DC Cook is reviewing the requirements for performing an annual review/audit of the SNM system.

Previously, 10CFR70.58.c.2 stated: "Provision for a review at least every 12 months of the nuclear material control system by individuals independent of both nuclear material control management and..."

ANSI N15.8-1974, Nuclear Material Control Systems for Nuclear Power Plants, stated: "10. System Review and Audit Procedures shall be established for a review, no less often than annually, of the nuclear material control system. Such a review shall include an audit of the nuclear materials records by individuals responsible to the utility management and independent of both nuclear material control management personnel and..."

ANSI N15.8-2009, Special Nuclear Material Control and Accounting Systems for Nuclear Power Plants, states "12 System Review and Assessment Review of the SNM program should be conducted periodically. The results of the review should be documented and reported in accordance with the requirements of the utility?s quality assurance or self-assessment program."

However, 10CFR70.58 has been deleted and referenced to 10CFR74. However, I don't see 10CFR74 covering a Power Plant.

Does anyone know where there is a requirement to do a annual audit/review of the SNM program?

If there isn't one anymore, are you still doing them?

thanks

Glen M Bradham, 269-465-5901 X1538

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