ML20056F922

Summary of 930803 Meeting W/Util in Rockville,Md Re Proposed Cost Beneficial Security Program Revs at Browns Ferry Nuclear Plant.List of Attendees & Meeting Handouts Encl

ML20056F922
Person / Time
Site:	Browns Ferry
Issue date:	08/26/1993
From:	Hebdon F Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 9309010028
Download: ML20056F922 (19)

Text

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g NUCLEAR REGULATORY COMMISSION g .g W ASHINGTON, D. C. 20555 g August 26, 1993 Docket Nos. 50-259, 50-260 and 50-296 LICENSEE: Tennessee Val' 4 Authority FACILITY: Browns Ferry Nuclear Plant Units 1, 2, and 3

SUMMARY

OF THE AUGUST 3, 1993 MEETING REGARDING PROPOSED COST BENEFICIAL SECURITY PROGRAM REVISIONS AT THE BROWNS FERRY NUCLEAR PLANT On August 3,1993, representatives of the NRC staff and the Tennessee Valley Authority (TVA) met in Rockville, Maryland to discuss proposed cost-beneficial security program revisions at the Browns Ferry Nuclear Plant (BFN). Meeting attendees are listed in Enclosure 1. Enclosure 2 contains handouts provided by the licensee. This meeting was not open to the public because of anticipated discussion of safeguards information. However, this summary, including the enclosed handouts, does not contain safeguards information, and can be distributed freely.

On July 14, 1993, Tad Marsh travelled to Browns Ferry to discuss NRC staff initiatives to accommodate cost-beneficial licensing actions (CBLAs) identified by the licensees. During Marsh's visit, TVA indicated interest in pursuing relief from certain security and fitness for duty requirements as CBLAs, and was encouraged to review these items with the NRC staff. This meeting resulted from that discussion.

TVA's CBLA program is part of their efforts to control and reduce operating and maintenance costs at Browns Ferry. TVA stated it wished to pursue cost controls in the most safety-beneficial manner, as opposed to blanket budget controls. TVA also noted that their decision to pursue restart of BFN Unit 1 is dependent on the economic viability of that unit. Three security requirements derived from 10 CFR Part 73 and certain fitness for duty requirements from 10 CFR Part 26 have been identified by TVA as requirements with high cost and low benefit.

TVA is planning to seek an exemption from 10 CFR 74.55(d)(8), which requires positive containment access control by security personnel. During the recovery of BFN Units 1 and 3, this control is required continuously. TVA feels that its employee screening programs, radiological work control process, and other programs provide a sufficient level of protection. The NRC staff I noted that this requirement is under consideration for revision by rulemaking, and that exemptions whicn may be granted would depend on consideration of special circumstances. Since BFN Units 1 and 3 are in extended outages, it may be possible to demonstrate these units are in a unique situation. A similar case for BFN Unit 2, which is operating, would be more difficult. The staf f does not wish to grant numerous exemptions for any of these items as a substitute for the rulemaking process. TVA stated they hope their actions 0

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may serve as a catalyst for rulemaking, and that the cost savings are sufficient that BFN is willing to serve as a lead plant for this change.

TVA also plans to seek an exemption from the requirements of 10 CFR ,

Part 73.55(d)(4), which requires escort of all vehicles within the protected '

area, except for designated licensee vehicles. TVA believes their personnel screening, vehicle search, and access control programs provide an adequate level of control for certain vehicles. The NRC staff noted that this issue is also being evaluated for potential rulemaking. -

TVA is also pursuing revisions of the BFN security plan to eliminate certain '

posting requirements for vital area doors. TVA believes these changes can be i made pursuant to 10 CFR 50.54(p)(2), which permits changes to safeguards controls without prior NRC approval if the overall effectiveness of the controls is not diminished.

TVA also plans to seek an exemption from sampling rate requirements for random fitness for duty testing requirements of 10 CFR Part 26.24(a)(2). TVA wishes to reduce the testing rate from 100% to 50% for all personnel, including contractors. This proposed exemption would apply to all TVA nuclear sites.

The staff is also considering rulemaking on this topic. TVA claimed that a ,

reduced sampling rate is justified by the low rate of positive results t obtained from their current testing program. However, the staff noted the ,

intent of this rule includes deterrence, as well as detection. Therefore, there is a concern that a lower sampling rate may reduce the deterrent effect.

The staff advised TVA that any exemption which may be granted must be based on maintenance of an acceptable level of safety and unique circumstances which make conformance with the regulations impractical or inappropriate. Cost savings alone will not be a factor in any staff decision to grant regulatory relief. TVA should emphasize why their facilities are unique, and demonstrate that other controls provide an acceptable level of safety. TVA stated they planned to make a submittal to the staff within the next few weeks.  ;

Original signed by Frederick J. Hebdon, Director Project Directorate 11-4 ,

Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation  ;

Enclosures:

1. Attendance List

2. TVA Handout PDII-4/PM*

cc w/ enclosures: DTrimble See next page *see previous concurrence 8/19/93 0FC PDII-(/NA PDII-4//tl PDII-4/PM* PDIII-1/D* PSGB* PDIh4/D NAME BClaytob JWil}k TRoss LMarsh PHCKee FH$ hon DATE /

8/SD93 8/h/93 8/23/93 8/23/93 8/25/93 8/ ')6 /93 !

Document Name: CBLAMIG. SUN ,

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Mr. W. H. Kennoy, Director State Health Officer Tennessee Valley Authority Alabama Dept. of Public Health  :

ET 12A 434 Monroe Street '

400 West Summit Hill Drive Montgomery, Alabama 36130-1701 Knoxville, Tennessee 37902 Mr. R. M. Eytchison, Vice President Regional Administrator Nuclear Operations U.S.N.R.C. Region II '

Tennessee Valley Authority 101 Marietta Street, N.W.

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3B Lookout Place Suite 2900 1101 Market Street Atlanta, Georgia 30323 Chattanooga, Tennessee 37402-2801 Mr. Charles Patterson i Site Licensing Manager Senior Resident Inspector .

Browns Ferry Nuclear Plant Browns Ferry Nuclear Plant l Tennessee Valley Authority U.S.N.R.C. '

P.O. Box 2000 Route 12, Box 637 Decatur, Alabama 35609-2000 Athens, Alabama 35611 Mr. O. J. Zeringue, Vice President Manager, Nuclear Assurance Browns ferry Nuclear Plant and Licensing Tennessee Valley Authority Browns Ferry Nuclear Plant P.O. Box 2000 Tennessee Valley Authority I Decatur, Alabama 35609-2000 P. O. Box 2000 Decatur, Alabama 35609-2000 l Mr. B. S. Schofield, Manager Dr. Mark 0. Medford, Vice President l Nuclear Licensing and Regulatory Affairs Technical Support l Tennessee Valley Authority Tennessee Valley Authority  !

SB Lookout Place 3B Lookout Place l 1101 Market Street 1101 Market Street i Chattanooga, Tennessee 37402-2801 Chattanooga, Tennessee 37402-2801 TVA Representative Tennessee Valley Authority 11921 Rockville Pike Suite 402 Rockville, Maryland 20852 General Counsel Tennessee Valley Authority ET 11H 400 West Summit Hill Drive i Knoxville, Tennessee 37902 '

Chairman, Limestone County Commission P.O. Box 188 Athens, Alabama 35611

ENCLOSURE I ATTENDEES AUGUST 3, 1993 TVA/NRC MEETING PROPOSED COST-BENEFICIAL SECURITY PROGRAM REVISIONS NAME ORGANIZATION Joe Williams NRR/PD II-4 L.B. Marsh NRR/PD III-I E.W. McPeek HRR/PSGB L. Bush NRR/PSGB Paul O' Conner NRR/PD IV-1 Phillip F. McKee NRR/PSGB Bruce Schofield TVA Manager NLRA Chris Kelly- TVA Manager Corporate Nuclear Security James Brazell BFN Site Security Manager Fred Hebdon NRR/PD II-4 Dave Trimble NRR/PD 11-4 Brian Hughes NRR/CBLA Pedro Salas BFN Site Licensing Manager O

s . .

DISTRIBUTl?jt Enclosure 1 T. Murley/F. Miraglia 12-G-18 J. Partlow 12-G-18 S. Varga G. Lainas F. Hebdon B. Clayton T. Ross D. Trimble OGC 15-B-18 E. Jordan MNBB-3701 ACRS (10)

L. Plisco 17-G-21 L. Marsh 13-D-18 E. McPeek 9-D-24 L. Bush 9-D-24 P. O'Connor 13-H-3 P. McKee 9-D-24 B. Hughes 10-D-22 Enclosures 1&2

' Docket File NRC and Local PDR BFN Rdg. File -

E. Merschoff J. Williams 270006

ENCLOSURE 2 i

TENNESSEE VALLEY AUTHORITY i BROWNS FERRY NUCLEAR PLANT i i

0&M COST REDUCTION PROGRAM  !

PROPOSED COST BENEFICIAL  ;

LICENSING ACTIONS ,

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AUGUST 3, 1993 l

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AGENDA l

l I. OVERVIEW 0F- BFN OPERATING & i MAINTENANCE COST REDUCTION PROGRAM i l

1 II. OVERVIEW 0F BFN SECURITY SYSTEM UPGRADE i I

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III. DISCUSSION OF PROPOSED COST l BENEFICIAL LICENSING. ACTIONS  ;

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EXEMPTION TO ELIMINATE POSTING OF ,,

CONTAINMENT EXEMPTION TO REDUCE VEHICLE ESCORT  :

REQUIREMENTS

- SECURITY PLAN REVISION TO REDUCE COMPENSATORY POSTING

- EXEMPTION TO REDUCE FITNESS-FOR-DUTY  :

RANDOM TESTING RATE t

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I. OVERVIEW 0F BFN 0&M COST REDUCTION PROGRAM e PROGRAM INITIATED TO REDUCE BFN OPERATING AND MAINTENANCE COSTS WHILE MAINTAINING SAFETY

• INITIAL EFFORTS INCLUDED STREAMLINED MANAGEMENT REVIEW TO IDENTIFY " BIG TICKET" ITEMS (COST SAVINGS >5100K) e JULY 14, 1993, MEETING AT BFN WITH THE NRC TASK FORCE ON COST BENEFICIAL LICENSING ACTIONS (CBLAS) e BFN IS ACTIVELY REVIEWING A NUMBER OF POTENTIAL CBLAS FOR SUBMITTAL To NRC e PURPOSE OF TODAY'S MEETING IS TO DISCUSS FOUR CBLAS WHICH TVA IS PREPARING TO SUBMIT 3

4 II. OVERVIEW 0F BFN SECURITY SYSTEM UPGRADE

• TVA IS IMPLEMENTING MAJOR ($28 MILLION) SECURITY SYSTEM UPGRADE AT BFN

• UPGRADE WILL INCORPORATE LATEST TECHNOLOGICAL ADVANCES, STATE OF THE ART EQUIPMENT, AND HUMAN FACTORS IMPROVEMENTS NEW CENTRAL AND SECONDARY ALARM STATIONS

- NEW WEST ACCESS PORTAL AND IMPROVED EAST ACCESS PORTAL NEW SECURITY COMPUTER SYSTEM -

PROVIDES FOR ONLINE AUTOMATED PERSONNEL ACCOUNTABILITY

- NEW PERIMETER / INTRUSION DETECTION SYSTEM WITH AUTOMATIC CALL-UP CAMERAS NEW PERSONNEL ACCESS CONTROL PORTALS WITH KEYPAD READERS REQUIRING A PERSONAL IDENTIFICATION NUMBER

- NEW MAGNETIC LOCK VITAL AREA DOORS WITH SMART ELECTRONICS

- VEHICLE SEARCH AREA AND REMOTELY OPERATED ELECTRONIC GATES MONITORED BY CLOSED CIRCUIT TELEVISION CAMERAS IMPROVED LIGHTING e UPGRADE WILL GREATLY INCREASE OVERALL LEVEL OF SYSTEM PERFORMANCE AND RELIABILITY, RESULTING IN GREATER PROTECTION AGAIliST RADIOLOGICAL SABOTAGE i

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III. DISCUSSION OF PROPOSED CBLAs SUPPORTING INFORMATION CBLAS 1-3 RELATED TO THE INSIDER THREAT (10 CFR PART 73) AND  !

ARE NOT NOVEL

• SIGNIFICANT REGULATORY CHANGES (PERSONNEL l SCREENING PROGRA!4S) WHICH PROTECT AGAINST INSIDER  :

THREAT HAVE OCCURRED SINCE PART 73 WAS ADOPTED IN 1977  !

- VITAL AREA ACCESS CONTROLS

- CRIMINAL HISTORY CHECKS l

- FITNESS-FOR-DUTY PROGRAMS l l

- ACCESS AUTHORIZATION PROGRAMS . I

• SECY 92-272 DEVELOPED TO RECONSIDER APPROPRIATENESS OF PART 73 REQUIREMENTS l

• CBLAS ARE CONSISTENT WITH NRC STAFF FINDINGS AND RECOMMENDATIONS IN SECY ' 2-272 )

CBLA 4 e

SIMILAR TO NRC PROPOSED RULE TO REDUCE FITNESS-FOR-DUTY RANDOM TESTING RATES e REQUESTS APPLICATION OF REDUCTION TO CONTRACTORS 6

III. DISCUSSION OF PROPOSED CBLAs CBLA 1 - EXEMPTION FROM 10 CFR 73.55(o)(8)

BACKGROUND e 10 CFR 73.55(D) (8) REQUIRES POSITIVE ACCESS CONTROL WITH GUARD OR WATCHMEN DURING PERIODS OF FREQUENT ACCESS TO ENSURE ONLY AUTHORIZED PERSONNEL AND MATERIAL ENTER CONTAINMENT e AT BFN PRIMARY AND SECONDARY CONTAINMENT AT BFN ARE PART OF THE SAME VITAL AREA - GUARDS ARE POSTED AT SECONDARY CONTAINMENT e DUE TO STATUS OF BFN UNITS 1 AND 3, CONTAINMENT MUST BE POSTED DURING ENTIRE RECOVERY PERIOD e REQUIRES 25 GUARDS TO MAN 24 HOURS / DAY 7

1 III. DISCUSSION OF PROPOSED CBLAs CBLA 1 - EXEMPTION FROM 10 CFR 73.55(o)(8)

CBLA JUSTIFICATION - SAFETY e POST-1977 PERSONNEL SCREENING PROGRAMS PROVIDE ADEQUATE ASSURANCE THAT ONLY AUTHORIZED PERSONNEL ENTER BFN CONTAINMENT e EXTENSIVE MEASURES EXIST AT BFN TO PREVENT INTRODUCTION OF UNAUTHORIZED MATERIAL INTO PLANT PERSONNEL ENTERING PROTECTED AREA MUST PASS THROUGH EXPLOSIVE AND METAL DETECTORS CHEMICAL TRAFFIC CONTROL PROGRAM (SPECIFIES MATERIALS PERMITTED INTO RADIOLOGICALLY CONTROLLED AREA [RCA] - CONTAINMENT PART OF RCA)

CONTROL OF TRANSIENT FIRE LOADS (PERMIT REQUIRED TO BRING SUCH MATERIAL INTO CONTAINMENT)

RADIOLOGICAL WORK PERMIT PROGRAM e SYSTEM RETURN TO SERVICE PROGRAM IS DESIGNED TO DETECT POTENTIAL SABOTAGE PRIOR TO STARTUP/ RESTART CBLA JUSTIFICATION - COST SAVINGS /0THER BENEFITS

• EXEMPTION WOULD SAVE $1.1 MILLION ANNUALLY WHILE UNIT IN RECOVERY ($290 TO S440K THEREAFTER) e EXEMPTION WOULD RESULT IN 4 MAN-REM ANNUAL DOSE REDUCTION 8

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III. DISCUSSION OF PROPOSED CBLAs CBLA 2 - EXEMPTION FROM 10 CFR 73.55(o)(4)

BACKGROUND l

10 CFR 73.55(D)(4) REQUIRES ESCORT OF ALL VEHICLES EXCEPT DESIGNATED LICENSEE VEHICLES INSIDE i PROTECTED AREA ,

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• REQUIREMENT PROVIDES LITTLE ADDED SECURITY IF DRIVER OF VEHICLE HAS UNESCORTED ACCESS TO BFN l I

e EXEMPTION WILL ELIMINATE ESCORT REQUIREMENTS FOR  !

VEHICLES OPERATED (DRIVEN) BY PERSONNEL WITH  !

l UNESCORTED ACCESS TO BFN l 1

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III. DISCUSSION OF PROPOSED CBLAs CBLA 2 - EXEMPTION FROM 10 CFR 73.55(o)(4)

CBLA JUSTIFICATION - SAFETY e CONTRACTOR & TVA PERSONNEL SUBJECT TO PERSONNEL SCREENING PROGRAMS FOR UNESCORTED ACCESS  :

e ALL VEHICLES, REGARDLESS OF OWNERSHIP / CONTROL, SUBJECTED TO SAME SEARCH METHODS e ADEQUATE ASSURANCE IS PROVIDED THAT ONLY AUTHORIZED PERSONNEL GRANTED ACCESS TO PLANT, AND THAT VEHICLES AND THEIR CONTENTS WILL NOT BE USED IN A MANNER INCONSISTENT WITH SAFEGUARDING THE PLANT CBLA JUSTIFICATION - COST SAVINGS /0THER BENEFITS e EXEMPTION WOULD SAVE 5172K ANNUALLY e ADDITIONAL COST SAVINGS WILL BE REALIZED THROUGH  ;

BETTER UTILIZATION OF EXISTING RESOURCES AND ,

REDUCED OVERTIME  ;

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III. DISCUSSION OF PROPOSED CBLAs l CBLA 3 - REVISE SECURITY PLAN FOR  !

COMPENSATORY POSTING l t BACKGROUND l l

• BFN'S SECURITY PLAN REQUIRES POSTING OF ARMED i SECURITY FORCE MEMBER AT VITAL AREA (VA) DOOR WHEN l ITS LOCK OR ALARM DOES NOT FUNCTION PROPERLY l

l i e TVA PROPOSES TO REVISE BFN SECURITY PLAN PURSUANT i l TO 10 CFR 50.54(P)(2) TO ELIMINATE POSTING VA 000RS I l AS FOLLOWS

l INTERIOR DOORS - ELIMINATE POSTING ,

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EXTERIOR DOORS - POST ONLY IF ALARMS MALFUNCTION I j AND DOOR WILL NOT LOCK '

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1 III. DISCUSSION OF PROPOSED CBLAs CBLA 3 - REVISE SECURITY PLAN FOR '

COMPENSATORY POSTING i i

I CBLA JUSTIFICATION - SAFETY I

e CHANGE WILL NOT DECREASE SAFEGUARDS EFFECTIVENESS AND COMPLIANCE WITH 10 CFR PART 73 WILL BE UNAFFECTED e PROTECTED AREA (PA) PERIMETER IS SURROUNDED BY AN ALARMED PHYSICAL BARRIER AND ILLUMINATED ISOLATION ZONE o VITAL AREAS ARE LOCATED WITHIN PA BEHIND MINIMUM OF 2 BARRIERS (BARRIERS CHECKED EACH SHIFT BY ROVING SECURITY PATROL)

VITAL AREA DOORS ARE EQUIPPED WITH HIGH SECURITY CARD KEY SYSTEM, OR PADLOCKS /DEADBOLTS

• BFN SECURITY FORCE INCLUDES A WELL TRAINED AND WELL EQUIPPED RESPONSE FORCE CAPABLE OF DETECTING EXISTENCE OF A THREAT, ASSESSING IT, AND ACTING SWIFTLY TO NEUTRALIZE IT e TVA'S CURRENT SCREENING PROCESS ENSURES THAT SITE i PERSONNEL WITH UNESCORTED ACCESS HAVE TRUSTWORTHY I BACKGROUNDS, STABLE PSYCHOLOGICAL PROFILES, AND l

RELIABLE BEHAVIOR l

o PERSONNEL WITH UNESCORTED ACCESS ARE IDENTIFIED, AUTHORIZED, SEARCHED, AND BADGED UPON ENTRANCE TO THE PROTECTED AREA ,

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i III. DISCUSSION OF PROPOSED CBLAs  :

CBLA 3 -

REVISE SECURITY PLAN FOR ,

i COMPENSATORY POSTING CBLA JUSTIFICATION - SAFETY (CONTINUED) l r

e OTHER COMPENSATORY MEASURES WILL BE PROVIDED WHEN A

. VITAL AREA LOCK OR ALARM DOES NOT RESET OR FUNCTION  :

( PROPERLY:

SECURITY PERSONNEL WILL PROMPTLY ENSURE THAT THE BARRIER IS IN PLACE WORK ORDER WILL BE SUBMITTED TO ENSURE SYSTEM IS EITHER REPAIRED OR RETURNED TO SERVICE WITHIN 72 HOURS WILL BE POSTED IF CONDITION NOT CORRECTED WITHIN

. 72 HOURS e SECURITY SYSTEM UPGRADE WILL INCREASE SYSTEM RELIABILITY THEREBY REDUCING NEED FOR COMPENSATORY POSTING I

CBLA JUSTIFICATION - COST SAVINGS /0THER BENEFITS e REDUCES DIVERSION OF SECURITY OFFICERS TO ,

UNNECESSARY POSTING DUTIES j e ESTIMATED ANNUAL SAVINGS OF S226K 13

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DISCUSSION OF PROPOSED CBLAs III.  !

CBLA 4 - EXEMPTION FROM 10 CFR 26.24(A)(2) l TO REDUCE RAND 0M TESTING RATE  !

l BACKGROUND l s RECENT PROPOSED RULE BY NRC STAFF PROPOSES REDUCTION IN RANDOM TESTING TO 50% FOR LICENSEE  !

EMPLOYEES BUT MAINTAINS 100% RATE FOR CONTRACTORS i

i e POSITIVE RANDOM TESTING RESULTS FOR BFN CONTRACTORS l WELL BELOW RATE IN PROPOSED RULE ,

e DUE TO STATUS OF UNITS 1 AND 3, SIGNIFICANT NUMBERS i OF CONTRACTORS WILL BE REQUIRED TO RECOVER UNITS e EXEMPTION REQUESTED TO REDUCE RANDOM TESTING RATE i

FOR ALL PERSONNEL TO 50%

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A III. DISCUSSION OF PROPOSED CBLAs  !

CBLA 4 -

EXEMPTION FROM 10 CFR 26.24(A)(2)

TO REDUCE RAND 0M TESTING RATE CBLA JUSTIFICATION - SAFETY ,

e RANDOM TESTING POSITIVE RESULTS VERY LOW AT BFN 1990-1992 AVERAGE FOR TVA EMPLOYEES - 0.21% (LESS THAN INDUSTRY AVERAGE IN PROPOSED RULE - 0.25%)

1992 AVERAGE FOR TVA EMPLOYEES - 0.09%

1990-1992 MERAGE FOR CONTRACTORS -

0.33%

(SIGNIFICANTLY LESS THAN INDUSTRY AVERAGE IN PROPOSED RULE - 0.56% AND COMPARABLE TO INDUSTRY AVERAGE FOR LICENSEE EMPLOYEES)

CBLA JUSTIFICATION - COST SAVINGS /0THER BENEFITS

• EXEMPTION WOULD SAVE 5500K ANNUALLY (EXCLUDES LOST PORDUCTIVITY) 1 15