ML20035B470

Notice of Opportunity for Public Comment Re Mod of TS Administrative Control Requirements for Emergency & Security Plans

ML20035B470
Person / Time
Issue date:	03/25/1992
From:	Marcus G Office of Nuclear Reactor Regulation
To:
Shared Package
ML20035B467	List: ML20035B466 ML20035B468 ML20035B470 ML20035C271
References
NUDOCS 9304020019
Download: ML20035B470 (11)

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' ag 7590-01 NUCLEAR REGULATORY COMMISSION Proposed Generic Communication MODIFICATION OF THE TECHNICAL SPECIFICATION ADMINISTRATIVE CONTROL REQUIREMENTS FOR EMERGENCY AND SECURITY PLANS (Generic Letter 93- )

AGENCY:

Nuclear Regulatory Commission.

ACTION:

Notice of opportunity for public comment.

SUMMARY

The Nuclear Regulatory Commission (NRC) is proposing to issue a generic letter.

A generic letter is an NRC document that 1) requests licensees to submit analyses or descriptions of proposed corrective actions, or both, regarding matters of safety, safeguards, or environmental significance, or 2) requests licensees to submit information to the NRC on other technical or administrative matters, or, 3) transmits information to licensees regarding approved changes to rules or regulations, the issuance of reports or evaluations of interest to the industry, or changes to NRC administrative procedures.

This draft generic letter provides guidance to nuclear power plant licensees on allowable changes to the technical specifications. These changes would remove the administrative control requirements for emergency and security plans that are adequately addressed by other existing regulatory requirements.

The NRC is seeking comment from interested parties regarding both the technical and regulatory aspects of the proposed generic letter presented under the Supplementary Information heading.

This proposed generic letter and supporting documentation were discussed in meeting number 232 of the Committee to Review Generic Requirements (CRGR).

The relevant information that was sent to the CRGR to support their review of 9304020019 930325 PDR ORG NRR3 PDR

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the proposed generic letter is available in the Public Document Rooms under j

accession number 9303230275.

The NRC will consider comments received from interested parties in the final evaluation of the proposed generic letter.

The fiRC's final evaluation will include a review of the technical position and, when appropriate, an analysis of the value/ impact on licensees.

Should this generic letter be issued by the NRC, it will become available for public inspection in the Public Document Rooms.

DATES:

The comment period expires [ Insert date 30 days after the FRN is 1

published).

Comments submitted after this date will be considered if it is practical to do so, but assurance of consideration cannot be given except for comments received on or before this date.

ADDRESSES:

Submit written comments to Chief, Rules and Directives Review Branch, U.S. Nuclear Regulatory Commission, Washington, DC 20555. Written comments may also be delivered to Room P-223, Phillips Building, 7920 Norfolk Avenue, Bethesda, Maryland, from 7:30 am to 4:15 pm, Federal workdays.

Copies of written comments received may be examined at the NRC Public Document Room, 2120 L Street, NW. (Lower Level), Washington, DC.

FOR FURTHER INFORMAT10!i CONTACT:

Tom Dunning, AC (301) 504-1189.

SUPPLEMENTARY INFORMATION: Draft Generic Letter Dated at Rockville, Maryland, this 27 day of Mrd-1992.

FOR THE NUCLEAR REGULATORY COMMISSION

^- ! h cus Gail H. Marcus, Chief Generic Communications Branch Division of Operating Reactor Support Office of Nuclear Reactor Regulation

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3 gy,, y > > a 2.v i e' s TO:

ALL HOLDERS OF OPERATING LICENSES FOR NUCLEAR POWER REACTORS SU3 JECT:

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 Regulations (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 proccdures, 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 technical specification requirements that have been marked to show the requirements that may be removed.

Licensees should retain th m,dit 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.

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Licensees that plan to adopt this line-item TS improvement are encouraged to

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I propose TS changes consistent with the enclosed guidance.

NRC project i

i managers will review the amendment requests to verify that they conform to the l

guidance.

Please contact your project manager or the contact indicated herein i

if you have questions on this matter.

i Any action by licensees to propose technical specification changes in accordance with the guidance of this generic letter is voluntary and, j

i therefore, not a backfit under 10 CFR 50.109.

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A Summary of Regulatory Requirements for Emergency and Security Plans i

i in Title 10 to the Code of Federal Regulations Emeroency Plan j

Section 50.54(q) includes the following statement:

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A licensee authorized to possess and operate a nuclear power reactor

-1 shall follow and maintain in effect emergency plans which meet the-l standards in 6 50.47(b) and the requirements in Appendix E of this part.

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L Section V, " Implementing Procedures," of Appendix E to Part 50 includes the following statement:

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No less than 180 days prior to the scheduled issuance of an operating

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license for a nuclear power reactor or a license to possess nuclear

-j material the applicant's detailed implementing procedures for its emergency plan shall be submitted to the Commissii, as speciim I

6 50.4.

Licensees who are authorized to operate a nuclear power facility shall submit any changes to the emergency-plan or procedures to l

the Commission, as specified in.6 50.4, within 30 days of such changes.

Section 50.54(t) includes the-following statementi A nuclear power reactor licensee shall provide for the development, j

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revision, implementation, and maintenance of its emergency preparedness

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program. To this end, the licensee shall provide for, a review of its

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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 review, along with recommendations 'for improvements,. shall' be

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documented, reported to the licensee's corporate and plant management, and retained for a period of five years.

I Security Plan Section 50.54(p)(1) includes the following statement:

The licensee shall prepare and maintain safeguards contingency plan.

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.

Section 50.54(p)(3) includes the following statement:

The licensee shall provide for the development, revision, implementation and maintenance (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 program management and personr.al 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 licensee 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 h

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a period of three years from the date of the review or audit.

i Section 73.55(b)(3) ' includes the following statement:

The licensee shall have a management system to provide for the

-development, revision, implementation, and enforcement of security j

procedures.

The system shall include-Section 73.55(b)(3)(i) includes the following statement:

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.l Written security procedures that document the structure of the security organization and detail,the duties of guards, watchmen, and other

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individuals responsible for ' security. The licensee shall maintain a copy of the current procedures as a record until the Commission

'l terminates each license for which the procedures were developed 'and, if -

any portion of the procedure is superseded, retain'the superseded materi~al for three years after each change.

Section 73.55(b)(3)(ii) includes the following statement:

Provisions for written approval of-these precedures 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 record for three years from the date of'the approval.

Section 73.55(g)(4) includes the following statement:

The security program shall be reviewed at least every 12 month's by individuals independent of both security management and security supervision. The review shall include a review and audit of 1

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I security procedures and practices.... The results of the review audit and evaluation along with recommendation for corrections and

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improvements, if any, shall be documented, reported to the j

licensee's plant management and to corporate management at least one level higher than that having responsibility for the day to i

day plant operation.

_j Section 73.56(g)(1) includes the following statement:

i Each licensee shall audit its access authorization program within 12 months of the effective date of implementation of this program' and at

-j 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:

l 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 are satisfied.

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.

Model Technical Specifications Administrative Control Requirements for Security and Emergency Plans (Modified as shown)

The following model technical specifications are derived from the

" Standard Technical Specifications for Westinghouse Pressurized Water Reactors," NUREG-0452, Revision 4a.

6.5.1 IUNIT REVIEW GROUP fURGil RESPONSIBILITIES 6.5.1.1 through 6.5.1.5 (No change.)

6.5.1.6 The [URG) shall be responsible for:

a'. through h.

(No change.)

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Rev4ea of the Security Plen end impicmentieg-proccdure; cnd subst4a4

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of reccmmended changes to the [ Company !!uclear Rev+ew-and-Audi4 Croup];

Not used

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Resic; Of the Emergency' Plan and implementing precedures and submi44a4 of recommended change; 10 the [ Company "uclear Revic; and Audit Crcup]; Not used.

k. and 1.

(No change.)

6.5.2 ICOMPANY NUCLEAR REVIEW:AND AUDIT GROUP (CNRAGil 6.5.2.1 through 6.5.2.7 (No change.)

AUDITS 6.5.2.B' Audits of unit activities shall be performed under the cognizance of the.[CNRAG). These audits shall encompass.

a. through d.

(No change.)

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The Security Plan and impicmenting pensedurc; at least once per I

2 ? month:=.- Not used.

f.

The Emergency Plcn and implementing procedure; ct le;;t cace per 6

20 months.

Nat uset.

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 6.8 PROCEDURES AND PROGRAMS l

6.8.1 Written procedures shall be eitablished, implemented, and maintained j

covering the activities referenced below:

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a. and b.

(No change.)

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Security Plan implemer.tation.

Not used.

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Emergency Plan implementatica.

Not used.

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e. through g.

(No change.)

6.8.2 Each procedure of Specification 6.8.1, and cha:.ge thereto, shall be l

reviewed by the [URG) and shall be approved by the [ Plant Superintendent]

prior to implementation and reviewed periodically as set forth in administra-i tive procedures.

(No change.)

The requirements of Specifications'6.5.1.6 for items i and j, 6.8.1'for iten c and d, and the provisions of Specification 6.8.2 are to be i

relocated to the security and emergency plans as applicable.

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