ML20244D288
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,, .h > 'p t g' ,g o% ~, ,ja NUCLEAR REGULATORY COMMISSION WASHING TON. D. C. 20555 N.v {/ .... El 2 6 385 E6M 85-03 MEMORANDUM FOR: Dan Holody, Region I Mike Puckett, Region II Bill Schultz, Region III Tom Westerinan, Region IV Al Johnson, Region V FROM:
Jane A. Axelrad, Director Enforcement Staff Office of Inspection and Enforcement
SUBJECT:
CITING SAFEGUARDS VIOLATIONS AGAINST APPROV SECURITY PLAN Recent events indicate some confusion over the application of Inspection and Enforcement niemorandum of May of the Office 13, 1982, safeguards violations against approved performance-oriented plans.regarding c That memorandum, a copy of which is attached, makes clear that licensees are to be citedof for sections noncompliance against approved p,1,ans ratherc than aga regulations.
Although the memorandum addresses Section 73.55, where the plan is imposed to it is also applicable plans condition.
by license implementing other provisions in the reg the provisions of an approved plan and those of the regulationsIf there is a conf, the matter should be referred to the Division of Safeguards, NMSS for resolt, tion.
The licensees' requirements responsibility which implement is to meet the plan's specifiedn objectives a the regulations.
In citing against plans, care must be taken to identify a required performance capability. correctly a specific plan commitment as o it relate testing commitments provided by a licensee as a means em of assur operability, the plan's specified do not relieve objectives andlicensees requirements. of their basic responsibilities to mee provided the following, For example, an approved plan a.
walking, running, or crawling between the transmitt .... ;
b.
through the zone at the rate of three feet per second.""E The system could have actually been defeated by crawling through one or ore l
zones and a citation against the plan objective was appropriate. Although the failurethe violate to detect crawling detection does not violate the testing provisions provisions. , it does the specified speed once every seven days would violate s ons, the tes pp N SS M A !/ H be __
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Regional Coordinators As indicated above and in the May 13, 1982 inemorandum, questions concerning the cortpleteness of plans which may not provide a clear basis for citation should be referred to the Division of Sa'ecuards, NMSS. Direct contact by the inspectors with the responsible litersing reviewers on such matters should
' be helpful to the understanding of the issues. If a particular question cannot be resolved in this manner, the regions should submit an Evaluation Memorandum to the appropriate safeguards branch for a policy decision.
f.1., .
Jane A. Axelrad, Director Enfc.rcement Staff 3
/ 0'ff e of Inspection and Enforcement t
Enclosure:
As stated cc:
R. Fonner, ELD J. Lieberman, ELD R. Burnett, SG/NMSS Enforcement Staff l
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