ML20053C388
| ML20053C388 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/19/1982 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Jackie Jones CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 8206020044 | |
| Download: ML20053C388 (6) | |
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Docket Files SSPB Reading W 7 MAY l 91982 Gray File N
ORB 2 Gray File g
NRC PDR
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RECEIVED Docket Hos.: 50-324/325 Local PDR f-J. Van Vliet I
MAY 211982* T3 S. Norris
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H. Denton/E. Case f-
"$N H Mr. J. A. Jones D. Eisenhut/R. Purple 1
Senior Executive Vice President M. Williams Carolina Power & Light Company R. Tedesco m
336 Fayetteville Stre?t R. Burnett Raleigh, North Carolina 27602 H. Bernard E. McPeek
Dear Mr. Jones:
P. Anderson Region II During the development of the upgraded physical security rules a few years ago, there were a number of concerns expressed that the new requirenents night lead to a reduction in reactor safety. On the other hand, there are snme who are concerned that the requirements for reactor safety may reduce the effectiveness of the physical security measures at facilities. These competing concerns were given careful consideration in finalizing the rules.
How that the upgraded physical security systems have been in place for some time and experience in their use has been gained, we believe it would be useful to review the safety / safeguards interface in place at a few reactors to detemine whether the requirenents of either one are having an adverse effect on the other. Before initiating an industry-wide review of this issue, we believe that the need for, and scope of, such a review can best be detemined by infomal management level discussions ct a few representative facilities. To this end, the Director of Safeguards, NMSS, and the Deputy Director of Licensing, NRR, would like to meet with your management to explore the issue. These meetings would-be nore effective if held at the site so that we can better appreciate the practical problems that are being encountered.
To help focus our discussion, enclosed you will find a list of representative questions on the subject. We plan to use these questions as an agenda for our meeting with you -- no fomal written responses are expected.
I hope you will assist us in this effort. Your NRC Project Manager will be contacting you to arrange the meeting, if you are agreeable to it.
Sincerely, Original signed by Darren G, Eisentut 8206020044 820519 Darrell G. Eisenhut, Director PDR ADOCK 05000324 Division of Licensing F
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ENCLOSURE i
SAFETY / SAFEGUARDS INTERFACE QUESTIONS 1.
Protected Area Access Controls a) Do protected area access control and search requirements have an adverse impact on safety during routine operations?
If yes, please explain.
Also, if the answer is yes, do you. believe the NRC requirements in this area can be met without such impact by a system redesigr:?
b). Do you expect protected area access control and search requirements to have an adverse impact on safety if an emergency response is required from off-site?
If yes, please explain. Also, if the answer is yes, is this impact more on your real ability to deal with an emergency or on your ability to meet NRC emergency planning require-ments (such as NUREG-0654) that certain people must respond to the site within a very limited time?
l 2.
Vital Area Access Controls - Routine x,, '
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a) Do vftal area security access controls have an adverse impact on safety duhing routine operations? If yes, please explain. Also, if the answer is yes, do you beTieve that the NRC requirements cr.n be met without such safety-impact by a system redesign?
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Do vital area security access controls have a positive impact on safety by keeping " sidewalk superintendents" out of vital arefs when " interesting" work is being performed?
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c)
Does NRC pressure to mini. ize the number of people authorized access to vital areas have an adverse impact on safety during routine oper-ations? If yes, explain.
d) Do NRC surveillance and testing requirements increase the number of people authorized access to vital areas beyond that prudent for good security? Do such requirements provide additional opportunities for malevolent acts?
e) Are hardened chains and padlocks use for the protection of Engineered Safety Feature valves?
If,yes, what are the safety implications?
3.
Vital Area Access Controls - Emergency a) Do you expect vital area security access controls to have an adverse impact on your staffs capability to dea' l with accidents or emergencies?
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If yes, please explain.
b)
Is unimpeded egress assured from vital areas following p power failure to the electrical locking system?
c) Are l'ocks or other fastening devic'es used on emergency exits that would prevent escape from the inside of a building?
4.
Work Rules - Routine 7 :Y a) Do security-related work rules (e.g., the two-man rule) adversely impact safety during routine operations? If yes, please explain.
c.
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Work Rules - Emergency a)
Do you expect security related work rules (e.g., the two man rule) to adversely impact your staff's capability to deal witg accidents or emergencies? If yes, please explain.
b) The Central Alarm Station, along with the Secondary Alarm Station, which controls all security-related systems, does not have the same radiological habitability requirements as the "TSC."
In view of th!s,
' do you see any possible conflicts associated with assuring adequate safety / safeguards during a safety-related emergency?
6.
Equipment Interaction a) Have you experienced problems with security equipment adversely impacting safety equipment?
(e.g., use of security walkie talkies in control room causes reactor trip).
If yes, please explain.
Do you believe these indicate or constitute a safety problem?
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b) Have you experienced problems with plant operating or safety equipment l
(e.g.,startingcirculating adversely' impacting security equipment?
l water pumps trips the security access control computer) If yes, please explain.
Do you believe that these indicate or constitute a security
-e problem?
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.j c) Do you believe that patrols of vital areas by armed security officers present a potential safety hazard? If so, how does the frequency of
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equipment damage or personnal injury related to this practice compare to the frequency from other types of accidents?
7.
Cost, Constuction, and Management Attention a) Do you believe that the expense and requirement for management attention associated with the security program t;as prevented you from initiating plant modifications that, although no specifically required by NRC, would enhance plant safety? If yes, please explain.
b) Do you believe that the expense and requirement for management attention
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associated with NRC mandated safety changes has prevented you from initiating program changes that, although not specifically required by NRC, would enhance plant security? If yes, please explain.
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c)
Do you believe that plant sehurity posture has been lowered during construction associated with safety related backfits of, the plant.
If yes, please explain.
d) Has construction associated with meeting NRC security requirements had an adverse impact on plant safety.
If yes, please explain.
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8.
Interpersonal Relations a)
Is there good rapport and mutual respect between plant securi,ty personneT and plant operational and construction personnel? If so, can you identify contributing factors? If not, can you identify problem areas? Co they
5-relate to NRC's regulatory approach or requirements in either the safety or security area or both?
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b) Does the use of guards, for compensatory measures, due to the j
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physical limitations of security equipment contribute to declining morale, complacency, and unsatisfactory performance of the guards, which could impact safety.
c)
Is the present practice of weapons being permitted into sensitive areas of the plant a safety concern?. '
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9.
Records and Reports a) Are NRC safeguards and safety reporting requirements consistent? Are duplicate safety and safeguards reports required on the same event?
b) Are NRC safeguards and safety recordkeeping and retention requirements consistent? Are duplicate safety and safeguards reports of the same information required to be maintained?
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