ML20037A154
| ML20037A154 | |
| Person / Time | |
|---|---|
| Site: | 05000087 |
| Issue date: | 09/19/1978 |
| From: | Dipiazzo R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| WRD-LS&S-548, NUDOCS 7809220172 | |
| Download: ML20037A154 (3) | |
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!PRINTR REGULATORY INFORMATION DISTRIDUTION SYSTEM (RIDS)
DISTRIBUTIltN FOR INCOMING MATERIAL 50-087 REC: DENTON H R ORG: DIPIAZZA R P DOCDATE: 09/19/78 NRC WESTINGHOUSE DATE RCVD: 09/20/78 COPIES RECEIVED DOCTYPE: LETTER NOTARIZED: NO LTR 1 ENCL 6 SUDJECT:
REQUESTING WITHHOLDING PURSUANT TO 2.790 INFO.
FORWARDING REQUEGT FOR EXEMPTION UNDER PROVISIONS OF 10CFR73.5 FROM REQUIREMENT IN 10CFR73.40(D),
CONSISTING OF SAFEGUARDS CONTINGENCY PLAN FOR THE WESTINGHOUSE NUC TRANINING REACTOR FACILITY.
REVIEWER INITIAL:
XJM PLANT NAME: NTR DISTRIBUTOR INITIAL:
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DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ******************
SECURITY PLANS (DISTRIBUTION CODE SOO1)
FOR ACTION:
BR CHIEF ORB #4 BC**LTR ONLY LIC, ASST **LTR ONLY INTERNAL:
REO FILE **W/O ENCL REG FILE #1**W/EN L
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NRC PDR**LTR ONLY
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THE END
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Westinghouse' Water Reactor sexass Electric Corporation Divisions P!tts:xrghPtrmyNxna15230 September 19, 1978 WRD-LS&S-548 u
U. S. Nuclear Regulatory Commission Director of Nuclear Reactor Regulation Washing ton, D.C.
20555 Attention:
Mr. H. Denton, Director Nuclear Reactor Regulation Gentlemen:
Subject:
Safeguards Contingency Plan for the Westinghouse Nuclear Training Reactor Facility, Facility License No. R-119, Docket 50-87 Under the regulations of 10CFR73.40(b), Westinghouse is to submit a safeguards contingency plan to the NRC for dealing with threats, theft and industrial sabotage, containing the information delin-eated in Appendix C to 10CFR73.
Westinghouse takes the position that the information required by Appendix C is already contained or implied in either the physical security plan of the Nuclear Training Reactor (NTR) Facility or in the formal written arrangement with the local law enforcement agency (LLEA) required by the security plan, or else is inapplicable.
This position is substantiated in the attachments to this letter.
Westinghouse is therefore seeking approval of this position so that no separate contingency planning document need be submitted.
Westinghouse believes that no separate document is needed because the NTR Facility is characterized by a compact site, a single organization structure, and by reliance on the LLEA for contingency response.
Moreover, we believe that, as stated above, the informa-tion required is available elsewhere.
Westinghouse requests an exemption under the provisions of 10CFR73.5 from the requirement in 10CFR73.40 (d) for an annual review and audit of the safeguards contingency plan.
We believe that a two year review and audit frequency is adequate for a facility of the characteristics given above.
A two year frequency has already been provided for in the pending physical security program transmitted to the NRC on September 14, 1977 which contains the required con-tingency planning provisions.
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Westinghouse believes that the requirements of 10CFR73.40 (c) are met in'that all capabilities specified in the security plan are available and functional, detailed procedures have been developed, and all personnel have been trained.
This belief has been substan-tiated by inspections conducted by Region III, USNRC Office of Inspection and Enforcement.
It is relevant to establishing the Westinghouse position to note that the detailed procedures were implemented as early as October, 1976, several months before the Commission requirements for contingency planning were even proposed.
Westinghouse hereby requests that the attachment to this transmittal be withheld from public disclosure in.accordance with the provi-sions of 10 CFR 2.790 (d).
If you have any questions concerning this matter,' please write to me at the above address or telephone me on (412) 373-4652.
Very truly yours, p
k nald P. DiPiazza, Manager NES License Administration
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