ML20044C669
| ML20044C669 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 04/27/1993 |
| From: | Mckee P Office of Nuclear Reactor Regulation |
| To: | Dan Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 9305030194 | |
| Download: ML20044C669 (9) | |
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UNITED STATES e-j
'l, j NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D.C. 20656-0001 p
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April 27, 1993 8
Docket No.: 50-261 MEMORANDUM FOR:
Douglas M.
Collins, Chief Nuclear Materials Safety & Safeguards Branch Division of Radiation Safety & Safeguards Region II FROM:
Phillip F. McKee, Chief Safeguards Branch Division of Radiation Safety & Safeguards, NRR
SUBJECT:
OPERATIONAL SAFEGUARDS RESPONSE EVALUATION PROGRAM An Operational SafegualJs Response Evaluation (OSRE) for the H.
B. Robinson Steam and Electric Plant Unit No. 2 has been scheduled for June 7 through June 10, 1993. is a draft letter to the Carolina Power & Light Company which explains-the purpose and schedule of the review.
Your assistance in 4
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.,
" Guidelines for the Safety /
Safeguards Interface Member," provides information for that individual.
Our team will also need a Physical Security For Inspector to accompany them for the duration of the OSRE.
the Thursday exit briefing, the attendance of a management representative, such as yourself, is requested. is a list of logistical matters which we would appreciate your help in resolving.
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Douglas M.
Collins 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.
/
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 F.
Congel E.
Butcher OSRE File P. McKee D. Orrik PSGB r/fc/'
R. J.
Dube L. Garner, SRI DRSS r/f B. Mozafari, PM k lW hblial/ l 47W}
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DRAFT LETTER TO CAROLINA POWER & LIGHT COMPANY
==Dear
- ==
The NRC is in the process of conducting operational safeguards responsa evaluations (OSREs) at nuclear power reactors.
I wish
~to inform you that the H. B. Robinson Steam & Electric Plant Unit 2 has been chosen for such a review scheduled for the week of June 7 through June 10, 1993.
The primary objective of the OSRE program is to evaluate the readiness of licensees' on-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, i
These reviews complement NRC's licensing and regional inspection functions.
l 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 a
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from the NRC regional office and the NRC resident inspector.
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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.
It is through these contact persons that arrangements are made for knowledgeable licensee personnel to escort the team members during the review.
i t
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 l
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 i
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 i
plant operators to assure that security systems are not interfering with safe operation of the plant.
i I
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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.
l The time that various team members spend on-site may vary, but generally will range from six to eight hours per day.- Some of i
this time is expected to be during evening hours.
If you have any questions regarding the conduct of the
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operational security readiness evaluation program which you wish to have answered prior to the team's visit, please contact Qavid t
Orrik, Safeguards Branch at (301) 504-3213, or of Region II staff.
Sincerely, cc:
F.
Congel, NRR E.
B. Mozafari, PM, NRR L. Garner, SRI D. Orrik, NRR ENCLOSURE 1 r
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i e
GUIDELINES FOR THE SAFETY / SAFEGUARDS INTERFACE MEMBER 1
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 l
each day, discussed with plant management at the exit briefing, t
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.
4 control room procedures for responding to malfunctions or i
alarms allowable times for correcting malfunctions operational personnel use of security assets to assist in i
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)
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2.
Identification of any security procedures that may interfere
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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 i
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 j
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 i
interference of locked doors with rapid entry into vital area (e.g., during health emergency or potential safety
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t incident) l 3.
General interaction of security, operational, and maintenance l
personnel.
s 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 i
committee security participation in review of operational i
procedures and system changes l
security awareness of maintenance activities that could affect security barriers er surveillance capabilities attitudes of site personnel towards level of security at I
site j
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i attitudes of site personnel regarding removing access controls from vital equipment i
attitudes of site personnel regarding wider availability of hard keys for operational staff for access to vital areas
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4.
Equipment Concerns.
adverse impact of security equipment on safety (e.g.,
Electromagnetic Interference (EMI) from security radios affecting safety systems) r 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 i
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 a
security systems failures positive / negative safety aspects of hardened chains and padlocks for protection of Engineered Safety Feature valves and motor controls Safetv/Safeauards References 1.
IE Information Notice No. 83-36, " Impact of Security
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Practices on Safe Operations," June 9, 1983.
2.
NUREG-0992, " Report of the Committee to Review Safeguards Requirements at Power Reactors," May, 1983.
3.
IE Information Notice 85-79, " Inadequate Communication Between Maintenance, Operations, and Security Personnel."
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4.
10 CFR 73. 55(d) (7) (ii).
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.k 5.
Generic Letter 87-08, " Implementation of 10 CFR 73.55 Miscellaneous Amendments and Search Requirements," May 11,
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1987.
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b OPERATIONAL SAFEGUARDS READINESS REVIEW ADMINISTRATIVE CONCERNS i
- 1. Dispatch letter to licensees confirming visit and identifying team members.
8 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 i
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.
i 8.
Determine what personnel information the licensees will need
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to facilitate access control requirements for team members.
9.
Ask the licensees to select a tire and place for a single entrance briefing soon a f cer the team's arrival on-site the first day.
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- 10. Inform licensees that the OSRE team may want to observe l
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.
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ENCLOSURE 3 4
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