ML20245A535
| ML20245A535 | |
| Person / Time | |
|---|---|
| Issue date: | 03/02/1987 |
| From: | Sniezek J Committee To Review Generic Requirements |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20244E562 | List: |
| References | |
| NUDOCS 8704150097 | |
| Download: ML20245A535 (79) | |
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ana
/ 'o g UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION t
5 eE WASHINGTON, D. C. 20555 mEAE TO THE PDR j MAR 2
% ....+ / 1987 i
FEMORANDUM FOR: Victor Stello, Jr.
Executive Director for Operations FROM: James H. Snierek, Chainnan l Committee to Review Generic Requirements
SUBJECT:
FINUTES OF CRGR MEETING NUMBER 105 l
The Committee to Review Generic Requirements (CRGR) met on Thursday, January 15, 1987, from 1-5 p.m. A list of attendees for this meeting is enclosed (Enclosure 1). The following items were addressed at the meeting:
- 1. R. Burnett/P. Dwyer (NMSS) presented for CRGR review the proposed licens-i ing guidance for recently effective new rules (Search Requirements and l , Miscellaneous Amendments). This matter is discussed in Enclosure 2.
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- 2. S. Scott (IRM) briefed the CRGR concerning NRC's request to OMC to con-l tinue the reporting and recordkeeping burden (about 5 million hours or
$300 million) of 10 CFR Part 50. A copy of Mr. Scott's briefing paper is enclosed (Enclosure 3).
, Standard Review Plan Section 6.5.2 entitled " Containment Spray as a Fission Product Clean-up System." This matter is discussed in (
i Enclosure A.
I Enclosures 2 and 4 contain predecisional information and, therefore, will not be released to the Public Document Room until the NRC has considered (in a I public forum 1 or decided the matter addressed by the information. !
In accordance with the ED0's July 18, 1983, directive ccreerning " Feedback and Closure on CPGR Peviews," a written response is required from the cognizant office to report agreement or disagreement with CRGP recommendations in Enclosures 2 and A. The response, which is required within 5 working days P# ter receipt of these meeting minutes, is to be forwarded to the CRGP Cheirnan ,
and if there is disagreement with the CRGR recommendations, to the EDO for decisionmaking.
Ouestions concerning these meeting mirutes should be re# erred to Walt Schwink (492-8639).
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w) f- wun V 2 larner H. Sniezek, Chai aan
( Cemittee to Feview Ger.eric Pequirernents
Enclosures:
As stated
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MAR 2 1987 l
cc: Commission (5)
SECY Office Directors Regional Administrators CRGR Members W. Perler R. Burnett P. Dwyer S. Scott T. Speis Distribution:
JSniezek JRoe JZerbe PRabideau JClifford GZwetzig FHebdon WLittle RErickson MLesar ROGR Staff- DEDROGR cf RFraley PDR(NPG/CPGR)
WMcDonald Central files STreby BZalcman l
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DATE :2/15/87 :?/77/87 (E/6 /87 : : :
er ' 0FFICIAL RECORD COPY
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F-Enclosure 1 LIST OF ATTENDEES CRGR MEETING NO. 105 January 15, 1987 CRGR MEMBERS J.H. Sniezek
! D.F. Ross R.E. Cunningham R.M. Bernero R.W. Starostecki J. Heltemes I W. Olmstead (for J.-Scinto)
'OTHERS W. Schwink J. Zerbe R. Burnett P. Dwyer G. McPeek J, Yardumian L. Ten Eyck G. McCorkle D. Carlson B. Brach T. Cox J. Conran J. McKinley J. Clifford S. Wigginton B. Shelton H. Smith J. Lyons W. Mcdonald S. Scott R. Hernan W. Magee D. Wigginton j
- 2. Rosztoczy ;
T. Speis L Soffer J. Read P. Polk
1 Enclosure 2 to the Minutes of CRGR Meeting No. 105 Proposed Licensing Guidance for Recently Effective New Rules (SearchRequirementsandMiscellaneousAmendments) l R. Burnett/P. Dwyer (NMSS) presented for CRGR review the proposed guidance to reactor licensees regarding implementation of recently effective rules (search requirements and miscellaneous amendments). At the meeting Mr. Burnett re-placed the proposal previously forwarded for CRGR consideration with a later version of the proposal. (A copy of the proposal is attached.) Mr. Burnett !
explained that this later version of the proposal reflected necessary technical and editorial corrections. The later version of the proposal was reviewed by CRGR at the meeting. The proposed guidance is in the form of responses to 21 questions raised by NRC license reviewers and/or reactor licensees that are l
concerned requirements with implementation and miscellaneous of recently) amendments . effective safeguards rules (search CRGR and NMSS agreed that after the responses to certain questions (nine) have been corrected / clarified (as agreed to by CRGR and HMSS representatives), the proposal should be forwarded by generic letter to licensees and NRC license reviewers. It was agreed that the responses to Questions 4, 6, 11, 12, 13, 16, 17, 20 and 21 should be modified as follows:
Question 4. What is meant by the statement that, "Certain access controls may be suspended during emergency or abnormal plant conditions...."?
Response proposed by NMSS:
10 CFR 50.54(x) states a licensee may take reasonable action that departs from NRC-issued license conditions or technical specifications in an emergency or abnormal condition declared by a senior licensed operator when (a) the safe operation of the reactor is affected, (b) the action is immediately needed to protect the public health and safety, and (c) no action consistent with the license conditions and technical specifications that can provide adequate or equivalent protection is immediately apparent. This same authority also ap-plies to physical security and safeguards contingency plans and plant proce-dures relating to security matters.
Response CRGR and HMSS agreed upon:
10 CFR 50.54(x) states that a licensee may take reasonable action that departs from a license condition or a technical specification in an emergency when this action is immediately needed to protect the public health and safety, and no action consistent with license conditions and technical specifications that can provide adequate or equivalent protection is immediately apparent. This same authority also applies to physical security and safeguards contingency plans and plant procedures relating to security matters.
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Question 6. What individuals are included in the term " operating 1 personnel" as used in Section 4.1 of Regulatory Guide 5.65?
Response proposed by NMSS:
The term " operating personnel" means any individual who is authorized by plant management to manipulate any reactor controls in order to mitigate or attempt to mitigate an emergency or abnormal condition. The term also includes any other individual who has been designated by plant management to aid in the mitigation of an emergency or abnormal condition (e.g., emergency response team, security personnel, etc.).
Response CRGR and NMSS agreed upon:
The term " operating personnel" means any individual (licensed operator) who is
- authorized to manipulate any reactor controls in order to mitigate or attempt to mitigate an emergency or abnormal condition. The term also includes any other individual who is needed to aid in the mitigation of an emergency or abnormal condition (e.g., emergency response team, security personnel, etc.).
_ Question 11. May all vital area doors fail open during an emergency or
.; power outage?
d Response proposed by NMSS:
C
% Yes. However, sufficient guards must be innediately available and deployed to 2 monitor ingress / egress of the vital area doors. Groups of vital area doors may 5 be monitored by a single guard provided that direct observation of all doors
< can be maintained. If a sufficient number of guards are not available to
" monitor all vital area doors, then the doors should fail shut, be provided with
- mechanisms for emergency egress, and procedures implemented to assure emergency access by operational personnel.
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Response CRGR and NMSS agreed upon:
Yes. From a safety standpoint it is preferable that doors fail open during emergencies or power outages although the regulation is silent on this matter.
However, regardless of whether doors fail open or closed, in an emergency in-J volving plant safety, i.e., threats to public/ worker health and safety, vital area access ance with 10 CFRcontrols 50.54(x may)be
. suspended without compensatory measures in The issue of whether vital area doors should fail open or closed was studied by the Committee to Review Safeguards Requirements at Power Reactors in 1983. The Committee's findings (documented in NUREG-0992, " Report of the Committee to l Review Safeguards Requirements at Power Reactors,") emphasized the importance of licensees considering a balanced safety / safeguards approach in the design of access control systems. This consideration helps assure adequate safeguards response while maintaining adequate safety precautions.
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4 It has been NRC's policy that when vital area doors are configured to " fail open" during a power outage and the situation does not involve public/ worker health and safety, the condition must be addressed in the site security /
contingency plan.
However, recognizing the potential problem of security force availability coupled with the need for heightened security force awareness in such situa-tions, the staff is at present considering other options which may be accept-able compensation for this condition. In the interim, a licensee wishing to implement alternative compensatory measures should receive approval of the measures by appropriate NRC staff prior to implementation.
In those instances where vital area doors are configured to " fail shut," the doors should be provided with mechanisms for emergency egress and procedures should be implemented to assure prompt access by operational personnel.
Question 12. Can logging of individuals granted access to vital areas be suspended during emergencies and power outages?
Response proposed by NMSS:
Logging requirements to vital areas may be suspended only when an emergency or abnormal condition has been declared by, as a minimum, a " licensed senior operator."
Response agreed upon by CRGR and NMSS:
Yes.
Question 13. Do the revised search requirements mean that every time a member of the security force leaves the protected area (PA) to perform official duties that he or she must be equipment searched for weapons, explosives, and incendiary devices prior to re-entry to the PA?
Response proposed by NMSS:
Yes. Only bona fide Federal, State and local law enforcement personnel on official duty are exempt from the search requirements of 10 CFR 73.55(d)(1).
Response agreed upon by CRGR and NMSS:
Members of the security force must be equipment searched on their initial entry to the PA at the beginning of their work shift. If these individuals leave the PA to perform official duties subsequent to this initial search, they need not be searched prior to re-entry into the PA if they have been under the direct observation or accompaniment of a member of the security organization while outside the PA. Security force individuals who do not meet this criterion must be equipment searched prior to their re-entry to the PA.
O Question 16. Is the central alarm station (CAS) required to be protected as vital?
Response proposed by NMSS:
No. The requirement to consider the central alarm station (CAS) a vital area was inadvertently deleted under the Miscellaneous Amendments. The staff is at present considering the desirability of pursuing a generic backfit to require the CAS to again be considered vital. :
Response agreed upon by CRGR and NMSS:
The requirement to consider the central alarm station (CAS) a vital area was inadvertently deleted under the Miscellaneous Amendments. The staff is at present preparing an imediately effective rule amendment to again require the CAS to be considered vital. This rulemaking is to correct an error and therefore is not a backfit.
Question 17. Does an onsite secondary power supply system for a privately owned telephone system have to be located within a vital area?
Response proposed by NMSS:
No. The revised regulation requires the secondary power supply systems for alarm annunciator eq ment and non-portable communications equipment as re- ,
quired in paragraph of 10 CFR 73.55 to be located within vital areas. The provisions of 973.55 require, in part, the capability of conventional tele-phone service and continuous communication, radio, or microwave transmitted !
two-way voice communications between the facility and offsite local law en-forcement authorities. Power for conventional telephone service is provided from offsite by the public telephone utility. The term "non-portable" refers strictly to the other means of required offsite communications (i.e., ratio or microwave) because in contrast to radio systems conventional telephone systems are typically not " portable" versus "non-portable."
Response agreed upon by CRGR and NMSS:
No.
Question 20. What components of the secondary power supply systems for the alarm annunciator and non-portable communications equipment have to be protected as vit , equipment?
Response proposed by NMSS: ,
i The objective of secondary power supply systems (SPSS) is to provide auxiliary power during power interruptions or outages. The duration of such interrup- .
tions or outages should be determined on a site-specific basis under station blackout criteria. It is necessary to protect all components of a SPSS needed '
to provide this site-specific period of stand-by power. Such components may include, but are not necessarily limited to, the following:
- a. Batteries
- b. Battery chargers
- c. Inverters
- d. AC alternators
- e. DC generators
- f. Emergency buses
- g. Control panels
- h. Switch gear
- 1. Identifiable Cabling
- j. Main fuel tanks or day tanks and associated plumbing / piping.
Response agreed upon by CRGR and NMSS:
Same as above but item 1. is deleted.
Question 21. Can the, secondary power supply systems for alarm annunciator equipment and non-portable communications equipment consist of "interruptible power systems (IPS)" or do they have to be "uninterruptible power systems (UPS)"?
Response proposed by NMSS:
None.
Response agreed upon by CRGR and NMSS:
The secondary power supply systems may consist of either an IPS or UPS.
However, an UPS is preferable.
In sumary, the IRGR recommended that the proposed guidance be issued via generic letter to reactor licensees after the modifications (agreed upon by CRGR and NMSS representatives attending the CRGR meeting) have been completed.
Prior to issuance, a copy of the generic letter fomarding the guidance to reactor licensees should be forwarded to the CRGR Chairman to assure that further CRGR consideration of this matter is not necessary.
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pVESTION_1. How should the " Miscellaneous Amendments Concerning Physical Protection of Nuclear Power Plants" and amendments concernina " Searches of l
Individuals at Power Reactor Facilities" be l
l submitted?
I ANSWER.
Plan amendments should be submitted to NRC Headquarters (Director, l Office of Nuclear Reactor Regulation ATTN: Document Control Desk) 1 as amendments in response to the new rules. They should not be submitted under the provisions of 650.54(pl or %50.90. Six copies of the plan amendments should be submitted.
Reference:
673.55 - Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage, as printed in FR/Vol. 51, No. 149/ Monday, August 4, 1986/
Rules and Regulations /pages 27817-27825 Miscellaneous Amend. Search Requirements m W es W preessess of meanses eeu' wens an aussear B'Y Dec 2.1986 esch licenses
,,,,,,,esseere sesenet enehoogeens shall submit revisions to its securttp sensessa. Plan which define ,how the final search By Dec. 2. tees each licensee, as requirements of this paragraph will be met. The final search requirements of appropriate. shall ghggt this package must be implemented by amendmenu to its mty p which the licensee within 80 days aftu define how the amended requirements Commission approval of the proposed of paragraphs (a). (d)(2). (d)(7). (d)(9).
and (e)(1) will be met. Each submittal 8'C""'Y PI '" Y "
must include a proposed implementation schedule for Commission approval. The amended safeguards requirements of these paragraphs must be isaplemented by the licensee within 180 days after Committee /NMSS comminion approval of the sicase_ad December 8, 1086
_secunty plan in accordance with the approved schedule, ,
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io' OVESTION 2.* Can.ageneric'SERwhichconta' ins.nohafeguards Information be used to document a NRC licensing-reviewer's findings on the adequacy of commitments made by licensees in response.to the Miscellaneous Amendments?
ANSWE_R.
Yes, but an appendix which-details certain of the specific commitments should be attached to the generic SER and protected pursuant to 673.21 requirements (Safeguards Informtion).
Reference:
Current policy.
Committee /NMSS January 14, 1987
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QUESTION 2. Can a generic SER be used to document a NRC l licensing reviewer's findings on the adequacy _of commitments made by licensees in response to the Miscellaneous Amendments 7 I
ANSWER.
Yes, but an appendix which details certain of the specific commitments should be. attached to the generic SER and protected l pursuant to $73.21 requirements.
Reference:
Current policy.
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l Committee /NMSS l November 19, 1986 i
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OVESTION 3.* Does the licensee's security plan have to be amended to incorporate commitments made in response to the new regulations?
ANSWER.
Yes.
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Reference:
10 CFR 73.55, confirmed through phone conversation with R. Fonner, OGC, 11/12/86 i
(
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Miscellaneous Amend. Search Requirements sts.ss meseemenesserw B'y Dec. 2.1966 each licensee a
y g g,,,,,g m m m shall submit revisions to its secunty .
power resseers agemet redemagnosi embetops. plan which define how the final search.
requirements of this persgraph will be By Dec. 2.1ses each licenses, as met. The final search reqwreJnants of appropriate. shall submit proposed amendments to its secunty plan which this package must be implernented by ,
the licensee within so days after define how the amended requirements Commission approval of the proposed of paragraphs (a). (d)(21. (d)(7). (d)(9).
secunty plan revisions.
and (e)(1) will be met. Each submittal must include a proposed implementation <
schedule for Commission approval.The y' '
amended safeguards n;i- te of , . .
these paragraphs must be implemented by the licensee within too days after Commission approval of the proposed secunty plan la accordance with the _
spprov,ed schedule. ,
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Committee /NMSS {
January 14, 1987 j l
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l ." oLD QUESTION 3.- Does the licensee's security plan have to be amended to incorporate commitments made in -
response to the Miscellaneous Amendments?
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ANSWER. _
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Yes.
Reference:
R. Fonner, 0GC, November 12, 1986.
Miscellaneous Amend.
ITs.as nemmenese,e,, nym Search Requirements 8'messen w assenes auss,emosnusiner m,g Demermestare agemet reesisglest N
By Dec. 2.19M each licensee #
% Dec. 2.1988 each licensee as shall submit revisions to its secunty, appropriate, shall submit proposed plan which define how the final search amendments to its security plan which requirements of this paragrapi will be define how the amended requirements met. The final search requirements of of parasrephs a). (d)(2). (d) 7). (d)(e). this packaec must be implemented by and (e)(1) will(be met. Each(submittal the licensee within so days af ter must include a proposed implementation Commission approval of the proposed schedule for Comminaim approval.& secunty plan revisions.
amended safeguards requirmeents of these paragraphs must be implemented k_88, licensee within 180 days after
- F"Y PE,la accordance with thepproval of the proposed approved schedule..
HG Committee /NMSS December 8, 1986
j l 00ESTION 4 What is meant by the statement that, "Certain
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access controls may be suspended during emergency or abnormal plant conditions,..."?
ANSWER.
10 CFR 50.54(x) states a licensee may take reasonable action that departs from NRC issued license conditions or technical f4eds specifications in an emergency or abnormal condition declared by a senior licensed operator when, la) the safe nperation of the reactor is affected, (b) the action is immediately needed to protect the public health cnd safety, and (c) no action consistent with the license conditions and technical specifications that can provide adeauate or eouivalent protection is'immediately apparent.
This same authority also applies to physical security and j safeguards contingency Plans and plant procedures relating to security matters.
Reference:
Regulatory Guide 5.65, Section 3 - Control Of Access To Vital Areas Under Routine Conditions, Subsection 3.1 -
R.G. 5.65 Access List 3J hh J Miscellaneous Amend. (
Paragraph 7135(dX7XIXA) segsires that the uneasse to the requirements of this section. In I accordance with l 30.M (x) and (y) of estabush airsest authonsation ascoes lines for each Waal I Part so, the licensee may suspend any area. The assess Msi should be updaad and mppw safeguards measures pursuant to I,73.55 by the cognisant Sceasse manager or mm os b last working day of each calendar month, he access list im e eyn de to p tect the inchide Wy thoes N whose specinc public health and safety and no action duties require that they have access to the vital area consistent with license conditions and during routine operations. Certain aceses coattels may technica'l specification that can provide be suspended during emergency or abnormal plant adequate or equivalent protection is conditions, and the List would be unnecessary under
) immediately apparent. This suspension must be approved as a minimum by a these circumstarcos. Thefore, the sames of einerpacy response personnel need not be on the list.
licensed senior coerator pnor to taking the action. The suspension of safeguards Committee /NMSS measures must be reported in November 19, 1986 accordance with the provisions of i 73.71. Reports made under i 50.72 need not be duplicated under i 73.71.
tJ Ew P
QUESTION 5.* May access controls for a vital area be suspended when a life threatening emergency has occurred to an on-site person?
ANSWER.
10 CFR 73.55(d)(4) permits emergency vehicles to enter the protected area without the normal search functions being performed.
There are no provisions in the regulations for suspending any vital area safeguards requirements. However, the emergency team would be escor',ed by site security personnel to the location of the emergency and accordingly it would not be necessary to void any requirements.
Reference:
. '(4) All vehicles, except tmder emer.
i n.nc, aandittaa= shau be searched for litems which could be used for sabo.
Itage purposes prior to entry into the lprotected area. Vehicle areas to be l starched shau include the cab, engine I
compartment, undercarriage, and !
puso area. All vehicles, except deels-pated th vehWes. requiring {
l matry into the protected area shan be escorted by a snember of the security !
organization while within the protect. l ed area and, to the extent practicable, shall be off loaded in the protected ares at a specific designated materials receiving area that is not adjacent to a vital area. Designated licensee vehicles shall be limited in their use to onsite plant functions and shall remain in the protected ares except for oper-ationG. maintenance, repair security j and emergency purposes. The licensee )
shall exercise positive control over all such designated vehicles to assure that they are used only by authorized per-sons and for authorized purposes. Committee /NPSS January 14, 1987 1
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4 Cub 00ESTIO M .
- Mayaccesscontroisforavitalareabe suspended when a life threatening event has~
occurred to an on-site person?
ANSWQ.
No. Suspension of safeguards measures under 10 CFR 50.54(x) and (y) should be exercised only under conditions affecting the safe operation of the power reactor. It is believed that the safeguards measures required under 10 CFR 73.55 adequately provide for emergency response to other events.
Deference: Reculatory Guide 5.65, Section 5 - Suspending Security Measures, Subsection 5.3 - Controls That Can Re Suspended During An Emergency R.G. 5.65 SJ Cenerek Tlat Can to Suspended Duke an Essessesy The types d controis that oculd be PM in as essergeney might lactode but are not theited to the 8888'las:
- 1. The search and idestulcation of personnel required by paragraph 73.55(dXI).
- 2. The search of hand <arried items esquired by paragraph 73.55(dX2).
- 3. The search of vehicles required by paragraph 73.55(dX4).
- 4. The use of a badge identification systern required by paragraph 73.55(dX5).
- 5. The registration.of personnel required by paragraph 73.55(dX6), and
- 6. The access controis for vital areas in paragraph Committee /NMSS 73.55(dX7). December 8, 1986
0 V E S T I,0 N_6, . * - What individuals are included in the term
" operating personnel" as used in Section 4.1 of Regu.latory Guide 5.65?
ANSWER.
The term " operating personnel" means any individual who rd8kf is authorized by plant management to manipulate any reactor tards controls in order to mitigate or attempt to mitigate an emergency or abnormal condition. .The term also includes any other individual who has been designated by plant management to aid in the mitigation of an emergency or abnormal condition (e.g.
emergency response team, security personnel, etc.).
Reference:
Regulatory Guide 5.65, Section 4 - Emergency Access To Vital Areas, Subsection 4.1 - Access Keys R.G. 5.65 4.1 Access Keys la the event of an emergency or abnormal condition 2t a power reactor it may be necessary for certain personnel, particularly an operator, to have prompt Jccess to vital areas or equipment. To facilitate access, operating personnel should be provided with keys to opep doors that are locked for security or other purposes.
Committee /NMSS January 14, 1987
.gp -
QUESTION 6. What indiv.iduals are included in the term
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" operating personnel" as used in the state-ment, "To facilitate access, operating personnel should be provided with keys to open doors that are locked for security or other purposes"?
y.
ANSWER. !
The term " operating personnel" means any individual who by virtue of..his/her position is authorized to manipulate any reactor l controls in order to mitigate or attempt to mitigate an emergency or abnormal condition and any member of an emergency response I
team.
O
Reference:
Regulatory Guide 5.65, Section 4 - Emergency Access To Vital Areas, Subsection 4.1 - Access Keys R.G. 5.65 4.1 Access Keys In the event of an emergency or abnormal condition at a power reactor, it may be necessary for certam personnel, particularly an operstor, to have prompt i JCGes5 to vit31 3reas or equipment. Io facLhtate access, f operating personnel snould be provided with keys 1 i
to opep Joors that are loded for security or oSer pu rpows.
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- Committee 1NMSS i November 19, 1986 j
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NEW QUESTION 7.* What individuals are included in the term "necessary personnel" as used in Section 4.3 of Regulatory Guide 5.65.
ANSWER.
The term "necessary personnel" means the same as the term "operatino personnel" discussed in Item 6 above.
Reference:
Regulatory Guide 5.65, Section 4 - Emergency Access To Vital Areas, Subsection 4.3 - Loss Of Electric Power 4.G. 5.65 4J Las of Elssels Peeer Is esser to taamanas asissy, the usassee.q>eund puesMe for sapid leggenWeguess dusing a _esupuser er power asesen, it einst uses deem me aos spes6asany M the lissesse's physiest assemey plas Je 3 ass na the sessed poshima mean issa er ehenes power, I
psessemos thes revende ser peemos emmenessnesy mesomes in opsains eshed n does stomed be emanashed.
The Astowing use assapesMe passaduses ist psevidias for safe legessWegress desing a power or eenputer estage:
- 1. Have leeks os istador vital area doors fail opes i destas as ousses or emergsacy and hme paards immedh l stely deployed to esonator lagress/ egress
- 2. Use as maissarruptib4e 1Mrwer 'sapply system for electdcel lockaas 4miises.
- 3. Have locas fait closed and prende keyed bypass locks for vital areas. Emmare that au secessary personas!
have keys.
4
- 4. Hoe locks fad closed sad instau crash (" panic") Committee /NPSS l bars and alarins os doors for emersency insress/esrest January 14, 1987 I i
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QUESTION 7. What individuals are. included in the term "necessary personnel" as used in the statement,
" Ensure that all necessary personnel have keys" when vital area locks fail closed during a power J or computer outage?
ANSWER.
The term "necessary personne1" means the same as the term
" operating personnel" discussed in Item 6 above, but also includes security personnel.
Reference:
Regulatory Guide 5.65, Section 4 - Emergency Access To Vital Areas, Subsection 4.3 - Loss Of Electric -
Power R_.G.
5.65 4J Less of Esseds Power .
In esder se fannisaas safety, the lineesse.p FJoHde far spid legam/egnes dudas a aa pew or power emenga. It skal ans doors am noe sysanceny sequised by the Manasse's physsoal asemary plas to fas la the eissed ponteios seen loss of misetdo power, pseentues that psodde for psompt p====*=y seemuso la apening leaked deess should be ==*=h The followles ass asespostle ,.- _'__ for providdag for safe lassess/egrams during a power or computet outage:
- 1. Have locks os interior vital arss doors fad open during an outage or emergency and have guards immedi.
ately deployed to monitor ingress / egress.
- 2. Use as uniatstruptible power supply system for electrical locking devices.
- 3. Hm locks fait closed and provide keyed bypass locks for vital areas. Ensun that au necasary personnel Committee /NMSS J have keys. November 19, 1986 3
- 4. Have locka fad closed and install crash (" panic") - -
bars and alarms os doors for emerlency utgress/ egress. ,
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l NEh!
l OllESTION 8.*
When should vital area hard keys which override f vital area access systems be issued to personnel? 1 l
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ANSWER. l
)
l Vital area .hard keys should be issued at the becint,ing of each shif t and properly accounted for at the end of each shift or as currently specified in a licensee's approved security plan. The use of any such keys to enter vital areas, however, must cause a vital area alarm to be generated and a response must occur when the door is opened.
Reference:
Regulatory Guide 5.e5, Section 4 - Emergency Access To Vital Areas, Subsection 4.1 - Access Keys Miscellaneous Amend.
R.G. 5.65
}3g (ii) Design the access authorization 4.1 Access Keys system to accornmodate the potential need for rapid lagress or egress of individuals during emergency conditions Ia ilta event of. an emerst
- or situations that could lead to at a power reactor; "it may emeW To bip e personnel. particularly an ope.
- as.ess to vital areas or equipmet6 operating personnel should be equipment. to opep Joors that are loded los (8) Periodically review physical P""' 55-security plans and contingency plans **
and procedures to evaluate their potential impact on plant and personnel safety.
Committee /NMSS
.lanuary 14, 1987
L- oto QUESTION 8.
When should vital area hard keys _ which override -~
Vital area access systems be issued to operating i l
personnel? i i
l l
ANSWER. )
l Vital area hard keys should be issued to on duty operating personnel at the beginning of each shift and properly accounted j
- for at the end of each shif t or as currently specified in a
.11censee's approved security plan. The use of any such keys to l
l enter vital areas, however, must cause a vital area alarm to be .
I I 1 generated and a response must occur when the door is opened.
Reference:
Regulatory Guide 5.65, Section 4 - Emergency Access -
To Vital Areas, Subsection 4.1 - Access Keys l
Miscellaneous Amend. R.G. 5.65 ii) Design the access authorization .t.1 Access Keys ff)3$ sy(stem to accommodate the potential
- need for rapid ingress or egress of Ia the event of an emergency or abnormal condition mdividuals durms emergency conditions at a power reactor it may be necessary for certam or situations that could lead to personnel, particularly an operator, to have prompt j
" 3"ess to vital areas or equipment. To facetate access, j h s. the fic l$
(A) Ensurs prompt access to vital operann, pers nnel sh uid be provided with keys equipment. Io opep Joors that ste loded for security or other (B) Periodically review physical purpows.
security plans and contingency plans and procedures to evaluate their potential impact on plant and personnel safety.
Committee /NMSS November 19, 1986 m
~
es M
M W W g C _ __ . _____ _ _ _ nmm gQ@OQQ g
QUESTION 9. Is a key card considered to be "a related access
- control device" subject to the requirement to be changed or rotated at least once every twelve l
months?
ANSWER.
No. However, whenever there is evidence or suspicion of compromise, or whenever an individual is terminated for cause, the
. individual's access authorization should be immediately removed I from the key card system.
i
Reference:
573.55(d)(9) - Access Controls Miscellaneous Amend (9) All keys. locks. combinations, and related access control devices used to control access to protected areas and vital areas must be controlled to reduce the probability of compromise. All such keys, locks. combinations, and related access control devices must be changed or rotated at least every 12 months.
- Committee /NMSS November 19, 1986
- . _ _ j
~~
^ ^ ^ "
- hmm a A . _h M
l 1
N Etv OVESTION 10
- Must licensees rotate or change keys, locks, etc., if an individual's unescorted access authorization is temporarily suspended as opposed -
to " revoked"?
MSWER.
If an individual's unescorted access authorization is temporarily suspended pending a review, locking devices'do not have to be rotated or changed,at the licensee's discretion, as long as access control devices possessed by the individual are returned to management ar.d the individual is escorted while on-site. If the individual's I unescorted access authorization is permanently revoked for cause at the end of the review, locking devices must be changed or rotated.
Reference:
673.55(d)(9) - Access Requirements Miscellaneous Amend Whenever there is evidence or suspicion that any key, bck. combination. or related access control devices may have been compromised. it must be changed or rotated.The hcensee shallinue keys.
locks. combinations and other access control devices to protected areas and vital areas only to persons granted, unescorted factlity access. Whenever an individual's unescorted access is revoked due to his or her lack of trustworthiness. re! ability, or inadequate work performance keys, locks. combinations and related access control devices to which that person had access must be changed or rotated. Committee /NMSS January 14, 1987
OLD -~
'[ -
00ESTION 10.. Must licensees rotate or change keys, locks, .
etc., if an individual's unescorted access authorization is temporarily suspended as opposed to " revoked"?
l I
ANSWER I If an individual's unescorted access authorization is temporarily suspended pendino a review, locking devices do not have to be l rotated or changed as long as access control devices possessed by the individual 3re returned to management and the individual is escorted while.on-site. If the individual's unescorted access ;
authorization is permanently revoked for cause at the old of the i review, locking devices must be chanced or rotated.
Reference:
973.55(d)(9) - Access Requirements Miscellaneous Amends Whenever there is evidence or suspicion that any key. lock. combination, or related access control devices may have been compromised. It must be changed or rotated. The licensee shallissue keys, locks. combmetions. and other access control devices to protected areas and vital areas only to persons granted.
unescorted facility access. Whenever an individual's unescorted access is revoked due to his or her lack of trustworthiness. reliability. or inadequate work performance. keys.
locks. combinations. and related access control devices to which that person had access rnust be changed or rotated.
Committee /NMSS November 19, 1986
s pVESTION 11_. May all vital area doors fail open during a power outage or emergency?
ANSWER.
Yes. However, sufficient guards most be immediately available and deployed to monitor ingress / egress of the vital area doors.
Groups of vital area doors may be monitored by a single guard
,)+
provided that direct observation of all doors can be maintained.
j h /A If a sufficient number of guards are not available to monitor all IV vital area doors, then the doors should fail shut, be provided with mechanisms for emergency egress, and procedures implemented to assure emergency access by operational personnel.
Reference:
Regulatory Guide 5.65, Section 4 - Emergency Access I To Vital Areas, Subsection 4.3 - Loss Of Electric R.G. 5.65 4J Less of manage power ps-.' - - ._g 3" 8 dw to facilianae safety, the basesse.
Pme outsen. It Waal ama doors are ast speciScauy o.
884 mind W the lissesse's physsoal sesunty plan to fse h the einsed peninae spos noss et .is.eg, p, ,
psessenne that provide for p, pe ,,,,,,,,y
"*""es la openins noeked doors ahomad be estabbahed.
N % ase asespeshie proceduns for providing for safe lagres# egress during a power or computer outses:
- 1. Have locks on interior vital area doon fad open durias as outaar or emergency and have guards immeds- l 4tely deployed to monitor ingress / egress. l j
- 2. Use sa unisterruptiAle power supply system for electncal locking devices,
- 3. Have locks fail closed and provide keyed bypass l locks for vital areas. Ensure that au necessary personnel Committee /NPSS j have keys. December 8, 1986
- 4. Have locks fad ckeed and instau crash (" panic")
bars and alarms os doors for emerlency mgress/ egress.
l N G. W OUESTION 12_.* Can logging of individuals granted access to vital areas be suspended during emergencies and power outages?
ANSWER.
'VES Logging r.e(uirements ,to vital apeas m e sus, pended,,only,when En ,
eme r,gency o r a bnorIa l c ond i tion ha s'6ee n dec l a red'by, as a mi imum,
,a licensed denior opefa.or."
Reference:
673.70(d)
Miscellaneous Amend g 73.70 to the requirenGnts of this section. In accordance with I 30.54 (x) and (y) of Part so, the licensee may suspend any 6 73.70 M safeguards measures pursuant to I 73.55
- * * *
- in an emergency when this action as (d) A los indicating name, badge immediately needed to protect the number. time of entry and time of exit ' public health and safety and no action of allindividurls granted access to a consistent with license conditions and vital area except those individuals technical specification that can provide entenng or exitmg the reactor control adequate or equivalent protection is room. immediately apparent. This suspension .
- = * *
- must be approved as a minimumby a licensed senior operator pnerJoTaking the action. The suspension of 4afeguards. .
measures must be reported in accordance with the provisions of I 7311. Reports made under i 50.72 need not be duplicated under i 73.71.
Committee /NMSS January 14, 1987
. . . .. OLD l
- QUESTION 12. Can logging of individuals granted access to
- i _
vital areas be suspended during emergencies and power outages?
ANSWER.
, Logging requirements to vital areas may be suspended only when an emergency or abnormal condition has been declared by a " licensed senior operator."
l l
Reference:
573.70(d)
Miscellaneous Amend.
~
73.70 to the requirements of this section. In accordance with I 50.54 (x) and (y) of I
Part 50 the licensee may suspend any l 73.70 M safeguards measures pursuant to I 73.55
- * * *
- in an eClergency when this action is immediately needed to protect the ,,
(d) A log indicating name, badge number, time of entry, and time of exit public health and safety and no action of allindividuals granted access to a consistent with license conditions and vital area except those individuals technical specification that can provide entenng or exiting the reactor control adequate or equivalent protection is room. immediately apparent. This suspension
- * * *
- must be approved as a minimum by a licensed senior operator prior to taking the action.The suspension of safeguards measures must be reported in accordance with the provisions of i 73.71. Reports made under 150.72 )
need not be duplicated under i 73.71.
i k
(
l Committee /NMSS -
l November 19, 1986 j
~
_3 _ _
7' -
I
' .o aF f4 cx g
ht % LC F b' R O pia ~
, , . ~ g A r< ae r.
OUESTION 13.* Do the revised search requirements mean that every time a member of the security force leaves the protected area (PA) to perform official duties that he or she must be equipment searched s
for weapons, explosives, and incendiary devices prior to re-entry to the PA?
ANSWER.
Yes. Only bona fide Federal, State, and local law enforcement personnel on official duty are exenpt from the search reoufrements of 10 CFR 73.55(d)(1).
Reference:
673.55(d)(1) - Access Requirements
\
~
l
. Search Requirements y l (d) Access Aeguirements. (1)The explosives. or incendiary devices into isolated within a bullet. resisting licensee shall control all points of protected aress. the licenses shall structure as desenbed in paragraph !
personnel and vehicis access into a conduct a physical pat down search of (c)(6) of this section to assure his or her protected area. identification and search that mdividual. Whenever firearms or ability to respond or to summon cf allindividuals unless otherwise explosives detection equipment at a assistance. By Dec. 2.1986 each licensee provided herem must be made and portalis out of service or not operating shall submit revisions to its secunty authorization must be checked at these satisfactonly, the licensee shall conduct plan which define how the final search points. The search function for detection a physical pat-down search of all \ requirements of this paragraph will be of firearms, explosives, and incendiary persons who would otherwise have \ met. The final search requirements of devices must be accomplished through been subject to equipment searches. The this package must be implemented by the use of both firearms and explosive individual responsible for the last \ the licenses within 80 days after detection equipment capable of, ~ access control function (controlhng Commission approval of the proposed detectmg those devices.The licensee admission to the protected ares) must ' be\secunty plan revisions.
must subject all persons except bona s. . . . .
fide Federal. State, and locallaw \
enforcement personnel on official duty 3' to these equipment searches upon entry into a protected area. When the licensee has cause to suspect that an individual is attemptmg to mtroduce firearms.
/
/
(
Committee /NFSS January 14, 1987
{
0VESTION-13. Do the revised search requirements mean that
~ every time a member of the se:urity force leaves the protected area (PA) to perform official duties that he or she must be equipment searched for weapons, explosives, and incendiary devices prior to re-entry to the PA?
ANSWER.
Members of the security force must be equipment searched on their initial entry to the PA at the beginning of their work ]
shift. If these individuals leave the PA to perform official duties subsecuent to this initial search, they need not be searched prior to re-eritry into the PA if they have been d
unde- the direct observation or accompaniment of a member of the security organization while outside the PA. Security force individuals who do not meet this criterion mu'st be equipment searched prior to their re-entry to the PA.
p
Reference:
9 73. 55 (d )(1) - Access Requirements ,
. Search Requirements
' (d) Access /teguhements. (1) The esplosives, or incendiary devices into isolated within a bullet resisting licensee shall control all points of protected areas. the licensee shall structure as desenbed in paragraph personnel and vehicle access into a conduct a physical pat down search of (c)(6) of this section in assure his or her protected area. identification and search tha? individual. Whenever firearms or ability to respond or to summon of allindividuals unless otherwise explosives detection equipment at a assistance. B'y Dec. 2.1986 each licensee provided herein must be made and portalis out of service or not operating . shall submit revisions to its security authorization must be checked at these satisfactonly, the licensee shall conduct plan which define how the final search points. The search function for detection a physical pat down search of all requirements of this paragraph will be of firearms. explosives, and incendiary persons who would otherwise have met. The final search requirements of devices must be accomplished through been subject to equipment searches. The this package must be implemented by )
the use of both firearms and explosive individual responsible for the last the licensee within 80 days after detection equipment capab!: of access control function (controlling Commission approval of the proposed detecting those devices.The licensee admission to the protected area) must be secunty plan revisions, must subject all persons except bona . . . .
fide Federal. State and locallaw <
enforcement personnel on official duty to these equipment searches upon entry Committee /NMSS into a protected area. When the licensee Ilecember 18, 1986 has cause te suspect that an individual i is attempting to mtroduce firearms. I
_ _ _ . _ _ _ . _ - _ .I
4
- W N__c__
QUESTION 14. If walk-through detection equipment alarms upon
~ the search of an individual, must -the individual be immediately " pat-down" searched or may the individual be more stringently searched by hand-held detection equipment to determine whether " pat-down" is necessary?
ANSWER.
If an alarm is received when an individual passes through a walk-through detector it is acceptable to conduct a search using hand-held equipment to assist in determining if a " pat-down" search is needed, s
Reference:
673.55(d)(1) - Access Requirements i Search Requirements (d) Access Requirements. (1) The licensee shall control all points of personnel and vehicle access into a protected area. Identification and search of allindividuals unless otherwise provided herein must be made and authonzation must be checked at these points. The search function for detection of firearms. explosives, and incendiary devices must be accomplished through the use of both firearms and explosive detection equipment capable of detecting those devices. The licensee must subject all persons except bona fide Federal State andlocallaw enforcement personnel on official duty to these equipment searches upon entry into a protected area. When the licensee has cause to suspect that an individual is attempting to introduce firearms, explosives, or incendiary devices into protected areas the hcensee shall conduct a physical pat down search of that individual. Whenever firearms or explosives detection equipment at a portalis out of service or not operating satisfactonly. the licensee shall conduct a physical pat down search of all C ommi t t ee / W S S persons who would otherwise have December 18* 1986 -
been subject to equipment searches.
M &J ~
What does a security plan commitment to detect MESTION 15.*
explosives at the entry point to the protected area mean?
ANSWER.
Such a commitment means that a licensee has procured and is maintaining explosives detection equipment as set forth in Review Guideline Number 20, Revision 1, dated April 18, 1978.
Reference:
973.55(d)(li - Access Requirements and Review Guideline Number 20. Rev. 1, dated April 18, 1978.
Search Requirements (d) Access ftequirements. (11 The licensee shall control all points of personnel and vehicle access into a protected area.1 identification and search of allindividuals unless otherwise provided herein must be made and authonzation must be checked at these points. The search function for detection of firearms. explosives, and facendiary devir.es must be accomplished through the use of both firearms and explostvc detection equipment capable of detectmg those devices.The licensee trust subject all persons except bona fide Federal. State. and locallow enforcement personnel on official duty to these equipment searchee upon entry into a protected area. When the licenses has cause to suspect that an individual ;
is attempung to mtroduce firearms.
explosives, or meendiary devices into
]
i protected areas. the licensee shal!
conduct a physu:al pat down search of {
l i that mdividual. Whenever firearms or explosives detection equipment at a portalis out of service or not operatmg satisf actonly. the licensee shall conduct a physical pat down search of all persons who would otherwise have been subject to equipment searches. 1 January la, 1987 l
. _ _ - . _ - - - . - - - - - - - - - - - - - - - - ----- - ~ ~ ~ ' ~ ~ ~~ ~ ~
t t y.
-j
- ,p" "\g; umrSo stAtas
- .g .gpf j,7, I ,
NUCLEAR AEGULATORY COMMisslCN wasMNGTON. c. C. 20515
! AFR 1 B E MEMORANDUM FOR: Reactor Safeguards Licensing Branch
.FROM: R. . A. Clark, Chief Reactor Safeguards Licensing Branch SUSJECT: SEARCHING FOR EXPLOSIVES -
REVIEW GUIDELINE NUMBER 20, REVISION 1 '
Backercund Faragracn (d)(1) of 10 CFR 73.55 states that "the search for detection of firearms, exclosives, and incendiary devices shall be conducted eit.er by ;nysical search or by use cf equic ent cacable of detecting suen cevices."
The acendment to 73.55(d)(1) published in tt.e September 30, 1977
- Feceral Recister provices interim relief frcm having to pat-down searca regular. plant amolayees entering nuclear power plants provided that ecuf; mar.t designed for detection of weapcns and explcsive catarial Aiscocy utilized to ;erfer=
of the Septem:er :he saaren function on regular piant employees.
30, 1977 Federal Reoister notice was trans-mitted as an enclosure to a letter from Ecson G. Case to all licensees (11/13/77). Also included was an enclosure "#RR Supplemental Staff Fosition on Fersonnel Search Requirements", which further clarified the staff pcsition on personnel searches. This position paper recognized that'not all licensees possessed the'necessary. equipment to conduct' the' searches on regular employees and therefore provided an alternative (random search procedures)*to the use of such equip-ment. It was never intended however, that these random search procedures be substituted indefinitely for the weepens and explosives detectir.g equipment. In fact, the staff position paper made it explicitly clear that acceptable metal detectors and explosive
- searching devices of the types currently available are deemed I, capable of detecting firearms, explosives and incendiary devices for regular employees of the licensee at the site and that such I equipment, if not currently in operation, must be ourchased and made operational as soon as possible if the licensee is to be in compliance with the performance requirement of 10 CFR 73.55. *
~em j joW D g
1 f- I i;
l l
- 1
,. i s
i '
I 1
Reacter Safeguards Licensing Branch h,;. ,
The staff is not presently aware of any additional infonnation or d, factors that will resul: in a change to the position that use of f explosive and metal detecting ecuipment will satisfy the '!h !
search requirement (cr regular plant empicyees. jl!
It is rec:gnized that currently available ex:losive detec-icn
- evices (1) are nc ca:atle of detectine all ty:es of available
~
ex;1osives and (E) generally c: era e on pFinciples (vacer ce:ec:icn) I j
tha allow f0F straigntf P arc avcicance technicues by kn:wIeegeable -i incivicuais. ;'-,
per#:r .ance Aecairenents
.L An ex:losives detector, or syste= of c:r:ctents and/or procedures, ; !
dested a::re:ria:a f:r :he :stecti:n of ex;1:sives snall ee: or
'ih "ll' excesc tre felic ing ;er#:rman:a c.. arac eris-ics:
- l. Detection of generally available types of high explosives ih (i.e., ce na:able c:mcositions) of U. 5. or foreign j' .li manufacture inclucing tu: not limited to comoeunds con-aining: Ni r:gi :f erin, TNT (e.g., 40:; dynami e). l'~ lI' l-gl'
. l'
- 2. The device or system provides high a' iurance of detecticn l
',C
(;rceability of cetec icn of a- least /.55) of hign '
p i
explosives (HE).
'j qj t
- 3. The minimum quanti:y of HE for which the required probability h', .si mi mus be demonstrated must te no greater than 0.5 kg. The -
i minimum ovantity of HE must be detected with required
- pr0bability when c ncealed en a pers:n or in hand carried ,,
garments or packages, j
^
CURRENTLY AVAILa2LE EXPLCSIVE CETECTCR" p.
Model Manufacture / Dis tributer a i o ,
i EXD-2 Elscint Inc. .
138-160 Johnson Avenue
!')l i
i P. O. Box 832 .
l
- Hackensack, New Jersey 07502 '
? ;
Medel.70 Ian Track Instruments, Inc. l Three "A" Street l Burlington, Massachusetts 01803 !
n 1
I
a d
l.
1 1 Reacter Safeguards Licensing Branch Medel Ma nu fa c tu re/Di s tri but:r.
5-201 Leigh-Marsland Engineering. Ltd.
5-201 35C Weber Street, North Waterloo, Ontarie, Canada NZJaE3 Centact: Security Freducts Marketing Cffice Fye Dynamics X-Ray Industrial Distributors. Inc.
Representatives fer Fye Dynamics 32E Oelawanna Avenue Clif ten. New Jersey 07014
'These cels have been tested by other agencias for de-tec-icn of HE en ;erscnnel. Accitional information may te found in Chacter 6 cf Sandia " Entry Control Systems I
hancbook" SAND 77-1023.
These mecels and others are acceotable if they meet or exceec the accve :erf:rmance Requirements.
Review Guideline Num er 20, dated April 10, 1978, is superseded by his revision.
A5uC'
'c{3:&4'/
Rec . . A. Clark, Chi React:* Safeguards Licensing 3 ranch Division of Operating Reactors
- l 1
- 1 1
i
L- CLB OVESTION 15_. What-does a security plan commitment to detect explosives at the entry point to the protActed a'rea mean?
ANSWE_R.
Such a commitment means that a licensee has procured and is maintaining commercially available " state of the art" walk-throuch explosives detection equipment.
Reference:
673.55(dl(1) - Access Requirements Search Requirements (d) Access Requirements. (1) The licensee shall control all points of <
personnel and vehicle acce6s into a protected area. identification and search i
of allindividuals unless otherwise provided herein must be made and authorization must be checked at these points.The search function for detection of firearms. explosives andincendiary devices must be accomplished through the use of both firearms and explosive detection equipment capable of detectmg those devices. The licensee must subject all persons except bona fide Federal. State, and locallaw enforcement personnel on official duty to these equipment searches upon entry into a protected area. When the licensee has cause to suspect that an individual is attempting to introduce firearms, explosives, or incendiary devices into protected areas, the licensee shall conduct a physical pa'.-down search of that mdividual. Whenever firearms or explosives detection equipment at a portalis out of service or not operating satisfactonly, the licensee shall conduct a physical pat-down search of all persons who would otherwise have been subject to equipment searches. '
Committee /NMSS December 18, 1986
_ _ - - _ _ - - - - _ _ _ _ _ _ _ _ _ _ - - . - - - - _ _ _ )
- TQ.U
- OVESTION 16.* Is the central alarm station (CASI required to be protected as vital?
ANSWER.
I No. The requirement to consider the central alarm station (CAS) a vital area was inadvertently deleted under the Miscellaneous l Amendments. The staff is at present considering the desirability of pursuing a generic backfit to require the CAS to again be considered vital.
Peference: 73.55(e)(1) - Detection Aids Miscellaneous Amend.
(e) Detection aids. (1) All alarms The Commission has considered the required pursuant to this part must public comment on the vitalisland annunciate in a continuously manned concept and " independent" vital islands central alarm (tation located within the (which in general indicated opposition protected area and in at least one other or confusion) and is cognizant of the continuously manned station not evolving nature of the NRC's vital area necessarily onsite so that a single act designation policy.The Commission cannot remove the capability of calling further notes that present regulations, for assistance or otherwise responding 1.e 10 CFR 73.55, do not preclude the to an alarm.The onsite central alarm consolidation of one or more vital areas station must be located within a into a single vital area if approved by building in such a manner that the the NRC. Based upon these three factors, the Commission beheves the interior of the central alarm station is most appropriate course of action is to .
not visible from the perimeter of the ;
protected area.This station must not delete the vitalisland and " independent contam any operational activities that vitalisland portions from the rule on an would interfere with the execution of the interim basis pending finalization of alarm response function.The wa!!s. policy in this area.
doors. floor, ceiling, and any windows in the walls and in the doors of the central a; arm station shall be bullet resistmg.
Committee /NMSS ila nu a ry 14, 1987
OLD ;
\ . , -
' Is the central alarm station (CAS) no !- ;u OVESTIO Q . ~
required to be protected as vital?
l
)
l ANSWER. i l
l i
While the CAS is no longer specifically designated as vital equipment by NRC requirements, it is the NRC's policy that it remain in a vital area.
Referencei 73.'55('e)(1) - Detection Aids Miscellaneous Amend.
(e) Detection aids. (1) All elarms no Commission has considered the required pursuant to this part must public comment on the vitalisland annunciate in a continuously manned concept and *"_" ;"-st" vitalislands central alarm station located within the (which in general indicated opposition protected area and in at least one other or confusion) and is cognisant of the contmuously manned station not evolving nature of the NRC's vital area necessanly onsite. so that a si e act designation policy.The Commission cannot remove the capability o calling further notes that present regulations. for assistance or otherwise responding i.e 10 CFR 73.53 do not preclude the to an alarm. The onsite central alarm consolidation of one or more vital areas station must be located within a ,
into a single vital area if approved by buildmg in such a mar.ner that the I the NRC. Based upon these three ir: tenor of the central slarm station is factors, the Commission believes the not visible from the penmeter of the most appropnate course of action is to protected ares. nis station must not delete the vital island and " independent contam any operational activities that vitalialand portions from the rule on an would interfere with the execution of the interta basis pending finalization of alarm response function. The walls.
policy in this area.- doors, floor. cetimg. and any wmdows in the walls and in the doors of the central alarm station shall be bullet.resistmg.
l l
Committee /NPSS 4 January 14, 1987
T!CN
~
QUESTION 17.*
Does an on site secondary power supply system for a privately owned telephone system have to be located within a vital area?
ANSPER.
No. Therevisedregulationrequiresthesecondarypowersupply x
systems 'for alarm annunciator equipment and non-portable communications equipment as required in paragraph (f) of 10 CFR 73.55 to be lo'ca ed within vital areas. The provisions of 973.55(f) require',x,in part, the capability of conventional telephone service g d_xcontinuous communication, radio, or microwave transmitted tw'o-way voice communications between the facility and off-site local{aw enforcement authorities. Power for conventional teleptione serv' ice is provided from off-site by ;
the public telephone utility. The ' term "non-portable" refers g i
strictly to the other means of require'dxoff-site communications '
j
'x (i.e., radio or microwave) because in contrast to radio systems,
~
l conventional telephone systems are typically not " portable" l
l vefs'us "non-portable".
Reference:
673.55(e)(1) - Detection Aids, and 573.55(f) - Communications.
iiiscellanoeus k end.
interior of the central alarm station is mt visible from the penmeter of the (e) Detection aids. (1) All alarms required pursuant to this part must protected area.This station must not annunciate in a continuously manned contain any operational activities that central alarm station located within the would interfere with the execution of the protected area and in at least one other alarm response function.The walls.
continuously manned station not doors, floor. ceiling, and any windows in I necessenly onsite, to that a single act the walls and m the doors of the central cannot remove the capability of calling alarm station shall be bullet resistmg.
for aeststance or otherwise responding On site secondary power supply Committee /NM$b ,
to an alarm.The onsite central alarm systems for alarm annunciator tanuary I4, }gg7 station must be ;ocated within a t l
building in such a manner that the equipment and non portablecommumcations equipment a in paragraph (f) of this section must be j located within vital areas.
t- . 1
. 1
. OLD J L. Does an on site secondary power supply system OVESTION_H. ,
i for a privately owned telephone system have to be _.
l i
located within a vital area?
ANSWER.
No. Only the secondary power supply systems for non-portable radio communications equipment and alarm annunciators equipment have to be loc:ted in vital areas.
Reference:
673.55(e)(1) - Detection Aids Miscellanc:us k end.
inteiior of the central alarm station is (e) Detection aids. (1) All alarms not visible from the perimeter of the required pursuant to this part must protected area. This station must not annunciate in a continuously manned contain any operational activities that central alarm station located within the would interfere with the execution of the protected area and in at least one other alarm response function. The walls.
continuously manned station not doors, floor, ceiling, and any windows in necessarily onsite, so that a single act cannot remove the capability of calling the walls and in the doors of the central for assistance or otherwise responding alarm station shall be bullet resisting.
On site secondary power supply to an alarm.The onsite central alarm systems for alarm annunciator station must be located within a equipment and non portable building in such a manner that the communications equipment as required in paragraph (f) of this section must be located within vital areas.
1 Committee /NMSS December 18, 1986 i
r.: lek 4 OVESTION 18.* Does the requirement to locate "on-site secondary power supply systems for alarm annunciator equipment and non-portable communications eouipment" within vital areas mean that: (a) the alarm annunciator equipment and the on-site secondary power supply system for non-portable communications equipment should be located within a vital area or (b) the on site secondary power supply systems associated I with alarm annunciator equipment and non-portable communications equipment should be located within a vital area?
i ANSWER.
This requirement means that the on-site secondary power supply i systems for both the alarm annunciator and non-portable communications equipment must be located within a vital area.
l
Reference:
673.55(e)(1) - Detection aids Miscellaneous Amend (e)Dessenen sids. (1) All elares interior of the central alarm station is required pursuant to this part must not visible from the penmeter of the annunciate in a costlaucusly manned protected area. This station must not central alarm staties located within the contain any operational activities that protected area and la at least one other would interfere with the execution of the continuously manned station not alarm response function.The walls, necessarily onante, so that a single act doors. floor. ceiling. and any windows in cannot remove the capability of calling the walls and in the doors of the central for assistance or otherwise responding alarm station shall be bullet resisting. .
to an alarm.The onsite central alarm On site secondary power supply station must be located within a systems for alarm annunciator a-building in such a manner that the equipment and non portable 3.
communications equipment as requred in paragraph (f) of this section must be . $
located withm vital areas. Committee /NMSS l January 14, 1o87 l i
u_____.__.__ _ _
~
OLD
- DUESTION 18. Does the equirement to locate "on-site i secondary power supply systems for alarm annunciator equipment and non-portable communications equipment" within vital areas mean that the on-site secondary power supply systems for non-portable communication equipment or the alarm annunciator and non-portable communications equipment itself must be located within vital areas?
ANSWER.
This requirement means that the on-site secondary power supply systems for both the alarm annunciator and non-portable radio communications equipment must be located within a vital area.
Reference:
673.55(e)(1) - Detection aids Miscellaneous Amend interior of the central alarm station is (e) Detection aids. (1) All alarms not visible from the perimeter of the required pursuant to this part must annunciate in a continuously manned protected area. This station must not contain any operational activities that !
central alarm station located within the protected area and in at least one other would interfere with the execution of the continuously manned station not alarm response function. The walls, necessarily onsite, so that a single act doors, floor, ceiling. and any windows in the walls and in the doors of the central i cannot remove the capability of callini!
for assistance or otherwise responding alarm station shall be bullet resisting. l to an alarm.The onsite central alarm On site secondary power supply l
station must be located within a systems for alarm annunciator building in such a manner that the equipment and non portable communications equipment as required in paragraph (f) of this section must be ,
located within vital areas. !
l l
I Committee /NMSS December 18, 1986
i f -
jN E k' O U E S T I O_ N_19, .
- Does the secondary alarm stations (SAS)
F secondary power supply systems for alarm annunciator equipment and non-portable communications equipment have to be pro-tected-as. vital eouipment?
ANSWER. ,
No.
Committee /NMSS
.lanuary 14, 1987 ;
---m-----__---_..__m__-_.._m __
OLD
]
l q
QUESTION 19.
Does the secondary alarm stations (SAS)
^
secondary power supply systems for alarm annunciator equipment and non-portable communications equipment have to be pro-tected as vital equipment?
A_N S W E R .
No. Only the secondary power supply systems for the primary systems have to be protected.
Reference:
673.55(e)(1) - Detection Aids On site secondary power supply systems for alarm annunciator equipment and non portable communications equipment as required in paragraph (f) of this section must be located within vttal areas, i
Committee /NMSS ;
December 18, 1986 l i
w_-__-__--.-- - - - _ _ _ _ _ . - - _ - - -
+
NE W 00ESTION 20.* What components of the secondary power supply systems for the alarm annunciator and non-portable communications eouipment have to be protected as vital equipment?
_ ANSWER.
The objective of secondary power supply systems (SPSS) is to provide auxiliary power during power interruptions or outages. The duration of such interruptions or outages should be determined on a site-specific basis under station blackout criteria. It is necessary 1 to protect all components of a SPSS needed to provide this site-specific period of stand-by power. Such components may include, but are not necessarily limited to, the following:
- a. Batteries
- b. Battery chargers
- c. Inverters
- d. AC alternators
- e. DC generators
- f. Emergency buses
- g. Control panels
- h. Switch gear
[ 1. Identifiable Cabling
- j. Main Fuel tanks or day tanks and associated plumbing / piping
Reference:
!73.55(e)(1) - Detecticn Aids and Regulatory Guide 5.65, Section 7 (Protection of Security Equipment)
Committee /NMSS January 14, 1987
o v.
1 Miscellaneous Amend.
(e) Detection aids. (1) All alarms interior of the central alarm station is required pursuant to this part must not visible from the penmeter of the annunciate in a continuously manned protected area.This station must not central alarm station located within the contain any operational activities that protected area and in at least one other would interfere with the execution of the continuously manned station not alarm response function. The walls, necessarily onsite, so that a single act doors. floor, ceiling. and any windows in cannot remove the capability of calling the walls and in the doors of the central for assistance or otherwise responding alarm station shall be bullet resisting, to an alarm.The onsite central alarm On site secondary power supply station must be located within a systems for alarm annunciator building in such a manner that the equipment and non portable !
communications equipment as required in paragraph (f) of this section must be located within vital areas.
R.G. 5.65 .
- 7. PROTICTION OF SECURfrY EQUrtssprr ,
Paragraph 73.55(s)(1) roquares, in part, that onsite i j
secondary power supply systems for alarra aamunciation '
equipment and nonportable communication equipment be located in vital areas. Protection of these stems of squapment is necessary to reduce ruinerabLlities an the systein bouuse their sabotage could ugruf'acastly impact the safeguards of a plant. Therefore, licensees are roquared to locate these pieces of equipment in vital areas, l
OLD
[. - , -. .
OUESTION 20.
What components of the secondary power supply systems for the alarm annunciator and non-portable communications eouipment have to be protected as vital equipment? l
_A_N_S_WE_R.
l The ob.iective of secondary power supply systems (SPSS) is to provide auxiliary power during power interruptions or outages for periods of .
t up to eight hours in duration. In view of the objective, it is necessary l to protect all components of a SPSS needed to provide this period of stand-by power. Such components may include, but are not necessarily i limited to, the following:
- a. Batteries
- b. Battery chargers i
- c. Inverters
- d. AC alternators ,
- e. DC generators J
- f. Emergency buses
- g. Control panels
- h. Switch gear
- 1. Identifiable Cabling
- j. Main Fuel tanks or day tanks and associated plumbing / piping
Reference:
673.55(e)(1) - Detection Aids and Regulatory Guide 5.65, Section 7 (Protection of Security Equipment) l Committee /NMSS ,
December 18, 1986 1
)
Miscellaneous Amend. .
1' l (e) Detection oids. (1) All elarms interior of the central alarm station is not visible from the penmeter of the 5 I required pursuant to this part must annunciate in a continuously manned protected area. This stahon must not central alarm stanon located withm the contam any operational activities that protected area and in at least one other would interfere with the execution of the continuously manned station not alarm response function. The walls.
necessenly onsite, so that a smgle act doors, floor. ceiling, and any wmdows in i cannot remove the capability of calling the walls and in the doors of the central )
for assistance or otherwise respo-dmg alarm stauon shall be bullet resistmg.
i to an alarm.The onsite central alarm On site secondary power supply station must be located withm a systems for alarm annunciator 3 building in such a manoer that the equipment and non portable !
commumcations equipment as required in paragraph (f) of this section must be R.G. 5.65 '****d*'""I."
- 7. FROTECDON OF SECURATY EQUIMENT Paragraph 73.j$(eXI) requuss, in part, that onante secondary power supply systeras for alarm annunciauon equipment and nonportable commurucauon equapment be located in vital areas. Protecuan of these items of equapment a necessary to reduce vulnerabilities in the system because their sabotage could sagn(scantly tmpact the safeguards of a plant. Therefore, licensees are required to locate these pieces of equipment in vital 4,.as.
I 1
I
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ - - - - - - - - - --- - - - - - - - - - -- - - - - ' ~~
i 1
4 NEW l
' I OUESTION 21.* Can the secondary powe supply syste s for alarm annunciator equipment an ron-porta le communications equipment onsist f O
"interruptible power sy stom 5)" or do they have to be " uni terr t /e power systems (UPS)"?
L 1
-ANSWER. .
j 1
The secondary ower supp y sy ms may consist of either an IPS or UPS. Howeve an S referrable.
R i
Reference:
973 .5 ,
- 1) - Detection Aids and Regulatory Guide 5.6 Section 7 - Protection of Security Equipment i 1
R.G. 5.65 Misce 11aneous Amend.
- 7. FROTECTION OF SECURfTY EQUrtiEPfT
- On site secondary power supply Paragraph 73.35(eXI) requuss. in part, that onsite systems for alarm annunciator ,
secondary power supply systems for alarm annunciation equipment and non portable equipment and nonportable commusucation eqmpment communications equipment as required in paragraph (0 of this section must be be located in vital areas. Protect 2on of these stems of locsted within vital areas.
equipment is necessary to reduce vulnerabilities in the system because thest sabotage could sign 6ficantly unpact the safeguards of a plant. Therefore. Licensees are required to locate these psoces of equipment m vital areas.
febf f f/ h Y
l l Committee /NMSS ila nu a ry 14, 1987 E____________________ J
e .. .
.- OLD 1;
QUESTION 21.. Can the se_condary power supply systems for alarm
~
annunciator equipment and non-portable communications equipment consist of "interruptible power systems (IPS)" or do they have to be "uninterruptible power systems (UPS)"?
ANSWER.
Generally, the use of UPS is the preferable method.for providing
. emergency power. However, IPS may also be a suitable means for providing emergency power if systems can withstand momentary failures of electric power input without significant detriment to the systems.
Protection devices like' alarm annunciators are usually rendered ineffective or are immediately reduced in effectiveness if there is'any interruption of their input power. Therefore, the Regulatory Position is that UPS should be used to protect the annunciators load from fluctuations or interruptions of the incoming power. On the other hand, momentary interruption of power to non-portable communications equipment may be acceptable provided that secondary power is available within one minute.
Reference:
673.55(e)(1) - Detection Aids and Regulatory Guide R.G. 5.65 5.65, Section 7 - Protection of Security Equipment
. Miscellaneous Amend. j
- 7. FROTICT10N OF SICURFtY EQUIPMENT On site secondary power supply Paragraph 73.55(e)(1) requires, in ;,.st. that onsite systems for alarm annunciator equipment and non portable 1 secondary power supphr systema for alem annunciation communications equipment as required Committee /NMSS j squipmeet and nonportable communication equipment in paragraph (f) of this section must be December 18, 1986 be located in vital areas. Protection of these items of located within vital areas.
equipment is necessary to reduce vulnerabilities in the q
, . system because their sabotage could sigsuficanuy impact >
lthe safeguards of a plant. Therefore. Licensees are j required to locate these pieces of equipment in vital L= _ - ___ __ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ ._ _ . ___
g
/ ~/T'65 y E Nctesunt s k W minuhs . cf CW R r/i<e % " fog 3 N """^7f
. (Gib b CCG% d % rheeN$ by tar. Scch de) i BRIEFING FOR THE CRGR ON NRC'S PAPERWORK REDUCTION EFFORTS: NARRATIVE JANUARY 15, 1987 We are pleased to have the' opportunity to brief the CRGR on the NRC's efforts to reduce paperwork burdens on reactor licensees. (Vugraph 1 provides overview of major points of briefing).
To accomplish its missions (Vugraph 2 outlines NRC's missions), NRC requires licensees to keep records and submit reports. This reporting and recordkeeping contributes to what is commonly perceived as " government paperwork burden," which in 1980 became the focus of the Paperwork Reduction Act. The Act transferred from the General Accounting Office to the Office of Management and Budget (OMB) the responsibility for reviewing and approving the application, reporting, recordkeeping and other information requirements imposed on the public by independent regulatory agencies, including NRC. The Act further requires that any information collection requirement approved by OMB display an OMB Clearance Number. OMB's review goals are consistent with the objectives of the Paperwork Reduction Act and'are as shown in Vugraph 3.
OMB approvals expire in three years or less and must be renewed if the need for the information continues. For example, information collections ,
specifically contained in Part 50 must be re-approved by 0MB every 3 years.
I NRC's most recent request for renewal was forwarded to OMB earlier this year.
i 1
i
3' Under the Paperwork Reduction Act of 1980, OMB was directed to set a two-year goal of reducing Federal paperwork burden by 25%. As a tool to get control of the Federal information collection burden, OMB created the Information Collection Budget (ICB) process, establishing a ceiling for each Agency within which to manage its information collections. After NRC's first ICB, we received special attention when Vice President Bush's Task Force on Regulatory Reform identified the information collection requirements imposed on reactor licensees as among the ten most burdensome in government. At that time
. (1981), NRC's paperwork burden was estimated at approximately 13 million hours.
When we last briefed the CRGR in January 1982 on the efforts of the NRC, including the CRGR, to control paperwork burdens imposed on industry, NRC's annual burden was estimated at 10.5 million hours. Since that time, the burden estimate has been significantly reduced. For FY'87, OMB has approved an NRC burden estimate of 5.7 million hours. NRC is no longer listed as one of the top ten " paperwork" agencies. (Vugraph 4 shows the reduction in NRC's Information Collection Budget.) ,
Since 1982, NRC has supplemented the routine Federal regulation approval process with additional management controls and mechanisms, such as (1)
Regulatory Analysis Guidelines (2) the CRGR Review Process (3) the Control of Rulemaking Process (4) the Paperwork Assessment and Approval Process, and (5) the Backfit Analysis Requirements, that have resulted in closer scrutiny of
v <:
I proposed regulatory requirements. (Vugraph 5 shows that the NRC's review and evaluation processes may affect a proposed information collection in several ways.)
During our 1982 briefing to the CRGR, we identified several industry areas of concern. (Vugraph6). These cuncerns were expressed in NUREG-0839 "A Survey by Senior NRC Management to Obtain Viewpoints on the Safety Impact of Regulatory Activities" and from views expressed to OMB and NRC by organizations such as the Atomic Industrial Forum, the Nuclear Information and Records Management Association, and the Nuclear Utility Backfit and Reform Group. In a'dition d to added control mechanisms., several other NRC initiatives have addressed these concerns during the past 5 years. (Vugraph7).
The most recent request to OMB for approval of the application, reporting and recordkeeping requirements contained in Part 50 reflects the cumulative results of these efforts to control and improve our information collection activities; however, there are other reasons for the difference between the 1982 and 1987 estimates. (Yugraph 8 provides an overview of the major reasons for change in the estimates).
(Vugraphs 9 and 9A provide "then and now" snapshots of the estimated burden being imposed on reactor licensees.) In 1982, the reactor licensee burden was 93". of NRC's total burden. In 1987, their share is down to 89%. (Vugraphs 10 and 10A break the burden into reporting, recordkeeping and application ,
requirements.)
The difference is largely attributable to changes in plant status (construction / operation). As plants move out of construction, the burden associated with QA records diminishes, while, as more plants become operational, the reporting burden increases and the need for operations and maintenance records begins. This suggests where any future efforts to improve information management should be directed. The focus needs to be on identifying the operational data that is essential to accomplishing the NRC mission and improving its availability, while eliminating requirements for information that is unnecessary and reducing the cost of necessary reporting /recordkeeping, i.e., managing it more efficiently.
Effective January 1,1987 amendments to the Paperwork Reduction Act require OMB to reduce Federal paperwork by 5% each year. In response to an OMB 1 request for an Agency plan to reduce paperwork toward the 5% goal, the E00 has described several on-going efforts to make information management more efficient and eliminate any unnecessary recordkeeping or reporting requirements. (Vugraph 11 identifies NRC activities that focus on improving information management). These initiatives should create positive results.
OMB has historically been very supportive of NRC's efforts to control paperwork. Most recently, the Director of OMB, Mr. James Miller, commended Chairman Zech for the success NRC has achieved. Your support has been a major factor in making the process work, without which the successes would not have been possible.
Thank'you for this opportunity to brief the CRGR on the paperwork program, i
.- Vugraph 1 OVERVIEW
-o. ACC0FPLISHING NRC'S MISSION NECESSITATES REPORTING AND RECORDKEEPING BURDENS o FEDERAL PA RWORK BECAME 111E FOCUS OF THE PAPERWORK REDUCTION ACT OF 1980 o IN 1981, NRC CITED AS ONE OF TOP 10 PAPERWDRK AGENCIES - 13 MILLION HOURS
- AND CONCERNS WERE EXPRESSED BY NUCLEAR INDUSTRY o NRC HAS ESTABLISHED CONTROL PROCESSES AND KCHANISMS, INCLUDING DEDROGR AND CRGR, TO ASSURE THAT REQUIREMENTS ARE ESSBfflAL TO NRC MISSION AND IMPOSED SO AS TO MINIMIZE BURDEN
- o. NRC CONTROLS AND OTHER EFFORTS TO BETTER MANAGE AND DEFINE PARRWORK BURDEN HAVE RESULTED IN REDUCTION -- 1987 ESTIMATE IS LESS THAN 6 MILLION HOURS o NRC PLANS FOR REDUCING PAPERWORK INCLUDE EMPHASIS ON MANAGEMENT CONTROL &
SPECIFIC INITIATIVES 4
r- ,
. Vugraph 2-REPORTING & RECORDKEEPING NEEDED TO ACCOMPLISH NRC MISSION TO ACC0rPLISH MISSIONS:
o PROTECTING PUBLIC HEALE AND SAFE W o PROTECTING THE Bh/IRONENT
.o SAFEGUARDING NUCLEAR MATERIALS -
o- ' ASSURING COMPLIANCE WITH ANTITRUST LAWS NRC IMPOSES f0RE THAN 500 DIFFERENT APPLICATION, EPORTING AND ECORDKEEPING
- EQUIREENTS.
e e
e L.----__._____ ______.__.__m.____________-_____.-_-___.-...-._______-_______________.____-_m. . _ _ _ _ _ - - _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . . _ _ . -._._____________________.______m-_ ______ . .- _ ___. ___ -_-
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!. . Vugraph 3 OBJECTIVES l
TO ELIMINATE UNNECESSARY PAPERWORK BURDEN TOELIMIPTEDUPLICATIVEREPORTING&RECORDKEEPING REQUIR9ENTS C0bbkhlbffRfITkffEb
~
TO ASSURE THAT THE REQUIREMENT HAS PRACTICAL UTILITY.
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l^ - WAYS NRC REVIEW AND EVALUATION PROCESS MAY L- AFFECT A PROPOSED INFORMATION COLLECTION 1
3 l.
o DETERMINE THERE IS NO NEED o IDENTIFY LESS BURDENS 0fE WAY TO COLLECT INFORMATION o BETTER DEFINE INFORMATION COLLECTION REQUIREMENT o DETERMINE THAT A POLICY STATEENT IS APPROPRIATE o- I WROVE BURDEN ESTIMATE S
a m___ ..____._______mu-____._..a__.___~_.__m_,__________._m_._.__m. ..__ _.__._.._________ _ __- - . m_. -m.____ _._.._ _ . _ . . _ .s,-_._ --.__.___. ___ .__ ____-._ ..____ ___.- . _ __ . -..__._._.
- .j Vugraph';6
'1982 INDUSTRY AREAS OF CONCERN b ',
l o- REPORTING THRESH 0LDS
'o REPORTING FREQUENCY
- s o PYRAMIDING RRIODICITY o COLLECTION TECHANISMS o SUBJECTIVE OR OPEN-ENDED REQUIREPBiTS j
i
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_ _ _ _ - - _ _ _ - - - - - - - - _ - _ - _ - - - - . - - _ _ - - - l
' ' ' Vugraph 7 j I
NRC INITIATIVES THAT IMPROVED INF0PPATION COLLECTION ACTIVITIES ,
1 l
)
1 <
o C0fER0L E CHANISMS HAVE IMPROVED OR AVOIDED PROPOSED INFORF% TION COLLECTION l
1 1
o POLICY GUIDANCE HAS ALLOWED LICENSEES FLEXIBILITY IN EETING PEGULATORY. -
REQUIRBB!TS o RULB% KING REDUCED COPY REQUIREMENTS FOR 10 CFR 50 LICENSEES .
o RULB% KING MADE LICENSEE EVENT REPORTING MORE EFFICIENT o RESOLUTION OF NUCLEAR UTILITY BACKFIT AND REFORM GROUP PETITION IDENTIFIED IMPROVB'ENTS o REVISION OF REG GD.I.28 "QA PROGRAM REQUIRENNTS (DESIGN AND CONSTRUCTION)" MORE CLEARLY DEFINED NECESSARY RECOPDS m
s - _-.___--________m____ _ _ _
l' Vugraph 8
. BASES FOR CHANGES IN BURDEN ESTIMAES l
o REVISED ESTIMATE-0F NUMBER OF PLANTS AFFECTED BY INFORMATION COLLECTION REQUIREMENTS o NEW INFORMATION COLLECTION REQUIREMENTS ISSUEJ o INFORMATION COLLECTION REQUIREMENTS ELIMINATED OR CHANGED o- ADJUSTENTS TO ESTIMATES BASED ON EXPERIENCE,0R POLICY DECISIONS 1
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Vugraph 11 g COMPONENTS OF NRC PLAN TO CONTROL PA RWORK BURDENS y o 0FFICE OF INFORMATION RESOURCES MANAGEENT o TECHNICAL SPECIFICATION IMPROVEE NT POLICY
-o ESTABLISH POLICY AND STANDARD FOR ELECTRONIC SUBMITTAL OF INFORMATION o EVALUATION OF "REQUIRDOTT GUIDELINES FOR PLANT MAINTENANCE AND OPERATIONS" PROPOSED BY NUCLEAR CONSTRUCTION ISSUED GROUP ,
f o REVALIDATE THE NEED FOR DATA CURRENTLY BEING COLLECTED BY NRC AUTOMATED 1
INFORMATION SYSTD1S o CONTINUE TO ALLOW LICENSEES FLEXIBILITY IN COLLECTING ~INFORMATION BY I
PROVIDING POLICY IN LIEU OF REGULATORY REQUIRD E1TS o CONTINUE TO SHARE INFORMATION WITH ORGANIZATIONS SUCH AS INPO, IN LIEU OF DUPLICATING THE COLLECTION OF DATA o CONTINUE TO PARTICIPATE IN WORKING GROUPS ON QUALITY ASSURANCE STANDARDS FOR 0 RATIONS PRESENTLY INCLUDED IN REG, GD,1.33 i o CONTINUE REVIB4 AND EVALUATION OF PROPOSED NEW INFORMATION COLLECTIONS, i o CONTINUE COMPREHENSIVE RECORDKEEPING RULEMAKING q o CONTINUE RULEMAKING TO IMPROVE REPORTING UNDER PART 21 AND 50.55(E) o CONTIN!)E TO IDENTIFY NEW PLANS FOR IMPROVEMENT i
Enclosure 4 to the Minutes of CRGR Meeting No. 105 Review of Draft Standard Review Plan (SRP) 6.5.2
" Containment spray as a Fission Product Cleanup System" T. Speis (NRR) and L. Soffer (NRR) presented for review by CRGR the subject proposed SRP revision which is intended to relax requirements in the existing SRP (specifically, to delete requirements for spray additive during injection and for automatic addition, and to relax sump pH control requirements) for those licensees wishing to take advantage of such proposed relaxations. No new requirements will be imposed by the proposed revision; licensee participation will be a voluntary matter. Copies of the slides used by NRR in presenting the draft SRP revision at this meeting are attached; see Attachment 1 to this Enclosure.
The package provided to CRGR for their review in this matter was transmitted by memorandum, dated December 5, 1986, H. R. Denton to J. H. Sniezek; that package included the following documents:
- 1. Proposed Revision 2 (undated 1 to SRP 6.5.2, " Containment Spray as a Fission Product Cleanup System";
- 2. " Regulator) hnalysis of the Automatic Actuation of Systems for Chemical Additions to Containment Spray and Sump Solutions"; and
- 3. " Technical Report (A-3788) dated August 12, 1986, by Brookhaven National Laboratory, " Fission Product Removal Effectiveness of Chemical Additives in PWR Containment Sprays."
Related review material also provided to the Committee (at Meeting No.105) in connection with their review of this matter was as follows:
- 1. Memorandum, dated December 30, 1986, D. Houston to ACRS Members and Con-sultants, " Followup On Comments On Severe Fuel Damage Research Meeting, October 21-24, 1986," and 7ttachment: 1
- a. Letter, dated December 15, 1986, J. P. Longworth, CEGB, to M.
D. Houston, ACRS, re: Sump Water pH Major points of discussion at this meeting regarding the proposed SRP revision !
were as follows: l
\
- 1. The Committee noted the addition of citations to recent Source Term re-sults in Section VI. " References" of the revised SRP, and also noted that the term "... iodine scrubbing..." had been generalized to "... fission product scrubbing..." throughout the proposed SPP revision. Further, the Committee noted that revised Section V., " Implementation" specified that CP applicants will be required to comply with the provisions of the new {
1 revision. They questioned, therefore, whether the staff did not intend I imposition of new requirements with issuance of the proposed SRP revision.
Specifically, the Committee nuestioned whether it was necessary to l
_ - - - _ _ _ _ _ _ _ _ __ __ . _ _ _ _ _ _ _ J
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generalize the term "... iodine scrubbing..." throughout the SRP, as pro-l posed, in order to accomplish the stated objective (i.e., relexation of requirements). The staff explained that the present SRP addresses fission products other than iodine (e.g., solid fission products), and the staff did not mean to imply by the wording generalization of concern that licen-sees would be expected to address a broader spectrum of fission products than are currently addressed in their licensing submittals. Specifically, the proposed changes are not intended to introduce the entire broader l range of severe accident considerations and implications that have been treated recently in the Source Term research; that will come later and will be more appropriately handled by rulemaking. The staff pointed out also that the present SRP does not provide explicit models for depletion of isotopes other than iodines that are addressed in current licensing submittals; that have beenbutadded it is possible to do so revision in the proposed now by(reference including some to the citations recent Source Term results where the recent results are supportive of other re-search results that have been available previously, but have simply not been made use of by the staff). In conclusion, the staff reiterated that SRP revision proposals present sone of the complex new Source Tern science in simplified licensing calculation format, and in a way that provides re-lief from requirements that are now known to be unnecessary (with poten-tial cost savings to licensees who want to avail themselves of this oppor-tunity), and in a way that does not impose significant new requirements on any licensee. The Committee accepted that explanation, but recommended that the staff review the wording of the proposed to assure that that ,
intent is made clearer.
- 2. The Committee questioned the lack of the corresponding Reg. Guide 1.3/1.4 changes in the package submitted for review, noting that those Reg. Guides are referenced explicitly in the proposed SRP revision. The staff ack- a nowledged the necessity of issuing revisions to those Reg. Guides before :
Rev. 2 of the SRP can be issued in final form for use by licensees, and !
stated their intent to do so. The Committee noted that any favorable :
recommendation by CRGP in this matter would be based on that assumption. [
In response to a related question, the staff stated that the proposed SRP revision will be submitted to the full public comment and peer review process that is followed for Reg. Guide revisions.
- 3. With respect to the comments submitted by Longworth (see Attachment 2 to this Enclosure), the general thrust of comments seems consistent with the staff's intent (i.e., that sump solution remain at least slightly basic to control possible iodine revolitilization), but does not seem to take into account the use of phosphate or biphosphate to buffer the sump solutions.
The staff comitted to contact the commenter to hetter understand these comments prior to issuing the proposed SRP in final form; it was agreed that this could be done in parallel with the public comment process, if necessary.
- 4. The Committee noted the deletion of all references to ventilation system requirements and questioned whether the potential impact of renoving all such requirements had been fully considered from the viewpoint of overall l
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containment performance. A specific area of concern was the possible adverse effects on control of hydrogen explosion hazard. Discussions on this point at this meeting were inconclusive, and the staff agreed to re-examine the proposed deletions on the basis of the Coninittee's questions in this area.
- 5. The Committee noted that the requirement in SPP Section.II.1.f that the containment sump be designed to promote mixing of ECCS and spray solutions-seemed to imply a high flow requirement that appeared to run counter to the staff's findings in the USI A-43 resolution context. The staff agreed to examine this question further in the process of preparing the package for issuance for comment.
- 6. The Committee questioned whether the specified pH for sump solutions had to be achieved at the onset of the spray recirc mode, as stated in Section 11.1 9 of the SW (because this appeared to penalize unnecessarily plants employing subatmospheric containments). It was agreed that this wording would be changed to read " ...hy the onset of the spray recirc node."
- 7. The Committee questioned the intent of the proposed revisions to Section II.2.c. of the SRP. For clarification purposes, the staff agreed to change this wording to read "... capability of the system to deliver spray additives (if any are needed) within the specified range of concentra-tions." (Also, see 8. below.)
- 8. The Committee noted that the "... limits listed in the acceptance criteria of subsection II above..." appeared to have been deleted in the proposed changes to the SRP. (See Sections III.1.a.(2) and II.1.e.) NRR agreed to fix.the wording of the subsections of the SRP) paragraph to clarify in question the intended meaning.(and related or re'erenced
- 9. The Committee questioned the requirement (in Section III.1.b.) for auto-matic spray initiation and switchover to recire, noting that in the TMI-2 accident one would not have wished for automatic recirc (because of potential dose to operators in the plant). The Committee also suggested that the staff consider removal of the last sentence of the SRP section in question. The staff agreed to reexamine the wording of this section of i the SRP in the process of finalizing the package for issuance for comment.
- 10. The Committee asked whether SRP Section III.3 on Technical Specifications had been reviewed for consistency with the thrust of the Tech Spec Improvement Project goals. The staf# agreed to check the package specif-ically in this respect prior to issuance for comment.
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- 11. The Committee had a number of questions concerning the four new pages of material that is inserted asSection III.4.c in the proposed SRP revision, as follows:
- a. Editorially, the format of the entire new insert looks inconsistent with the format of the original SPP. The staff should consider re-vising the new material accordingly.
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- b. The Committee questioned whether the staff has reviewed fully all of the computer codes specified (by reference) for use in new section III.4.c.2; they also questioned whether it was necessary to define so specifically the methods to be employed by licensees in their analy-ses in this area. The staff agreed to revise the wording of these inserts to indicate that the computer codes in question, as well as other equivalent methods, are acceptable for use as specified therein.
- 12. The Committee questioned how the final revised SRP will be promulgated to licensees. The staff stated that the new SRP will be distributed by service list as is the usual practice for such regulatory guidance. Also, it is the intent of the staff to promulgate as a package both the revised SRP and the corres onding revised Reg. Guides 1.3/1.4 (at least in draft form "For Comment" .
RECOMMENDATION TO EDO As a result of their review of the subject package, and on the further basis of discussions at this meeting, the Committee recommended to the ED0 that the proposed revision to the subject SRP be issued for public comment, subject to incorporation of comments and recommendations made by CRGP'at this meeting as noted in the preceding.
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OVERVIEW PROPOSED REVISION OF SRP 6,5,2 BACKGROUND:
o ONE OF THE SHORT-TERM CHANGES DISCUSSED IN SECY 86-76 PROPOSED CHANGES o REMOVES EMPHASIS ON IMMEDIATE INJECTION OF SPRAY ADDITIVES . . , . t, y dn e. - e 0 RETAINS POST-ACCIDENT SUMP PH CONTROL, BUT AT LOWER PH LEVEL o EXTENDS EVALUATION OF SPRAY TO OTHER FISSION PRODUCTS, IN ADDITION TO 10 DINE, OTHER ASPECTS i
j r o NjTDEPENDENTONPARTICULARSOURCETERMINSIDECONTAINMENT, CAN BE USED WITH TID-14844 OR POTENTIAL REVISION !
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4 o NO LICENSEE ACTION REQUIRED l l l i
SUMMARY
-- REPRESENTS RELAXATION WITH NO SIGNIFICANT DETRIMENT T0 SAFETY, BUT COST SAVINGS TO INDUSTPY ATTACHMENT 1 TO ENCLOSURE 4
SIANDARD REVIEW PLANS INVOKED BY DBA LOCA DOSE EVALUATION o 6.5.2 CONTAINMENT SPRAY AS A FISSION PRODUCT CLEANUP SYSTEM o 6.5.3 FISSION PRODUCT CONTROL SYSTEMS AND STRUCTURES o 6.5.4 ICE CONDENSER AS A FISSION PRODUCT CLEANUP SYSTEM l o 15.6.5A RADIOLOGICAL CONSEQUENCES OF A DBA-LOCA FROM CONTAIN-MENT LEAKAGE o 15.6.5B LEAKAGE FROM ENGINEERED SAFETY COMPONENTS OUTSIDE CONTAINMENT o 15.6.5D LEAKAGE FROM MAIN STEAM LINE ISOLATION VALVE LEAKAGE CONTROL SYSTEM (BWR) )
o A/9. c.s.5
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m SRP 6.5.2 - PRESENT VERSION o BASED ON TID-14844 4
o TIMING-RADI0ACTIVilY-IN CONTAINMENT AT T=0 o COMPOSITION - NOBLE' GASES AND IODINE ONLY I0 DINE IS PRIMARILY ELEMENTAL (12 )
cys. 5 7a i n eu SRP o SPRAY ADDITIVE STRONGLY ENCOURAGED, (M M bis A- ~&:leh IF PRESENT, REQUIRED T0 BE INJECTED AUTOMATICALLY o LOW IODINE REMOVAL CREDIT UNLESS SUMP PH AB0VE 8.5 o NO EXPLICIT MODELS FOR SPRAY REMOVfL COEFFICIENTS OR PLATE 0
.AND DEPOSITION (h) f
BASES FOR PROPOSED CHANGES o RE-EVALUATION OF U.S., JAPANESE AND ITALIAN EXPERIMENTS INDICATE
( F m L - u >ad n 4 THAT INITIAL REMOVAL 0F ELEMENTAL 10 DINE BY UNRECIRCULATED SPRAY SOLUTION IS VIRTUALLY INDEPENDENT OF PH, HENCE, ADDITIVES NOT NEEDED DURING SPRAY INJECTION, o DATA INDICATE PH OF 6 OR GREATER KEEPS IODINE RE-EVOLUTION IN SUMP SOLUTION AT VERY LOW LEVEL (SMALL COMPARED TO ORGANIC I0 DINE), NO SIGNIFICANT DIFFERENCE IN IODINE RE-EVOLUTION j o* s . o OBSERVED AT PH 9 VS, PH 7, 6 /crp., #td a q u/o ;ehv (
n 2 7o A o ALLOW SEVERE ACCIDENT INSIGHTS REGARDING SPRAY EFFECTIVENESS FOR OTHER FISSION PRODUCTS (BESIDES 10 DINE) TO BE REFLECTED ,
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SFP 6.5.2: CONTAINMENT SPRAY AS A FISSION PRODUCT CLEANUP SYSTEM REVISIONS i
o DELETE REQUIREMENTS FOR SPRAY ADDITIVE DURING INJECTION I AND FOR AUTOMATIC ADDITION o BASE SUMP PH CONTROL ON NEED TO KEEP IODINE REVOLATILIZAIION )
AT VERY LOW LEVEL l
0 REMOVE TID-14804 SOURCE TERM, REPLACING THIS BY REFERENCE i TO REG GUIDES 1.3/4 C %g yyk 7, ,4 -
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o PROVIDE EXPLICIT MODELS FOR IS0 TOPES OTHER THAN 10 DINES (SOLID FISSION F.P.) {
1 o PROVIDE EXPLICIT MODELS FOR NATURAL DEPLETION (PLATEUUT, WALL DEPOSITION) o PERMIT VARIETY OF SPRAY SYSTEMS TO BE REVIEWED (E.G., BWR SPRAYS) 1
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i PH0 POSED IMPLEMENTATION FOR SRP 6.5.2 o NO CHANGE REQUIRED FOR PRESENT PWR'S LICENSEES HAVE CH01CE OF USING AUTOMATIC. ADDITION OF SPRAY ADDITIVES
- MANUAL ADDITION (UN HIGH RAD. SIGNAL, FOR EXAMPLE)
NO ADDITIVES (BUT ASSURE PH CONTROL IN SUMP) o CAN USE WITH EXISTING TID-14844 SOURCE TERM OR NEW SOURCE TERMSTUBEGIVEfjINREVISEDR.G.1.3/1,4
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