Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
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
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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
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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.
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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.
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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.
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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.
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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.)
