ML18345A358

IP 81000 Security

ML18345A358
Person / Time
Issue date:	01/29/2019
From:	Niry Simonian NRC/NSIR/DSO/SOSB
To:
Niry Simonian 301-287-3636
Shared Package
ML18345A3487, ML19029A107	List:
References
CN 19-004
Download: ML18345A358 (4)

Text

NRC INSPECTION MANUAL NSIR/DSO/SOSB INSPECTION PROCEDURE 81000 SECURITY PROGRAM APPLICABILITY: IMC 2200 App A 81000-01 INSPECTION OBJECTIVE 01.01 The objective of this inspection procedure (IP) is to gather information to determine whether a licensee is meeting the objective of the construction security cornerstone, which is to provide assurance that construction activities are not adversely impacted because of fitness-for-duty issues, and that the licensees security programs use a defense-in-depth approach and can protect against the design-basis threat of radiological sabotage from internal and external threats.

01.02 In meeting this objective, this procedure has provisions for the verification and assessment of licensee security construction and operational programs. Such verification is intended to support the Commissions determination, in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 52.103(g), that the acceptance criteria in the combined license have been met.

81000-02 INSPECTION REQUIREMENTS AND INSPECTION GUIDANCE 02.01 Pursuant to Inspection Manual Chapter (IMC) 2200, Security Inspection Program for Construction, construction security inspection requirements are identified in and satisfied by the following inspectable area attachments to this IP:

a. Inspection of ITAAC-Related Security Structures, Systems, and Components (IP 65001.17)

b. Fitness-for-Duty Program (IP 71130.08)

c. Access Authorization (IP 81000.01)

d. Access Control (IP 81000.02)

e. Performance Evaluation Program (IP 81000.03)

f. Equipment Performance, Testing, and Maintenance (IP 81000.04)

g. Protective Strategy Evaluation (IP 81000.05)

h. Protection of Safeguards Information (IP 81000.06)

i. Security Training (IP 81000.07)

j. Fitness-for-Duty (FFD) Operational Program (IP 81000.08)

k. Cyber Security Inspection for Construction (IP 81000.09)

l. Security Organization, Management Effectiveness, Program Reviews and Audits (IP 81000.10)

m. Material Control and Accounting (MC&A) (IP 81000.11)

n. Review of New Reactor Target Sets (IP 81000.14)

Issue Date: 01/29/19 1 81000

o. Fixed Site Physical Protection of Special Nuclear Material of Low Strategic Significance (IP 81431)

p. Fitness-for-Duty Program for Construction (IP 81504)

q. Protection of Safeguards Information for Construction (IP 81505)

The NRC developed guidance to give the inspector an acceptable approach to verifying inspection requirements. Inspector(s) should not view the recommended actions contained in the guidance section as mandatory but rather as an acceptable method for evaluating licensee programs that provides high assurance that the licensees are meeting NRC regulatory requirements within the security program area undergoing inspection. Should questions arise about procedural requirements or guidance, inspectors should consult with regional management or the appropriate Office of Nuclear Security and Incident Response representative for clarification.

02.02 These requirements represent the minimum inspection activity to be conducted at each reactor site at the frequencies shown in each inspectable area attachment.

a. The inspection requirements in Section 02 of the listed attachments describe the necessary actions to be completed in order to achieve the inspection objective(s) stated in Section 01 of the listed attachments. Inspection requirements may include, but are not limited to, inspecting systems, components, records, procedures, programs, and operations.

b. The sample size stated in Section 04 of the listed attachments is the sum of the inspection requirements in Section 02 of the listed attachments. The sample size has been determined to meet the inspection objective(s) and the general performance objective of the security construction cornerstone. Inspection of all inspection requirements identified within each inspectable area attachment demonstrates the completion of the respective IP.

02.03 Corrective Action Program Effectiveness Reviews. A fundamental goal of the U.S. Nuclear Regulatory Commissions (NRCs) oversight of new construction activities is to establish confidence that applicants/licensees (and their contractors) are detecting and correcting problems in a manner that provides assurance that construction activities are not adversely impacted because of fitness-for-duty issues, and that the licensees security programs use a defense-in-depth approach and can protect against the design-basis threat of radiological sabotage from internal and external threats. A key premise of the NRCs oversight is that weaknesses in an applicants/licensees corrective action program (CAP) will manifest themselves as performance issues that will be identified through the NRC inspection program.

Therefore, each security construction IP includes a Corrective Action Program sample for verifying the effectiveness of a licensees CAP related to the inspectable area. In addition to the CAP samples, construction resident inspectors screen CAP issues frequently by following up on selected NRC-identified issues and performing periodic team inspections in accordance with IP 35007, Quality Assurance Program Implementation During Construction and Pre-Construction Activities. For these periodic team inspections, the inspection team may or may not include a Security Specialist as a full-time or part-time team member.

Issue Date: 01/29/19 2 81000

81000-03 INSPECTION RESOURCES Each inspectable area attachment contains estimates of needed inspection resources.

END : Revision History for 81000 Issue Date: 01/29/19 3 81000

Attachment 1 - Revision History for 81000, Security Comment Resolution and Commitment Accession Number Description of Training Closed Feedback Tracking Issue Date Description of Change Required and Form Accession No.

Number Change Notice Completion Date (Pre-Decisional, Non-Public Information)

Inspection procedure issued to support ML11192A029 Inspection Manual Chapter 2200.

N/A 08/27/13 N/A N/A Researched commitments for the last CN 13-018 four years, none found.

Minor administrative changes to update inspection procedure names and ML18345A358 numbers. Upon completion of a SUNSI N/A 01/29/19 review, the staff concluded that this IMC N/A N/A CN 19-004 should be decontrolled. Consistent with the staffs SUNSI determination, this IMC is now publicly available.

Issue Date: 01/29/19 Att-1 81000