ML12310A029

Request for Additional Information Related to Physical Security Plan, Revision 16

ML12310A029
Person / Time
Site:	Davis Besse
Issue date:	11/16/2012
From:	Michael Mahoney Plant Licensing Branch III
To:	Lieb R FirstEnergy Nuclear Operating Co
Michael Mahoney, NRR/DORL 415-3867
References
TAC D91660
Download: ML12310A029 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 16, 2012 Mr. Ray Lieb Site Vice President FirstEnergy Nuclear Operating Company Mail Stop A-DB-3080 5501 North State, Route 2 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO.1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO PHYSICAL SECURITY PLAN, REVISION 16 (TAC 091660)

Dear Mr. Lieb:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 3, 2012, FirstEnergy Nuclear Operating Company submitted Davis-Besse Nuclear Power Station's, Unit No.1, Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 16. The enclosure to the letter contained safeguards information and has been withheld from public disclosure.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on October 25, 2012, it was agreed that you would provide a response within 60 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.

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Michael Mahoney, proje~~Lanager Plant Licensing Branc~21<:l Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION 10 CFR 50.54(p)(2) CHANGES TO SECURITY PLAN FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 DOCKET NO. 50-346 LICENSE NO. NPF-3 By letter dated August 3, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12219A226), FirstEnergy Nuclear Operating Company (the licensee) submitted Davis-Besse Nuclear Power Station's Physical Security Plan (PSP), Training and Qualification Plan, and Safeguards Contingency Plan (SCP), Revision 16. 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. Sections 11.1 of the PSP and Section 7 of the SCP include descriptions of the Restricted Owner Controlled Area (ROCA) 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: (1) the function of the ROCA 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; (2) how the detection and assessment capability at the ROCA barrier facilitates the initiation of operator actions that are credited as target elements within target sets; (3) Describe how the implementation of the ROCA barrier and associated intrusion detection and assessment equipment have been included in the drills and exercises of the site's protective strategy that have been conducted to meet the Performance Evaluation Program requirements of 10 CFR Part 73, Appendix B VI, C.3; and (4) the percentage of drills and exercises, conducted since implementation of the ROCA barrier, in which initiation of the protective strategy resulted from adversary detection at the ROCA 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 Enclosure

-2 10 CFR 73.55(e)(1){ii), the licensee shall describe in the security plan the physical barriers, barrier systems, and their functions, within the physical protection program.

b. Describe how the openings in the ROCA 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 ROCA 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(b).

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

Regulatory Basis:

Consistent with 10 CFR 73.55(g)(1)(i)(8), 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 ROCA access control points.

-3 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 ROCA 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 licensee's protective strategy.

h. Describe how the intrusion detection and assessment equipment at the ROCA 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 and at least one of which must be protected in accordance with the requirements of the Central Area Station within this section.

i. Describe how the ROCA 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 licensee's intrusion detection and assessment systems must be designed to: 0) provide visual and audible annunciation of the alarm; (ii) provide a visual display from which

-4 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 the 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.

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

Regulatory Basis:

Consistent with 10 CFR 73.SS(i)(S)(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.

t. Describe the type of illumination assets that are implemented to ensure the area of the ROCA is provided with the illumination necessary to satisfy the design requirements of 10 CFR 73.SS(b) and implement the protective strategy.

Regulatory Basis:

Consistent with 10 CFR 73.SS(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.SS(b) and implement the protective strategy.

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

Regulatory Basis:

Consistent with 10 CFR 73.SS(m)(1), as a minimum, the licensee shall review each element of the physical protection program at least every 24 months.

n. Describe how the ROCA 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 ROCA are tested for operability and performance.

Regulatory Basis:

Consistent with 10 CFR 73.SS(n)(1)(i), the licensee shall establish, maintain, and implement a maintenance, testing and calibration program to ensure that

-5 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.

o. Describe the compensatory measures that are implemented when ROCA 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.

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.

Additionally, appropriate changes should be made during the next revision of the site's security plans to ensure the language clearly describes the intended function of this ROCA 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.).

2. Sections 11.2.1, 11.2.2, and 14.4.1 of the PSP describe vehicle barrier systems at the site. There is also a figure (Figure 11-8) that depicts the site vehicle barrier configuration. The descriptions in Sections 11.2.1 and 11.2.2, and the depiction in Figure 11-8, indicate a configuration that differs from the description of the site vehicle barriers in Section 14.4.1 (Le., the number of vehicle barriers implemented).

Describe the number of vehicle barrier systems the site employs. Describe each vehicle barrier system in detail, to include its function, and the regulatory requirements it is designed to meet. Additionally, appropriate changes should be made during the next revision of the site's security plans to ensure the language clearly describes the function of each vehicle barrier system at the site.

RegUlatory Basis:

Consistent with 10 CFR 73.55(c)(1), licensee security plans much 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

-6 predetermined response plans and strategies, and the protection of digital computer and communication system and networks.

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.

In accordance with1 0 CFR 73.55(e)(1 0), consistent with the physical protection program design requirements of Section 73.55(b), and in accordance with the site-specific analysis, the licensee shall establish and maintain vehicle control measures, as necessary, to protect against the design basis threat of radiological sabotage vehicle bomb assault.

Consistent with 10 CFR 73.55(e)(1 O)(i)(A), the licensees shall design, construct, install, and maintain a vehicle barrier system, to include passive and active barriers, at a stand-off distance adequate to protect personnel, equipment, and systems necessary to prevent significant core damage and spent fuel sabotage against the effects of the design basis threat of radiological sabotage land vehicle bomb assault.

3. Section 15.1 of the PSP describes illumination and alternative technology used to augment illumination within the isolation zones at the protected area (PA) perimeter.

Describe how: (1) the assets, that provide illumination within the PA perimeter isolation zones, remain operable without interruption during the loss of normal power; (2) the alternative technology used to augment illumination provides the capability to perform PA perimeter assessment in no-light or low-light conditions and specifically during the loss of normal power; and (3) 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 site's PSP to ensure the language clearly describes: (1) the capabilities of the protected area perimeter illumination assets to remain operable without interruption during the loss of normal power; and (2) the 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 PSP which describes how the performance objective and requirements set forth in this section will be implemented.

Consistent with1 0 CFR 73.55(e)(7)(i)(C), isolation zones 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.

-7 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 licensee's intrusion detection and assessment systems must be designed to ensure intrusion detection and assessment equipment at the PA 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.

Mr. Ray Lieb Site Vice President FirstEnergy Nuclear Operating Company Mail Stop A-DB-3080 5501 North State, Route 2 Oak Harbor, OH 43449-9760 SUB.IECT: DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO.1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO PHYSICAL SECURITY PLAN, REVISION 16 (TAC 091660)

Dear Mr. Lieb:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 3, 2012, FirstEnergy Nuclear Operating Company submitted Davis-Besse Nuclear Power Station's, Unit No.1, Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 16. The enclosure to the letter contained safeguards information and has been withheld from public disclosure.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on October 25,2012, it was agreed that you would provide a response within 60 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.

Sincerely, Michael Mahoney, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION:

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