NRC Generic Letter 1993-07
UNITED STATESNUCLEAR REGULATORY COMMISSI dt'WASHINGTON. D.C. 2C6RDecember 28, 1993TO: ALL HOLDERS OF OPERATING LICENSES FOR NUCLEAR POWER REACTORS
SUBJECT: MODIFICATION OF THE TECHNICAL SPECIFICATION ADMINISTRATIVE CONTROLREQUIREMENTS FOR EMERGENCY AND SECURITY PLANS (Generic Letter 93-07)The U.S. Nuclear Regulatory Commission (NRC) is issuing this guidance forchanges to technical specifications (TS) to remove the audit of the emergencyand security plans and implementing procedures from the list of responsibil-ities of the company nuclear audit and review group. Parts 50 and 73 ofTitle 10 of the Code of Federal Regulations (10 CFR) include provisions thatare sufficient to address these requirements (see Enclosure 1). Also, thisguidance will allow TS changes to remove (1) the review of the emergency andsecurity plans from the list of responsibilities of the unit review group and(2) the requirements for the unit review group to review procedures, andprocedure changes, for the implementation of the emergency and security plans, -provided the licensee relocates these requirements to the respective emergencyand security plans. The NRC developed this line-item TS improvement inresponse to a proposal by the Duke Power Company to amend the operatinglicenses of its plants.Enclosure 2 contains sample TS requirements that have been marked to show therequirements that may be removed. Licensees should retain these audit andreview activities in a manner that fully satisfies the regulatory requirementsthat are summarized in Enclosure 1. Although the TS change removesrequirements that are specific with regard to providing a plant operationsperspective in the review and audit of emergency and security plans andimplementing procedures, the NRC staff is not suggesting that licensees removereviewers or auditors with this perspective when satisfying the regulatoryrequirements for these activities.Licensees that plan to adopt this line-item TS improvement are encouraged topropose TS changes consistent with the enclosed guidance. NRC projectmanagers will review the amendment requests to verify that they conform to theguidance. Please contact your project manager or the contact indicated hereinif you have any questions on this matter.Licensee action to propose TS changes under the guidance of this genericletter is voluntary. Therefore, such action is not a backfit under theprovisions of 10 CFR 50.109. The following information, although notrequested under the provisions of 10 CFR 50.54(f), would help the NRC evaluatecosts and benefits for licensees who propose the TS changes described in thisgeneric letter:* licensee time and costs to prepare the amendment request* estimate of the long-term costs or savings accruing from this TS change9312170114- C§ _ 7 in 00208107 0. ' dO'0 7 00 8 X w s. 9 Generic Letter 93-07 --2 --December 28, 1993The voluntary information collections contained in this request are covered bythe Office of Management and Budget clearance number 3150-0011, which expiresJune 30, 1994. The public reporting burden for this voluntary collection ofinformation is estimated to average 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per response, including the timefor reviewing instructions, searching existing data sources, gathering andmaintaining the data needed, and completing and reviewing the collection ofinformation. Send comments regarding this burden estimate or any other aspectof this voluntary collection of information, including suggestions forreducing this burden, to the Information and Records Management Branch(MNBB-7714), U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, andto the Desk Officer, Office of Information and Regulatory Affairs, NEOB-3019,(3150-0011), Office of Management and Budget, Washington, D.C. 20503.
Sincerely,c ng Assocnate Director for ProjectsOffice of Nuclear Reactor Regulation
Enclosures:
1. A Summary of Regulatory Requirementsfor Emergency and Security Planin Title 10 of the Code of Federal Regulations2. Model Technical Specifications AdministrativeControl Requirements for Security andEmergency Plans3. List of Recently Issued NRC Generic LettersTechnical contact:T. G.(301)Dunning, NRR504-1189 Generic Letter 93-07Enclosure IA Summary of Regulatory Requirements<->for Emergency and Security Plansin Title 10 of the Code of Federal RegulationsEmergency PlanSection 50.54(q) includes the following statement:A licensee authorized to possess and operate a nuclear powerreactor shall follow and maintain in effect emergency plans whichmeet the standards in § 50.47(b) and the requirements inAppendix E of this part.Section V, 'Implementing Procedures,* of Appendix E to Part 50 includes thefollowing statement:No less than 180 days prior to the scheduled issuance of anoperating license for a nuclear power reactor or a license topossess nuclear material the applicant's detailed implementingprocedures for its emergency plan shall be submitted to theCommission as specified in § 50.4. Licensees who are authorizedto operate a nuclear power facility shall submit any changes tothe emergency plan or procedures to the Commission, as specifiedin § 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 emergencypreparedness program. To this end, the licensee shall provide fora review of its emergency preparedness program at least every12 months by persons who have no direct responsibility forimplementation of the emergency preparedness program. The reviewshall include an evaluation for adequacy of interfaces with Stateand local governments and of licensee drills, exercises,capabilities, and procedures. The results of the review, alongwith recommendations for improvements, shall be documented,reported to the licensee's corporate and plant management, andretained for a period of five years.Security PlanSection 50.54(p)(1) includes the following statement:The licensee shall prepare and maintain safeguards contingencyplan procedures in accordance with Appendix C of Part 73 of thischapter for effecting the actions and decisions contained in theResponsibility Matrix of the safeguards contingency pla Generic Letter 93-07-2 -Enclosure ISection 50.54(p)(3) includes the following statement:The licensee shall provide for the development, revision, imple-mentation and maintenance [sic) of its safeguards contingencyplan. To this end, the licensee shall provide for a review atleast every 12 months of the safeguards contingency plan byindividuals independent of both security program management andpersonnel who have direct responsibility for implementation of thesecurity program. The review must include a review and audit ofsafeguards contingency procedures and practices.... The resultsof the review and audit, along with recommendations for improve-ments, must be documented, reported to the licensee's corporateand plant management, and kept available at the plant forinspection for a period of two years.Section 73.55(b)(3) includes the following statement:The licensee shall have a management system to provide for thedevelopment, revision, implementation, and enforcement of securityprocedures. The system shall include:(I) Written security procedures that document the structure ofthe security organization and detail the duties of guards,watchmen, and other individuals responsible for security. Thelicensee shall maintain a copy of the current procedures as arecord until the Commission terminates each license for which theprocedures were developed and, if any portion of the procedure issuperseded, retain the superseded material for three years aftereach change.(ii) Provisions for written approval of these procedures andany revisions to the procedures by the individual with overallresponsibility for the security functions. The licensee shallretain each written approval as a record for three years from thedate of the approval.Section 73.55(g)(4) includes the following statement:The security program must be reviewed at least every 12 months byindividuals independent of both security program management andpersonnel who have direct responsibility for implementation of thesecurity program. The security program review must include anaudit of security procedures and practices.... The results andrecommendations of the security program review, management'sfindings on whether the security program is currently effective,and any actions taken as a result of recommendations from priorprogram reviews must be documented in a report to the licensee'splant manager and to corporate management at least one levelhigher than that having responsibility for the day-to-day plantoperation. These reports must be maintained in an auditable form,available for inspection, for a period of 3 year Generic Letter 93-07-3 -Enclosure ISection 73.56(g)(1) includes the following statement:Each licensee shall audit its access authorization program within12 months of the effective date of implementation of this programand at least every 24 months thereafter to ensure that therequirements of this section are satisfied.Section 73.56(g)(2) includes the following statement:Each licensee who accepts the access authorization program of acontractor or vendor as provided for by paragraph (a)(4) of thissection shall have access to records and shall audit contractor orvendor programs every 12 months to ensure that the requirements ofthis section are satisfied.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 threeyear Generic Letter 93-07Enclosure 2K>Model Technical SpecificationsAdministrative Control Requirementsfor Security and Emergency Plans(Modified as Shown)The following model technical specifications are derived from the IStandardTechnical Specifications for Westinghouse Pressurized Water Reactors,NUREG-0452, Revision 4a, and are an example for the types of changes that maybe proposed for plant TS that are different in wording or format.6.5.1 rUNIT REVIEW GROUP (URG)lRESPONSIBILITIES6.5.1.1 through 6.5.1.5 (No change.)6.5.1.6 The [URG] shall be responsible for:a. through h. (No change.)i.j.Review of the Security Plan and implementing procedures and submittalof recommended changes to the [Company Nuclear Rcvicw and AuditGreup]; Not used, *Review of the Emergency Plan and Implementin procedures and submittalef recommended chamnges to the [Company Nuclear Review and AuditCroup]; Not used,k. and 1. (No change.)6.5.2 [COMPANY NUCLEAR REVIEW AND AUDIT GROUP (CNRAG M6.5.2.1 through 6.5.2.7 (No change.)AUDITS6.5.2.8 Audits of unit activities shall be performed under the cognizance ofthe [CNRAG]. These audits shall encompass:a. through d. (No change.)e.24h months l Not used cTh Emrgnc Plan andJ impemetin prceuesa lat ne ef.24 month<s. Not used.g. through J. (No change.)* Deleted sections are noted as "Not used" to avoid renumbering section Generic Letter 93-07 -2- Enclosure 26.8 PROCEDURES AND PROGRAMS6.8.1 Written procedures shall be established, implemented, and maintainedcovering the activities referenced below:a. and b. (No change.)c. Seccurity Pan implemcntation. Not used.d. Emergency Plan implemcntation. Not used,e. through g. (No change.)6.8.2 Each-procedure of Specification 6.8.1, and change thereto, shall bereviewed 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.)The requirements of Specifications 6.5.1.6 for items I and j and 6.8.1 foritems c and d and the provisions of Specification 6.8.2 are to be relocatedto the security and emergency plans as applicabl tnciosure jGL Q3-07I' De per 28, 1993Pag FE of ILIST OF RECENTLY ISSUED GENERIC LETTERS -GenericI teDate ofTeei, neClihivotTee etA TnL.1y t, %IC F juuJv'_t. AaaUSAIM.N. .-93-0693-0589-10,SUPP. 593-0493-0393-02RESEARCH RESULTS ONON GENERIC SAFETY ISSUE 106,wPIPING AND THE USE OFHIGHLY COMBUSTIBLE GASES INVITAL AREAS"LINE-ITEM TECHNICALSPECIFICATIONS IMPROVE-MENTS TO REDUCE SURVEILLANCEREQUIREMENTS FOR TESTINGDURING POWER OPERATIONINACCURACY OF MOTOR-OPERATED VALVEDIAGNOSTIC EQUIPMENTROD CONTROL SYSTEMFAILURE AND WITHDRAWALOF ROD CONTROL CLUSTERASSEMBLIES, 10 CFR 50.54(f)VERIFICATION OF PLANTRECORDSNRC PUBLIC WORKSHOP ONCOMMERCIAL GRADE PRO-CUREMENT AND DEDICATIONEMERGENCY RESPONSE DATASYSTEM TEST PROGRAM10/25/9309/27/9306/28/9306/21/93ALL HOLDERS OF OLs ORCPs FOR NPRsALL HOLDERS OF OLs ORCPs FOR NPRsALL LICENSEES OFOPERATING NUCLEAR POWERPLANTS AND HOLDERS OFCONSTRUCTION PERMITS FORNUCLEAR POWER PLANTSALL HOLDERS OF OLs ORCPs FOR (W)-DESIGNEDNPRs EXCEPT HADDAM NECKALLCPsANDANDHOLDERS OF OLs ORFOR (CE)-DESIGNED(B&W)-DESIGN NPRsHADDAM NECK10/20/9303/23/9303/03/93ALL HOLDERS OF OLs ORCPs FOR NPRsALL HOLDERS OF OLs ORCPs FOR NPRs AND ALLRECIPIENTS OF NUREG-0040,"LICENSEE CONTRACTOR ANDVENDOR INSPECTION STATUSREPORTO (WHITE BOOK)ALL HOLDERS OF OLs ORCPs FOR NPRs, EXCEPTFOR BIG ROCK POINT ANDFACILITIES PERMANENTLYOR INDEFINITELY SHUTDOWN93-01OL -OPERATING LICENSECP -CONSTRUCTION PERMITNPR = NUCLEAR POWER REACTORS Generic Letter 93-07 -e 8-2 -December 28, 1993The voluntary information collections contained in this request are covered bythe Office of Management and Budget clearance number 3150-0011, which expiresJune 30, 1994. The public reporting burden for this voluntary collection ofinformation is estimated to average 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per response, including the timefor reviewing instructions, searching existing data sources, gathering andmaintaining the data needed, and completing and reviewing the collection ofinformation. Send comments regarding this burden estimate or any other aspectof this voluntary collection of information, including suggestions forreducing this burden, to the Information and Records Management Branch(MNBB-7714), U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, andto the Desk Officer, Office of Information and Regulatory Affairs, NEOB-3019,(3150-0011), Office of Management and Budget, Washington, D.C. 20503.
Sincerely,orig /s/'d by LJCallanL. J. CallanActing Associate Director for ProjectsOffice of Nuclear Reactor Regulation
Enclosures:
1. A Summary of Regulatory Requirementsfor Emergency and Security Planin Title 10 of the Code of Federal Reaulatlons2. Model Technical Specifications AdministrativeControl Requirements for Security andEmergency Plans3. List of Recently Issued NRC Generic LettersTechnical contact:DISTRIBUTION:PDRCentral FilesDORS R/FOTSB R/FFJMiragliaWTRussellLJCallanT. G. Dunning, NRR(301) 504-1189SATrebyBKGrimesGHMarcusCIGrimesFMReinhartWDReckleyTGOunningThis letter incorporates CRGR comments described in a memo from BKGrimes toELJordan dated 11/29/93, and additional changes discussed with JConran on12/2/93 which were confirmed by DAllison on 12/3/93.*See previous concurrenceOTSB:DORSTGDunning*7/30/93PD4-2:DRPWWDReckley*9/10/93DOCUMENT:Tech EditorMMejac* f7/2t8/93fRR{E~r~s12/249393-07.GLSC:OTSB:DORSFMReinhart*8/9/93OGCSATreby*9/14/93C:OTSB:DORSCIGrimes*9/7/93ADPR kLJCallan12 tZZ/93C:OGCB:DORSGHMarcus*9/9/93