ML20127M594

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Summary of 930112 Meeting W/Util in Rockville,Md Re Reactor Bldg Access Control Mod & Operational Safeguards Response Evaluation.List of Attendees & Handouts Encl
ML20127M594
Person / Time
Site: Oyster Creek
Issue date: 01/26/1993
From: Dromerick A
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
References
NUDOCS 9301280240
Download: ML20127M594 (25)


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Docket No. 50-219 LICENSEE: GPU Nuclear Corporation FACILITY: Oyster Creek Nuclear Generating Station

SUBJECT:

SUMMARY

OF MEETING REGARDING REACTOR BUILDING ACCESS CONTROL MODIFICATIONS AND OPERATIONAL SAFEGUARDS RESPONSE EVALUATION On Tuesday, January 12, 1993, a meeting was held at One White Flint North, Rockville, Maryland with GPU Nuclear Corporation (GPUN/the licensee) to discuss the reactor building access control modification and operational safeguards response evaluation (OSRE). Enclosure 1 is the list of individuals participating in the discussion. Enclosure 2 is the licensee's agenda.

to discuss their The plans meeting to cancel awas requested reactor by GPU building access control Nuclear modificatCorporation (GPUN) ion to conduct an Operational Safeguards Response Evaluation at Oyster Creek. The modification had originally been planned to address issues raised by the NRC concerning the adequacy of security measures to protect certain systems and components located in the reactor building needed for safe plant shutdown.

Based on higher priority work, GPUN had extended the schedule for the modification several times. In a letter dated September 14, 1992, GPUN informed the NRC of their decision to cancel the modification and the bases for the decision. By letter dated November 18, 1992, the NRC informed GPUN that staff planned to conduct an OSRE at Oyster Creek which would provide information necessary for the staff to complete their evaluation of the proposal for cancelling the modification.

At the meeting the licensee described and expanded on their rationale for cancelling the modification. With respect to the insider threat, the licensee presented their position that measures other than reactor building access control modification provided sufficient protection. Staff did take issue with this rationale. With respect to the external threat, the licensee indicated that the barriers proposed in the modification would provide little protective benefit and that contingency procedures were in place to enhance '

protection of equipment in the reactor building. Staff stated _that the purpose of the OSRE would be to confirm the adequacy of the, contingency procedures and that the issue could be closed subject to findings of the OSRE.

Regarding an OSRE for Oyster Creek, the licensee agreed that the evaluation would be beneficial but proposed that it not be scheduled until after identified improvements, including measures taken to strengthen the (

9301280240 930126, DR ADOCK 0500 9 n

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s GPU Nuclear Corporation 0)erations/ Security interface, were made. Based on-this, GPUN proposed that t1e OSRE be scheduled for the first quarter of 1994. Staff stated that-closure of the issue did not need to be delayed pending program refinements and proposed the OSRE be scheduled no later than the summer of 1993.

Original signed by Alexander W. Dromerick, Sr. Project Manager Project Directorate 1-4 Division of Reactor Projects - 1/11-Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/ enclosures:

See next page Distribution:-

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O Mr. John J. Barton Oyster Creek Nuclear GPU Nuclear Corporation Generating Station cc:

Ernest L. Blake, Jr., Esquire Resident inspector Shaw, Pittman, Potts & Trowbridge c/o -U.S. Nuclear Regulatory Commission 2300 N Street, NW. Post Office Box 445 Washington, DC 20037 Forked River, New Jersey 08731 Regional Administrator, Region 1 Kent Tosch, Chief U.S. Nuclear Regulatory Commission New Jersey Department of 475 Allendale Road Environmental Protection King of Prussia Pennsylvania 19406 Bureau of Nuclear Engineering

  • CN 415 BWR Licensing Manager Trenton, New Jersey 08625 GPU Nuclear Corporation 1 Upper Pond Road Parsippany, New Jersey 07054 Mayor Lacey Township 818 West Lacey Road Forked River, New Jersey 08731 Licensing Manager Oyster Creek Nuclear Generating Station Mail Stop: Site Emergency Bldg.

Post Office Box 388 Forked River, New Jersey 08731

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Enclosure 1 OYSTER CREEK Nt) CLEAR GENERATING STATION-DOCKET NO. 50-219 MEETING - JANUARY 12. 1993 AIIINDANCE LIST HAE ORGANIZATION Ron Hernan NRC/NRR John Fornicola GPU Nuclear James Knubel - GPU Nuclear  ;

Rich Enkeboll NUMARC Bob Whitesel NUMARC-Ken Pastor GPU Nuclear ,

Bob Dube -

NRC/NRR Alex Dromerick - - NRC/NRR Phil McKee NRC/NRR Barry Manili NRC/NRR-Ed Butcher NRC/DRSS Phil Scallon GPU Nuclear Larry J, Defibaugh GPU Nuclear Richard T. Ewart GPU Nuclear

  • Mike Heller GPU Nuclear Mike Lair GPU Nuclear-Mike Laggart GPU Nuclear-John Stolz NRC/NRR RKeimig NRC/ Region I i.-

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d'WC/osudd" A GPU NUCLEAll PilESENTATION nn ItEACTOlt ilUILDING ACCESS CONTitOL MODIFICATION '

and OPEllATIONAL SAFEGUAllDS ItESPONSE EVALUATION JANUARY 12,1993 ItOCKVILLE, MAllYLAND

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AGENDA- }

I. Introduction / Objectives M. Laggart II. Background M. Laggart 4

III. Reactor Building Access Control Mod K. Pastor A. Integrated Schedule M. Lair B. Industry Initiatives J. Knubel IV. Operational Safeguards Response Evaluation P. Scallon V. Conclusion M. Laggart ,

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s OB.lFCTIVE 9 Reactor Building Access Control Modification 4 Operational Safeguards Response Evaluation (OSRE)

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BACKGROUND g T t

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-7/88 Regulatory Effectiveness Review.

Decision to modify Rx Bldg access controls -

2/89 Modification added to Integrated Schedule-  ;

6/89

-6/92 Integrated Schedule update letter .

3 7/92 Inspection 92-17, GPUN/NRC meeting

.i 9/92 GPUN letter re: cancellation of modification -

11/92 NRC letter re: OSRE 12/92 Integrated Schedule update letter P

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REACTOR 11UILDING ACCESS CONTROL MODIFICATION TIIE ESTIMATED COST FOR THE MODIFICATION IIAS INCREASED SINCE IT WAS INITIALLY .

PROPOSED.

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. 1989 ESTIMATE (CONCEPTUAL):

$570,000

. 1992 ESTIMATE:

$859,000 4

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e LOCKED AND ALARMED DOORS IIAVE LITTLE VALUE.

. The RER Program gave little credit for the protective benefit of access control barriers.

"The NRC RER drills have shown that vital area doors are of minimal value as an obstacle".

Chain-Reaction, October 1992

. The current OSRE Program continues that practice.

Peach Bottom OSRE: Seventeen (17) seconds to penetrate the perimeter fence and breach the access control barrier.

Similar experience with other plant's evaluations:

. San Onofre 18 Seconds

. Duane Arnold 30 Seconds

. Maine Yankee - 45 Seconds 5

I IIIGH TRAFFIC LEVELS IN TIIE REACTOR BUILDING '

COULD DIVERT SECURITY RESOURCES FROM A'ITENTION TO TIIE BALANCE OF THE SECURITY SYSTEMS.

. It is estimated that in the order of 1100 individuals would have access to the Reactor Building during a normal operating cycle.

. The number doubles (to about 2200) during an outage.

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C ADDITIONAL REACTOR BUILDING ACCESS CONTROL BARRIERS WOULD DECREASE OPERATIONAL EFFECTIVENESS.

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. The Coinmissioners are looldng for linproved operational effectiveness. In their response to the Stati regarding recommendations of SECY-92 272, they state: .

"The changes proposed by the Staff provide very little in the way of an expected increase in operational safety or increase in operational clicctiveness".

. Additional Reactor 11ullding access controls would decrease operational clicctiveness.

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TIIE ALTERNATE PROTECTION STRATEGY ELIMINATES TIIE NEED FOR INTERNAL ACCESS CONTROL 11ARRIERS.

. Insider threat reduced by new regulations:

> 10 CFR 73.57 Criminal llistory Checks

> 10 CFR 26 - Fitness for Duty Program

> 10 CFR 73.56 - Access Authorization Program o Psychological Evaluations o Ilackground Investigations a Continual llehavioral Observation

. Commissioner's response to the Staff regarding SECY-92 272:

"I'he stali. . .should work with NUMARC to fully understand the goals of their proposed Alternate Protection Strategy as a stepping off point for exploring alternatives'.

"The staff should consider the implementation of fitness for duty and supervisor observation for aberrant behavior in a comprehensive review of the insider threat. This includes a review of the usefulness of vital areas within the plant boundary".

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9 OYSTER CREEK CONTINGENCY PROCEDURES ENIIANCE PROTECTION OF EQUIPMENT IN TIIE .

REACTOR I3UILDING.

. Response force reacts immediately to pre determined locations, which include the Reactor Building.

. Response locations determined in conjunction with Plant Operations based on the importance of the equipment to safe shutdown. .

. Security force drills monthly provide training in rapid response to these critical locations.

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f AN ADDITIONAL DEGREE OF PROTECTION IS PROVIDED BY PERIODIC VERIFICATION OF SAFETY SYSTEM EQUIPMENT LINEUP.

. Station Procedure 680.4.007, ' Safety Related Equipment Verification" periodically confirms that safety systems are properly aligned to perform their safety function.

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APPROPRIATENESS OF AN OSRE TO EVALUATE ,

ACCESS CONTROL BARRIERS.

  • An Operational Safeguards Response Evaluation (OSRE) evaluates the response capability of the Site Security Force to an external design basis threat i .

. Previous OSRE exercise scenarios breach vital area barriers within seconds from the start of protected area intruslon by the external adversary.

. An OSRE will provide no significant information with which the NRC can evaluate the value or effectiveness of access control barriers.

. The review of GPU Nuclear's proposal to cancel plans to modify Reactor Ilullding access control barriers is separate from evaluation of the response capability of the Oyster Creek security force to an external threat.

. The Oyster Creek OSRE should not be accelerated because of the Reactor Iluilding access control barrier issue.

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e PROJECI' PRIORITY i

GENERAL PRIORITIZATION HASIS

. License Amendment to negotiate the appropriate balance and -

prioritization of proposed projects

. Consider costs and benefits Nuclear safety Capacity Factor System Reliability ,

Personnel Safety i

Person Rem General Working Conditions

. Management review of projects and resource targets.

  • Resources defined by Life Cycle Forecast and GPU Management - .

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GPUN FOCUS _

  • Material Condition of plant equipment

. Reduce operator challenges >

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  • Improvements in availability -

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INITIAL ACCESS CONTROL PRIORITIZATION 1989 - Access Control Projects initiated Control Room Access planned for 1990 (Cycle 12).

Reactor Unilding Access planned for 1993 (Cycle 14) >

1990 - Projects combined and planned for 1993 (Cycle 14)

I 1992 - Estimate increased and project split into 2 parts

- Control Room Access Control planned for 1994 (Cycle 14)

- Reactor Building Access Control planned for 1997 (Cycle 16) 14 e y 9' -599 "+ e -v9 ry '--* --wwreww g ysmy-w- y rios vyMy- y ymyf yr't*ftw (v**N D'W WWf*+d-'4L-J'- f*-E-wwWWF3--ev h -M?t?M- nr 9

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MAlfHt PRO.1ECU DEFERRED 4CARCEIED

. Replace Upper Turbine Building Roof

. Drywell Exposure Reduction Modifications

. Reactor Building Roof Frame

. T.B.C.C.W. IIcat Exchanger Replacement

. Recirculation Flow Scram Electronics Replacement

. Low Pressure Turbine 'C' Blade Replacement

. Reactor Overfill Protection

. Generator Protection Upgrade

. Recirculation Pump Motor RTD Circuit Upgrade 15 4

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CURRENT PRIORITIZATION

  • Control Room Access Control planned for 1994 in cycle 14

. Reactor Building Access Control proposed cancellation ,

REASON FOR CURRENT PRIORITIZATION t-

. Reactor Building Access'Controlis a high cost and perceived low benefit project

  • NUMARC Initiative would limit extent of plant vitalization ,

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  • 4 blUMARC INITIATIVE IIISTORY

. NUMARC Security Working Group was formed mid 1990, with its first meeting August 7,1990. 1

. On June 24,1992 - NUMARC submitted " Protective Measures Requirements Re evaluation" to the NRC Staff,

. August 4,1992 - NRC Staff proposal for Security changes was forwarded to the Commissioners (Secy-92-272) with the NUMARC

" Alternate Protection Strategy" (APS), as an enclosure.

  • October 2,1992 NUMARC briefed Commissioner Remick and other representatives of the commissioners staff on the NUMARC "APS" and the industry's view on Secy-92 272.

. November 5,1992 - Staff Requirements Memorandum (SRM) issued, directs the staff to work with NUMARC to understand "APS".

. December 22,1992 - N'UMARC Working and NRC Staff Members met for information exchange.

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NUMARC POSITION

. The basis for the "APS" Is 10 CFR_73.5(a)

'The Commissioner may authorize'an applicant or licensee to provide measures for protection against radiological sabotage other than:-

those required by this section...'-

. The "APS" provides a level of assurance that obviates the need for the; vol area requirements'specified in-10 CFR 73.55 paragraphs (b).

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Q DERE READINESS _/1993 OYSTER CREEKACHEDULE

  • Response Improvements Underway

. July 1988 - RER conducted at Oyster Creek identified weaknesses in armed response to security contingencies.

. Tactical Response Team Deployment Plan and Exercise Control Plan developed and implemented. Joint Training / Security monthly drills initiated.

. Use of plant referenced simulator for security drills will strengthen Operations / Security interface.

. 14R Outage - November 1992 through February 1993 Plant Referenced Simulator / Operator Availability

. Ready for Training - March 1993

. Emergency Operating Procedure Audit - May/ June / July 1993 l

. Operator Training - March 1993 through August 1993 l

. INPO Evaluation & Assessment - June 1993 l

. Operator Evaluations - August / September 1993

- Available for security drills ~ Ist quarter 1994 19

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CONCLUSION-O The Reactor Building Access Control Modification should be separate and-distinct from the OSRE.  !

O The Reactor. Building Access Control Modification is not justified per a cost -

benefit perspective.

e 'It would be inappropriate to consider adding an additional vital area at-Oyster Creek given the' industry position on "APS" and ~the consideration-being given to the. industry positio'n by the NRC Commissioners and Staff.1 9 An OSRE would benefit Oyster Creek after identified improvements are; addressed.

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