ML18029A276
| ML18029A276 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/29/1984 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18029A275 | List: |
| References | |
| NUDOCS 8411210403 | |
| Download: ML18029A276 (17) | |
Text
~pR REQy(
- >'JIII4
~**<<+.
UNITED STATES NUC LEAR R EGULATORY COMMISSION WASHINGTON, O. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.
115 TO FACILITY OPERATING LICENSE NO; DPR-33 AMENDMENT NO.
109 TO FACILITY OPERATING LICENSE NO.
DPR-52 AMENDMENT NO.
83 TO FACILITY OPERATING LICEI'lSE NO.
DPR-68 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2
AND 3 DOCKET NOS. 50-259, 50-260 AND 50-296 1.0 Introduction By letter dated April 3, 1984 the Tennessee Valley Authority- (the licensee or TVA) requested amendments to Facility Operating License Nos.
DPR-33, DPR-52 and DPR-68 for the Browns Ferry Nuclear Plant, Units 1, 2 and 3.
The Amendments would revise a condition in each license to reflect changes in the Commission-approved physical security plan for the Browns Ferry Nuclear Plant.
2.0 Discussion Each of the Browns Ferry licenses now contain a condition that "the licensee shall maintain in effect and fully implement all provisions of the Commission-approved physical security plan...
dated June 15, 1978.".
r As a result of NRC comments and inspections and the licensee's experience; with the above plans, TVA revised the plan, and submitted it for NRC approval by letter dated June 11, 1982 as supplemented by letters dated August 31 and October 19, 1982.
The staff has reviewed the revised plan and has concluded that the revi'sed plan will significantly enhance security at Browns Ferry and; with the addition of language to assure positive access controls over containment described more fully below, is acceptable.
-The proposed action is to revise the condition in the licenses to identify the dates of the updated physical security plan vs the June 15, 1978 edition now specified.
Since the license condition refers to a plan with a specific date, until or unless this condition is modified, the licensee must maintain in-effect a plan which is not as effective as the revised plan.
3.0 Evaluation In the latest version of the security plan, the licensee made a change in the general format of the plan.
The plan now consists of two parts, a
841'1210403 841029
, PDR
- DOCK 05000259 P'DR
generic plan (Part I) which will also be applied at other TVA nuclear power
- plants, and a site specific plan (Part II), which describes unique site specific features at the Browns Ferry site.
The administrative changes do not alter the level of or the basic nature of the security at the site, but provide for a more comprehensive security plan which is easier to inspect and to implement.
In addition to this safety evaluation, the staff has prepared a more detailed safety evaluation - which is protected as safeguards information and is withheld from public disclosure as provided for in 10 CFR Part 73.21.
The protected safety evaluation analyzes how the revised physical security plan will meet the requirements of 10 CFR Part 73 with respect to the physical security organization, physical barriers, access requirements, detection aids, communications, test and maintenance requirements and response requirements.
The protected safety evaluation report also includes a protected Appendix and a protected worksheet on the size of the response force.
In summary, the significant changes in the new, revised Plan vs the Physical Se'curity Plan now in effect will be as follows:
a ~
b.
TVA completely reformed the physical security plan as discussed initially to provide a two-part plan.
Part I consists of a generic plan applicable to all TVA sites; Part II is a site
'pecific plan.
The revised plan reflects organizational changes with changed authorities and responsibilities which enhance security.
The responsibilities of the Public Safety Service Unit supervisor were reoriented to be more effective.
C.
d.
e.
The Personnel Reliability Program was modified.
Certain security personnel qualification criteria were removed from the physical security plan, upgraded and placed in the Training gualification Plan.
Access procedures covering emergency response personnel were included in the Plan.
I
~
The control over access of vehicles onto the site was modif'.ed.
g.
The use of protective lighting was modified.
h.
The physical requirements relating to the fence barrier were modified.
The level of accountability was increased on control of security keys.
j.
The descriptions of the protected and vital area perimeters were simplified.
k.
The Plan requi res an increased level of testing of intrusion detection devices.
l.
The list of definitions was revised to be more comprehensive and inclusive.
With respect to access requirements, the staff determined that the revised physical security plan as proposed by TVA would provide positive control o.
personnel.
and vehicles to protected areas as required by 10 CFR 73.55{.d) except for one proposed change.
A picture badge/key card system, utilizing encoded information, identifies individuals that are authorized unescorted access to protected and vital areas and is used to control access to these areas.
Individuals not authorized unescorted access are issued non-picture badges that indicate an escort is required.
Access authorizations are limited to those individuals who have a need for access to perform their duties.
Unoccupied vital areas are locked and alarmed.
Access to the reactor containment(s) is positively controlled to assure that only authorized individuals are permitted to enter.
However, in section 9.1 of the revised plan, TVA had proposed that during extended maintenance
- outages, when all fuel was removed from the reactor vessel, conta'inment would become a non-vital area.
During such
- outrages, as many as 500 to 600 outside craftsmen may be working in the area; Revising the designation of the area to "non-vital" would reduce the search and escort requirements.
Although TVA proposed various compensatory
- measures, the proposed change is not consistent with the regulatory.requirements set forth in 10 CFR 73.55(h)(8),
and accordingly is not acceptable.
Accordingly, we are adding a sentence to the license condition which states:
I Notwithstanding the statement in Section
- 9. 1 of the physical security plan, the licensee shall maintain positive access control over containment in accordance with the requirements of 10 CFR 73.55(d)(8).
Based on a review of the subject documents and visits to the site, the staff has concluded that with the addition of the proposed statements regarding access to containment during extended
- outages, the protection provided by the Tennessee Valley Authority against radiological sabotage at the Browns Ferry Nuclear Plant meets the requirements of 10 CFR Part 73.
4.0 Environmental Considerations This amendment relates solely to safeguards matters and does not involve any significant construction impacts.
The amendment is confined to organizational and procedural matters and administrative changes.
Accordingly, this amendment meets.the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(12).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
5.0 Conclusion
'l/e have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed
- manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.
Enclosure:
Security Plan Evaluation Report Principal Contributor:
C. Gaskin Dated:
October 29, 1984
ENCLOSURE 1 TO SAFETY EVALUATION SECURITY. PLAN EVALUATION REPORT BROWNS FEPRY NUCLEAR PLANT
- 1. 0 Introduction The Tennessee Valley Authority filed with the Nuclear Regulatory Commission for the Browns Ferry Nuclear Plant the following security program plans:
"Browns Ferry Nuclear Plant Physical Security Plan" dated, June I, 1981 as revised Hay 15 and October 19, 1982.
"Browns Ferry Nuclear Plant Contingency Plan" dated December 21, 1980 (via letter dated January 23, 1981) as revised
")arch 3, 1981 (via letter dated April 7, 1981).
"Browns Ferry Nuclear Plant Guard Training and qualification Plan" dated Hay 1, 1982 (via letter dated July 19, 1982).
This Security Plan Evaluation Report (SPER) summarizes how the licensee has provided for meeting the requirements of 10 CFR Part 73.
The SPER is'composed of a basic analysis that is available for public review, a protected
- Appendix, and a protected response force size worksheet.
Based on a review of the subject documents and visits to the site, the staff has concluded that the orotection provided by the Tennessee Valley Authority against radiological sabotage at the Browns Ferry Nuclear Plant meets the requirements of 10 CFR Part 73.
Accordingly, the protection will ensure that the health and safety of the public will not be endanaered.
2.0 Physical Security Organization To satisfy the requirements of 10 CFR 73.55(b) the Tennessee Valley Authority has provided a nhysical security organization that includes a Public Safety Service Shi t Supervisor who is onsite at all times with the authority to direct the physical protection activities.
To implement the commitments made in the physical security plan, guard training and aualification olan, and the safeouar ds continqencv plan written security procedures specifying the duties of the security organization r emhe.
s are available for inspection.
The traininq program and critical security tasks and duties for the security organization personnel are defined in the "Browns Ferry Nuclear Plant Guard I
Traininq and qualification Plan" which meets the requirements of 10 CFR Part 73, Appendix B for the training, equippinq and requalification of the security oraanization members.
The physical security plan and the training program provide commitments that preclude the assignment of any individual'o a security related duty or task prior to the individual being trained, equipped and oualified to perform the assigned duty in accordance with the approved guard training and qualification plan.
3.0 Physical Barriers In meeting the requirements of 10 CFR 73.55(c) the licensee has orovided a Drotected area barrier which meets the definition in 10 CFR 73.2(f)(1).
An isolation zone,, to permit observation of activities along the barrier, of at least 20 feet is provided on both sides of the barrier with the exception of the locations listed in the Aopendix.
The staff has reviewed those locations and determined that the security measures in place are satisfactory and continue to meet the reauirements of 10 CFR 73. 55(c).
Illumination of 0.2 foot-candles is maintained for the isolation zones, protected area barrier, and external portions of the protected area.
In areas where illumination of 0.2 foot-candles cannot be maintained special procedures are aop>ied as described in the Appendix.
Vital eouinment is located within vital areas which are located within the protected area and requi res nassaqe through at least two barriers, as defined 'in 10 CFP 73.2(f)( 1) and (2), to gain access to the vital equipment.
Vital area barriers are separated from the protected area barri er.
Patrol's of the protected area are performed at random intervals to detect the presence of unauthorized
- persons, vehicles arid Aaterials.
The control room and central alarm station are provided with bullet-resistant walls, doors, ceilings, floors and windows.
- 4. 0 Access Requirements I
In accordance with 10 CFR 73.55(d) all points of'personnel and vehicle access to the orotected area are controlled.
The individual responsible for controlling the final point of access into the protected area is located in a hullet-resistan't structure.
As part of the access control program vehicles (except under emergency conditions) personnel,
- packages, and mat-
\\
erials entering the protected area are searched for explosives, firearms and
'ncediary devices by electronic search equipment and/or physical search.
Vehicles admitted to the protected
- area, except licensee designated vehicles are controlled by escorts.
Licensee designated vehicles are limited to on-site station functions and'emain in the protected area except for oper-
- ational, maintenance, repair, security and emergency purposes.
Positive control over these vehicles is maintained by personnel authorized to use the vehicles or hy the escort personnel.
A picture badge/key card system, utilizing encoded infon.ation, identifies individuals that are authorized unescorted access to prot:ected and vital areas and is used to control access to these areas.
Individuals not authorized unescorted access are issued non-picture badges that indicate an escort is reouired.
Access authorizations are limited to those individuals who have a
need for access to perform their duties.
IJnoccupied vital areas are locked and alarmed.
Access to the reactor containment(s) is positively controlled to assure that only authorized individuals are permitted to enter.
(See Appendix regarding access control to containment during fueling or major maintenance).
In addition all doors and personne1/equipment hatches into the reactor containment(s) are locked and alarmed.
Keys, locks, combinations and related equipment are changed on an annual basis.
In addition, when an individual's access authorization has been terninated due to the lack of reliability or trustworthiness, or for poor work performance, the keys, locks, combinations and related equipment to which that person had access are changed.
5.A Detection Aides In satisfying the reauirements of 10. CFR 73.5(e) the licensee has installed intrusion detection systems at the protected area barrier, at entrances to vital areas, and at all emergency exits.
Alarms from the intrusion detection system annunciate within the continously manned central alarm station and a secondary alarm station located within the protected are'a.
The central alarm. station is located such that the interior of the station is not visihle from outside the perimeter of the pr otected area.
In addition, the central station is constructed so,that walls, floors, ceilings,
- doors, and windows are bullet-resistant (See Appendix).
The alarm stations are located and designed in such a manner so that a sinqle act cannot interdict the capability of calling for assistance or responding to alarms.
The central alarm station contains no other functions or duties that would interfere with its alarm response function.
The intrusion detection system transmission lines and associated alarm annunciation hardware are self-checking and tamper-indicatinq.
Alarm annunciators indicate the type of alarm and its location when activated.
An automatic indication of when the alarm system is on stand-by power is provided in the central alarm station.
6.0 Communications As required in 10 CFR 73. 55(f) the licensee has provided for the capability of continous communications between the central and secondary alarm station operators,
- guards, watchmen, and armed response personnel through the use of a conventional telephone
- system, and a security radio system.
In addition, direct communication with the local law enforcement authorities is main-tained through the use of a conventional telephone system and two way FN radio link.
All non-portable communication links, exceot the conventional telephone
- system, are provided with an uninterruptable emergency power source hacked up by diesel qenerators.
7.0 Test and hlaintenance Requirements In meeting the requirements of 10 CFR 73.55(g) the licensee has established a program for the testing and maintenance of all intrusion alarms, emergency
- alarms, communication equipment, physical barriers and other security related devices or eouipment.
Fquipment or devices that do not meet the design per-.
formance criteria or have failed to otherwise operate will be compensated for hy appropriate compensatory measures as defined in the "Browns Ferry Nuclear Plant Physical Security Plan" and in site procedures.
The compensatory measures de ined in these olans will assure that the effectiveness of the security system is not reduced by failures or other contingencies affecting the operation of the security related equioment or structures.
Intrusion detection systems are tested for proper performance at the beainnino and end of any period that they are used for security.
Such testing will be conducted at least once every seven days.
~
~
Communication s stems for y
or onsite communications are tested t th a.
e beginning of each securit shift.
Offiste communications are tested t
1 a
east once each day.
Audits of the security program are conducted once every 12 months by the Ouality Assurance and Audit Staff which "
d w ic is independent of site security management and suoervision.
The audits f
i s, ocusing on the effectiveness of the physical protection provided hy the onsite sec
't i e securi ty organization im-plementing the approved security program plans 1 d, s,
inc u e, but are not
~
~
limited to:
a r eview of the securi ty pr ocedures and t
prac ices; system testing and maintenance programs local 1
f ca aw en orcemet assistance agree-ments.
The equality Assurance and Audit Staff i
a prepares a report documenting the>r f>nd>ngs and recommendations and submits it t th D
o e
erector of 4'uclear Power and the plant superintendent.
8.0
Response
Requirements In meeting the requirements of 10 CFR 73.55(h) th
'e licensee has provided for armed responders immediately avail bl i
a e.or response duties on all shifts consistent with the requirement f "h n
s o e regulations (see Appendix).
Considerations used in ssupport of this number are attached.
In addition liaison with local law enforcement authorities to provide dd't 1
a>>ona response support in the event of security events has been e t bl h d s
a is e
and documented.
The licensee's safeguards contingency plan for dealina with thefts threats I
and radioloqical sabotage even events satisfies the reouirements of 10 CFR Part 73, Aopendix C.
The lan id p
entifies appropr iate secur ity events which could initiate a radiological sabotaqe event a
d d t'f'
.i en i ies the licensee's pre-
- plannino, res onse re oi p
s
- irces, safeguards contingency participants and coordination activities for each ide t'f'
'n i ie event.
Through this plan,
~
~
.~
upon the detection of abnormal presence or activities within the protected or vital areas, response activities using the available resources woul,d be initiated.
The 'response activities and objectives include the neutralization of the existing threat by requiring the response force members to inter pose themselves between the adversary and their objective, instructions to use force commensu'rate with that used by the adversary, and authority to request sufficient assistance from the local law enforcement authorities to main-tain control over the situation.
To assist in the assessment/response activities a closed circuit television
- system, Droviding the capability to observe the entire protected area perimeter, isolation zones and a majority of the protected
- area, is provided-to the security organization.
~,