United States Nuclear Regulatory Commission - Protecting People and the Environment

Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans (Generic Letter 93-07)



December 28, 1993


TO:       ALL HOLDERS OF OPERATING LICENSES FOR NUCLEAR POWER REACTORS

SUBJECT:  MODIFICATION OF THE TECHNICAL SPECIFICATION ADMINISTRATIVE CONTROL  
          REQUIREMENTS FOR EMERGENCY AND SECURITY PLANS (Generic Letter 93-07)


The U.S. Nuclear Regulatory Commission (NRC) is issuing this guidance for
changes to technical specifications (TS) to remove the audit of the emergency
and security plans and implementing procedures from the list of responsibil-
ities of the company nuclear audit and review group.  Parts 50 and 73 of
Title 10 of the Code of Federal Regulations (10 CFR) include provisions that
are sufficient to address these requirements (see Enclosure 1).  Also, this
guidance will allow TS changes to remove (1) the review of the emergency and
security plans from the list of responsibilities of the unit review group and
(2) the requirements for the unit review group to review procedures, and
procedure changes, for the implementation of the emergency and security plans,
provided the licensee relocates these requirements to the respective emergency
and security plans.  The NRC developed this line-item TS improvement in
response to a proposal by the Duke Power Company to amend the operating
licenses of its plants.  

Enclosure 2 contains sample TS requirements that have been marked to show the
requirements that may be removed.  Licensees should retain these audit and
review activities in a manner that fully satisfies the regulatory requirements
that are summarized in Enclosure 1.  Although the TS change removes
requirements that are specific with regard to providing a plant operations
perspective in the review and audit of emergency and security plans and
implementing procedures, the NRC staff is not suggesting that licensees remove
reviewers or auditors with this perspective when satisfying the regulatory
requirements for these activities.  

Licensees that plan to adopt this line-item TS improvement are encouraged to
propose TS changes consistent with the enclosed guidance.  NRC project
managers will review the amendment requests to verify that they conform to the
guidance.  Please contact your project manager or the contact indicated herein
if you have any questions on this matter.  

Licensee action to propose TS changes under the guidance of this generic
letter is voluntary.  Therefore, such action is not a backfit under the
provisions of 10 CFR 50.109.  The following information, although not
requested under the provisions of 10 CFR 50.54(f), would help the NRC evaluate
costs and benefits for licensees who propose the TS changes described in this
generic letter:

  • licensee time and costs to prepare the amendment request
  • estimate of the long-term costs or savings accruing from this TS change
9312170111 . Generic Letter 93-07 - 2 - December 28, 1993 The voluntary information collections contained in this request are covered by the Office of Management and Budget clearance number 3150-0011, which expires June 30, 1994. The public reporting burden for this voluntary collection of information is estimated to average 40 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this voluntary collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch (MNBB-7714), U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-3019, (3150-0011), Office of Management and Budget, Washington, D.C. 20503. Sincerely, /S/'D BY LJCALLAN L. J. Callan Acting Associate Director for Projects Office of Nuclear Reactor Regulation Enclosures: 1. A Summary of Regulatory Requirements for Emergency and Security Plan in Title 10 of the Code of Federal Regulations 2. Model Technical Specifications Administrative Control Requirements for Security and Emergency Plans 3. List of Recently Issued NRC Generic Letters Technical contact: T. G. Dunning, NRR (301) 504-1189 . Generic Letter 93-07 Enclosure 1 A Summary of Regulatory Requirements for Emergency and Security Plans in Title 10 of the Code of Federal Regulations Emergency Plan Section 50.54(q) includes the following statement: A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements in Appendix E of this part. Section V, "Implementing Procedures," of Appendix E to Part 50 includes the following statement: No less than 180 days prior to the scheduled issuance of an operating license for a nuclear power reactor or a license to possess nuclear material the applicant's detailed implementing procedures for its emergency plan shall be submitted to the Commission as specified in 50.4. Licensees who are authorized to operate a nuclear power facility shall submit any changes to the emergency plan or procedures to the Commission, as specified in 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 development, revision, implementation, and maintenance of its emergency preparedness program. To this end, the licensee shall provide for a review of its emergency preparedness program at least every 12 months by persons who have no direct responsibility for implementation of the emergency preparedness program. The review shall include an evaluation for adequacy of interfaces with State and local governments and of licensee drills, exercises, capabilities, and procedures. The results of the review, along with recommendations for improvements, shall be documented, reported to the licensee's corporate and plant management, and retained for a period of five years. Security Plan Section 50.54(p)(1) includes the following statement: The licensee shall prepare and maintain safeguards contingency plan procedures in accordance with Appendix C of Part 73 of this chapter for effecting the actions and decisions contained in the Responsibility Matrix of the safeguards contingency plan. . Generic Letter 93-07 - 2 - Enclosure 1 Section 50.54(p)(3) includes the following statement: The licensee shall provide for the development, revision, implementation and maintenance [sic] of its safeguards contingency plan. To this end, the licensee shall provide for a review at least every 12 months of the safeguards contingency plan by individuals independent of both security program management and personnel who have direct responsibility for implementation of the security program. The review must include a review and audit of safeguards contingency procedures and practices.... The results of the review and audit, along with recommendations for improve ments, must be documented, reported to the licensee's corporate and plant management, and kept available at the plant for inspection 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 the development, revision, implementation, and enforcement of security procedures. The system shall include: (i) Written security procedures that document the structure of the security organization and detail the duties of guards, watchmen, and other individuals responsible for security. The licensee shall maintain a copy of the current procedures as a record until the Commission terminates each license for which the procedures were developed and, if any portion of the procedure is superseded, retain the superseded material for three years after each change. (ii) Provisions for written approval of these procedures and any revisions to the procedures by the individual with overall responsibility for the security functions. The licensee shall retain each written approval as a record for three years from the date of the approval. Section 73.55(g)(4) includes the following statement: The security program must be reviewed at least every 12 months by individuals independent of both security program management and personnel who have direct responsibility for implementation of the security program. The security program review must include an audit of security procedures and practices.... The results and recommendations of the security program review, management's findings on whether the security program is currently effective, and any actions taken as a result of recommendations from prior program reviews must be documented in a report to the licensee's plant manager and to corporate management at least one level higher than that having responsibility for the day-to-day plant operation. These reports must be maintained in an auditable form, available for inspection, for a period of 3 years. . Generic Letter 93-07 - 3 - Enclosure 1 Section 73.56(g)(1) includes the following statement: Each licensee shall audit its access authorization program within 12 months of the effective date of implementation of this program and at least every 24 months thereafter to ensure that the requirements of this section are satisfied. Section 73.56(g)(2) includes the following statement: Each licensee who accepts the access authorization program of a contractor or vendor as provided for by paragraph (a)(4) of this section shall have access to records and shall audit contractor or vendor programs every 12 months to ensure that the requirements of this 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 three years. . Generic Letter 93-07 Enclosure 2 Model Technical Specifications Administrative Control Requirements for Security and Emergency Plans (Modified as Shown) The following model technical specifications are derived from the "Standard Technical Specifications for Westinghouse Pressurized Water Reactors," NUREG-0452, Revision 4a, and are an example for the types of changes that may be proposed for plant TS that are different in wording or format. 6.5.1 [UNIT REVIEW GROUP (URG)] RESPONSIBILITIES 6.5.1.1 through 6.5.1.5 (No change.) 6.5.1.6 The [URG] shall be responsible for: a. through h. (No change.) i. Not used. * (Previously read: Review of the Security Plan and implementing procedures and submittal of recommended changes to the [Company Nuclear Review and Audit Group];) j. Not used. (Previously read: Review of the Emergency Plan and implementing procedures and submittal of recommended changes to the [Company Nuclear Review and Audit Group];) k. and l. (No change.) 6.5.2 [COMPANY NUCLEAR REVIEW AND AUDIT GROUP (CNRAG)] 6.5.2.1 through 6.5.2.7 (No change.) AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the [CNRAG]. These audits shall encompass: a. through d. (No change.) e. Not used. (Previously read: The Security Plan and implementing procedures at least once per 24 months.) f. Not used. (Previously read: The Emergency Plan and implementing procedures at least once per 24 months.) g. through j. (No change.) _______________ *Deleted sections are noted as "Not used" to avoid renumbering sections. . Generic Letter 93-07 - 2 - Enclosure 2 6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below: a. and b. (No change.) c. Not used. (Previously read: Security Plan implementation.) d. Not used. (Previously read: Emergency Plan implementation.) e. through g. (No change.) 6.8.2 Each procedure of Specification 6.8.1, and change thereto, shall be reviewed 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 for items c and d and the provisions of Specification 6.8.2 are to be relocated to the security and emergency plans as applicable.)
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