ML20105C246
| ML20105C246 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Summer |
| Issue date: | 04/08/1983 |
| From: | Gray J NRC |
| To: | Hopkins J NRC |
| Shared Package | |
| ML20102A920 | List:
|
| References | |
| FOIA-84-166 NUDOCS 8502090352 | |
| Download: ML20105C246 (2) | |
Text
{{#Wiki_filter:. April 8, 1983 e- -[ . Note.to: L B.-H'opkins fFrom:- J.R. Gray j
- Re:
Summer Physical Security Plan ~ I ?'
- In' a note to S. Goldberg dated April 1,1983, you raise a question about the Sumer physical. security plan referenced in the facility operating 111 cense.: 1Specifica11y, you note that the license currently references
-the physical. security plan.through amendment 6 of the plan although amendment:9:is now 'actually in effect and, ask "whether it is incorrect iand/or. misleading to have the license only list plan amendments through <6 when plan amendment 9 is in effect."
- As-you know, 10lCFR 5 50.54(p) authorizes a licensee to make changes to "its~ security ~ plan or to its safeguards contingency plan without prior lNRC
- approval.provided that such changes do not decrease the
- effectiveness of the plans.
Such changes to plans are permitted under the regulation despite the. fact that the operating hense may reference ~~ sversionslof.the-plans'which~do not reflect the most recent changes made ' pursuant to Section 50.54(p). Thus, because of this regulatico it is ' legally permissible for-the Summer licensee, for example, to actudly soperate under a security plan changed through amendment 9, although tSc Llicense references '_a plan only through amendment'6, provided that the unapproved changes 'in plan amendments L7, 8 and 9 do not decrease the cJeffectivenesss of the-plans. It is not legally. incorrect."to have the s, ilicense'only list plan amendments through 6 when plan amendment 9 is in
- effect.*
- gThe fact that the Summer license references a plan changed only through--
J -amendment 6 is not necessarily misleading.--- As you may' note, the condition in the Sumer' license references the approved plan through famendment'6-(amendments 7,-8 and 9 are, as yet', not approved and need- "not be:' approved.to be effective provided that those. amendments did not Ldecrease' plan' effectiveness). However, the. license' does not reflect the
- currently effective plans;and it ~cannot be ascertained from the face of L the;1icense what ~ version of the plan is in effect or
- that plans changed -
1 lbeyond amendment 6 are being implemented.. This situation exists for inearly all. licensed commercial reactors and is a consequence of the . provisions of Section 50.54(p)'which ' allows licensees to modify plans E C ' without having obtained. license-. amendments. In:an attempt to have-tlicenses reflect the latest versions; of? security plans, the Staff does - cperiodically' amend-security' plan license conditions, in conjunction with-l unrelated license? amendments,.to include reference to the = latest version e ofLthe: plans'..Since', in light of what Section 50.54(p) allows,'the
- Staff-generally could not legally. require a licensee to apply for a -
glicense amendment every time the. licensee amends its plans pursuant to 'm Section 50.54(p),;the' current. practice of periodically updating the a 1 1 RJ.'8502090352.840518 2- - +:PDR FOIA _ d*ADATOS4 166-POR _ 7 nr
e;;..p,. - m.: .v, 1 a: W- - be... - 2-r- 1 security ' plan reference in conjunction with an unrelated license araendment is probably the appropriate course to take. J.R. Gray 4 w i S
- e S
V b I >.d '.. e i / + e w-. O b Y s /y I .a w E ? N _P- .s 4 =_}}