ML12276A269
| ML12276A269 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/01/2012 |
| From: | Mahesh Chawla Plant Licensing Branch III |
| To: | Hassoun A Detroit Edison, Co |
| Chawla M | |
| References | |
| Download: ML12276A269 (3) | |
Text
file:///Cl/...rary%20File/Request%20for%20Additional%20Information%20for%20Fermi%202%20Security%20Plan%20Revision%2014.htm[10/2/2012 1:58:24 PM]
From: Chawla, Mahesh Sent: Monday, October 01, 2012 1:37 PM To: Alan I Hassoun Cc: Costa, Richard; Beltz, Terry
Subject:
Request for Additional Information for Fermi 2 Security Plan Revision 14
By letter dated August 1, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12219A359), Detroit Edison Company, (the licensee) submitted the Fermi Nuclear Power Plants Physical Security Plan (PSP), Training and Qualification Plan, and Safeguards Contingency Plan, Revision 14. The enclosure to the letter contained Safeguards Information and has been withheld from public disclosure. The U.S.
Nuclear Regulatory Commission staff is currently reviewing the submittal to ensure compliance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(p)(2). The NRC staff has determined that the additional information requested below is needed to complete its review. Please provide your response within 30 days of the receipt of this request. Also, let us know if you would like to discuss this with the NRC staff.
- 1. In section 4.1 of the PSP, the security organization is described. In the second full paragraph on page 4 and throughout the security plans, the term team is replaced with force. This change was not described in the Revision Summary that was provided with the revision. Provide the rationale for this change.
Regulatory Basis:
Consistent with 10 CFR 50.54(p)(2), the licensee may make changes to the plans referenced in paragraph (p)(1) of this sections, without prior Commission approval if the changes do not decrease the safeguards effectiveness of the plan. The licensee shall maintain records of changes to the plans made without prior Commission approval for a period of 3 years from the date of the change, and shall submit, as specified in §50.4 or §52.3 of this chapter, a report containing a description of each change within 2 months after the change is made.
- 2. Section 11.3 of the PSP describes protected area (PA) barriers at the site. On pages 10-12 of Revision 13 of the PSP, there was a list of items associated with the PA barrier. This list is not found in Revision
- 14. While the Revision Summary lists this change, it provides no rationale for the change. Provide the rationale for this change and how this change was evaluated to ensure it complies with 50.54(p)(2).
Regulatory Basis:
Consistent with 10 CFR 50.54(p)(2), the licensee may make changes to the plans referenced in paragraph (p)(1) of this sections, without prior Commission approval if the changes do not decrease the safeguards effectiveness of the plan. The licensee shall maintain records of changes to the plans made without prior Commission approval for a period of 3 years from the date of the change, and shall submit, as specified in §50.4 or §52.3 of this chapter, a report containing a description of each change within 2 months after the change is made.
- 3. Section 14.4.4 of the PSP describes vehicle searches at the protected area. The language in this section was changed to account for Security Frequently Asked Question (SFAQ) 12-06. However, the language in the PSP does not include the acceptable methodology described in the resolution to SFAQ 12-06 to maintain integrity of the search for the armed security officer. Describe the specific proceduralized security measures (as specified in section 14.4.4 of the PSP) used to maintain the integrity of the search performed on armed security officers and how this process meets the requirements of 10 CFR 73.55(h)(3)(i). Additionally, appropriate changes should be made during the next revision of the sites security plans to ensure the language clearly and fully describes the search process for armed security officers at the protected area.
Regulatory Basis:
file:///Cl/...rary%20File/Request%20for%20Additional%20Information%20for%20Fermi%202%20Security%20Plan%20Revision%2014.htm[10/2/2012 1:58:24 PM]
Consistent with 10 CFR 73.55(c)(1), licensee security plans must describe: (i) how the licensee will implement requirements of this section through the establishment and maintenance of a security organization, the use of security equipment and technology, the training and qualification of security personnel, the implementation of predetermined response plans and strategies, and the protection of digital computer and communication system and networks.
Consistent with 10 CFR 73.55(h)(3), protected area searches, licensees shall search all personnel, vehicles and materials requesting access to protected areas, (i), the search for firearms, explosives, incendiary devices, or other items which could be used to commit radiological sabotage shall be accomplished through the use of equipment capable of detecting these items, or through visual and physical searches, or both, to ensure that all items are clearly identified before granting access to protected areas. The licensee shall subject all persons except official Federal, state, and local law enforcement personnel on official duty to these searches upon entry to the protected area. Armed security officers who are on duty and have exited the protected area may re-enter the protected area without being searched for firearms.
- 4. Section 15.1 of the PSP describes illumination at the site. Describe how the technology being used to augment site lighting for the assessment of the PA perimeter in no-light or low-light conditions meets the requirements of 10 CFR 73.55(e)(7)(i)(C), 73.55(i)(2), and 73.55(i)(3)(vii). See SFAQ 10-15.
Additionally, appropriate changes should be made during the next revision of the sites security plans to ensure the language clearly describes how the technology used to augment site illumination for the assessment of the PA perimeter in no-light or low light conditions meets the requirements specified above.
Regulatory Basis:
Consistent with 10 CFR 73.55(c)(1), licensee security plans must describe: (i) how the licensee will implement requirements of this section through the establishment and maintenance of a security organization, the use of security equipment and technology, the training and qualification of security personnel, the implementation of predetermined response plans and strategies, and the protection of digital computer and communication system and networks.
Consistent with 10 CFR 73.55(e)(7), isolation zone. (i), an isolation zone must be maintained in outdoor areas adjacent to the protected area barrier. The isolation zone shall be: (C) monitored with assessment equipment designed to satisfy the requirements of § 73.55(i) and provide real-time and play-back/recorded video images of the detected activities before and after each alarm annunciation.
Consistent with 10 CFR 73.55(i)(2), intrusion detection equipment must annunciate and video assessment equipment must display concurrently, in at least two continuously staffed onsite alarm stations, at least one of which must be protected in accordance with the requirements of the central alarms station within this section.
Consistent with 10 CFR 73.55(i)(3)(vii), the licensees intrusion detection and assessment system must be designed to ensure intrusion detection and assessment equipment at the protected area perimeter remains operable from an uninterruptible power supply in the event of the loss of normal power.
- 5. In section 7 of the SCP, the first paragraph on page C-33 describes a piece of intrusion detection equipment at the site. This piece of equipment is not described in the PSP. Describe the function of this piece of equipment within the physical protection program and how it is used to support the sites protective strategy. Also, describe how this intrusion detection equipment meets the requirements of 10 CFR 73.55(i), specifically, 73.55(i)(1) through 73.55(i)(3)(vi). Additionally, appropriate changes should be made during the next revision of the sites security plans to ensure the language clearly describes the function of this equipment and how the equipment meets the requirements of 10 CFR 73.55(i).
Regulatory Basis:
file:///Cl/...rary%20File/Request%20for%20Additional%20Information%20for%20Fermi%202%20Security%20Plan%20Revision%2014.htm[10/2/2012 1:58:24 PM]
Consistent with 10 CFR 73.55(c)(1), licensee security plans must describe: (i) how the licensee will implement requirements of this section through the establishment and maintenance of a security organization, the use of security equipment and technology, the training and qualification of security personnel, the implementation of predetermined response plans and strategies, and the protection of digital computer and communication system and networks.
Consistent with 10 CFR 73.55(i), detection and assessment systems, (1) the licensee shall establish and maintain intrusion detection and assessment systems that satisfy the design requirements of 10 CFR 73.55(b) and provide, at all times, the capacity to detect and assess unauthorized persons and facilitate the effective implementation of the licensees protective strategy.
Consistent with 10 CFR 73.55(i)(2) intrusion detection equipment must annunciate and assessment equipment shall display concurrently, in at least two continuously staffed onsite alarm stations, at least one of which must be protected in accordance with the requirements of the central alarm station within this section.
Consistent with 10 CFR 73.55(i)(3)(i) through (i)(3)(vi), the licensees intrusion detection and assessment systems must be designed to: (i) provide visual and audible annunciation of the alarm; (ii) provide a visual display from which assessment of the detected activity can be made; (iii) ensure that annunciation of an alarm indicates the type and location of the alarm; (iv) ensure that alarm devices to include transmission lines to annunciators are tamper indicating and self-checking; (v) provide an automatic indication when the alarm system or a component of the alarm system fails, or when the system is operating on the back-up power supply; (vi) support the initiation of a timely response in accordance with the security plans, protective strategy, and associated implementing procedures.