ML20067D498

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Responds to 821030 Generic Ltr 82-23 Re Inconsistency Between Requirements of 10CFR73.40(d) & STS Concerning Independent Reviews of Safeguards Contingency Programs.No Tech Spec Changes Necessary.Audit Controls in Place
ML20067D498
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 12/07/1982
From: William Jones
OMAHA PUBLIC POWER DISTRICT
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
GL-82-23, LIC-82-385, NUDOCS 8212130312
Download: ML20067D498 (2)


Text

n Omaha Public Power District 1623 HARNEY e OMAHA. NEBRASMA 68102 a TELEPHONE 536 4000 AREA CODE 402 December 7, 1982 LIC-82-385 Mr. Darrell G. Eisenhut, Director U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Washington, D.C.

20555

Reference:

Docket No. 50-285

Dear Mr. Eisenhut:

Fort Calhoun Station Safeguards Contingency Program Generic Letter 82-23 dated October 30, 1982 identified an apparent inconsistency between the requirements of 10 CFR 73.40(d) and the Standard Technical Specifications (STS) regarding independent reviews of Safeguards Contingency Programs.

The District has reviewed the re-quirements of 10 CFR 73.40(d) and has verified the proper controls are presently in place to ensure an annual review of the Fort Calhoun Station program is conducted in accordance with the subject Code of Federal Regulations section.

As stated in Chapter 14, " Security Audits",

of the Fort Calhoun Station Site Security Plan, Corporate Quality Assurance is responsible for conducting an annual audit and review of the plant's security program. This audit encompasses those items specifically identified in 10 CFR 73.40(d) which require review.

The Combustion Engineering STS detail that under the cognizance of a plant's independent offsite review committee, the security plan and implementing procedures shall be audited at least once per 24 months.

Fort Calhoun Station Technical Specification Section 5.5.2.8(f) requires our Safety Audit and Review Connittee to oversee the completion of such an audit of the Site Security Plan and associated implementing pro-cedures once every two years.

As discussed above, the District presently conducts the necessary reviews and audits of our security program as defined in both 10 CFR 73.40(d) and the STS. The District believes no Technical Specification hMO 8212130312 821207 PDR ADOCK 05000285 F

PDR

1 f1r. Darrall G. Eisenhut LIC-82-385 Page Two (TS) changes are necessary since the required audit controls are pre-sently in place. Additionally, the regulations require the District to maintain and comply with an approved Safeguards Contingency Plan (i.e.,

our Site Security Plan) and, since an annual review and audit of the security program is stipulated in the plan, the District is required to conduct an annual review even though this frequency is not specifically identified in our TS's.

Sincerely, Y't 0 I

W. C; Jones Division Manager Prcduction Operations WCJ/TLP:jmm cc:

LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, D.C.

20036 l

2 l

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