Emergency Plan and implementing procedurc; and submittal l
of reccmmended change; to the [ Company Nuclear Revic'.. and Audit Croup];
Not used.
- k. and 3.
(No change.)
6.5.2 ICOMPANY NUCLEAR REVIEW AND AUDIT GROUP (CNRAG)1
'{
6.5.2.1 through 6.5.2.7 (No change.)
AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the [CNRAG].
These audits shall encompass.
l
- a. through d.
(No change.)
e.
The Security Plan and implementing procedure at least cace per i
21 rent h Not used.
t f.
The Emergency Plan and implementing procedure; at le;;t once per 21 months.
Not used.
C
- g. through j.
(No change.)
i
- Deleted sections are noted as "Not used" to avoid renumbering sections.
L 8
4
)
r I
Generic Letter 93-
--2 4
6.8-PROCEDURES AND PROGRAMS' t
6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced-below:
- a. and b.
(No change.)
c.
Security Plan implement-at4enr Not used.
d.
Emergency Plan implementatica.
Not used.
- e. through g.
(No change.)
6.8.2 Each procedure of Specification 6.91, and change thereto, shall be 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.)
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.
l l
l i
P"*%g J
3"-
i, UNITED STATES E
E NUCLEAR REGULATORY COMMISSION s
'f WASHINGTON, D.C. 205f6
%, * * * * * /
October 20, 1992
)
MEMORANDUM FOR:
Edward L. Jordan, Chairman Committee to Review Generic Requirements i
FROM:
Frank J. Miraglia, Deputy Director Office of Nuclear Reactor Regulation
SUBJECT:
MODIFICATION OF TECHNICAL SPEClilCATION ADMINISTRATIVE CONTROL REQUIREMENTS FOR EMERGENCY AND SECURITY PLANS The staff is proposing a generic letter for a line-item improvement to technical specifications (TS), to address a request by the Duke Power Company for this TS change. The proposed generic letter, " Modification of Technical Specification Administrative Control Requirements for Emergency and Security Plans," attached to the enclosed CRGR review package, is submitted for review as a Category 2 item.
The TS change removes the administrative control requirements for the emergency and security plans that are adequately addressed by existing regulatory requirements.
The generic letter includes a model TS to help licensees and project managers process license amendments to implement the changes. The staff intends to implement a similar TS modification in the improved standard technical specifications for each nuclear steam supply system (NSSS) vendor.
Brian K. Grimes, Director, Division of Operating Reactor Support is sponsoring this work.
Please schedule a meeting at the earliest opportunity for the CRGR to review this proposal.
at.
A'4 Frank,
iraglTa, Deputy Director Office of Nuclear Reactor Regulation
Enclosure:
As stated W352 33c CONTACT: Tom Dunning, 504-1189
- g-l}QQQ Qf~n
I Enclosure
{
CRGR REVIEW PACKAGE i
Prooosed Action: Issue ~a generic letter to give licensees guidance for i
implementing a line-item technical specification (TS) improvement to remove specific administrative control requirements for auditing and reviewing the emergency and i
security plans and for implementing procedures for the emergency and security plans.
CATEGORY 2 t
RESPONSE TO RE0VIREMENTS FOR CONTENT OF PACKAGE SUBMITTED FOR CRGR REVIEW
~
h (i)
The proposed generic requirements or staff position as it is proposed to be sent out to licensees. Where the objective or intended result of a proposed generic requirement or staff position can be. achieved by setting a readily quantifiable standard that has an unambiguous relationship to a readily measurable quantity and is enforceable, the proposed requirements should merely specify the objective or result to be attained, rather than prescribing to the licensee how the objective or result is to be attained.
.l See the proposed generic letter, " Modification of Technical-t Specification Administrative Control Requirements for Emergency and Security Plans." (Attachment)
(ii)
Draft staff papers or other underlying staff documents supporting the requirements or staff positions.
A list of existing regulatory requirements for emergency and security I
plans are provided in Enclosure 1 to the proposed generic letter.
These requirements are listed so that licensees can readily identify duplicative requirements in the administrative control section of individual plant technical specifications.
(iii)
Each proposed requirement or staff position shall contain the sponsor-ing office's position as to whether the proposal would increase requirements or staff positions, would implement existing requirements l
or staff positions, or would relax or reduce existing requirements or staff positions.
This TS change does not change requirements or staff positions.
It only removes portions of TS that duplicate 10 CFR Parts 50 and 73 requirements.
(iv)
The proposed method of implementation along with the concurrence (and any comments) of the Office of the General Counsel (0GC) on the method proposed. The concurrence of affected program offices or an explanation of any nonconcurrenccs.
Each licensee would voluntarily propose TS changes consistent with the generic letter.
Project managers would review proposed changes, prepare the safety evaluation report (SER), and process the license
)'l
amendment to implement the TS changes.
OGC has reviewed the proposed generic letter and had no comment or objections. This TS improvement does not directly affect other offices.
(v)
Regulatory analysis generally conforming to the directives and 1_
guidance of NUREG/BR-0058 and NUREG/CR-3568.
A regulatory analysis is not required because action taken by e
licensees in response to the generic letter is voluntary.
(vi)
Identification of the category of reactor plants to which the generic requirement or staff position is to apply.
This guidance applies to all power reactor plants.
\\
(vii)
For backfits other than compliance or adequate protection backfits, a backfit analysis as defined in 10 CFR 50.109.
The backfit analysis shall include, for each category of reactor plants, an evaluation which demonstrates how action should be prioritized and scheduled in light of other ongoing regulatory activities. The backfit analysis shall document for consideration information available concerning any of the following factors as may be deemed appropriate and any other information relevant and material to the proposed action:
(a)
>atement of the specific objectives that the proposed action is designed to achieve; (b) General description of the activity that would be required by the licensee or applicant in order to complete the action;
)
(c)
Potential change in risk to the public from the accidental offsite release of radioactive material; (d)
Potential impact on radiological exposure of facility employees and other onsite workers; I
l g
(e)
Installation and continuing costs associated with the l
y action, including the cost of facility downtime or the cost i
of construction delay; (f) The potential safety impact of cnanges in plant or opera-tional complexity, including the relationship to proposed and existing regulatory requirements and staff positions; (g) The estimated resource burden on NRC associated with the proposed action and the availability of such resources; (h) The potential impact of differences in facility type, design, or age on the relevancy and practicality of the proposed action; (i) Whether the proposed action is interim or final, and if interim, the justification for imposing the proposed action on an interim basis; 1
i P-i (j) How the action should be prioritized and scheduled in light of other ongoing regulatory activities. The following l
information may be appropriate in this regard-1.
The proposed priority or schedule, 2.
A summary of the current backlog of existing requirements awaiting implementation, 3.
An assessment of whether implementation of existing requirements should be deferred as a result, and 4.
Any other information that may be considered appropriate 6
with regard to priority, schedule, or cumulative impact.
For example, could implementation be delayed pending i
public comment?
Backfit considerations do not apply because a licensee's response to e
this generic letter would be voluntary.
(viii) for each backfit analyzed pursuant to 10 CFR 50.109(a)(2) (i.e., not adequate protection backfits and not compliance backfits) the proposing office director's determination, together with the rationale 4
for the determination based on the considerations of paragraphs (i) through (vii) above, that (a) there is a substantial increase in the overall protection of j.
public health and safety or the common defense and security to be derived from the proposal; and (b) the direct and indirect costs of implementation, for the
\\
facilities affected, are justified in view of this increased protection.
j Backfit considerations do not apply because a licensee's response to this generic letter would be voluntary.
(ix)
For adequate protection or compliance backfits evaluated pursuant to 10 CFR 50.109(a)(4)
(a) a documented evaluation consisting of:
(1) the objectives of the modification, i
(2) the reasons for the modification, and (3) the basis for invoking the compliance or adequate protection exemption.
(b)
In addition, for actions that were immediately effective, the evaluation shall document the safety significance and appropriateness of the action taken and consideration of how costs contributM to selecting the solution among various acceptable alternatives.
Backtit considerations do not apply because a licensee's response to this generic letter would be voluntary.
l (x)
For each evaluation conducted for proposed relaxations or decreases in current requirements or staff positions, the proposing office director's determination, together with the rationale for the,
t f
l determination based on the considerations of paragraphs (i) through
-l (vii) above, that (a) the public health and safety and the common defense and security would be adequately protected if the proposed reduction in requirements or positions were implemented, and The TS change will not adversely affect the public health and safety since the regulations include adequate provisions to l
address the administrative control requirements removed from the TS.
(b) the cost savings attributed to the action would be substantial enough to justify taking the action.
The intent of this generic letter is to reduce a licensee's costs to prepare and the staff's cost to review a related license amendment request.
The licensee's costs to maintain administra-tive controls for the emergency and security plans will be reduced by the elimination of duplicate requirements.
(xi)
For each request for information under 10 CFR 50.54(f), (which is not subject to exception as discussed in III.A) an evaluation that includes at least the following elements:
(a) A problem statement that describes the need for the information in terms of potential safety benefit.
(b) The licensee actions required and the cost to develop a response to the information request.
(c) An anticipated schedule for NRC use of the information.
(d) A statement affirming that the request does not impose new requirements on the licensee, other than for the requested l
information.
The generic letter would not request information under 10 CFR 50.54(f). However, it would request the licensee to voluntarily submit information on the licensee's time and cost to prepare the license amendment request and an estimate of long-term savings to be realized from the proposed TS change.
i (xii)
An assessment of how the proposed action relates to the Commission's Safety Goal Policy Statement.
The proposed action is not related to the policy statement on safety goals.
l l
I
- I
. -