ML13029A713

Email, Request for Additional Information, Revision 13 to Physical Security, Safeguards Contingency, and Training and Qualification Plan (TAC No. D91660)

ML13029A713
Person / Time
Site:	Grand Gulf
Issue date:	01/29/2013
From:	Wang A Plant Licensing Branch IV
To:	Seiter J Entergy Operations
Wang A
References
TAC D91660
Download: ML13029A713 (7)

Text

Lent. Susan From: Wang, Alan Sent: Tuesday, January 29,20139:12 AM To: SEITER, JEFFERY ALAN Cc: Lent, Susan; Burkhardt, Janet Attachments: GG PSP RAIS.docx Jeff and Christina, by letter dated September 25, 2012 (Agencywide Documents Access and Management System Accession No. ML12271A124), Entergy Operations, Inc. submitted the Grand Gulf Nuclear Station's (GGNS) Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision

13. The enclosure to the letter contained Safeguards Information and has been withheld from public disclosure. The US Nuclear Regulatory Commission (NRC) staff is currently reviewing the submittal to ensure compliance with Title 10 of the Code of Federal Regulations, Section 50.54(p)(2).

The NRC staff has determined that the attached request for additional information (RAI) is needed to complete our review. This RAI was discussed with Mr. Jeffrey Seiter on December 17, 2012, and it was agreed that a response would be provided by February 28, 2013. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1445 or via e-mail at Alan.Wang@nrc.gov.

The NRC staff has determined that the RAls attached do not contain Safeguards Information ..

Alan Wang Project Manager (Grand Gulf Nuclear Station)

Nuclear Regulatory Commission Division of Operating Reactor Licensing Alan.Wang@NRC.gov Tel: (301) 415-1445 Fax: (301) 415-1222 1

REQUEST FOR ADDITIONAL INFORMATION PHYSICAL SECURITY PLAN GRAND GULF NUCLEAR STATION, UNIT NO. 1 50-416 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 (i.e. SOCA detection fence and SOCA delay fence) 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 SOCA barriers, specifically the SOCA detection fence, 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 detection fence facilitates the initiation of operator actions that are credited in 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 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. Describe the percentage of drills and exercises, conducted since implementation of the SOCA detection fence, in which initiation of the protective strategy resulted from adversary detection at the SOCA detection fence.

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. Describe how the openings in the owner controlled area (OCA) barrier are secured and monitored to prevent exploitation of the openings.

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.

b. Describe how the openings in the SOCA detection fence 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 Enclosure

requirements of this section must be secured and monitored to prevent exploitation of the opening.

c. Describe how vehicle and material access through the SOCA detection fence is 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 vehicle and material access control portals of the SOCA detection fence, specifically whether they are located outside of, or co-located with, the fence.

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 personnel, vehicle, and material access control portals within the SOCA detection fence 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 access control portals within the SOCA detection fence.

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.

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

h.

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.

i. Describe how the intrusion detection and assessment equipment at the SaCA detection fence 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.

j. Describe how the intrusion detection and assessment systems at the SaCA detection fence 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: (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.

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

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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.

I. Describe the type of illumination assets that are implemented to ensure the area of the SaCA detection fence 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 SaCA detection fence and associated intrusion detection and assessment equipment 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 SaCA detection fence and associated intrusion detection and assessment equipment 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 this barrier 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 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 the SaCA barrier, intrusion detection, assessment, access control, and if applicable search equipment fails or becomes degraded.

Regulatory Basis:

Consistent with 10 CFR 73.SS(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.

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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 the SaCA detection fence 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 security plan, physical barriers, barrier systems, and their functions within the physical protection program.

2. Section 13.2 of the PSP describes control and accountability of access control devices. Revision 12 of the site's PSP described how locks and cylinders were accounted for when locks and cylinders were changed. Revision 13 of the site's PSP has omitted this language. Also, the language utilized within this section of the site's PSP does not address all of the information contained within the last paragraph of Section 13.2 of the NRC endorsed NEI 03-12 Revision 7, template for security plans. Describe the accountability process for key locks and cylinders when they are changed to include the information not addressed from the NRC endorsed NEI 03-12 Revision 7, template for security plans. Additionally, appropriate changes should be made during the next revision of the site's PSP to ensure the language fully addresses the control and accountability of access control devices.

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(g)(6)(i), the licensee shall control all keys, locks, combinations, passwords and related access control devices used to control access to protected areas, vital areas and security systems to reduce the probability of compromise.

3. Section 7.0 of the SCP describes the SaCA vehicle search area. The location of the officer that is armed and positioned at the SaCA vehicle search area 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). The member of the security organization who is responsible for monitoring the SaCA vehicle access control portal via video surveillance equipment is unclear. Describe the member of the security organization responsible for monitoring the SaCA vehicle access control portal and the location, from which, this individual performs the monitoring function. See Security Frequently Asked Question (SFAQ) 12-08. Additionally, appropriate changes should be made during the next 5

revision of the site's security plans to ensure the language clearly articulates the oversight of the SaCA 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 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.

Consistent with 10 CFR 73.55(h)(2)(v), vehicle access control points must be equipped with video surveillance equipment that is monitored by an individual capable of initiating a response.

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