Information Notice 2008-10, Response to Indications of Potential Tampering Vandalism or Malicious Mischief
| ML072970816 | |
| Person / Time | |
|---|---|
| Issue date: | 05/01/2008 |
| From: | Pierson R C NRC/NMSS/FCSS |
| To: | |
| References | |
| IN-08-010 | |
| Download: ML072970816 (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 staff's 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 staff's 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 (1980's)" ;and (3) IN 83-27; "Operational response to events concerning deliberate acts directed against plant equipment."
IN 2008- 10
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.
ML072970816 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 NRR/DPR RII via emailNSIR NSIR NAME DBeaulieu DCollins DDorman THolahan RPierson DATE 11/ /07 11/ 06 /07 11/09/07 11/13/07 5/01/08 OFFICAL RECORD DOCUMENT
Enclosure IN 2008-XX Recently Issued FSME/NMSS Generic Communications
Date GC No. Subject
Addressees
02/02/07 IN-07-03 Reportable Medical Events Involving Patients Receiving Dosages of
Sodium Iodide Iodine-131 less than
the Prescribed Dosage Because of Capsules Remaining in Vials after Administration
All U.S. Nuclear Regulatory Commission medical use licensees and NRC Master
Materials Licensees. All Agreement State
Radiation Control Program Directors and State Liaison Officers. 02/28/07 IN-07-08 Potential Vulnerabilities of Time-reliant Computer-based Systems
Due to Change in Daylight Saving
Time Dates All U. S. Nuclear Regulatory Commission licensees and all Agreement State
Radiation Control Program Directors and
State Liaison Officers. 03/13/07 IN-07-10 Yttrium-90 Theraspheres
and Sirspheres
Impurities All U.S. Nuclear Regulatory Commission (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 Evaluate Criticality-related Process
Upsets at Fuel Cycle Facilities All licensees authorized to possess a critical mass of special nuclear material. 05/02/07 IN-07-16 Common Violations of the Increased Controls Requirements and Related
Guidance Documents All licensees who are implementing the U.S. Nuclear Regulatory Commission
(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 and Counterfeit Notices All holders of operating licenses for nuclear 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.
Enclosure IN 2008-XX Date GC No. Subject
Addressees
07/19/07 IN-07-25 Suggestions from the Advisory Committee on the Medical Use of Isotopes For Consideration to Improve Compliance With Sodium
Iodide I-131 Written Directive
Requirements in 10 CFR 35.40 and Supervision Requirements in 10 CFR 35.27 All U.S. Nuclear Regulatory Commission (NRC) medical-use licensees and NRC Master Materials Licensees. All Agreement State Radiation Control Program Directors
and State Liaison Officers. 08/08/07 IN-07-23 Inadvertent Discharge of Halon 1301Fire-suppression System from Incorrect and/or Out-of-date
Procedures All holders of operating licenses for nuclear power reactors, except those who have permanently ended operations and have
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 Coatings at Commercial Nuclear Power Plants All holders of operating licenses for nuclear power reactors and fuel cycle facilities 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 Criticality Safety Accident Scenario for Fissile Solution Container
Transport at Fuel Cycle Facility
All licensees authorized to possess a critical mass of special nuclear material. 09/28/07 IN-07-33 Exposures To Members Of The Public Caused By Inadequate
Controls Over Well Logging Sources All U.S. Nuclear Regulatory Commission Well Logging Licensees. All Agreement
State Radiation Control Program Directors and State Liaison Officers. 10/15/07 IN-07-32 Out-of-Service Equipment Connected to In-service Process Line Results in Fissile Solution Spill at Fuel Cycle Facility All licensees authorized to possess a critical mass of special nuclear material 10/17/07 IN-07-35 Varian Medical Systems Varisource HDR Events: Iridium-192 Source Pulled From Shielded Position All U.S. Nuclear Regulatory Commission medical use licensees and NRC Master Materials Licensees authorized to possess 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
Enclosure IN 2008-XX Date GC No. Subject
Addressees
03/09/07 RIS-07-04 Personally Identifiable Information Submitted to the U.S. Nuclear Regulatory Commission All holders of operating licenses for nuclear power reactors and holders of and 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 of NRC Regulatory Authority for Certain Naturally-occurring and
Accelerator-produced Radioactive
Material All NRC materials licensees, Radiation Control Program Directors, State Liaison Officers, and NRC's Advisory Committee
on the Medical Uses of Isotopes 04/05/07 RIS-07-07 Clarification of Increased Controls for Licensees That Possess
Collocated Radioactive Material During Transportation Activities All U.S. Nuclear Regulatory Commission (NRC) licensees issued NRC's Order
Imposing Increased Controls and all Radiation Control Program Directors and State Liaison Officers 05/04/07 RIS-07-09 Examples of Recurring Requests for Additional Information (RAIs) for 10
CFR Part 71 and 72 Applications All holders of, and applicants for, a: (1) 10 CFR Part 71 certificate of compliance
(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, Suppl. 1 Availability of NRC 313A Series of Forms and Guidance for Their
Completion All U.S. Nuclear Regulatory Commission (NRC) medical-use licensees and NRC
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 Medical-Related Generic
Communications, Federal Register
Notices And Newsletters
All U.S. Nuclear Regulatory Commission (NRC) medical-use licensees and NRC
Master Materials licensees. All Radiation
Control Program Directors and State
Liaison Officers.
Enclosure IN 2008-XX Date GC No. Subject
Addressees
08/31/07 RIS-07-13 Verification of the Authenticity of Materials Possession Licenses All U.S. Nuclear Regulatory Commission materials licensees. All Agreement State Radiation Control Program Directors and State Liaison Officers. 09/07/07 RIS-07-18 Data for Updating the Interim Inventory of Radioactive Sources All U.S. Nuclear Regulatory Commission (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 Of Nrc Regulatory Authority for Certain Naturally-Occurring and Accelerator-Produced Radioactive Material All U.S. Nuclear Regulatory Commission materials licensees, radiation control program directors, State liaison officers, and the NRC's Advisory Committee on the Medical Uses of Isotopes. 10/04/07 RIS-07-23 Date For Operation Of National Source Tracking System All licensees authorized to possess 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