ML19263B105
| ML19263B105 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 12/19/1978 |
| From: | Mccorkle G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Schultz D UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| References | |
| NUDOCS 7901050094 | |
| Download: ML19263B105 (4) | |
Text
F0v UNITED STATES 1
NUCLEAR REGULATORY COMMISSION
{ ( f@
WASHINGTON, D. C. 20555
%v DEC 19 1978 SGPS:RBM 70-820 United Nuclear Corporation ATTN:
D. M. Schultz, Manager Compliance Fuel Recovery Operation Wood River Junction, R. I.
02894 Gentlemen:
Based on our review of your Contingency Plan submitted on September 19, 1978, we find that rather extensive revision is needed for it to be-come an acceptable document.
As you know, one of the principal purposes of a cantingency plan is ^o provide a basis for the development of meaningful operational procedure.
for security personnel.
It is our view that alti.ough the draft plan which you submitted does contain a considerable amount of useful material, the organization of the plan and the inclusion of extraneous and redundant materials reduce its utility.
The shortcomings we have noted in the plan fall into several c.ategories.
Examples of our observations according to these categories are set forth in the enclosure to this letter.
Plecse note that our examples are ex-actly that and are not ;o be considered as all inclusive.
We would appreciate your submittal of this plan on an expedited casis since we are hopeful of having an approved plan by January 19, 1979. Our project officers are available to work with you relative to any questions you may have. They are Messrs. Mitchell, 42-74193, and Manili, 42-74181,
of the Contingency Planning and Physical Security Licensing Branches, respoctively.
We have determined that your Safeguards Contingency Plan dated September
~9,1978 contains information of a type specified in 10 CFR 2.790(d).
Accordingly, it is deemed to be commercial or financial information within the meaning of lG CFR 9.5(a)(4) and shall be subject to disclosure only in accordance with the provisions of 10 CFR 9.12.
Sincerely.
y $4 w
L George W. McCorkle Chief n Physical Security Licensine Branch Enclosure :
As sta ted m
SGPS:RBM 70-820 ENCLOSURE COMMENTS UPON SAFEGUARDS CONTINGENCY PLAN ORGANIZATION The organization of the plan could be improved by removing material not directly connected with its individual components and placing it in an appendix or in necessary procedural documents.
For example, under Section 1.1 only the first sentence on page 1-2 pertains to the perceived danger. The material on pages 1-3,1-4 and 1-5 appears to be instructional and not pertinent to the bmsic plan. Regarding Section 1.2, ti e material appears to miss the point that the purpose of the plan is to guide and coordinate security force response actions with the objective of preventing theft and sabotage. Only the first six lint.s of the entire page actually pertain to the stated subject. The remainder of the material is merely an explanation of decision-making and such material along with that on page 1-7 could more appropriately be included in an appendix.
In a like vein, only paragraphs one, three and five of Section 1.3.1 actually pertain to the given subject.
The remaining material is superfluous to this and should be placed in a training appendix.
EXTRANEOUS MATERIAL The inclusion of extraneous material throughout the document tends to distract from the overall usefulness of the plan. Meaningful items of information are hidden in historical references to UNC planning processes and in excess verbiage on what the various events are intended to mean.
For example, on page 2-70 a system of priorities is given which are situation dependent and not necessarily valid for the security force. Emergency teams should'have been assigned the given functions in order to assure that the security force is available to perform their primary mission which is to safeguard the SNM. We also noted specifically the 10 pages of definitions and terms in Section 1.4.
Many of these definitions were not used in the plan, whereas, on the other hand a number of abbreviations, e.g., PCDS, S&R, FNMC, etc. were used in the plan and not defined. Obviously, editing and reduction in content is indicated. The material in Section 3.9 is entirely extraneous to the needs of contingency planning efforts.
With the exception of the last two paragraphs on page 3-32/33, all information should be deleted since it is not applicable to the plan.
. CONFLICTING MATERIAL On page 1-9, the statement is made in Section 1.3.2 that the security force will act as directed by the Field and Tactical commander, whereas, the first paragraph on page 3-22 states that the responsibility for tactical disposition and command of all employee security forces will always lie with the senior UNC security person onsite. Similar con-flict exists between information on the response of guards discussed under item 8-1 (page 4-36) and that contained in the write-up on page 2-33.
INADEQUATE COVERAGE The maps in Section 3.2 (page 3-11/12) are inadequate for LLEA and licensee planning. A map is needed snowing reentry and exit roads to the facility with prominent terrain features in sufficient detail for sound roadblock planning. Section 4.0 also contains numerous examples of inadequate coverage.
For example, in P.1, P.2, and P.3 there is no indication that once a threat is determined to be serious that follow-on action is required.
Reference P.1 on page 4-5 which discusses "A Threat By A Third Party" indicates that departments are advised of the situation by the UNC security management representative, however, this task is not assigned as a duty to that individual. The same situation pertains to management /CMT functions.
In reference to P-9 on page 4-42, decisions are again stressed and actions are neglected. Although this event was defined on page 2-80 as a condition requiring a red alert status, there is no such indication in the Responsibility Matrix.
There are numerous similar shortcomings throughout the entire Section 4.0.
EXCESSIVE MATERIAL Information on pages 3-13 and 3-14 exemplifies the use of excessive verbiage. These pages could be reduced to less than one page showing which buildings are of prime safeguards concern. The way the material is now presented hides the important aspects of the information.
Totally excessive information is contained in Section 3.3 on page 3-15.
Paragraph four is certainly excessive since it discusses training needs and is not related directly to the subject.
e
' CONFUSING MATERIAL A properly written contingency plan should resolve any existing con-flicts in order to eliminate possible confusion. However, a degree of confusion exists in the assignment of routine actions within the Responsibility Matrix.
For example, in the event of a third party threat (P-1) the Manager, Compliance is to take action to convene the CMT meeting, however, P-2 indicates that the general manager takes action to convene the meeting. Similarly, in regard to P-20 on page 4-109-114, it is difficult to determine who is responsible for calling the CMT meeting, i.~., the Manager, Compliance or e
management.
REDUNDANCY Section 2.0, Generic Planning Base exemplifies both the inclusion of excessive material and the inclusion of redundant material. All information after page 2-14 is not needed in the basic plan.
It may have some value as training material.
If so, it should be placed in an appendix. Essentially, the same type of information is repeated later in the Responsibility Matrix. Thus, pages 2-15 through 2-80 are t.1necessary to the basic plan. Also, it is noted that all of the information given in paragraph two of Section 4.1, page 4-1, is prac-tically a word-for-word repeat of the same material previously given on page 3-6.
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