ML20134B928
| ML20134B928 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/15/1985 |
| From: | Burnett R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20134B911 | List: |
| References | |
| FOIA-85-401 NUDOCS 8508160140 | |
| Download: ML20134B928 (11) | |
Text
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et UNITED STATES NUCLEAR REGULATORY COMMisslON
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MAR 151985 MEMORANDUM FOR:
Thomas E. Murley Regional Administrator Region I FRG4:
Robert F. Burnett, Director Division of Safeguards, NHSS
SUBJECT:
REGULATORY EFFECTIVENESS REVIEW PROGRAM A Regulatory Effectiveness Review (RER) for Indian Points Units 2 and 3 has been scheduled for May 14 - 22, 1985.
Enclosed are draft letters to Consolidated Edison Company of New York, Inc., and Power Authority of the State of New York 7
which explain the purpose and schedule of the review.
Your assistance in for-warding these letters is appreciated.
In addition, the RER team reviews the possible impact of security on plant sa fety.
In view of this responsibility, our team needs the full time support of an individual from your regional office with technical power reactor safety expertise, who will be a member of the RER team.
The enclosed " Guidelines for the Safety / Safeguards Interface Member of a Regulatory Effectiveness Review" provides infonnation on the duties of this individual.
Your support in this regard is important to this aspect of the program.
A list of logistical matters is also enclosed, which we would very much appreciate the assistance of your staff in resolving.
Many thanks for your cooperation and assistance.
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Robert F. Burnett, Director Division of Safeguards, NMSS
Enclosures:
As stated i
cc:
D. Eisenhut NRR 5081 g 0 850703 l
CORRIGA85-401 PDR
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Consolidatzd Edison Corr.p of New York, Inc.
Dear The NRC is in the process of conductins safeguards re3ulatory effectiveness reviews at nuclear power reactors.
I wish to infom you that the Indian Point 2 facility has oeen-cnosen for such a review scheouled for May 14-22, 1985.
Tne prime purpose of the review program is to evaluate.the overall effectiveness of the Indian Point 2 safeguards program and to detemine whether existing safeguards regulations yielo the level of protection intended by NRC.
Tne team perfoming the review supports NRC's quality assurance program for safeguards, both as it applies to the Indian Point 2 security system and to NRC's regula-tions.
The review will complement, but be independent of, the licensing and inspection functions.
The review at incian Point 2 will be conducted coincident with Inoian Point 3 by a team with representatives from the Division of Safeguards, Region I, and U.S. Army Special Forces personnel from Fort Bragg, NC.
Tne review team will be comprised of two groups.
One group will look at the facility's safeguards l
from the perspective of an insider, while the otner will view safeguaras from an external adversary's perspective.
Tne review will initiate with a single entrance briefing for both Units.
You may wish to have a representative of your corporate. staff present during this briefin, as 1t will provice an overview of tne team's objectives and antici-s pated activities for the duration of the visit.
Any questions that may arise concerning tne teau's review technique or other matters, will De aaaressed at l
2 that time.
For the remainder of the first day, the team would like to have a plant orientation tour witn emphasis on safeguards areas and systems, and begin the exanination of plant vital areas.
During the remainder of the on-site assessment, tne team will continue reviewing vital areas and canpunents, and the entire safeguards program. The last day is reserved for any activities the team has been unable to accomplish and for a separate briefing of plant and corporate personnel for each unit on the preliminary results of the review.
Please provide appropriate plant personnel support for botn groups of the team during the scheduled review.
The external group will require an escort from the security department who can communicate with alarm stations.
Tne internal group will need escorts from both security and plant operations.
The latter should be indiviouals familiar with the locations ano detailed operation of the engineered safety feature systems and components.
The team will make every effort to scnedule its activities so as to minimize disruption of nonnal plant opera tions.
Tne time that various team members will spend on-site will vary, but generally will range fran four to seven hours per day.
Listed below are the names of the participants, baage nuaber and level of clearance.
Name Organization Social Security #
Badge #
Clearance
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Elizabeth Ten Eyck NRC/HQ 217-42-0025 A-3230 Q
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Daviu li. urrix f4RC/H'y 026-26-0360 S-3174 L
John E. Johnson US Army 557-04-4015 ASF L
Ricnard L. Maywald US Army 449-92-1399 ASF L
Jack D. Pope US Army 241-88-5042 ASF L
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e kame Organization Social Security a Badge i
_ Clearance Zen-Shing R. Hsu NRC/HQ 265-59-1792 C-1440 145B-Waiver l
Kathleen McConnell NRC/HQ 213-66-2285 A-3010 Q
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Dou'glas Pickett NRC/HQ 266-66-0134 B-0545 L
If you have any questions rewaroing the conduct of these regulatory effectiveness reviews, which you wish to have answered prior to the team's visit, please contact Elizabeth Ten Eyck, Safeguards Special Projects Branch, at (301) 427-4723 or of the Region staff.
Sincerely, cc:
R. F. Burnett, NMSS C. O. Thomas, NRR D. Neighbors, NRR M. Slosson, NRR h
Guidelines for a Saf'ety/Safeuuarus Interfdce Pentber of 4 Regulatory Ef fectiveness Review One of the purposes of tne RER pro 3rau is to ensure that plant security end safety assets cooperate, to maximum extent practicable, in achieving the cual l
goals of prevention of realological sabotage and safe operation of tne plant.
This is cone by investigating the interaction between operational safety and secu ri ty.
You will do Inis initially tnrough occasional discussions curing tne facility tour with plant personnel, asking similar questions of several opera-tional anu security personnel to get a variety of perspectives.
This should be supplemented with a review of these issues in an office setting before leaving the site.
Concerns ioentified will be discussed with the team at synthesis meetings usually nela at the end of each day, discussea with plant management at the exit briefing, and incorporated into the formal RER report.
Issues you should address include:
1.
Tne saanner in whicn security proceaures and safety proceaures provide an integrateo response to indications of unusual plant conditions.
control room procedures for responding to malfunctions or alarms
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allowable times for correcting malfunctions operational personnel consideration of security assets to assist in investigating the cause of an unusual condition use of access control computer and. security officers for personnel accountabillt, use of security officers for fire brigade
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Identification of any security procedures that may interfere with pidnt safety during routine or emergency conditions and the extent of that interface.
operator actions when norudl access to vital areas is prevented procedures for access to key caras for vital areas proceoures for access to keys for auniinistrative locks security procedures normally implemented when access computer in not operational.
anti-passback features and capability for over-ride in emergencies' time delays caused by security access controls for on-site ano off-site response of licensee personnel procecures so that off-site energency response (non-licensee) personnel are not delayeo -- bacging, escorts familiarization of licensee personnel relative to site manager's ultisaate authority in energency situations -
procedures to accanmodate expanded work force during outages 3.
General interaction of security and operational personnel 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 committee security participation in review of operational procedures and systea changes attituces of site personnel towards level of security at site attituaes of site personnel regaroing removing access controls from vital equipnent
attitudes of site personnel regarding w1oer availability of key caras for operational staff for access to vital areas attituaes towards benefits of screening programs in general and in particular in lieu of access controls attituaes towards fitness for duty programs - benefits, objections 4.
Equipment Concerns adverse impact of security equipnent on safety (e.g., ENI fran security radios effecting safety systems) aaverse 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 officers in vital -areas woulo raciological habitability requirements for Central Alann Station permit smoother handling of safety-related emergency situations?
means for unimpeueo egress fraa vital areas even auring security systeas failures positive / negative safety aspects of hardened chains and padlocks for protection of Engineered Safety Feature valves and motor controls 1
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Rewulatory Effectiveness Review Administrative Concerns 1.
Dispatch letter to licensees confirming visit and identifying team members.
2.
Arrange for bringing cameres on-site.
3.
Inform licensees that aerial photographs will be taken.
4.
Infona licensees tnet the external group will want to make an appointment to meet with a senior representative of the primary local law enforcement authority at their office.
S.
Confina that licensees will provide _ at least two security escorts, one for the internal group and or.2 for the external group.
6.
Confirm that tne licensees will provide an additional internal group i
escort who is familiar with the location and detailed operation of each untt's engineered safety feature systems and canponents.
7.
Inform the licensees that the team will be on-site one evening during the second snift, probably Wednesday, and will neea a knowledgeable security escort.
8.
Determine what, if any, healtn physics documents, training, whole body counts, etc. will be needed for escorted eccess to these equipment areas.
9.
Determine for wnich equipment, if any, respirator protection would be requireo for access.
10.
After consulation with the red team leaaer, scnedule any health physics appointnents with the licensees that might be necessary.
11.
Detennine what personnel information the licensees will need to facilitate access control requirements for team menbers.
Ask the licensees to select a time and place for a single entrance briefing 12.
in the early morning of the first day on-site (8:30 AM - 9:30 AM).
The location should be suitable for showing a slide-sound presentation (the RER team will provide the projector).
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3/o/fr NRC FORM 255 CON 1 R ACT NU'.9BE R
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NRC-02-76-311
'OlVISION OF CONTR ACTS MOOlFICAllON NUMBE R U.S. NUCLE AR REGULA10RY COMMISSION 15-WASHINGTON, D.C. 205S5 O NEW QMODIFICATION OTHE R (Specify]
NOTIFICATION OF CONTRACT EXECUTION CONTRACT BASED ON:
TO:
.1nhn nuri e, n i g r. + n,-
AUTHORIZATION NUMBER g 7,,,
!!f15-76-311
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Office of Nuclear Material Safety & Safeguards OArg 1
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- gj7jg, CONTR ACT CH ANGES PER TH15 ACTION Marie Page period'of performance is Contract Administrator extended Technical Contracts Branch DIVISION OF CONTRACTS, ADM CONTR ACTOR IName & t ocarmn/
EXECUTION OATE Army - John F.~ Kennedy Center February 14, 1985 Fort Bragg, NC TvPE OF CONTR ACT PROJE C1 1tTLE PERIOD OF PERFORMANCE 7/2/76 - 12/31/85 Transport / Fixed Site Vulnerability Analysis PRINCIPAL INVESTIG ATOR NRC AUTHORIZED REPRESENTATIVE Nicholas Piradiso B&R NUMBER N/A FIN NUMBER N/A AMOUNT NEW NRC FUNDS S 72.965.00 FUNDING TOTAL FY _._ FUNDING (prior) 8?97.790.64 TOTAL NRC OBLIGATIONS S 370,755.64 GOVERNMENT PROPERTY AT T ACH r.'E NT tSI:
CONT R ACT DOCUMENT l
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March 21, 1985 J
PROJECT nESCRIPTIVE
SUMMARY
OFFICE:
NMSS NUM9ER:
PROJECT TITLE:
TRANSPORTATION / FIXED SITE VULNERARILITY APPRAISALS FIN NO:
R 1536 TYPE OF CONTRACT:
Interagency Agreement CONTRACTOR:
U.S. Army 1st Special Operations Command FY BUDGET ($K):
F184 FY85
.FY86 FY87 FY88 PRIOR:
0 73 e-OPERATING:
09 FOLLOV-ON:
8R 88 SCOPE OF UORK:
The U.S. Army 1st Special Operations Command (U.S. Army Special Forces) will continue 'to assist NRC in evaluatinc safeguards, as innlenented, at licensed power reactors, fuel cycle facilities, and during transportation. It is anticipated that acproximatelF~18 facility evaluations will be perforned during fiscal year 1096 HCCD NEFO:
The Energy Deorganization Act o' 1474 requires tha Office of Nuclear Material Safety and Safeguards to review the safeguards of the facilities and materials licensed under
.he Ato91c Enerav Sct o' 105d.
This procee9 provides vital innut to the revieu n ocess.
- 1 - e.
cesour es from this co-P9 a e used co assist 'N evslL*ti"?
the e"ectiveness n' i9plemented safenuards %yste9s n'ir'n9 Degul atory Ef fectivaness Deviaws-ca
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- ne; re oc a..ler.TS :
cesno cas 'en..F.is - acrc-5;ve been : sed to sur.ao t "RC safeauarcs or-site since 107'.
~hese estreces have been used to assist in Degulatory Ef'ectiveress Devie*'s for nuclear pnwer reactors and at CAT 1 fuel cycle facilities since 10;?.
It is an.4cir,a.ed that this progra, will continue to 7rovide suoport te
?eculato y effectiveness Ceviews of licensed nuclaar power reactors. fuel cycle facilities and licensed transport of soecial nuclear natarial, as required.
's.
2 J'ISTIFICATION FOR SOURCE SELECTED AND DISCUSSION OF ALTERNATIVES There are several reasons for using interagency tasking to -perform this effort. These include:
- 1. ' Continuity - This is a continuation of an existing evaluation program.
It is more. efficient to continue to use tne same performing organization that is aware of NRC's mission and evaluation requirements.
2.
Unique Capability - While capabilites comparable to those of the U.S.
Army Special Forces may exist elsewhere within the Government (e.g., U.S.
Navy seals), the U.S. Army Special Forces have, by virtue of their experience in conducting analogous military operations, a capability, not found in con -
mercial contractors, to identify and access the significance of safeguards vulnerabilities.
3.
Financial Advantaae - Under the terns of the interagency agreement, MRC is billed only for-travel expenses, per diem, and special equipmeng required incidental to the evaluations.
NRC is not charged for personnel salaries, overhead or administrative expenses.
Tnis program enables NRC to use the tactical planning skills of the U.S. Arny Special Forces to provide support -for safeguards facility evaluations.
Me,cers n' the it.S. Army Special Forces teams which carticibate in these evaluations are exnerienced in both the evaluation of sensitive 9epartcent n' Defense installations and _ the plannin: and execution of tactical nissions and nave attenced tn* current "RC Raactors Courses on RWR and PWRs.
If this procran is not undertaken, NOC's caoability to evaluate licensee safeguards will be significantly impairea.
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