ML122780019

Draft RAI - Seabrook Security Plan

ML122780019
Person / Time
Site:	Seabrook
Issue date:	10/04/2012
From:	John Lamb Plant Licensing Branch 1
To:	Okeefe M NextEra Energy Seabrook
Lamb J
References
Download: ML122780019 (6)

Text

From:

Lamb, John Sent:

Thursday, October 04, 2012 6:55 AM To:

OKeefe, Michael Cc:

'Kilby, Gary'; 'Willoughby, Paul'; Khanna, Meena; Rockhill, Rupert

Subject:

For Your Review - DRAFT RAI - Seabrook Security Plan Importance:

High

Mike, Attached, for your review, is a DRAFT RAI regarding Seabrook Physical Security Plan, Revision

18. Please review to ensure that the questions are understandable, the regulatory basis is clear, there is no proprietary or safeguards information contained in the RAI, and to determine if the information was previously docketed. Please also let me know if you need a conference call and how much time NextEra needs to respond to the RAI.

Thanks.

John DRAFT RAI By letter dated August 1, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12216A086), NextEra Energy Seabrook, LLC, (the licensee) submitted the Seabrook Stations Physical Security Plan (PSP), Training and Qualification Plan (T&QP), and Safeguards Contingency Plan (SCP), Revision 18. The enclosure to the letter contained Safeguards Information and has been withheld from public disclosure. The U.S.

Nuclear Regulatory Commission (NRC) 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.

1. Section 11.1 of the PSP and Section 7 of the SCP include descriptions of the Security Owner Controlled Area (SOCA) barriers at the site. Describe how the intrusion detection and assessment equipment that is identified in Section 11.1 of the PSP and Section 7 of the SCP meets 10 CFR 73.55 requirements. Specifically:

a. Describe the function of the SOCA barrier by identifying how it and the associated intrusion detection and assessment capabilities are integrated within the physical protection program and protective strategy and how these capabilities are used to support the initiation of the protective strategy. Describe how the detection and assessment capability at the SOCA barrier facilitates the initiation of operator actions that are credited as target elements within target sets. Describe how the implementation of the SOCA barrier and associated intrusion detection and assessment equipment have been included in the drills and exercises of the sites protective strategy that have been conducted to meet the Performance Evaluation Program requirements of 10 CFR Part 73,

Appendix B VI, C.3. Describe the percentage of drills and exercises, conducted since implementation of the SOCA barrier, in which initiation of the protective strategy resulted from adversary detection at the SOCA barrier.

Regulatory Basis:

Consistent with 10 CFR 73.55(c)(3), the licensee shall establish, maintain, and implement a PSP which describes how the performance objective and requirements set forth in this section will be implemented.

Consistent with 10 CFR 73.55(e)(1)(ii), the licensee shall describe in the security plan, physical barriers, barrier systems, and their functions within the physical protection program.

b. Describe how the openings in the SOCA barrier are secured and monitored to prevent exploitation of the openings.

Regulatory Basis:

In accordance with 10 CFR 73.55(e)(4), consistent with the stated function to be performed, openings in any barrier or barrier system established to meet the requirements of this section must be secured and monitored to prevent exploitation of the opening.

c. Describe how personnel, vehicle, and material access through the SOCA barrier are controlled.

Regulatory Basis:

In accordance with 10 CFR 73.55(g)(1), consistent with the function of each barrier or barrier system, the licensee shall control personnel, vehicle, and material access, as applicable, at each access control point in accordance with the physical protection program design requirements of 10 CFR 73.55, and 10 CFR 73.55(g)(1).

d. Describe the personnel, vehicle and material access control portals of the SOCA barrier, specifically whether they are located outside of, or co-located with, the SOCA barrier.

Regulatory Basis:

Consistent with 10 CFR 73.55(g)(1)(i)(A), access control portals must be located outside of, or concurrent with, the physical barrier system through which it controls access.

e. Describe how the locking devices, intrusion detection equipment, and surveillance equipment implemented at the SOCA personnel, vehicle, and material access control portals meet regulatory requirements.

Regulatory Basis:

Consistent with 10 CFR 73.55(g)(1)(i)(B), access control portals must be equipped with locking devices, intrusion detection equipment, and surveillance equipment consistent with the intended function.

f.

Describe the search procedures that have been implemented at SOCA access control points.

Regulatory Basis:

Consistent with 10 CFR 73.55(h)(2)(i), where the licensee has established physical barriers in the Owner Controlled Area, the licensee shall implement search procedures for access control points in the barrier.

g. Describe how the intrusion detection and assessment equipment at the SOCA provides, at all times, the capability to detect and assess unauthorized persons and facilitate the effective implementation of the protective strategy.

Regulatory Basis:

Consistent with 10 CFR 73.55(i)(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 capability to detect and assess unauthorized persons and facilitate the effective implementation of the licensees protective strategy.

h. Describe how the intrusion detection and assessment equipment at the SOCA is designed to annunciate and display concurrently in two continuously staffed onsite alarm stations.

Regulatory Basis:

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 Control Area Station within this Section.

i.

Describe how the SOCA intrusion detection and assessment systems are designed to: 1) provide visual and audible annunciation of an alarm; 2) provide a visual display from which assessment of the detected activity can be made; 3) ensure that the annunciation of an alarm indicates the type and location of the alarm; 4) ensure that alarm devices to include transmission lines to annunciators are tamper indicating and self-checking; 5) 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; and 6) support the initiation of a timely response in accordance with the security plans, protective strategy, and associated implementing procedures.

Regulatory Basis:

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.

j.

Describe how unattended openings that intersect the SOCA barrier have been addressed to detect exploitation by surreptitious bypass.

Regulatory Basis:

Consistent with 10 CFR 73.55(i)(5)(iii), unattended openings that intersect a security boundary such as underground pathways must be protected by a physical barrier and monitored by intrusion detection equipment or observed by security personnel at a frequency sufficient to detect exploitation.

k. Describe the type of illumination assets that are implemented to ensure the area of the SOCA is provided with the illumination necessary to satisfy the design requirements of 10 CFR 73.55(b) and implement the protective strategy.

Regulatory Basis:

Consistent with 10 CFR 73.55(i)(6)(i), the licensee shall ensure that all areas of the facility are provided with illumination necessary to satisfy the design requirements of 10 CFR 73.55(b) and implement the protective strategy.

l.

Describe how the implementation of the SOCA is included in security program reviews.

Regulatory Basis:

Consistent with 10 CFR 73.55(m)(1), as a minimum the licensee shall review each element of the physical protection program at least every 24 months.

m. Describe how the SOCA is included in the site maintenance, testing, and calibration program and the intervals that the security equipment (intrusion detection and assessment, access control, and if applicable search equipment) at the SOCA are tested for operability and performance.

Regulatory Basis:

Consistent with 10 CFR 73.55(n)(1)(i), the licensee shall establish, maintain, and implement a maintenance, testing and calibration program to ensure that security systems and equipment, including secondary power supplies and uninterruptible power supplies, are tested for operability and performance at predetermined intervals, maintained in an operable condition, and are capable of performing their intended function.

n. Describe the compensatory measures that are implemented when SOCA intrusion detection, assessment, access control, and if applicable search equipment fails or becomes degraded.

Regulatory Basis:

Consistent with 10 CFR 73.55(n)(1)(v), licensees shall implement compensatory measures that ensure the effectiveness of the onsite physical protection program when there is a failure or degraded operation of security-related component or equipment.

Additionally, appropriate changes should be made during the next revision of the sites security plans to ensure the language clearly describes the intended function of this SOCA barrier as it pertains to the implementation of certain aspects of the physical protection program (e.g., access control, initiation of the protective strategy, etc.) in accordance with 10 CFR 73.55(e)(1)(ii).

Regulatory Basis:

Consistent with 10 CFR 73.55(c)(3), the licensee shall establish, maintain, and implement a PSP which describes how the performance objective and requirements set forth in this section will be implemented.

Consistent with 10 CFR 73.55(e)(1)(ii), the licensee shall describe in the PSP, physical barriers, barrier systems, and their functions within the physical protection program.

2. Section 15.1 of the PSP describes illumination at the site. Describe the type of alternative technology being implemented at the protected area (PA) perimeter to augment illumination. Describe how the alternative technology provides the capability to perform PA perimeter assessment in no-light or low-light conditions and specifically during the loss of normal power. Describe how the alternative technology is integrated within the PA perimeter intrusion detection and assessment systems to meet the requirements of 10 CFR 73.55(e)(7)(i)(C), 10 CFR 73.55(i)(2), and 10 CFR 73.55(i)(3)(vii). See Security Frequently Asked Question 10-15.

Additionally, appropriate changes should be made during the next revision of the sites PSP to ensure the language clearly describes the type(s) of technology used to augment illumination for the assessment of the PA perimeter in no-light or low light conditions and during the loss of normal power, and how the technology meets the requirements of 10 CFR 73.55(e)(7)(i)(C), 10 CFR 73.55(i)(2), and 10 CFR 73.55(i)(3)(vii).

Regulatory Basis:

Consistent with 10 CFR 73.55(c)(3), the licensee shall establish, maintain, and implement a Physical Security Plan which describes how the performance objective and requirements set forth in this section will be implemented.

Consistent with 10 CFR 73.55(e)(7)(i)(C), the isolation zone shall be monitored with assessment equipment designed to satisfy the requirements of Section 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 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)(vii), the licensees intrusion detection and assessment systems 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.

Consistent with 10 CFR 73.55(i)(6)(iii), the licensee shall describe in the security plans how the lighting requirements of this section are met and, if used, the type(s) and application of low-light technology.