Information Notice 1986-83, Underground Pathways Into Protected Areas, Vital Areas, Material Access Areas, & Controlled Access Areas
| ML031250275 | |
| Person / Time | |
|---|---|
| Issue date: | 09/19/1986 |
| From: | Jordan E NRC/IE |
| To: | |
| References | |
| IN-86-083, NUDOCS 8609170346 | |
| Download: ML031250275 (4) | |
-'- SSINS No.: 6835 IN 86-83 UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555 September 19, 1986 IE INFORMATION NOTICE NO. 86-83: UNDERGROUND PATHWAYS INTO PROTECTED AREAS,
VITAL AREAS, MATERIAL ACCESS AREAS, AND
CONTROLLED ACCESS AREAS
Addressees
All nuclear power reactor facilities holding an operating license or construction
permit and fuel fabrication and processing facilities using or possessing formula
quantities of special nuclear material.
Purpose
This notice is to advise licensees of the potential for undetected, unauthorized
access to controlled areas on the site through unprotected, underground pathways.
The existence of any unprotected underground pathway of the type described below
may be considered a violation and may be reportable to the NRC in accordance
with the appropriate sections of 10 CFR Part 73.
It is expected that the recipients of this notice will review the information
for applicability to their facilities and consider actions, if appropriate, to preclude similar problems from occurring at their facilities. However, suggestions contained in this information notice do not constitute NRC
requirements; therefore, no specific action or written response is required
at this time.
Description of Circumstances
There have been a number of recent discoveries by licensees and NRC inspectors
of underground pathways into protected areas (PAs), vital areas (VAs), material
access areas (MAAs), and controlled access areas (CAAs). These pathways are
normally some form of tunnel, pipe, or other design feature for which no
protection had been installed or from which the protective features have been
removed. (Protective features must provide a nonremovable physical obstacle
to attempted entry to, or exit from, the tunnel.) Because these penetrations
are often underground, traditional intrusion detection systems are ineffective
for monitoring unauthorized attempts at entry, and the existence of such a
pathway simultaneously defeats both the barrier and monitoring elements of
access control.
8609170346
IN 86-83 September 19, 1986 The following examples were discovered at various sites during
recent inspections:
1. Large piping used as part of the storm drain system led from
outside the
PA to inside the PA where numerous unsecured manhole covers
were located.
2. Personnel restraint bars which were required by design had
not been installed
in a 20-inch drain line penetrating a vital area barrier.
3. Personnel restraint features installed in a heating, ventilating, and air
conditioning system had only bolted covers which failed to
meet the standards
for physical barriers, thereby reducing the overall level
of security.
4. Two large storm drains penetrated the VA barrier and could
be accessed by
as many as 30 unsecured manholes and other openings inside
the PA. One of
the drain outfalls was covered by a grate that was secured
by four bolts
into the concrete, but bolts had not been welded or peened
over and were
accessible for easy removal by a hand wrench. The other
could be accessed
through two manholes secured only with a metal strap and
brass shackled
locks.
5. A drainage pipe extended from outside the PA into the PA.
The manhole cover
intended to seal the opening inside the PA had originally
been welded closed, but traffic over the grate had broken the weld.
Discussicon:
Improperly secured underground pathways into PAs and VAs pose
a potentially
significant threat to site security because they allow unauthorized
and
undetected access. The seriousness of the threat is determined
by the physical
characteristics of the pathway, which include the type of entry
as well as
impediments to entry.
Vital area barriers are expected to completely enclose vital
equipment to prevent
the introduction of objects and materials useful in sabotage
as well as to
preclude unauthorized access by individuals. Therefore, any
opening that reduces
effectiveness of the barrier would be unacceptable.
Any breach of a PA barrier that exceeds the industry standards
of 96 square
inches with at least one dimension greater than 6 inches (as
referenced in
NUREG-0908 and ANSI 3.3) is considered to be sufficient to
allow the unauthor- ized entry of an individual. Therefore, openings into or out
of tunnels that
cross PA physical barriers may not exceed the 96-square-inch
standard. Openings
include the open ends of the tunnel, removable grates and
manholes, and gaps in
the grates and manholes.
IN 86-83 September 19, 1986 However, the 96-square-inch standard applies only to two-dimensional openings
and may not apply to large pipes and tunnels. Tunnels may be slightly larger
than 96 square inches cross-section (11.04-inch diameter) and still preclude
passage to a controlled area because its length and circuitous route may make
it impossible for an intruder to move along the interior of the tunnel in such
a small area.
It is suggested that licensees review their physical barriers for suspected
penetrations to assure that they conform to existing requirements. It is
advisable that any variation from the 96-square-inch standard be documented
and appended to the physical security plan (PSP). It is suggested that these
situations be evaluated and that a determination be made as to whether operational
or physical impediments to entry should be installed.
Continuous operational impediments to entry include such things as continuous
flushing, high pressure areas, or other activity that would prevent a person
from using the tunnel. Discontinuous or random operational impediments cannot
adequately preclude unauthorized entry.
Physical impediments to entry can include bars installed in the tunnel to reduce
the size of the opening; grates or covers that are locked and alarmed, welded, or permanently installed in a way that precludes the entry of a person;
bottlenecks in the tunnel; pipe bundles installed inside the tunnel; or other
devices that form a barrier between the areas. Note that physical impediments
must have penetration resistance equivalent to that specified in 10 CFR 73.2- for physical barriers.
No written response to this information notice is required. If you need additional
information about this matter, please contact the Regional Administrator of the
appropriate NRC regional office or the technical contact listed below.
0wardi Director
Divis of Emergency Preparedness
and ngineering Response
Office of Inspection and Enforcement
Technical Contact:
Dick Rosano, IE
(301) 492-4006 Attachment: List of Recently Issued IE Information Notices
Attachment I
IN 86-83 September 19. 1986 LIST OF RECENTLY ISSUED
IE INFORtATION NOTICES
Tht
Toratio Date of
Notice No. Subject Issue Issued to
86-82 Failures Of Scram Discharge 9/16/86 All power reactor
Volume Vent And Drain Valves facilities holding
86-81 Broken Inner-External Closure 9/15/86 All power reactor
Springs On Atwood & Morrill facilities holding
Main Steam Isolation Valves an OL or CP
86-80 Unit Startup With Degraded 9/12/86 All power reactor
High Pressure Safety Injection facilities holding
86-79 Degradation Or Loss Of 9/2/86 All power reactor
Charging Systems At PWR facilities holding
Nuclear Power Plants Using an OL or CP
Swing-Pump Designs
86-78 Scram Solenoid Pilot Valve 9/2/86 All 8WRfacilities
(SSPV) Rebuild Kit Problems holding an OL or CP
r1
86-77 Computer Program Error Report 8/28/86 All power reactor
Handling facilities holding
nuclear fuel man- ufacturing facilities
86-76 Problems Noted In Control 8/28/86 All power reactor
Room Emergency Ventilation facilities holding
86-75 Incorrect Maintenance 8/21/86 All power reactor
Procedure On Traversing facilities holding
Incore Probe Lines an OL or CP
86-74 Reduction Of Reactor Coolant 8/20/86 All 8WRfacilities
Inventory Because Of Misalign- holding an OL or CP
ment Of RHRValves
86-73 Recent Emergency Diesel 8/20/86 All power reactor
Generator Probleas--- - factl~tiaL holding
UNITED STATES
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