ML20100R324
| ML20100R324 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Turkey Point |
| Issue date: | 05/27/1983 |
| From: | Mcdonald D Office of Nuclear Reactor Regulation |
| To: | Thomas C Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20100Q372 | List: |
| References | |
| FOIA-83-531 NUDOCS 8412170382 | |
| Download: ML20100R324 (6) | |
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'o UNITED STATES g
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Standardization & Spe' cia.1 #rQbd;'t B'rbfeCecil 0. Thomas, Chief""
MEMORANDUM FOR:
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Division of Licensin 2.w mir THRU:
Steven A. Varga, Chief y
Operating Reactors Branch No. 1 Division of Licensing FROM:
Daniel G. Mcdonald, Project Manager Operating Reactors Branch No. 1 Division of Licensing
SUBJECT:
COMMENTS ON REGULATORY EFFECTIVENESS REVIEW AND VITAL AREA VALIDATION - TURKEY POINT PLANT UNITS 3 AND 4 As Project Manager for Turkey Point Plant Units 3 and 4, I participated in the Safeguards Regulatory Effectiveness Review (RER) and Vital Area Validation (VAV), at the Turkey Point Site from May 23 through May 27, 1983.
I have been provided copies of the RER and VAV reports and have been requested to provide coments.
By letter dated May 12, 1983, we informed the licensee of our proposed visit and purpose.
The purpose, as stated in our letter, was to determine whether existing safeguard regulatior.s yield the level of protection intended by the NRC.
In addition, it snould be noted that the licensee has an approved security plan.
I assume tnis plan provides a level of safeguards adequate to meet the Regulations as provided in 10 CFR Part 73.
However, the RER report identifies severai concerns of sufficient significance indicating the need for prompt remedial action.
The report, as written, infers that the licensee is required to take prompt remedial action to correct the several items (seven pages) identified as significant concerns.
However, there appears to be no regulatory basis f rom which to require the changes. The RER program appears to be a backfit/
ratchett to the operating plants with approved security plans. Little mention of the NRC approved site security plan is made.
The concerns appear to be based on the judgement.of the team rather than written criteria.
The following are specific comments on the RER Report by Section:
l 1.0 Overview The main objective is not consistent with the objectives stated in our letter dated May 12, 1983.
The level of protection intended by NRC, as expressed in 10 CFR Part 73, are met by the licensee based on the NRC-approved site security plan.
If this 8412170382 840430 PDR FOIA SHOLLY83-531
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" ~ *i is not true then the Comission should consider an expedited mechanism for upgrading the existing NRC approved security plans for the operating plants on a timely and consistent basis.
1.1 Site Ch'aracteristics The ultimate heat sink is not Biscayne Bay. The ultimate heat sink is the Closed Cycle Cooling Canals.
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2.1 Potential Sabotage Vulnerabilities No coment.
2.2 Safeguards Program Concerns 1
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i 2.2.1 Perimeter Detection System & Barrier t
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i 2.2.2 Vital Area Barrier Integrity l
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Cecil 0. Thomas 3
2.2.3 Maintenance of Security Equipment The general coments on Section 2.2.1 are applicable.
2.3 General Observations No coments.
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2.4 Notable Safeguards Strengths l._
No coments.
2.5 Safety / Safeguards Interface Review The coments from Auxiliary Systems and Procedures & Systems Review Branches, who were represented during this RER/VAV effort, will address this area in detail.
The review of the l
safety / safeguards interface appears not to be based on analyzed l
conflicts.
General statements relating to coordination of l
operations and security are made and that safe operation of the plant is paramount during emergency or off-normal conditions.
No detailed operating or security procedures were reviewed during the RER effort to determine if specific conflicts exist.
j There was no coordinated effort with NRR prior to the RER/VAV l
. site review.. The reports.indi.cate the team expended considerable effort in preparation for the site review.
Howey r, the NRR representatives were not included in this preparation.
Specifically, the NRR Technical Review Branches had no input on the adequacy of the safety / safeguards interface portion of the review or the adequacy of the Los Alamos VAV studies.
Based on the report, it cannot be determined if current modifications have been considered in the Los Alamos studies and factored into the RER/VAV review.
q Cecil 0. Thomas 2.6 Reduction of Safeguards Rejulatory Review No coments.
This background document appears to be inconsistent with the findings of the report as identified by the coments provided above.
In addition, it is stated that after a number of these reviews if the level of protection in-tended is not met or the requirements are misinterpreted or misunderstood, then j
specific improvements in the regulations and NRC guidance will be suggested.
y I am not sure how many of these reviews are necessary to make this determination.
The following might be considered in assessing the continuation of the program as presently conceived:
- 1) The NMSS Review Team consisted of seven membert for one week ~ which did not include their preparation time. Three NRR staff members were included for the week, or portion of the week, with no specific participation or in-volvement.
NRR was not included in the preparation effort.
I&E had one or two staff members involved for a portion of review.
They also had no specific participation and were not included in the preparation.
Attachment 1 to this memo identifies all the people attending entrance and exit briefing to provide an assessment of the impact on the NRC Staff and the Licensee.
The time and resources to continue this effort, both NRC and l
Licensees, should be considered.
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- 2) As previously stated, the findings of no potential sabotage vulnerabilities l
and the identification of the need for7rompt remedial action based on the report are contradictory and appear to be a mechanism for backfit/ratcheting of an NRC-approved security plan.
This is an inconsistent, expensive (both in people and time) and subjective method to achieve upgrading.
- 3) An alternative plan should be considered to identify weaknesses in existing approved security plans and establish minimum criteria necessary for all security plans. One alternate mechanism to achieve this would be to utilize the information gained by the current RER/VAV effort to date, combined with detailed input from the Regional Safety / Safeguards inspection effort,to establish _the minimum r.equirements..The, results would include l-value/ impact assessments and the necessary CRGR approvals.
This or a similar method would provide a significant savings in resources and a more timely upgrading of existing approved security plans if necessary.
EDanie#G ticDorfafd; Projeci Manager Operating Reactors Branch No. 1 Division of Licensing
Attachment:
As stated l
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- k SAFEGUARDS REGULATORY EFFECTIVENESS REVIEV TURKEY POINT PLANT Jtl.TRANCL.B.RIEFING - 5/23/83-9AM
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.i.',q H. E. YAEGER SITE MANAGER J. W. KA I t C SUPERVISOR V. R. VI O
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R. G. ESPOSITO TWC C. C. CR0THERS TVC M. A. BARRY TVC L. A. PICKENS TVC R. E. GARRETT FPL SITE SECURITY
~w D. T. HUNT FPL SITE SECURITY J. D. POPE NRC NICK PARADISO NRC JOHN SOMERINDYKE NRC JOHN G. WEST FPL ST. LUCIE SECURITY FRANK H. FABOR JR.
FPL CORP. SECURITY DAVID E. MOORE US NRC REGION 11 RENE V0GT-LOWELL NRC RESIDENT INSPECTOR DOUG KUNZE NRC/NMSS/SG/SGPR (lZ QUINN NRC/NMSS/SGPR JOHN HOCKERT NRC/NMSS/SGPR BARRY MENDELSOHN NRC/NMSS/SGPR DANIEL G. MCDONALD hRC/NRR/DL O
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EXIT BRIEFING o.m -TtlRKEY POINT PLANT
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, 1983 Doug Kunze N
R John Hockert NRC NMSS/SG/SGP Liz Quinn NRC NMSS/SG/SGPR Barry T. Mendelsohn NRC NMSS/SGPR Vene Vogt-Lowell
~ ~ ~ " ' ', NRC Turkey Point Resident Inspector l
D. E. Moore NRC/R-II D. R. McGuire NRC/R-II D. W. Jones FP&L - QC Supv T. A. Finn FP&L - Oper Supv Nuc(Act)
J. K Hays FP&L - Plant Manager - Nuclear H. E. Yaeger FP&L - Site Manager R. E. Garrett FP&L - Security D. T. Hunt FP&L - Security R. G. Esposito
,TWC
- 5. C. Hawley TWC D. O. Davis TWC C. F. Wheeler Virginia Electric & Power Co.
D. B. Roth '
-Virginia Electric & Power Co.
John.Somerindyke -
-NRC Jack Pope NRC Nick Par g
l Nick Fioravante NRC/NRR/DSI/ASB
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l Dan Mcdonald NRC/NRR/DL Don Kasun NRC/NMSS/SG l
John Hockert NRC/NMSS/SGPR
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Rich:rd A. Uderitz Public $er deEleciric n5 Gas Co. pany P.O Box 236. Hancocks Bridge. NJ 03038 609 935-6010
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NJCDF March 23, 1983 Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing U.S. Nuclear Regulatory Commi'ssion
~5 Washington, D.C.
20555 4
Dear Mr. Varga:
NRC LETTER DOCKET NO. 50-272, DATED FEBRUARY 24, 1983 RE:
REGULATORY EFFECTIVENESS REVIEW The comments requested relati've to the areas of concern identified in Section 2.2 of the attachment to subject letter are pr,ovided in Enclosure 1.
As stated in the enclosure, PSE&G had previously identified most items of concern and had initiated corrective. actions.
All concerns have been addressed in a
l positive and effective manner consistent with the ongoing policy to optimize the performance of our nuclear security program.
The
' contributions of the revies team to this effort are sincerely i
appreciated.
Sincerely, W
CC.
Ronald C.
Haynes Regional-Administrator - Region I U.S.
N.R.C.
NRC Resident Inspector 500'j l
Salem Generating Station b
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ENCLOSURE 50-2.72/311
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COMMENTS ON PUBLIC SERVICE ELECTRIC AND GAS COMPANY'S RESPONSE TO THE SAFEGUARDS REGULATORY EFFECTIVENESS REVIEW REPORT OF FEBRUARY 24, 1983 ITEM REPORT SECTION COMMENT
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Docket Nos.
50-272/311 Mr. R. A. Uderitz
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Vice President - Nuclear
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Public Service Electric.and Gas Company
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P. O. Box 236 Hancocks Bridge, New Jersey 08038
Dear Mr. Uderitz:
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Subject:
Request for Additional Information on the Regulatory Effectiveness Review Report for Salem, Units 1 and 2 This is in response to your letter of March 23, 1983 which transmitted Public Service Electric and Gas Company's response to the Safeguards Regulatory Effectiveness Review Report dated February 24, 1983.
We have reviewed your responses and have detemined that two items still require further consideration and resolution.
Our comments on these items are enclosed.
Please provide your response on the first item within 30 days of receipt of this letter.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
The enclosures to your letter' contain Safeguards Information of a type specified in 10 CFR 73.21 a'nd are being withheld from public disclosure.
The enclosure to this letter also contains Safeguards Information and should be protected against unauthorized disclosure.
SincereJy,
)
AL even A. Varga, C ef Operating Reactors nch No. 1 Division of Licensing
Enclosure:
Comments cc: w/o enclosure See next page r
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- gr +3f' Servi:e Electric and Gas Comoany cc:
" ark J. Wetterhahne Esddii'Fs*"T-Mr. Ecsir A. Liden, M? nager -
Conner anc Wetterhano..
-m Nuclear Licensing Suite 1050 Public Service Electric and 1747 Penn's'ylvania Avenue, NW Gas Company Washington, D. C.
20006 Post Office Box 236 Hancocks Bridge, New Jersey 08038 Richard Fryling, Jr., Esquire Assistant General Solicitor Public Service Electric and Gas Company Regional Administrator - Region I Mail Code T5E - P.O. Box 570 U. S. Nuclear Regulatory Commission' Newa-k, New Jersey 07101 631 Park Avenue Gene Fisher, Bureau of Chief Bureau of Radiation Protection Mr. Charles P. Johnson 380 Scotch Road Assistant to Vice President - Nuclear Trenton, New Jersey 08628 Public Service Electric and Gas Company P.O. Box 570 Mr. R. L. Mitti, General Manaaer 80 Park Plaza - 15A Nuclear Assurance and Regulation Newark, New Jersey 07101 Public Service Electric and Gas Company Mail Code T16D - P.O. Box 570 Newark, New Jersey 07101 Mr. Henry J. Midura, Manager Salem Operations Public Service Electric and Gas Company P. O. Box E Hancocks Bridge, New Jersey 08038 Leif J. Norrholm, Resident Inspector Salem Nuclear Generating Station U. S. Nuclear Regulatory Commission l
Drawer I Hancocks Bridge, New Jersey 08038 l
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c UNION OF CONCERNED SCIENTISTS me ce._tu.t m.... s.w.. s. mi. we.hi., ten. oc 20ose. <2o2> 2%.5eoo S September 1983 Mr. J. M. Felton, Director FREEDOM OF INfDRMATION Division of Rules and Records M1 REQUEST Of fice of Administration U.S. Nuclear Regulatory Commission
$fA.f J -M /
Washington, D.C.
20555
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Dear fir. Felton:
Pursuant to the Freedom of Information Act, please make available at the Cor.enis sio n 's Washington, D.C.,
Public Document Room copies of the following documents:
1 SAND 76.0314, B.
L.
Hulme, " Pat.hfinding in Graph-Theoretic Sabotage Models", July 1976, several volumes.
2.
SAND 75-0595, B.
L.
Hulme, " Graph-Theoretic Models of Theft Problems", November 1975, several volumes.
3 SAND 75-6159, L.
D.
Chapman, " Effectiveness Evaluation of Alternative Fixed-Site Safeguard Security Systems", July 1976.
4 SAND 75-0658 H.
A.
Bennett, " Dynamic Model of A Terrorist Attack", February 1976.
5.
SAND 77-0644, NUREG/CR-0313 G.
Varnado, et al.,
" Reactor Safeguards System Assessment and Design, Volume II".
6.
Documents concerning " Regulatory Effectiveness Reviews",
including the charter for organizations performing such reviews and the results of all such reviews performed since 1/1/81.
7.
" Power Reactors, 81100 Series", prepared for the Offi'e of Inspection and Enforcement by La.crence Livermore Laboratory.
8.
Documents concerning the establishment and operation of an organization known as the " Safety Interface Group" within the Office of Nuclear Reactor Regulation, including minutes of all meetings held by the group since 1/1/81.
9.
Documents concerning " Safeguards Incident Reports" or
" Safeguards Event Reports", including reporting requirements, and copies of all such reports since 1/1/81.
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Main Office: 26 Church Street. Cambridge, Massachusetts 02238. (617) 547 5552
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10 SAND 77-0043.
D.
D.
Baur<- and D. 'En g i. "Insid,r Sa feduard s c
Effectivene:.. Model.(ISDO Sandia Haer', r ine".
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11 SAND 76-0M2, D.
D.
Boo ze r and D.
Engi, " Simulation of Personnel Control-Systems with the Insider Safeguards Effectiveness Mode (ISEM)", April 1977.
tj dates since 10/1/77 to SAND 77-0777, " Barrier Technology 12.'
p lland book".
13.
SA ND77-1367, L.
D.
Chapman, et al.,
" User's Guide for Evaluating Alternative Cixed-Site Physical Protection Systems Using FESEM", November 1977.
14 SAND 77-04106.
D.
Engi and D.
D.
Boozer, "The Use of ISEM ' in Studying the Impact of Guard Tactics on Facility Safeguards System. Ef fectiveness", Jul y 1977.
15.
SAND 77-1130, G. W. Dyckes, " Development of Explosive Resistant Walls".
.16.
SAND 76-0218, D. G.t Bauder, " Concepts for Increasing the Penetration Resistance of Facilities", May 1976.
.Should you or your staff have any questions regarding this - request,-
please do not hesitate to contact me at the Washington, D.C. office of UCS.
Partial responses to this. request will be-appreciated in the event of delays in locating and/or reviewing one or more of the requested documents.
Sincerely, 4
xanC.
Steven C. Sholly Technical Research Associate 3
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.