Inconsistency Between Requirements of 10 Cfr 73.40(d) and Standard Technical Specifications for Performing Audits of Safeguards Contingency Plans (Security Plan) (Generic Letter No. 82-23)

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                           WASHINGTON, D.C. 20555
                                     
                               October 30 1982

TO ALL LICENSEES AND APPLICANTS FOR OPERATING POWER REACTORS AND HOLDERS OF 
CONSTRUCTION PERMITS FOR POWER REACTORS 

Gentlemen: 

SUBJECT:  INCONSISTENCY BETWEEN REQUIREMENTS OF 10 CFR 73.40(d) AND  
          STANDARD TECHNICAL SPECIFICATIONS FOR PERFORMING AUDITS OF 
          SAFEGUARDS CONTINGENCY PLANS (SECURITY PLAN) (Generic Letter No. 
          82-23) 

Section 73.40(d) of Title 10 of the Code of Federal Regulations requires 
that each nuclear power reactor licensee provide for an independent review 
of its safeguards contingency plan at least every 12 months. 

It has come to our attention that the Standard Technical Specifications in 
use by a number of licensees and some existing plant-specific Technical 
Specifications require that this independent audit be carried out every 24 
months. 

All licensees are required to meet the requirements of 10 CFR 73.40(d), 
notwithstanding any provision that may have been in their Technical 
Specifications prior to the issuance of 10 CFR 73.40(d) or that have been 
added since its issuance. 

Accordingly, you are requested to assure that your provisions for carrying 
out an independent audit of your safeguards contingency plan is in 
accordance with 10 CFR 73.40(d). If your Technical Specifications contain a 
provision that is less frequent than the regulations, you should request the 
staff to modify your technical specifications to conform to the rule. 

Because this Technical Specification is clarifying and made at the request 
of the Commission, you are not required to remit a license fee for the 
change. 

This request has been approved by OMB Clearance Number 3150-0002, which 
expires May 31, 1983. 

                                   Sincerely, 


                                   Darrell G. Eisenhut, Director 
                                   Division of Licensing 



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