ML12279A226
| ML12279A226 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/04/2012 |
| From: | Beltz T Plant Licensing Branch III |
| To: | Jim Costedio Point Beach |
| References | |
| Download: ML12279A226 (7) | |
Text
NRR-PMDAPEm Resource From: Beltz, Terry Sent: Thursday, October 04, 2012 9:41 AM To: 'Costedio, James' Cc: 'Hennessy, William'; Costa, Richard
Subject:
Point Beach Nuclear Plant, Units 1 & 2 - Draft RAIs re: PBNP Physical Security Plan, Training
& Qualification Plan, and Safeguards Contingency Plan, Rev. 12 Attachments: image001.gif; Draft Requests for Additional Information re Changes to Security Plan.pdf
Dear Mr. Costedio:
By letter dated August 2, 2012 (Agencywide Documents Access and Management System Accession No. ML12219A234), NextEra Energy Point Beach, LLC., submitted the Point Beach Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 12. The enclosure to that letter contained Safeguards Information and was withheld from public disclosure.
The U.S. Nuclear Regulatory Commission (NRC) staff in the Reactor Security Licensing Branch (RSLB) of the Office of Nuclear Security and Incident Response is currently reviewing the submittal to ensure compliance with Title 10 of the Code of Federal Regulations, Section 50.54(p)(2). The RSLB staff has determined that additional information is necessary to complete its review. The draft requests for additional information (RAIs) are attached.
You may accept these draft RAIs as formal Requests for Additional Information and respond to the questions by November 9, 2012. Alternatively, you may request to discuss the contents of these RAIs with the NRC staff in a conference call, including any change to the proposed response date.
Please let me know if you have any questions or concerns.
Sincerely, Terry A. Beltz, Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation (301) 415-3049 Terry.Beltz@nrc.gov 1
Hearing Identifier: NRR_PMDA Email Number: 498 Mail Envelope Properties (87B1F1BDFE5A554CA9DC5EAA75EB6D0DBEE272643D)
Subject:
Point Beach Nuclear Plant, Units 1 & 2 - Draft RAIs re: PBNP Physical Security Plan, Training & Qualification Plan, and Safeguards Contingency Plan, Rev. 12 Sent Date: 10/4/2012 9:40:54 AM Received Date: 10/4/2012 9:40:00 AM From: Beltz, Terry Created By: Terry.Beltz@nrc.gov Recipients:
"'Hennessy, William'" <William.Hennessy@nexteraenergy.com>
Tracking Status: None "Costa, Richard" <Richard.Costa@nrc.gov>
Tracking Status: None
"'Costedio, James'" <JAMES.COSTEDIO@nexteraenergy.com>
Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 1515 10/4/2012 9:40:00 AM image001.gif 3939 Draft Requests for Additional Information re Changes to Security Plan.pdf 70183 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
10 CFR 50.54(p)(2) CHANGES TO SECURITY PLAN NEXTERA ENERGY POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301 LICENSE NOS. DPR-24 AND DPR-27 By letter dated August 2, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12219A234, NextEra Energy Point Beach LLC (the licensee) submitted the Point Beach Nuclear Plants Physical Security Plan (PSP), Training and Qualification Plan (T&QP), and Safeguards Contingency Plan (SCP), Revision 12. 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 Owner Controlled Area (OCA) barriers at the site. Describe how the 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 OCA barrier by identifying how it and the associated 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 OCA barrier and associated 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 OCA barrier, in which initiation of the protective strategy resulted from adversary detection at the OCA 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.
Enclosure
- b. Describe how the openings in the OCA 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 OCA 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(b).
- d. Describe the personnel, vehicle and material access control portals of the OCA barrier, specifically whether they located outside of, or co-located with, the OCA 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 OCA barrier 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 OCA barrier access control points.
Regulatory Basis:
Consistent with 10 CFR 73.55(h)(2)(i), where the licensee has established physical barriers in the OCA, the licensee shall implement search procedures for access control points in the barrier.
- g. Describe how the intrusion detection and assessment equipment at the OCA barrier 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 OCA barrier 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 central alarm station within this section.
- i. Describe how the OCA barrier 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; and (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 OCA 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 OCA barrier 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 OCA barrier 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 OCA barrier 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 OCA barrier 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 OCA barrier 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 OCA 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.
- 2. Section 7.0 of the SCP describes the OCA vehicle search area. The location of the officer that is armed and positioned at the checkpoint to observe the search process and provide immediate response consistent with 10 CFR 73.55(h)(2)(iii) is unclear.
Describe the location of the armed individual that is responsible for observing the search process and initiating immediate response for the vehicle search area in relation to the location of the vehicle search area (i.e. distance). See Security Frequently Asked Question (SFAQ) 12-08. Additionally, appropriate changes should be made during the next revision of the sites security plans to ensure the language clearly articulates the oversight of the search process consistent with 10 CFR 73.55(h)(2)(iii).
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(h)(2)(iii), vehicle searches must be performed by at least two (2) trained and equipped security personnel, one of which must be armed.
The armed individual shall be positioned to observe the search process and provide immediate response.