ML20236P135
| ML20236P135 | |
| Person / Time | |
|---|---|
| Issue date: | 02/19/1987 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20236P120 | List:
|
| References | |
| FOIA-87-618, RTR-NUREG-0885, RTR-NUREG-885 SECY-87-047, SECY-87-47, NUDOCS 8711170162 | |
| Download: ML20236P135 (6) | |
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a i POLICY ISSUE (Information)
February 19, 1987 SECY-87-47 For: The Commissioners From: Victor Stello, Jr.
Executive Director for Operations
Subject:
REGULATORYEFFECTIVENESSREVIEW(RER) PROGRAM ANNUAL REPORT FOR FY86
Purpose:
This annual report is in response to the U.S. Nuclear Regulatory Commission Policy and Planning Guidance 1986 (NUREG-0885 Issue
- 5) which states:
"The staff, in addition to assuring that safeguards plans are in place at operating facilities and for transportation, will continue its independent assessment that these imple-x mented plans meet safeguards objectives and that safeguards regulations adequately support those objectives. An annual report shall be provided to the Comission detailing the results of the previous year's assessments. The report
- shall contain recommendations for continuing or discontinu-ing the assessment."
Background:
The Regulatory Effectiveness Review (RER) program provides independent assessments of safeguards at both power reactors and Category I fuel cycle facilities. These assessments focus on -
the actual capability of facility safegur.rds to cope with NRC's design basis threats. Detailed background information relative to the inception of the program and its technical approach and
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objectives is contained in SECY-84-341, dated August 28, 1984.
In summary, the RER program is a deliberate attenpt to provide a systematic review of licensees' implemented safeguards programs to assure standardization and consistency of HRC's safeguards approach and the adequacy of licensees' implementing procedures.
The objectives of the REP program are 1) to validate the identi-fication and protection of vital equipment required by 10 CFR 73.55, 2) to examine the interface between safety and safeguards to identify any safety problems that may result from implementing security requirements, 3) to assess the overall effectiveness of implemented safeguards to protect against the design basis threats contained in 10 CFR 73.1, 4) to evaluate contingency response capabilities and coordination with local law enforcement, and 5) to identify any generic issues and validate the regulatory base, 4?-74723 b , NMSS gg11gg28711D FLORA 87-613 PDR 4f U
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The Commis$ioners 2 Discussion: . Regulatory Effectiveness Reviews were completed during fiscal year 1986 for eighteen power reactor units at twelve sites. The facilities were the following: Donald C. Cook Nucle'ar Power Plant Units 1 and 2; La Salle Nuclear Power Plant Units 1 and 2; Calvert Cliffs Nuclear Power Plant Units 1 and 2; Point Beach Nuclear Plant Units 1 and 2; Joseph M. Farley Power Plant Units 1 and 2; Virgil C. Summer Nuclear Station; Duane Arnold Energy Center; Fort Calhoun Station; Diablo Canyon Power Plant Units 1 and 2; Three Mile Island Nuclear Power Station Unit 1; Yankee Rowe Nuclear Power Station; and Indian Point Nuclear Power Station ;
Unit 3. Infonnation-obtained from these RERs was analyzed, evaluated and compiled in final reports for transmittal to the respective licensees. The RER findings are highlighted below for each of the five major objectives of the RER program.
Vital Eauipment Validation 10 CFR 73.2 defines vital equipment as: "any equipment, system, device, or material. the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. Equipment or systems which would be required to function to protect public health and safety following such failure, destruction, or release are also considered '
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to be vital." 10 CFR 73.2 also defines a vital area as "any .
area which contains vital equipment." l
. In developing their safeguards plans, licensees identify vital l equipment and areas in their respective plants to be protected l as vital. The NRC staff's safeguards licensing evaluation reports )
1: have accepted licensees' vital area commitments subject to future l NRC validation. The RER program is facilitating this validation, j using computer analyses performed for the NRC by the Los Alamos i National Laboratory (LANL). -l On March 5,1986 an internal NRC Vital Area Comittee (VAC), estab-lished by the EDO, submitted a report which recommended a revised o staff position and included new assumptions and guidelines for the identification of specific equipment and areas in each plant that require protection as vital. However, an evaluation pursuant ;
to 10 CFR 50.109 must be conducted prior to implementing any new I requirements on licensees. Therefore, in accordance with Manual Chapter 0514 and the CRGR Charter, a regulatory analysis is currently being prepared for review by the Committee to Review I Generic Requirements (CRGR). Consideration of site-specific )
actions suggested by the validation findings are also being held l in abeyance pending disposition of the VAC recommendations.
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The' Commissioners 3
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i Safety / Safeguards Interface In general, 'the RER team has not found operatio.nal safety l significantly affected by NRC security requirements. However. -l' at three sites possible failure of vital area doors in a locked position during loss of electrical power or access computer i failure could be a potential problem. Security response at .
these sites appeared adequate to provide prompt operator access I to vital areas. Nevertheless, the NRC staff has recomended that interior vital area doors be desioned to fail in an open -
position and that procedures be established to provide prompt compensatory measures for open doors. The staff also recom-mended that operators routinely carry controlled backup keys to 1 open any doors that fail in the locked position. These recom- I mendations were brought to the attention of all power reactor j licensees.in IE Information Notice No. 83-36 issued June 9, 2 i 1983.
i Safeguards Systems Effectiveness and Contingency Response !
Capabilities The RER team's' findings are categorized by degree of severity. !
The most severe category is a " Potential Sabotage Vulnerability." l This is a safeguards program deficiency judged to require im-mediate corrective action because the licensee would otherwise j be incapable of protectir.g against NRC's design basis threat.
The next two categories are of lesser severity and can tolerate a r' ore deliberate regulatory review and corrective action pro-cess. The'first of these categories is called a "Significant 2 Safeguards Inadeauncy." This is a safeguards program deficiency judged by the RER team to cause the level of protection provided by the licensee to be considerably less than intended by the NRC ,
and which, if allowed to continue, could degrade to a " Potential {
Sabotage Vulnerability." The lowest severity level,.a " Safe- -
j guards Prooram Concern," is an observed weakness in a specific element of the safeguards system or procedures such that impro- ]
vements would be necessary to achieve the full intent of HRC's regulations. j In FY86 seven PER findings were categorized as " Potential Sabotage Vulnerabilities," 57 as "Significant Safeguards Inadequacies,"
and 72 as " Safeguards Concerns."
As in FY84 and FY85 one of the more significant and common deficiencies noted was en inability to detect intrusion at all portions of the protected area boundary. Contributing factors 1
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.inciude poor design of perimeter barriers, not compensation'g forL
[ .. limitations of some intrusion detection systems, improper instal--
lation or alignment' of. intrusion detection equipment, and inade-
> quate maintenance. Another notable concern involved security alarm assessment-(i.e. determining the causes.of intrusion 1 detection alarms). Most facilities essess. alarms by means.of- i fixed closed circuit television. Weaknesses found by RER team :
- included ineffective installation and orientation of cameras, j i poor picture quhlity, ee;ipment. blocking camera's. view, zones
. too long'for/ single camera coverage. and zones that could be -
c traversed'by an adversary before an alarm could be assessed. ;
The FY86 RER fir. dings included several Weaknesses related to i contingency response capabilities. These-included the deploy- H ment of weapons and response equipment that could be easily-l - interdicted and the' lack of readiness for. iscue of response * >
! force weapons. - The'hck of demonstrated ability. of security l officers to effectively obtain, handle and carry weapons and ammunition and qui:kly don' response gear during an emergency 1< could adversely affect their timely and effective response.
- . Another weakness.was thiassignment of conflicting duties to certain security personnel. 'During an emergency, duties such as
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fire brigade,'first aid and rescue could prevent one or more of the security force's designated armed responders from being dispatched in a timely manner.
Response to RER Findings i
.. Licensees voluntarily took prompt compensatory actions to remedy
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all the "Potentiel Sabotage Vulnerabilities" either during or at .
the. cempletion of the RERs. Licensees also voluntarily corrected many of the;"Inadauacies" and " Concerns" before the teams left the: sites. Licen'see comments in response to written RER reports reflect agreement'with many of the findings and describe addi _
tional voluntary actions taken as a result.
The staff is tracking each RER finding and associated response to verify resolution or determine the need for possible additional .
action. If11t is determined that additional actions are justified !
beyond those taken voluntarily, they may be pursued through rule-making, improved guidance or other appropriate methods, in accord-ance with 10 CFR 50.109 and agency procedures contained in Manual q Chapter 0514, and the CRGP Charter. (To date, staff has not had !
to impose any site specific backfits).
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, . r- Some findings have been items of noncompliance and resolved by:
L 1* .the Regions. Regardless of whether findings are items.of non -
o compliance, NRC's regional inspectors routinely include follow
.up of-licensee corrective. actions in post RER inspections.
Possible Generic Issues !
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's As more RERs:are performed, some deficiencies are emerging as-possible generic-issues. For example, at some sites .RER teams
.found vital area. barriers that did not provide penetration re-sistance to a broad range of possible adversary actions. In i
-addition, the team.found vital eouipment'which could be damaged-by an external adversary with hand-carried explosives from out- 1 side a vital. area. barrier. .Although general guidance on vital ,
x area barriers exists, more specific guidance is needed to clarify (
the desired functions of vital' area barriers in the overall '
security' system and to better define criteria for the acceptability i
of vital ~ area- barriers.- i Another possible generic issue concerns backup power for security lighting.'. Many plants have no provisions on procedures to-provide emergency power to' security lighting or use a type of security lighting that takes several minutes to restore following a power interruption. Since security lighting is essential to
. adequately monitor the protected area and assess alarms and since it is impossible to protect the off-site power normally used for security lighting, it may be appropriate to require security lighting to have an uninterruptible backup power supply.
Resolution of' generic issues may be pursued through rulemaking,
... improved guidance or other appropriate methods, in accordance-
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with 10 CFR 50.109 and agency procedures contained in Manual Chapter 0514, and the CRGR Charter.
Conclusion
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The RER program has proven beneficial as a means of assessing the effectiveness of safeguards programs against the design basis threats of theft and sabotage and as a means of determining whethar. existing regulations yield the level of protection intended by NRC. On January 14, 1987, OIA forwarded to the EDO l a draft report on their audit of the Regulatory Effectiveness Eeview Program for power reactors. The draft report states that the PER program is beneficial to both the licensees and the NRC and that one of its strengths is the capability and enthusiasm of the employees carrying out the RERs. However, the report also includes 12. recommendations which are being addressed by the staff, i
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The' Commissioners 6 f..
At the end of FY86, RERs had been completed at three fuel facilities and at 46 power reactor units (29 reactor sites).
Based on the findings of the RER program to date, it,is recom-1 mended that the effort be continued. Staff resources have been budgeted to conduct 18 reviews in FY87 and la reviews per year subsequent to FY87. At this rate all power reactors and fuel cytta facilities possessing formula quantities of SSNM can be-reviewed by the end'of FY93.
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Executive' Dire o for Operations I
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