ML20059F989
| ML20059F989 | |
| Person / Time | |
|---|---|
| Issue date: | 12/10/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-93-337, NUDOCS 9401210005 | |
| Download: ML20059F989 (10) | |
Text
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PS EASED TO THE PDR em ft A
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December 10, 1993 SECY-93-337 (Information)
FOR:
The Commissioners fl0J:
James H. Taylor Executive Director for Operations
SUBJECT:
ISSUANCE OF GENERIC LETTER 93-XX, " MODIFICATION OF THE TECHNICAL SPECIFICATION ADMINISTRATIVE CONTROL REQUIREMENTS FOR EMERGENCY AND SECURITY PLANS" PURPOSE:
To inform the Commission of the staff's intent to issue the subject generic letter (copy enclosed) in accordance with the guidance in a memorandum of l
December 20, 1991, from Samuel J. Chilk to James M. Taylor relating to SECY-91-172. The purpose of the generic letter is to recommend, but not to impose, line-item technical specification (TS) improvements to modify the administrative control requirements for emergency and security plans.
DISCUSSION:
The staff proposed this generic letter to address a request by the Duke Power Company for this TS change. 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 i
model TS to help licensees and project managers process license amendments to I
implement the changes.
The staff met with the Committee To Review Generic Requirements (CRGR) on November 4, 1992, to review the proposed generic letter. The letter, as approved by the CRGR, and the supporting documentation are available in the l
Public Document Room (PDR) under Accession Number 9303230275.
l A notice of opportunity for public comment was published in the Federal Becister on April 1,1993. The public comment period expired on May 5,1993.
The NRC received comments from four licensees.
Copies of the comments are available in the PDR. A copy of the staff's detailed evaluation of these l
l comments is available in the NRC Central Files and will be placed in the PDR after the staff issues the generic communication.
NOTE:
TO BE MADE PUBLICLY AVAILABLE CONTACT-Tom Dunning, NRR 504-1189 IN 10 WORKING DAYS FROM THE 9401210005 931210 DATE OF THIS PAPER PDR SECY l
93-337 PDR
4 The Commissioners 2
Two licensees supported, without comment, the NRC staff's action to issue the proposed generic letter. One licensee noted that its experience is that
'525,000 is the minimum license amendment cost for this type of TS change. The licensee suggested that the NRC staff consider alternatives to enable handling generic changes to TS as a one-time generic process for all future applicants, so that the approval is "prepositioned" for use by licensees when they select the change. The staff currently provides a model safety evaluation report to project managers to reduce the administrative burden associated with processing line-item TS improvements. The staff will continue to evaluate further means to reduce the administrative burden on licensees and the NRC staff, within the constraints of the governing procedural regulations, as part of the ongoing regulatory improvement efforts.
Another licensee suggested that the generic letter recognize that the TS for some plants may have requirements similar to the model specifications that were marked to show the requirements that may be removed.
Specifically, it recommended that the generic letter note that proposed changes to similar TS requirements would be processed by the NRC staff where they are consistent with the guidance of the generic letter. The staff added this clarification to the generic letter.
The staff intends to issue the generic letter approximately 10 working days after the date of this information paper.
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J mes M. H ylor xecutive Director for Operations
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Enclosure:
Proposed Generic Letter DISTRIBUTION:
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0 Enclosure GENERIC LETTER FINAL DRAFT LINE-ITEM TECHNICAL SPECIFICATIONS IMPROVEMENTS TO MODIFY TECHNICAL SPECIFICATI0N ADMINISTRATIVE CONTROL REQUIREMENTS FOR EMERGENCY AND SECURITY PLANS
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UNITED STATES
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,j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20565-0001 4.....$
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ALL HOLDERS OF OPERATING LICENSES FOR NUCLEAR POWEP, 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 remove the audit of the emergency and security plans and implementing procedures from the list of responsibil-ities of the company nuclear audit and review group.
Parts 50 and 73 of Title 10 of the Code of Federal Regulations (10 CFR) include provisions that are sufficient to address these requirements (see Enclosure 1). Also, this guidance will allow TS changes to remove (1) the review of the emergency and security plans from the list of responsibilities of the unit review group and (2) the requirements for the unit review group to review procedures, and procedure changes, for the implementation of the emergency and security plans, provided the licensee relocates these requirements to the respective 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 TS 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 reviewers or auditors with 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 any questions on this matter.
Licensee action to propose TS changes under the guidance of this generic letter is voluntary.
Therefore, such action is not a backfit under the provisions of 10 CFR 50.109.
The following information, although not requested under the provisions of 10 CFR 50.54(f), would help the NRC evaluate costs and benefits for licensees who propose the TS changes described in this generic letter:
licensee time and costs to prepare the amendment request estimate of the long-term costs or savings accruing from this TS change
Contact:
T. G. Dunning, NRR (301) 504-1189
Generic letter 93-,
Office of Management and Budget Clearance Number 3150-0011, which expires June 30, 1994, covers this request.
The estimated average number of burden hours is 40 person-hours per licensee response, including those needed to assess the recommendations, search data sources, gather and analyze the data, and prepare the required letters. Send comments on this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch (MNBB 7714), Division of Information Support Services, Office of Information Resources Management, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and to Ronald Minsk, Office of Information and Regulatory Affairs (3150-0011), NE08-3019, Office of Management and Budget, Washington, DC 20503.
Sincerely, L. J. Callan Acting Associate Director for Projects Office of Nuclear Reactor Regulation Enclosures.
As stated l
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Generic Letter 93--
a.
A Summary of Regulatory Requirements for Emergency and Security Plans in Title 10 of the Code of Federal Reaulations Emeroencs Plaa 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 standards in 5 50.47(b) and the requirements in Appendix E of this part.
Section V, " Implementing Procedures," of Appendix E to Part 50 includes the following statement:
No less than 180 days prior to the scheduled issuance cf 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 5 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 5 50.4, within 30 days of such changes.
Section 50.54(t) includes the following statement:
A nuclear power reactor licensee shall provide for the develop-ment, revision, implementation, and maintenance of its emergency preparedness program. To this end, the licensee shall provide for a review of its emergency preparedness rogram at least every p
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 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:
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The licensee shall prepare and maintain safeguards contingency plan procedures in accordance with Appendix C of Part 73 of this cnapter for effecting the actions and decisions contained in the Responsibility Matrix of the safeguards contingency plan.
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p-Generic Letter 93-Enclosure 1 s
9 Section 50.54(p)(3) includes the following statement:
The licensee shall provide for the development, revision, imple-mentation 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 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 improve-ments, 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 73.55(b)(3) includes +he following statement:
The licensee shall have a management system to provide for the development, revision, implementation, and enforcement of security procedures.
The system shall include:
(i)
Written security procedures that document the structure of the security organization and detail the duties of guards, watchmen, and other 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 any portion of the procedure is superseded, retain the superseded material for three years after each change.
(ii)
Provisions for written approval of these procedures and any revisions to the procedures by the individual with overall responsibility for the security functions.
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 must be reviewed at least every 12 months by individuals independent of both security program management and personnel who have direct responsibility for implementation of the security program. The security program review must include an audit of security procedures and practices....
The results and recommendations of the security program review, management's findings on whether the security program is currently effective, and any actions taken as a result of recommendations from prior program reviews must be documented in a report to the licensee's plant manager and to corporate management at least one level higher than that having responsibility for the day-to-day plant operation. These reports must be maintained in an auditable form, available for inspection, for a period of 3 years.
Generic Letter 93- -
Eaclosure 1 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 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 i
vendor programs every 12 months to ensure that the requirements of-this section'are satisfied.
I 1
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, i
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i Generic Letter 93-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, and are an example for the types of changes that may i
be proposed for plant TS that are different in wording or format.
6.5.1 fuNIT REVIEW GROUP (URG)1 RESPONSIBillTIES 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.)
i.
Rev4ew-ef the Sec4*eRy-Men-and-4ep4ement4ng-peeeedurc; and submittal ef-reccmmended-change; tc the [Campany-Nuelear Revic.. nd Audit Geeup3t Not used.
- j.
Review of the-Emergency-Mon-and implemcating -procedurc; and-submittal of-recommended-change; to the [ Company Nuclear Review-and Aud4 Geeup}t Not used.
- k. and 1.
(No change.)
6.5.2 TCOMPANY 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:
- a. through d.
(No change.)
Re-Geewi-tM4an-and-4mplemcat4ng procedure; at least-ence-per e.
24 monthL Not used, f.
Re-Emergency Plan and implement 4ng-peacedure; at -Icaet-ence-per 24-monthsr Not used.
- g. through J.
(No change.)
- Deleted sections are noted as "Not used" to avoid renumbering sections.
I Generic Letter 93-Enclosure 2
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6.8 PROCEDURES AND PROGRAMS i
6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:
- a. and b.
(No change.)
c.
Geeurity Plan-implement-at4ent Not used.
i d.
Emergeney-Men-4mphaentet4enr Not used.
- e. through g.
(No change.)
i 6.8.2 Each procedure of Specification 6.8.1, and change thereto, shall be 1
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.)
1 The requirements of Specifications 6.5.1.6 for items i and j and 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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