ML20195C501
| ML20195C501 | |
| Person / Time | |
|---|---|
| Issue date: | 11/12/1998 |
| From: | Galen Smith NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9811170132 | |
| Download: ML20195C501 (6) | |
Text
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November 12, 1998 MEMORANDUM TO: File Original signed by FROM:
Gregory C. Smith, Senior Security Specialist Framework Grcup, Performance Assessment Task Group Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE NOVEMBER 5,1998, MEETING WITH THE NUCLEAR ENERGY INSTITUTE TO DISCUSS OPTIONS IN THE SAFEGUARDS AREA FOR REVISlNG THE REGULATORY OVERSIGHT PROCESS A meeting was held on November 5,1998, during which the industry and the NRC discussed the Safeguards areas to be assessed and the methods to measure performance in those areas.
The NRC and the industry reached general alignment on the areas and the methods to measure performance in those areas. The areas and the methods to measure performance are described in the attached draft proposal.
There was also discussion on the thresholds for performance in the areas being measured by performance indicators (PI). Proposed thresholds were developed and are under review by the NRC and the industry to assure alignment. The target date for general alignment on the proposed thresholds for the Pls is November 13,1998.
Attachments: 1. Agenda
- 2. List of Attendees
- 3. Draft proposal on the areas and methods to measure performance Distribution:
File Center PDR S. Collins /F, Miraglia J. Roe D. Matthews G. Smith G. Belisle l/
J. Creed B. Murray R. Rosano E. McPeek i
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AGENDA FOR NOVEMBER 5,1998, NRCINEl MEETING TO DISCUSS AND REVIEW THE DEVELOPMENT OF SAFEGUARDS ISSUES IN THE PERFORMANCE ASSESSMENT PROCESS AND INSPECTION PROGRAM IMPROVEMENTS.
Introduction
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Background===
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Comerstone Framework Defining Principles Areas and Methods to Measure Performance i
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ATTENDEES Name Title organization Gregory C. Smith Senior Security Specialist NRC Region l l
. James F. Labis Security Operations Supervisor AEP - Cook Plant l-Thomas E. Mahon Manager, Perry First Energy Rich Enkebol Senior Project Manager NEl 202-739-8102 l
E. W. McPeek Security Specialist NRC 301-415-3210 Ray Hsu Nuclear Engineer NRC/PSGB l
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SAFEGUARDS Comerstone Physical Security Objective To protect against the threat of radiological sabotage Key Attribute i
1.
Physical Protection System
- s. Barriers
- b. Intrusion Detection System
- c. Asarm Assessment DffjREDREGtJ,Q This is a risk significant system that is necessary for protection against the extemal threat of radiological sabotage. Operability of this system is necessary to identify initiating safeguards events and to provide the first line of defense in the defense in depth concept of protection against radiological sabotage.
PERFORMANCE INDICATOR The perfonnance of the system will be measured by tracking the compensatory hours expended due to equipment failure. Compensatory measures are implemented when equipment fails to meet operability or performance standards during routine testing or when equipment falls during normal operations. Compensatory measures are considered acceptable for short periods of system inoperahility, however, experience has shown that the effectiveness of compensatory metsures degrades over time. The compensatory hours expended due to equipment failure will provide data on equipment availability and maintenance effectiveness. This data is currently available and will be reported to the NRC on a quarterly basis.
' VERIFICATION AND VAllDATION The verification and validation (V&V) process willindude a review of testing requirements for each system to assure performance standards and testing periodically are appropriate. After the initial V&V process, additional inspection should not be necessary unless the Pi indicates degradation of the systems.
2.
Access Control
- a. Search
- b. Identification and Authorization DESIRED RESULT This is a nsk significant system that is necessary to (1) prevent the introduction of contraband i
into the protected area that could be used to commit radiological sabotage and (2) assure that only personnel that have been screened to verify their trustworthiness and authorized are i
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permitted unescorted access to the site protected area. During discussions between NEl and the NRC, it was concluded that meaningful tracking data on the performance of this system was not practical since much of the performance of the system is dependent on the quality of the tasks performed. This system is best assessed through the baseline inspection program.
PERFORMANCE INDICATOR None 3.
Access Authorization System
- a. PersonnelScreening
- b. Fitness For Dety (FFD)
- c. BehaviorObservation DESIRED RESULTS This is a risk significant area because the personnel screening and FFD processes are used to -
verify personnel trustwodhiness prior to granting unescorted access to the site protected area
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and the FFD Behavior Observation process is used to monitor the continuation of trustworthiness for persons authorized unescorted access. The establishment of trustworthiness for persons granted unescorted access to the site protected area is a major component of protection against the insider threat of radiological sabotage.
PERFORMANCE INDICATOR The performance of this system will be measured by tracking the failures in the personnel screening process that granted unescorted access to persons who did not meet all appropriate criteria for unescorted access and by tracking FFD data on FFD test failures. The failures in the
~ personnel screening process will provide data on the effectiveness of the process to accomplish
. its desired objective to not grant unescorted access to those persons whose trustworthiness cannot be verified. The FFD data on test failures will provide data on effectiveness of the program to identify persons with substants issues in the pre-employment portion of the program and the random FFD program will demonstrate the effectiveness of the Behavior Observation Program to identify FFD issues through the fo;-cause testing program versus the random testing program. The above data is currently available. The access authorization data will be reported quarterly and the FFD is currently reported semiannually.
VERIFICATION AND VAllDATION The verification and validation (V&V)' process willinclude a review of the implementation of the programs in accordance with regulatory requirements. After the initial V&V process, additional inspection should not be necessary ui.less the ?! ino4;ates degradation of the programs.
4.
Response to initiating Events
- a. Protective Strategy
- b. Irnplementation of protective strategy ge p.r
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3 DESIRED RESULT This is a high risk significant system necessary io protect against the design-basis threat of radiological sabotage. The licenses should be able to demonstrate the ability to respond with sufficient force, property armed and within the appropriate timeframe to interdict and defeat the design-basis adversarial force in order to protect vital equipment necessary for safe shut down of the plant.
PERFORMAN 3E INDICATOR None. A PI was considered for this ama, however, because there is no regulatory requirement for licensees to onduct drills or exercises on any prescribed frequency, each licensee conducted them on different !requencies. The NRC determined that absent a standardized frequency to insure a minimunt valid number of data points could be assured, a standardized Pl could not be developed.
This area will be inspected as part of the baseline inspection and will include a review of Training and Qualification Records, the protective strategy, drill scenarios, drill critiques, and a requested demonstration of the ability to defend against the design-basis threat.
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