ML20154M364

Responds to Requesting Clarification Re Security Upgrade Project.Description of Planned Monitoring of Outer Isolation Zone & Confirmation of Maint of Outer Isolation Zone in Accordance W/Approved Security Plan Provided

ML20154M364
Person / Time
Site:	Cooper
Issue date:	01/13/1988
From:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NLS8800008, NUDOCS 8809270136
Download: ML20154M364 (3)

Text

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1 GENEaAL CF8tCE Nebraska Public Power District * ""JEWS'#d's'!# "]'"

.N L 58800008 January 13, 1988 U.S. Nuclear Regulatory Commission Attention : Document Control Oesk Washington, DC 20555 G entlemen :

Reference:

1. Letter from L. J. Calle N

, to G. A. Trevers dated December 2,1967

2. Docket 50-298 S u bject: Security Upgrade Project at Coops. a uclear Station Reference 1 documented a meeting bild between U.S. NRC Region IV and Nebraska Pu blic Power District personnel on , the subject activity.

Reference 1 also listed three items which required further clarification. T his letter is in response to that request. For clarity, the question is repeated followed immediately by the District's responte.

Q ues'. ion 1:

Region IV has con firm ed w tn the NRR staff in headquartars that i Amendment 111 to the Cooper Nucle?r Station Facility O p eratin g License autnerized the modification to the clused circuit television (CC TV) system as you described in the m eetin g . This does not relieve NPPD cf the responsibility to monitor the outer isolation zone in accordance w ith 10C F R73.$5(c)(5), and we request that you provide to Region IV a 1escription of how NPPD intends to m:nitor the outer isolation zona.

Response

M The District recognizes the regulatory requirements contained in the nS8 applicable sections of 10CFR73. As such, the perimeter at Cooper Nuclear O'

o Station was surveyed and assessed for the application of intrusion detection equipment, illumination devices, and closed circuit television equipment. As 8 part of the survey and assessment, existing NRC Rules and Regulations, and a associated guidance were considered as ciscussed below.

m'

$v o Paragraph 10C F R73,55(c)(5) requires light levels w hich allow the g4 security force to readily see outdoor areas at night either by C C T y or direct visual observation. NPPO has recently designed and installed an

@ enhanced lighting system that meets the minimum illumination levels w u- /tr k%Cb fttY ~ZZZZ/p N l l 9lK1hT

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o Page 2 Manuary 13, 1988  !

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specified, and will be compatible with the upgraded C CT V equipment and direct visual observation. Paragraph 10CFR73.55(c)(5) goes on to j *eference other paragraphs in the rule. i o Paragraph 10CFR73.55(c)(3) requires isolation zones on either side of )

4 the protected area (PA) barrier that permit observation under specific '

circumstances (i.e., barrier penetration). The perimeter concept, as specified in the C NS Physical Security Plan, caTls for 20 foot clear areas (isolation zones) on either side of the P A barrier where practicable.

Where this criteria could not be fully met, additional equipment will be applied to compensate.

o Paragraph 10CFR73.55(c)(4) requires that exterior areas be periodically checked. At CNS, this is accomplished by random patrols which are committed to and defined in the CNS Security Pla n . (

! Paragraph 10CFR73.55(c)(4) also requires that upon detection of  !

i penetration of the F A barrier, an adequate response be initiated.

Adequate response is partially defined in paragraph 10CF R73.55(h)(4) which requires an assessment of and neutralization of any threat. At CNS the intrusion detection equipment is placed inside and parallel to  !

! the P A barrier as recommended by Regulatory Guide 5.44, Section f

! C.1.a.(5). The fixed C C TV equipment is placed to view the entire zone f i and allow assessment, and is controlled to enhance the operator's ability i I

to assess an alarm. By placing the perimeter systems (105 and C C TV)  !

interior to the P A barrier, the fixed C C TV equipment must be located

• interior to and away from the fence and biased towards the interior of the site to allow optimum intrusion assessment. This configuration does ,

l not allow the fixed C C TV equipment to fully view the exterior isolation  ;

zone due to a fence "shr. dowing" effect. The shadowing effect is due to the viewin angle which causes the fenes to appear opaque.

The District o6. eyes the system upgrade, as proposed, is adequate and meets 4 the requirement of 10C FR73,56. However, to resolve this issue, thn District ,

will modify tae original CCTV upgrade by increasing the number of cameras  :

by two (one PTZ and one fixed) and relocating one PTZ camera. Adequacy [

of the upgraded CC TV system will be verified during the post. maintenance }

i testing phase following implementation. t y

Q uestionJ: [

] NPPO nceds to confirm that the outer isolation zone is being maintained in accordance with th, approved Physical Security Plan. (

Response: I 1

J NPPD is currently maintaining the outer isolation zone in accordance with the  !

I appreved Safeguards Plan. Changes have recently been made in two areas of i J the zone to ensure continued compliance. An existing road, which passes 1

through the outer isolation zone on the northwest corner, has been blocked (

i

and removed from daily use. Additionally, controls have been implemented in j l the isolation zone area adjacent to the main warehouse to control entries into l the zore without prior notification. l l

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I Page 3 January 13, 1988 4

Question 3:

Region IV requests that you provide to us for information a description of the design change in the areas of the intrusion detection system and the C C TV system.

Response

In response to this request, the District is providing a copy of the proposed Description section of the implementing Design Change, DC 87 050.

The District believes the answers provided are responsive to your needs.

However, if further information or clarification is required, please contact me.

Sincerely, t

V

$;fr:evors

. Deor .

Division Manager of Nuclear Support G A T/kcw:d h11/3(.14)

E nclosure cc: W. L. Swantz .

U.S. Nur. lear Regulatory Commission Region Office, Region IV NRC Resident Inspector  !

Cooper Nuclear Station l

bc NKC Distribution f t

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