ML17334B470
| ML17334B470 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/13/1993 |
| From: | Mckee P Office of Nuclear Reactor Regulation |
| To: | Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9304190186 | |
| Download: ML17334B470 (11) | |
Text
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FORD 2 REGULAT<Q INFORMATION DISTRIBUTION'STEM (RIDE)
M ACCESSION NBR:9304190186 DOC.DATE: 93/04/13 NOTARIZED:
NO DOCKET FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana M
05000315 50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana M
05000316 AUTH.NAME AUTHOR AFFILIATION MCKEEFP.F.
Safeguards Branch RECIP.NAME RECIPIENT AFFILIATION PEDERSON,C.D.
Region 3 (Post 820201)
SUBJECT:
Informs that operational safeguards response evaluation scheduled for plant, units 1
2 on 930816-19.Draft ltr to util explaining purpose
& schedule for review encl. Requests assistance in forwarding ltr.
DISTRIBUTION CODE:
DF03D COPIES RECEIVED:LTR I ENCL I
SIZE:
TITLE: Direct Flow Distribution: Subject Files a 40,70,71 Dkts w out LPDRs NOTES:
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RECIPIENT ID CODE/NAME INTERNAL: NUDOCS-ABSTRACT EXTERNAL: NRC PDR COPIES LTTR ENCL 1
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1 REG FILE Ol RECIPIENT ID CODE/NAME COPIES LTTR ENCL 1
1 YOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCVMENfS YOU DON'T YEED!
TOTAL NUMBER OF COPIES REQUIRED:
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 13, 1993 Docket No's.:
50-315 50-316 MEMORANDUM FOR FROM Cindy D. Pederson, Chief Reactor Programs Branch Division of Radiation Safety
& Safeguards Region III Phillip F.
McKee, Chief Safeguards Branch Division of Radiation Safety
& Safeguards, NRR
SUBJECT:
OPERATIONAL SAFEGUARDS RESPONSE EVALUATION PROGRAM An Operational Safeguards
Response
Evaluation (OSRE) for the Donald C.
Cook Nuclear Plant, Units 1
& 2 has been scheduled for August 16 through 19, 1993.
Enclosure 1 is a draft letter to the Indiana Michigan Power Company which explains the purpose and schedule of the review.
Your assistance in forwarding this letter is appreciated.
During an OSRE the team also reviews the possible impact of security on plant safety.
In view of this responsibility, our team needs the assistance of an individual from your regional office or a resident inspector with technical power reactor safety expertise.
Enclosure 2, "Guidelines for the Safety/
Safeguards Interface Member," provides information for that individual.
Our team will also need a Physical Security Inspector to accompany them for the duration of the OSRE.
For the Thursday exit briefing, the attendance of a management representative, such as yourself, is requested.
I Enclosure 3 is a list of logistical matters which we would appreciate your help in resolving.
Cindy D. Pederson If you have any questions regarding the conduct of this Operational Readiness Review which you wish to have answered prior to the team s visit, please contact David Orrik, Safeguards Branch at (301) 504-3213.
Thank you for your cooperation and assistance.
Original signed by Phil McKee, Chief Safeguards Branch Division of Radiation Safety and Safeguards, NRR
Enclosures:
1.
Draft Letter 2.
Guidelines for the Safety/Safeguards Interface Member 3.
List of Administrative Items DISTRIBUTION Central Files OSRE File PSGB r/f~
DRSS r/f F. Congel P.
McKee R. J.
Dube W. Dean, PM E. Butcher D. Orrik J.
- Isom, SRI OFC
- DRSS:PSGB
- DRSS:PSGB DRSS:PSGB NAME
- DOrr'ATE
- 4/ 3 /93 RJDubebjM PM 4/7 /93
- 4/Q /93
DRAFT LETTER TO INDIANA MICHIGAN POWER COMPANY Dear The NRC is in the process of conducting operational safeguards response evaluations (OSREs) at nuclear power reactors.
I wish to inform you that the Donald C.
Cook Nuclear Plant, Units 1
& 2 has been chosen for such a review scheduled for the week of August 16 through 19, 1993.
The primary objective of the OSRE program is to evaluate the readiness of licensees'n-site security forces to respond to an external threat.
A focus of these reviews is the priorities established between plant operations and security departments for protection of equipment and on the defensive strategies used.
These reviews complement NRC's licensing and regional inspection functions.
An OSRE team includes a nuclear systems
- engineer, reactor safeguards specialists, and at least two U.S.
Army Special Forces personnel.
Additional assistance is provided by an inspector
ENCLOSURE 1
from the NRC regional office and the NRC resident inspector.
Any licensee questions on methodology or other matters are then addressed so that a
common understanding can be reached.
- Also, the suggested schedule for the onsite activities is discussed and key licensee contact persons are identified.
Zt is through these contact persons that arrangements are made for knowledgeable licensee personnel to escort the team members during the review.
After the entrance briefing, the OSRE team takes a general orientation tour of the protected area perimeter.
Following the orientation tour the team will meet with appropriate site
- security, operations, and/or engineering staff to select and walk-down potential sets of targets to be used in response drills and table-top exercises.
The team will observe a response drill or drills, which should be conducted using normal drill procedures and participants.
Team participation will be limited to scenario selection and drill observation.
The team will also conduct several table-top response exercises with response team leaders.
Additionally, the team will interview training staff and observe weapons familiarity and proficiency.
The team nuclear systems engineer will also want to meet with additional plant operators to assure that security systems are not interfering with safe operation of the plant.
ENCLOSURE 1
Please provide appropriate plant personnel support for the OSRE team during the scheduled evaluation.
Specifically, security members will require escorts from the security training department, and the team systems engineer will need an individual familiar with safety equipment location and functional capabilities.
The team will make every effort to schedule its activities so as to avoid disruption of normal plant operations.
The time that various team members spend on-site may vary, but generally will range from six to eight hours per day.
Some of this time is expected to be during evening hours.
If you have any questions regarding the conduct of the operational security readiness evaluation program which you wish to have answered prior to the team's visit, please contact David Orrik, Safeguards Branch at (301) 504-3213, or of Region IV staff.
Sincerely, cc:
F. Congel, NRR E. Butcher, NRR P.
GUIDELINES FOR THE SAFETY SAFEGUARDS INTERFACE MEMBER One of the purposes of the OSRE program is to assess the coordination and interaction of plant security with plant operations.
In particular, you should explore how well the intent of 10 CFR 73.55(d)(7)(ii) is being met.
This rule addresses the potential need of equipment operators for rapid access to vital equipment.
It also addresses the potential need for rapid entry into plant areas of on-site and off-site medical and fire fighting personnel as well as rapid escape from enclosed areas of the plant in the event of such things as steam line breaks, fires, or release of fire suppression gases.
You may accomplish your assignment initially during the facility tour by asking similar questions of different operational personnel (e.g.,
equipment operators, control room operators, and shift supervisors) and security personnel (e.g., security manager) to get a variety of perspectives.
This should be supplemented with a review of these issues in office settings (with other OSRE team members present) before leaving the site, meeting separately with security and operational staff.
Concerns identified will be discussed with the team at meetings usually held at the end of each day, discussed with plant management at the exit briefing, and incorporated into the formal OSRE report.
Issues you should address include:
1.
The manner in which security procedures and safety procedures provide an integrated response to indications of unusual plant conditions.
control room procedures for responding to malfunctions or alarms allowable times for correcting malfunctions operational personnel use of security assets to assist in investigating the cause of an unusual condition use of access control computer and security officers for personnel accountability use of security officers for fire brigade operator/shift supervisor/plant manager responsibilities and decision process in security contingencies (e.g., at what point would a plant shutdown be started)
ENCLOSURE 2
2.
Identification of any security procedures that may interfere with plant or personnel safety during routine or emergency conditions and the extent of that interference.
operator actions when normal access to vital areas is prevented procedures for access to hard keys for vital areas procedures for access to keys for administrative locks security procedures normally implemented when access computer is not operational anti-passback features and capability for over-ride in emergencies time delays caused by security access controls for on-site and off-site response of licensee personnel procedures so that off-site emergency response (non-licensee) personnel are not delayed badging, escorts familiarization of licensee personnel relative to site manager's ultimate authority in emergency situations interference of locked doors with evacuation plan routes interference of locked doors with rapid entry into vital area (e.g.,
during health emergency or potential safety incident) 3.
General interaction of security, operational, and maintenance personnel.
rapport and appreciation of the needs for safety and security procedures program for review of safeguards procedures by operational departments affected and/or by safety committee security participation in review of operational procedures and system changes security awareness of maintenance activities that could affect security barriers or surveillance capabilities attitudes of site personnel towards level of security at site ENCLOSURE 2
attitudes of site personnel regarding removing access controls from vital equipment attitudes of site personnel regarding wider availability
~of hard keys for operational staff for access to vital areas 4.
Equipment Concerns.
adverse impact of security equipment on safety (e.g.,
Electromagnetic Interference (EMI) from security radios affecting safety systems) adverse impact of plant equipment on security systems (e.g.,
EMI from pump start-up tripping the security access computer) any safety problems caused by patrols of armed security officers in vital areas would radiological habitability requirements for Central Alarm Station permit smoother handling of safety-related emergency situations?
means for unimpeded egress from vital areas even during security systems failures positive/negative safety aspects of hardened chains and padlocks for protection of Engineered Safety Feature valves and motor controls Safet Safe uards References 1 ~
IE Information Notice No. 83-36, "Impact of Security Practices on Safe Operations,"
June 9,
1983.
2 ~
3 ~
NUREG-0992, "Report of the Committee to Review Safeguards Requirements at Power Reactors,"
May, 1983.
IE Information Notice 85-79, "Inadequate Communication Between Maintenance, Operations, and Security Personnel."
4
~
5.
Generic Letter 87-08, "Implementation of 10 CFR 73.55 Miscellaneous Amendments and Search Requirements,"
May ll, 1987.
ENCLOSURE 2
OPERATIONAL SAFEGUARDS READINESS REVIEW ADMINISTRATIVECONCERNS
- 1. Dispatch letter to licensees confirming visit, and identifying team members.
- 2. Arrange for bringing video cameras on-site.
3.
Confirm that the licensees will provide an escort who is familiar with the location and detailed operation of each unit's engineered safety feature systems and components, as well as security escorts.
- 4. Inform licensees that the OSRE team will want to observe typical licensee security contingency response drills.
The specific drills will be selected from among those normally run, after the team arrives on-site.
- 5.
Inform the licensees that the team is prepared to observe these drills in the evenings during the back shifts.
6.
Determine what, if any, health physics documents,
- training, whole body counts, etc. will be needed for unescorted access to areas where drills will be conducted and to appropriate areas to evaluate the potential safety impact of vital area access controls.
- 7. After consultation with the OSRE team leader, schedule any health physics appointments with the licensees that might be necessary.
- 8. Determine what personnel information the licensees will need to facilitate access control requirements for team members.
9.
Ask the licensees to select a time and place for a single entrance briefing soon after the team's arrival on-site the first day.
10.
Inform licensees that the OSRE team may want to observe weapons firing by selected security force personnel if the OSRE team determines, during the review, that it may be useful in assessing security force operational readiness.
ENCLOSURE 3
E