Information Notice 2008-10, Response to Indications of Potential Tampering, Vandalism, or Malicious Mischief
| ML093620107 | |
| Person / Time | |
|---|---|
| Issue date: | 05/01/2008 |
| From: | Pierson R NRC/NMSS/FCSS |
| To: | |
| acl2 | |
| References | |
| IN-08-010 | |
| Download: ML093620107 (8) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, DC 20555-0001 May 1, 2008 NRC INFORMATION NOTICE 2008-10 RESPONSE TO INDICATIONS OF POTENTIAL
TAMPERING, VANDALISM, OR MALICIOUS
MISCHIEF
ADDRESSEES
All fuel cycle facilities and uranium recovery licensees.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform
addressees of how important it is to recognize the early indications of possible acts of
tampering, vandalism, or malicious mischief, and to respond to them rapidly and appropriately.
It is expected that recipients will review this information, for applicability to their facilities, and
consider actions, as appropriate. However, suggestions contained in this IN are not NRC
requirements; therefore, no specific action or written response is required.
DESCRIPTION OF CIRCUMSTANCES
In August 2007, an incident occurred at an NRC-licensed fuel cycle facility, that highlights the
importance of recognizing the potential significance of early indications of tampering, vandalism, or malicious mischief. A licensee found a portable gamma monitor with a damaged cord. The
technician who found the monitor then performed a calibration check and discovered an
incorrect energy peak was programmed into the instrument. The technician entered the
problem into the corrective action program. The instrument had been calibrated 2 days earlier.
This incident and previous problems within this calibration lab, regarding unplugged or damaged
gamma monitors, caused the NRC Resident Inspector to raise the possibility of intentional
tampering. The licensee implemented corrective actions to investigate the occurrence, raise
employee awareness of vandalism, and verify that other instruments did not have evidence of
tampering. The licensee did not have formal instrument sign-out accountability. This instrument
was considered an item relied on for safety (IROFS) in the integrated safety analysis and
therefore had safety implications. However, the licensee believed the instrument could perform
its intended function in the as-found condition.
DISCUSSION
The significance of this issue is the importance of identifying the possibility of intentional
tampering with safety-significant plant equipment. Although there was no known compromise of
plant safety, since the instrument, in this case, was believed still capable of performing its
function, NRC still remains very concerned about possible tampering of IROFS
or with other security or safety-related equipment.
The potential implications of this incident include the following:
- Tampering, vandalism, or malicious mischief could have adverse impacts to plant operations
safety, and security;
- Incident investigations designed to identify and correct root causes of process and operational
safety concerns may not be adequate for identifying intentional acts; and
- The licensees staffs ability to identify the perpetrator of an intentional act and institute
protective measures diminishes as time elapses.
Some protective measures that recipients of this IN should consider taking include:
- Establishing a procedure/process to identify, evaluate, and follow up on possible tampering, vandalism, and malicious mischief incidents, and considering such factors as safety and
security significance, overtness, intent, sophistication of method, and history of similar incidents;
and
- Licensees periodically refreshing their Operations and Security staffs sensitivity to and
awareness of the process of evaluating deliberate acts, since the Operations staff may be the
first to encounter signs of tampering, vandalism, or malicious mischief during its tours and
surveillance activities.
- Consider additional control measures for IROFS as an impediment to tampering, vandalism
and malicious mischief.
Based on the events described above, licensees should consider implementing a program to
respond to indications of tampering, vandalism, or malicious mischief. Licensees should
evaluate, develop, or revise site policies and procedures, and train and educate all appropriate
facility personnel regarding the importance of recognizing potential signs of tampering, vandalism, or malicious mischief.
When assessing their programs, licensees should consider reviewing the guidance NRC had
previously issued in: (1) IN 96-71, Licensee response to indications of tampering, vandalism, or malicious mischief; (2) NUREG/CR-4462 PNL-5690, A ranking of sabotage/tampering
avoidance technology alternatives (1980s) ;and (3) IN 83-27; Operational response to events
concerning deliberate acts directed against plant equipment.
CONTACT
This IN does not require any specific action nor written response. Please direct any questions
about this matter to the technical contact listed below, or to the appropriate NRC project
manager.
/RA/
Robert C. Pierson, Director
Division of Fuel Cycle Safety
and Safeguards
Office of Nuclear Material Safety
and Safeguards
Technical Contact:
Amy Luebbering, NMSS
Phone: 301-492-3231 E-mail: acl2@nrc.gov
Attachment: List of Recently Issued NMSS Generic Communications
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
CONTACT
This IN does not require any specific action nor written response. Please direct any questions
about this matter to the technical contact listed below, or to the appropriate NRC project
manager.
/RA/
Robert C. Pierson, Director
Division of Fuel Cycle Safety
and Safeguards
Office of Nuclear Material Safety
and Safeguards
Technical Contact:
Amy Luebbering, NMSS
Phone: 301-492-3231 E-mail: acl2@nrc.gov
Attachment: List of Recently Issued Generic Communications
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
OFC FCSS Tech Ed FSME FCSS FCSS
NAME ALuebbering EKraus AMcIntosh PHabighorst MTschiltz
DATE 10/ 25 /07 10/ 29 /07 11/ 06 /07 10/ 25 /07 11/ 07 /07 OFC NRR/DPR RII via email NSIR NSIR
NAME DCollins DDorman THolahan RPierson
DATE 11/ 06 /07 11/09/07 11/13/07 5/01/08 OFFICAL RECORD DOCUMENT Recently Issued FSME/NMSS Generic Communications
Date GC No. Subject
Addressees
02/02/07 IN-07-03 Reportable Medical Events Involving All U.S. Nuclear Regulatory Commission
Patients Receiving Dosages of medical use licensees and NRC Master
Sodium Iodide Iodine-131 less than Materials Licensees. All Agreement State
the Prescribed Dosage Because of Radiation Control Program Directors and
Capsules Remaining in Vials after State Liaison Officers.
Administration
02/28/07 IN-07-08 Potential Vulnerabilities of Time- All U. S. Nuclear Regulatory Commission
reliant Computer-based Systems licensees and all Agreement State
Due to Change in Daylight Saving Radiation Control Program Directors and
Time Dates State Liaison Officers.
03/13/07 IN-07-10 Yttrium-90 Theraspheres and All U.S. Nuclear Regulatory Commission
Sirspheres Impurities (NRC) Medical Licensees and NRC Master
Materials Licensees. All Agreement State
Radiation Control Program Directors and
State Liaison Officers.
04/04/07 IN-07-13 Use of As-Found Conditions to All licensees authorized to possess a
Evaluate Criticality-related Process critical mass of special nuclear material.
Upsets at Fuel Cycle Facilities
05/02/07 IN-07-16 Common Violations of the Increased All licensees who are implementing the
Controls Requirements and Related U.S. Nuclear Regulatory Commission
Guidance Documents (NRC) Order Imposing Increased Controls
(EA-05-090), issued November 14, 2005 and December 22, 2005.
05/21/07 IN-07-19 Fire Protection Equipment Recalls All holders of operating licenses for nuclear
and Counterfeit Notices power reactors and fuel cycle facilities;
except those licensees for reactors that
have permanently ceased operations and
who have certified that fuel has been
permanently removed from the reactor
vessel; and except those licensees for
decommissioned fuel cycle facilities.
06/11/07 IN-07-20 Use of Blank Ammunition All power reactors, Category I fuel cycle
facilities, independent spent fuel storage
installations, conversion facility, and
gaseous diffusion plants. Date GC No. Subject
Addressees
07/19/07 IN-07-25 Suggestions from the Advisory All U.S. Nuclear Regulatory Commission
Committee on the Medical Use of (NRC) medical-use licensees and NRC
Isotopes For Consideration to Master Materials Licensees. All Agreement
Improve Compliance With Sodium State Radiation Control Program Directors
Iodide I-131 Written Directive and State Liaison Officers.
Requirements in 10 CFR 35.40 and
Supervision Requirements in 10
CFR 35.27
08/08/07 IN-07-23 Inadvertent Discharge of Halon All holders of operating licenses for nuclear
1301Fire-suppression System from power reactors, except those who have
Incorrect and/or Out-of-date permanently ended operations and have
Procedures certified that fuel has been permanently
removed from the reactor vessel. All
holders of licenses for fuel cycle facilities.
08/13/07 IN-07-26 Combustibility of Epoxy Floor All holders of operating licenses for nuclear
Coatings at Commercial Nuclear power reactors and fuel cycle facilities
Power Plants except licensees for reactors that have
permanently ceased operations and who
have certified that fuel has been
permanently removed from the reactor
vessel.
09/13/07 IN-07-30 Radiological Controls Create All licensees authorized to possess a
Criticality Safety Accident Scenario critical mass of special nuclear material.
for Fissile Solution Container
Transport at Fuel Cycle Facility
09/28/07 IN-07-33 Exposures To Members Of The All U.S. Nuclear Regulatory Commission
Public Caused By Inadequate Well Logging Licensees. All Agreement
Controls Over Well Logging State Radiation Control Program Directors
Sources and State Liaison Officers.
10/15/07 IN-07-32 Out-of-Service Equipment All licensees authorized to possess a
Connected to In-service Process critical mass of special nuclear material
Line Results in Fissile Solution Spill
at Fuel Cycle Facility
10/17/07 IN-07-35 Varian Medical Systems All U.S. Nuclear Regulatory Commission
Varisource HDR Events: medical use licensees and NRC Master
Iridium-192 Source Pulled From Materials Licensees authorized to possess
Shielded Position or use a Varian Medical Systems
VariSource High Dose Rate Remote
Afterloader (VariSource HDR). All
Agreement State Radiation Control
Program Directors and State Liaison
Officers.
03/01/07 RIS-07-03 Ionizing Radiation Warning Symbol All U.S. Nuclear Regulatory Commission
licensees and certificate holders. All
Radiation Control Program Directors and
State Liaison Officers Date GC No. Subject
Addressees
03/09/07 RIS-07-04 Personally Identifiable Information All holders of operating licenses for nuclear
Submitted to the U.S. Nuclear power reactors and holders of and
Regulatory Commission applicants for certificates for reactor
designs. All licensees, certificate holders, applicants, and other entities subject to
regulation by the U.S. Nuclear Regulatory
Commission of the use of source, byproduct, and special nuclear material
03/20/07 RIS-07-05 Status and Plans for Implementation All NRC materials licensees, Radiation
of NRC Regulatory Authority for Control Program Directors, State Liaison
Certain Naturally-occurring and Officers, and NRCs Advisory Committee
Accelerator-produced Radioactive on the Medical Uses of Isotopes
Material
04/05/07 RIS-07-07 Clarification of Increased Controls All U.S. Nuclear Regulatory Commission
for Licensees That Possess (NRC) licensees issued NRCs Order
Collocated Radioactive Material Imposing Increased Controls and all
During Transportation Activities Radiation Control Program Directors and
State Liaison Officers
05/04/07 RIS-07-09 Examples of Recurring Requests for All holders of, and applicants for, a: (1) 10
Additional Information (RAIs) for 10 CFR Part 71 certificate of compliance
CFR Part 71 and 72 Applications (CoC) for a radioactive material
transportation package; (2) 10 CFR Part 72 CoC for a spent fuel storage cask; and (3)
10 CFR Part 72 specific license for an
independent spent fuel storage installation
(ISFSI).
06/27/07 RIS-06-27, Availability of NRC 313A Series of All U.S. Nuclear Regulatory Commission
Suppl. 1 Forms and Guidance for Their (NRC) medical-use licensees and NRC
Completion Master Materials licensees. All Radiation
Control Program Directors and State
Liaison Officers.
05/15/07 RIS-07-10 Subscriptions To New List Server
For Automatic Notifications Of All U.S. Nuclear Regulatory Commission
Medical-Related Generic (NRC) medical-use licensees and NRC
Communications, Federal Register Master Materials licensees. All Radiation
Notices And Newsletters Control Program Directors and State
Liaison Officers. Date GC No. Subject
Addressees
08/31/07 RIS-07-13 Verification of the Authenticity of All U.S. Nuclear Regulatory Commission
Materials Possession Licenses materials licensees. All Agreement State
Radiation Control Program Directors and
State Liaison Officers.
09/07/07 RIS-07-18 Data for Updating the Interim All U.S. Nuclear Regulatory Commission
Inventory of Radioactive Sources (NRC) Part 40, Part 50, Part 70, Part 72, and Part 76 licensees and certificate
holders who are authorized to possess
sources of radioactive material
at the Category 3.5" (as defined below)
activity or higher.
10/04/07 RIS-07-22 Status Update For Implementation All U.S. Nuclear Regulatory Commission
Of Nrc Regulatory Authority for materials licensees, radiation control
Certain Naturally-Occurring and program directors, State liaison officers, Accelerator-Produced Radioactive and the NRCs Advisory Committee on the
Material Medical Uses of Isotopes.
10/04/07 RIS-07-23 Date For Operation Of National All licensees authorized to possess
Source Tracking System Category 1 or Category 2 quantities of
radioactive materials.
All Radiation Control Program Directors
and State Liaison Officers.
Note: A full listing of generic communications may be viewed at the NRC public website at the following address:
http://www.nrc.gov/Electronic Reading Room/Document Collections/Generic Communications