ML20234D738

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Forwards NRR Ofc Ltr 801 Re Procedures & Responsibilities for Safeguards Reviews to Ensure That NRR Overall Responsibilities Are Carried Out Effectively & Consistently
ML20234D738
Person / Time
Issue date: 12/29/1987
From: Murley T
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
References
NRRL-801, NUDOCS 8801070164
Download: ML20234D738 (11)


Text

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December 29, 1937 o

MEMORANDUM FOR:

All NRR Employees FROM:

Thomas E. Murley, Director Office of Nuclear Reactor Regulation

SUBJECT:

NRR OFFICE LETTER N0. 801 PROCEDURES AND RESPONSIBILITIES FOR SAFEGUARDS REVIEWS PURPOSE These procedures provide NRR policy and responsibilities for safeguards reviews. This directive supersedes and replaces NRR Office Letter No. 46, Revision 1, dated April 4, 1986.

RESPONSIBILITIES AND AUTHORITIES The Directors of the Division of Reactor Projects I/II; Division of Reactor Projects III, IV, V; and the Division of Reactor Inspection and Safeguards are responsible for ensuring that their staffs adhere to the procedures delineated in the enclosure to this office letter.

The Project Directors are expected to ascertain that the enclosed procedures are followed when letters to licensees or license actions that pertain to safeguards issues are transmitted.

BASIC REQUIREMENTS The Reactor Safeguards Branch (RSGB) in the Division of Reactor Inspection and Safeguards is responsible for the implementation of the reactor safeguards program and serves as the focal point within NRR for all such matters.

RSGB is to ensure that NRR's overall responsibilities pertaining to safeguards reviews are carried out effectively and consistently.

Whenever a package contains safeguards information, which requires special handling, the procedures enclosed specify that the package should be returned to RSGB for assembly and dispatch after signature.

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-2 December 29, 1937 EFFECTIVE DATE This office letter is effective immediately.

OriCinal Signcd by i

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- p/j/ Thomas E. Murley, Director" J

Office of Nuclear' Reactor Regulation ~

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Enclosure:

NRR Safeguards Review Procedures cc: See next.are n

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NRR OFFICE LETTER cc:

V. Stello, ED0 MNBB-6209 M. Taylor, EDO MNBB-6209 T. Murley, NRR P-428 J. Sniczek, NRR P-428 J. Axelrad, NRR EWW-322 S. Ebneter, OSP EWW-322 J. Lieberman, OE MNBB-4100 W. Mcdonald, ARM MNBB-6201 P. Bird,0P W-407 J. McDermott, OP W-407

-E. Jordan, AEOD MNBB-3302 C. Heltemes, AE0D MNBB-3302 H. Thompson, NMSS 958-SS R. Benero, NMSS 958-SS M. Knapp,-NMSS 623-SS J. Greeves, NMSS 623-55

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R. Browning, NMSS 623-55 M. Bell, NMSS 623-SS R. Burnett, NMSS 825-SS E. Ten Eyck, NMSS 825-SS R. Cunningham, NMSS 396-SS G. Sjoblom, HMSS 396-SS E. Beckjord, RES NL-007 B. Sheron, RES NL-007 W. Minners, RES NL-007 B. Morris, RES NL-007 Z. Rosztoczy, RES NL-007 G. Arlotto, RES NL-007 R. Bosnak, RES NL-007 W. Houston, RES NL-007 H. Denton, GPA H-1013 S. Connelly, DIA EWS-461 B. Hayes, 0I EWS-434 W. Russell R-I J. Grace R-II A. Davis R-III R. Martin R-IV J. Martin R-V SECY H-1149 OGC H-1035 OGC-MNBB MNBB-9604 NRC PDR

ENCLOSURE NRR Office Letter NRR SAFEGUARDS REVIEW P.ROCEDURES The Reactor Safeguards Branch (RSGB) in the Division of Reactor Inspection and Safeguards is responsible for all matters related to reactor safeguards and l

serves as the focal point within NRR for all such matters.

This Office Letter provides NRR procedures, policies, and responsibilities for safeguards reviews to ensure that NRR's overall responsibilities are carried out effectively and consistently.

I.

General 1.

The RSGB staff is responsible for all formal Headquarters communications with licensees / applicants on matters related to the implementation of the reactor safeguards program, except as specified below.

These communications should be through or with the knowledge of the Project Manager (PM).

2.

The PM establishes and maintains overall project schedules.

Any safeguards review activities which affect established project schedules must have the concurrence of the PM.

3.

RSGB maintains the NRR files of all safeguards and security information that must be stored and handled in accordance with the requirements of 10 CFR 73.21 and 2.790 and as described in NRC Appendix 2101. This information is always available for review by PMs and other cognizant personnel.

PMs should be familiar with the content of security plans for their facilities.

4.

RSGB keeps track of the status of all ongoing safeguards issues and reviews and coordinates, as necessary, with the PMs to resolve review problems and to ensure that reviews are completed on schedule.

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5.

RSGB provides annual inputs to the Systematic Assessment of Licensee i

Performance (SALP) program on licensees' performance with respect to safeguards matters directly to the Project' Manager.

In addition,

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1 RSGB prepares individual SALP reports to accompany Safegugrds Evaluation Reports (SGER) for license. amendments and new operating j

licenses.

I 6.

Whenever a package contains safeguards information and requires 1

special handling, these procedures specify that the package should be returned to RSGB for assembly and dispatch after signature.

II.

Operating Power Reactors i

e A.

1pCFR50.90AmendmentReviews 1.

When a safeguards amendment request is received from a licensee, RSGB will screen it to determine if the submittal involves any j

safety implications.

If the requested amendment does involve any safety implications, it is sent to the PM who is asked to obtain a Technical Assignment Control System (TACS) number and to ensure that all NRR participants receive a copy of the TACS l

3 forin. At the same time, a copy is sent to the Plant. Systems Branch, Division of Engineering and Systems Technology for technical review.

The TACS number is used to keep track of all NRR resources expended on the effort.

RSGB prypares and forwards a Technical Assistance Request (TAR) to the flant Systems Branch for the technical review.

Completion dates are based on programmatic needs and are verbally negotiated by RSGB on a I

case-by-case basis with the appropriate PM.

2.

RSGB also prepares' a proposed "no significant hazards" finding i

for the Federal Register "Sholly" notice.

All safeguards information is handled in accordance with 10 CFR 73.21.

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1 3.

The cognizant Project Directorate completes the prenotice package and processes it for publication in the Federal Register.

4.

Ifadditionalinformationisrequiredtocomplete.therev'15w, RSGB prepares a transmittal letter to the licensee for signature by the appropriate PM.

After the letter is signed, it is returned to RSGB to be assembled with the package, dispatched to the licensee, and distributed.

The Project Directorate furnishes a service list for distribution of the transmittal letter.

5.

When the review is complete, by memorandum RSGB forwards the-proposed license amendment, the non-safeguards portion of the SGER presenting the results of the technical review, SALP report and any supplementary documentation to the appropriate Project Directorate; copies are also sent to the Licensing Assistant and

-l the PM for preparation of the license amendment and associated I

paperwork.

The safeguards information portion of the SGER is retained permanently by RSGB.

6.

The PM follows the procedures for processing license amendments.

RSGB receives two copies of the amendment package when it is

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The appropriate Project Director sends a copy of l

the amendment to the appropriate Regional Division Director.

7.

When the amendmer.t is issued, the PM closes the TACS number for this specific review effort, i

B.

10 CFR 50.54(p) Oversight Reviews 1.

Responsibility for reviewing 10 CFR 50.54(p) security plan changes has been delegated to the Regions. When a Region transfers responsibility for a 10 CFR 50.54(p) review to Headquarters in accordance with the established criteria and guidance for regionalized safeguards functions, RSGB reviews

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4 the item and, if safety-related issues are involved, prepares and forwards a TAR to the Plant Systems Branch.

The TAR includes a target completion date based on programmatic needs, h

which is verbally negotiated on a case-by-case basis among RSGB, the appropriate reviewers, and the PM.

RSGB sends copies of the TAR to the appropriate Regional Division Director and the PM.

RSGB ensures that all safeguards information is handled in accordance with 10 CFR 73.21 and tracks the review status.

2.

NRR personnel use TACS number M51592 to record the effort

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expended on the review.

3.

If additional information is required to complete the review,

.f RSGB prepares a transmittal letter to the licensee for signature by the PM.

The signed letter is returned to RSGB to be assembled with the package, dispatched to the licensee, and distributed. The Project Directorate furnishes a service list j

for distribution of the transmittal letter.

4.

When the review is complete, RSGB prepares a letter to the licensee for signature by the PM. The letter should reference the licensee's original submittal and the. Region's letter to the licensee concerning the transfer of review responsibility to Headquarters. The signed letter is returned to RSGB to be assembled with the package, dispatched to the licensee, and distributed.

A copy is sent to the appropriate Regional Division Director.

The Project Directorate furnishes a service list for distribution of the transmittal letter.

i C.

Regulatory Effectiveness Reviews (RERs) 1 1.

RSGB, in coordination with the Regions, identifies plants to undergo RERs and establishes schedules.

RSGB coordinates site visits with the appropriate Region, Resident Inspector, and PM,

.i and coordinates the RERs with licensees through.the Region.

Regional personnel participate in all the RERs. The PM may.

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.c participate in the entire RER and should at least' attend the exit briefing.

2.

RSGB sends a draft letter for the licensee to the Region, along with a request for regional support. The Region forwards the letter to the licensee, with copies to the PM, RSGB, and the Resident Inspector, advising the licensee of the upcoming RER, explaining the purpose of the RER, and identifying the necessary information and personnel to be available at the; time of the visit.

3.

Before the site visit, RSGB asks the PM to obtain a TACS-q number to keep account of NRR resources expended on the

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effort.

RSGB prepares the RER report, which is coordinated

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with the regional team member.

The Vital' Area Definition i

portion of the report may be sent later under a separate cover, and a separate TACS number may be needed to account for that q

effort.

4.

RSGB prepares a letter to the licensee, for signature by the cognizant Division D.irector - Projects, to transmit the RER.

report..-The signed letter is returned to RSGB to be assembled with the package, dispatched to'the licensee, and distributed.

The Project Directorate furnishes a service list'for' distribution of the transmittal letter.

5.

When the letter to the licensee is issued, the PM closes out the appropriate TACS number for this specific review effort.

6.

When a response to the RER report is received from the licensee, it is forwarded to RSGB for action and the PM obtains a TACS number to keep account of NRR resources expended on the effort.

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D.

IAEA Safeguards By agreement between the United States and the International Atomic Energy Agency (IAEA), the IAEA is permitted to perform certain safeguards inspections at selected nuclear power reactors in the United States.

IAEA selects facilities from an eligibility list provided by the U.S. government.

These facilities are then subject to IAEA safeguards inspections for some fixed term, usually a few years.

The objective of the inspections is to permit the IAEA to verify that source or special nuclear materials are not removed from l

the facilities, except as provided by the agreement.

RSGB is the cognizant group for coordinating all NRR responsibilities for the interoffice Safeguards Agreement Implementation Group chaired by NMSS.

The relevant procedures are as follows:

1.

RSGB prepares the reactor portion of the annual update of the eligibility list.

This list is furnished to NMSS (International-Activities Section), for transmittal through the State Department to IAEA.

2.

When facilities have been selected, RSGB notifies the l

appropriate PMs.

RSGB also prepares the correspondence for the Division Director of Reactor Projects' signature, notifying the affected licensees of the requirements under 10 CFR 75. RSGB dispatches this correspondence after it has been signed.

3.

RSGB acts as the NRR coordinator between NMSS and the appropriate PM during the entire time the facility is being examined.

This includes arranging facility visits and preparing facility attachments (The U.S. and IAEA develop facility attachments that define the IAEA and U.S. safeguards responsibilities.), "Sholly" notices, and termination amendments.

In accordance with the requirements of 10 CFR 75, pertinent portions of the facility attachments are incorporated in the licenses as conditions.

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E.

Information Assessment Team'(IAT) i The IAT provides a multi-office, on-call _ group within the NRC to rapidly assess the seriousness of threats involving lice,ns,ed nuclear

.l facilities, materials, or activities; to review'and evaluate safety-related and safeguards-related data to determine the consequences of the threatened act; and to recommend appropriate actions to senior NRC management.

The IAT.is comprised of~ members from each of the regional offices, NMSS, and NRR.

The NRR l-representatives of the IAT are members of the Events Assessment l

Branch and RSGB staff.

In this capacity NRR is responsible for:

1 1.

Screening pertinent data and determining and initiating the appropriate IAT response mode including notification of appropriate NRR management.

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2.

Providing technical support regarding safety / safeguards implications and system consequence analyses for threats involving any reactor.

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3.

Ensuring that the NRC Operations Center has a current contact 1

list of NRR IAT representatives.

l III. Operating License Reviews of Security Submittals (Physical Security, Safeguards Contingency, and Guard Training Plans) l l

These reviews parallel those outlined in Section II.A. except that a "no significant hazards" consideration need not be made.

IV.

Non-Power Reactors Non power reactor (NPR) safeguards reviews of revisions to previously approved plans and submittals for new security plans [10 CFR 50.90 or 10 CFR 50.54(p)] parallel those outlined for power reactors in' sections i

II.A., II.B., and III.

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All NRR resources expended on these efforts are recorded by appropriate

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docket number and planned accomplishment number 1141.

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