ML20246P564
| ML20246P564 | |
| Person / Time | |
|---|---|
| Issue date: | 07/26/1988 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20245B290 | List: |
| References | |
| FOIA-88-490 NUDOCS 8905220231 | |
| Download: ML20246P564 (33) | |
Text
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MEMORANDUM FOR:
NRR Division Directors l
FROM:
Thomas E. Murley, Director Office of Nuclear Reactor Regulation
SUBJECT:
NRR/ REGIONAL ADMINISTRATORS MANAGEMENT MEETING ON JUNE 27, 1988
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The subject meeting covered many topics of interest and resulted ;^ several follow-up assignments. The responsible organization and schedule for the assignments is contained in the enclosure to this memo.
v jf you have any questions regarding the assignments, please discuss it with Jim Sniezek or me.
Thomas E. Murley, Direc or
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Office of Nuclear Reactor Regulation
Enclosure:
Follow-up Assignments cc:
J. M. Taylor W. T. Russell J. N. Grace A. B. Davis R. D. Martin J. B. Martin J. H. Sniezek F. Miraglia T. T. Martin F. Gillespie J. Lieberman 1
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NRR/ Regional Administrators June 27. 1988 Meeting j
Follow-up Assignments Assigned Topic Organization Schedule 1.
JCOs and Relationship to DOEA(Rossi)
Complete by Operability Determination September 10, 1988 (GL 87-02 and 86-15). NRR develop program guidance for use by NRR and Regions.
2.
Coordinate the scheduling of DRIS(Grimes)
Ongoing - issues a all HQ Team Inspections, revised schedule at Interface with Regions and least once a quarter.
publish schedules at least 8 weeks in advance, it is recognized that some last minutes changes may be necessary.
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3.
Management Team Visits are DD(Sniezek)
August 15, 1988 well received by the Regions and are found to be a-valuable tool for effecting positive changes to ways of doing business. Determine whether current frequency of once/ year is optimum frequency.
4.
Examine the Enforcement DRP (Varga)
Complete by Discretion / Waiver of September 15, 1988 Compliance Process. Develop programmatic guidance and administrative process and promulgate it for NRR and Regional use f m
Staff Response to Operator DD(Sniezek)
Completed Positive Drug Testing Until Fitness for Duty Rule issued.
It was decided that the talking points used by Jim Sniezek at t
the meeting should be used as
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infonnal guidance. A copy is j
attached.
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i NRR Regional Administrators June 27.-1988 Meeting
~ %,i Follow-up Assignirents (continued) 1 l-Assigned-Topic
-Organization.
Schedule l
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INPO role in the Operator DLPQ(ROE)'
Ongoing in Requalification Program.-
accordance with.
Develop the appropriate existing schedules.
INPO role in the requal program.
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STAFF RESPONSE TO LICENSEE PERSONNEL POSITIVE DRUG TESTING
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i Adopt general staff position parallel to provisions of proposed rule Non-licensed operator Onsite use, sale, possession -- remove from Protected Area access Testpositive(confirmed)
- 1st time - rehab program
- 2nd time - remove from Protected Area access for 3 years v
Utility expected to take the~above action NRC will issue show cause order (if needed)
Licensed operator
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Onsite use, sale, possession -- remove from Protected Area access Test positive (confirmed)
- 1st time - rehab p7ogram I
- 2nd time - remove from Protected Area access for 3 years Utility expected to take the above action NRC takes no action after 1st offense unless utility does not enter into rehab program I
NRC suspends operator's license (imediately effective) af ter 2nd offense and issues order to show cause why license should not be revoked Draft position -- J. Sniezek, June 20, 1988 i-i
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AN S.3.4 -
ANSI N546o1976
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medical certification and monitoring of personnel requiring operator licenses for nuclear power plants l
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AN S.3.4 ANSI N546-1976 American National Standerd-Medical Certification and Monitoring
.of Personnel Requiring Operator Licenses for Nuclear Power Plants Secretariat American Nuclear Society i
Prepared by the American Nuclear Society Standards Committee Working Group ANS 3.4 Published by the i
American Nuclear Society 244 East Ogden Avenue Hinsdale, Illinois 60521 Approved April 12,1976 l
. by the American National Standards Institute, Inc.
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g gg (Then Foreword is not a part of American National Standard Medical Cernfication and Monitonns of Per.
sonnel Requinng Operator Licenses for Nuclear Power Plants. N5461976. ANS441 I
The organization which operates a nuclear power plant has the responsibility for safe and efficient operation ~of the plant. Inherent in this overall responsibility is the responsibility to select and retain operators and senior operators that are phpically capable of such operatins. The selection of operators and senior operators is of great importance since they perform ar.d direct the manipulations of mechanisms and con.
trols that affect the safe operation of the reactor. This Standard provides the minimum requirements necessary '?. an examining physician to determine that the phnical con.
dition and general hesith of the operators are not such as might cause operational errors.
This Standard was developed by Working Group ANS-3.4 of the Amer 4*a Nuclear Society Standards Committee which had the participation of the following members during the period it prepared and approved the Standard; J. L Crais M.D. Chastman. General %Ils Inc.
' R L. Crais. M D. Tennessee Valle, Authonty W. & Albers. M.D.. US Energy Research and T. J. Dovle. M D. Couchdated Eduon Company Development Admanistresson G. A. Poda. M.D El duPont deNemours and Com.
P. F Collsns. U.S Nuclear Regulatory Cwmasson pany M J Cooney. Phaladelphus Electne Company The membership of Subcommittee ANS 3 at the time of their approval of this Stan-dard was:
G. C. Andognsns. Chssrman: Boston Edaan Com.
H J. Green. Tennesser Valley Authonty pany R F Jonen. Crvuse Company T. L. Kelly. Secretary. Nuclear Serners Corporutson J A List. Consultant H. T. nskb. South Carohna Elecerse & Gas Com-H L Ottoson. Southem Calsforma Edaan Company
.pany F A Peltner. Commonwealth Edaon Company S E Bryan. US Nuclear Regulator, Commasson J A. Prentele. Electne rouer Research lutstute J C. Carroll. Factfic Gas & Eiretne Company R. H Votlrner. US. Nuclear Regulatorv Commanon M J Cooney. Phstadelphsa Eirerne Company G K. Whstman. Argonar Natsonal Lolwarm l
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. Contents ection-Page S
- 1. Score...............................................................,..1
- 2. Definitions '
2.1 Limitations
............................1-
- 2.2 Glossary of Terms
............................................1-3! Hestth Evaluation Responsibility 3.1 G en e r a l As pec ts..................................................... 1 3.2 Facility Operator's Report to the Designated Medical Examiner,.........!
4.' Medical Ex amina tion Frequency......................................... 2 '
- 5. Health Requirements and Disqualifying Conditions 5.1 Ba sis of Requ ireme nts.......................................... 2 5.2 G ener al Req uir em en ts........................................ 2 5.3 Disqualifying Conditions........................................ 2 5.4 Specific Minimum Capacities Required for Medical Qualifications...... 4 E. Walver or Specifically Limited Approval
' 6.1 Application Requirements and Criteria...
..........................~.5 6.2 Specifically Limited Approva!..........
........................ 5
- 7. R e fer e n ce......,...................
............................ 5 a
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Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants 1.
Scope nuclear reactor operator. An individual who manipulates the controls or directs others to This Standard applies to nuclear reactor manipulate the controls.
operators licensed or otherwise design...ed by the facility operator.
shall, abould and may. The word "shall" is used to denote a requirement; the word 2.
Definitions "should" to denote a recommendation; and the word "may" to denote permission, neither a 2.1 Limitations. The definitions given below requirement nor a recommendation.
are of a restricted nature for the purpose of this Standa rd.
solo operation. Operation of the controls, in-ciuding monitoring of instrumentation during 2.2 Glossary of Terms stea dy station operations, with no other qualified person in the control room or other controls. Apparatus and mechanisms the specified control areas, such as the refueling manipulation of which directly affect the reac-console.
tidty or power level of the reactor.
3.
Health Evaluation Responsibility designated medical examiner. A licensed medical practitioner designated by the facility 3.1 General Aspects. The primary respon.
operator to perform reactor operator medical aibility for assuring that qualified personnel are examinations.
on duty rests with the facility operator. The health requirements set forth herein are con-facility operator. An authorized representative sidered the minimum necessary to determine of a holder of a License pursuant to Title 10, that the physical condition and gene.al health Code of Federal Regulations. Part 50. "Licen-of the individual are not such as might cause sing of Production and Utilization Facilities" operational errors endangering public health
[ 1 ) 8, or any government, public, or private and safety.
organization which is the owner and operator or The designated medical examiner should is the designated responsible operator of a reac.
have a clear understanding of the duties and tor facility, responsibilities of a nuclear reactor operator.
multi person facility. A facility where it is 3.2 Facility Operator's Report to the Des-mandatory that more than one qualified in-Ignated Medical Examiner. Tha facility dividual be present in the control room or other operator shall forward o the designated specified control areas when the reactor is medical examiner a repois on each employee opera ting.
referred for a reactor operator medical examination prior to the examination. This nuclear power plant. A nuclear power plant is report shall include information specihed by the any plant using a nuclear reactor to produce designated m9 dical examiner and should ad-electric power, process heat, or space heatmg.
drama armas such as work performance, at-tendance, and behavioral changes noted since i
nuclear teactor. Any assernbly of fissionable the previous review. Incidents of ineptness, pooe
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material which is designed to achieve a con-judgment, and lack of physical or emotional j
trolled, self. sustaining neutron chain reaction.
stamina should be noted. Unusual absence or wnterm in brieken eeter to correspondmr ournbers in sec.
lateness ad secMent experience sbd W con 1, werenm recorded.
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Amencan National Standard N546197s/ANS.3 4 (4) Prosthetic valve.
neurologist should be considered.
l (5) Artificial pacemaker.
(2) History of a distrubance of i
(6) Peripheral vascular insufficiency.
consciousness within the past five years without l
(7) Arterial aneurysm.
satisfactory toedical explanation of the cause i
5.3.3 Endocrine, Nutritional or Metabolic shall disqualify for solo operation.
l (1) Diabetes m ellit u s.
Uncontrolled (3) Organic brain syndrome.
i diabetes. ketoacidosis, diabetic coma, or insulin (4) Any other convulsive disorder, distur.
f shxk within the previous two years.
bance of consciousness or neurologic condition-l ta) Requirements for use of insulin shall that the designated medical examiner finds j
disqualify for solo operation. Well. controlled makes the exarninee unable to safely perform j
stable diabetics requiring insulin may qualify all operator duties.
1 for a multi. person facility if history and 5.3.8 matal. An established history or examination findings indicate such duties are clinical diagnosis of any of the following:
within their physical capacity and that such (1) Any psychological or mental condition duties and scheduling will not interfere with which could cause impaired alertness, judgment, control measures for their diabetes.
or motor ability shall constitute sufficient cause (b) Stable dia beties adequately con.
for disqualification. A history of clinically trolled by diet or oral medication may be significant emotional or behavioral problems qualified as solo operators.
shall require, thorough clinical evaluation (2) Other conditions requiring th'e con.
which may include, but not necessarily be tinued or frequent use of steroids.
limited to, psychological testing and psychiatric 5.3.4 Integumentary. Recurrent severe der.
evaluation.
rnatitis or hypersensitivity to irritants or sen.
(2) A personality disorder that is severe sitiiers sufficient to interfere with wearing of enough to have repeatedly manifested itself by personal protective equipment or likely to be overt acts.
a ggra u ;ed by personal decontamination (3) History or threat of suicide attempt.
procedures.
(4) History of a psychotic disorder.
5.3.5 Hematopoietic Dysfunction.
(5) Alcoholism is used in this section to (1) Polycythemia mean a condition in which a person's intake of (2) Agranulocytosis alcohol is great enough to damage his physical (3) Leukemia and Lymphoma health, and personal or social functioning; or a (4) Other sig nifica nt hematopoietic condition when s!cohol has become a dyscrasia prerequisite to his normal functioning.
5.3.6 Malignant Neoplasma. Malignant
- (6) Drug dependence is used in this section neoplasm shall disqualify unless resiew of to mean a condition in which a person is ad.
medical history and current medical evaluation dieted to, or dependent on, drugs other than indicate clinical remission which renders the alcohol, tobacco, or ordinary caffeine.
examinee capable of tneeting all other containing beverages, as evidenced by non.
requirements of thia Standard.
prescribed habitual use of the drug.
5.3.7 Neurological (7) History or presence of any other (1) History of epilepsy shall disqualify for clinically significant mental, character, behavior solo operator duties. Examinee may be con.
or personality disorder including anxiety, ob.
sidered for qualification for a multi. person sessive. compulsive, conversion, disassociative, facility if he has remained seizure free for at depressive, or phobic reactions shall disqualify least the previous five years with medication or if the designated toedical examiner finds that has remained seizure free during the previous the condition or any treatment thereof makes two years without rnedication. Before con.
the examinee potentially unable to safely per.
sidering such qualification, history and form all operator duties.
examination findings tnust document the fact 5.8.g mdication. Any medication taken in that the residuals of, or medication to control such a dosage that the taking or temporary the seizure disorder do not impair the delay of taking might be expected to result in in.
examinee's capacity to perform all required capacity. For example, certain dosages or duties. Evaluation and prognosis by a requirements for steriods, anticoagulants, an.
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j Amenean hational Siendard N546.t9%. ANM 4 i
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(3) Normal electrocardiogram (ECG) the individuals job performance (4) Any. other medical ~ investigative (3) Description by the facility operator of i
m procedures, including chest z. ray, which the specific practical tests and demonstrations of designated medical examiner considers ability to perform those duties which might be necessary for adequate medical evaluation shall reasonably expected to be affected by the im.
be conducted pairment.
designated
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(4) Certification frotn the 6.
Walver or Specifically Limited medical examiner and facility operator in.
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Approval dicating that the individual can safely perform -
. his assigned duties 6.1 Application Requirements and Criteria.
If an examinee fails to meet any of the above 6.2 Specifically Limited Approval.
specified minimum requirements but can' Examinees who do not meet cil requirements demonstrate to the satisfaction of the facility for either qualification or waiver for unrestric.
operator complete ca pa city to perform ted operator duties may request specifically operational duties, the designated medical limited approval. Consideration of any such examiner may recommend waiver of that por.
request shall require the facility operator's con.
tion of this Sandard. It is the examinee's currence and recommendations and all other in-responsibility to supply additional information formation necessary for a waiver application necessary for consideration of the granting of (see 6.1 ). The facility operator shall also
- auch a waiver. Documentation supporting the.
propose the exact wording of any such specific waiver shall include:
limita tion.
(1) Medical history and results of physical examinanon and other pertinent medical find.
7.
Refere nce ings
[1] Title 10, Code of Federal Regulations Part (2) Specific statements by the designated 50 " Licensing of Production and L'tilization i
medical examiner as to the individual's capacity Facilities," Government Printmg Office, and the potential effects of any impairment on Washington, D.C.
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Contact:
- 5. Shankaan (301)492-9806 i
REGULATORY GUIDE 1.134 Task 0L 401-5 HEDICAL EVALUATION OF LICENSED PERSONNEL FOR NUCLEAR POWER PLANTS A.
INTRODUCTION ~
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Sections 55.31, "How to Apply," a9 55.57, " Renewal of Licenses," of 10 CFR Part 55, " Operators' Licenses," require that each initial or renewal application for an operator or senior operator license contain a medical exami-nation certification following the fore prescribed in 5tt>part C "Medicai Requirements." Sections 55.33, " Disposition of Initial Application,' and 55.57 state that the initial or renewal appitcations for these licenses will be a,) proved if, among other things, the applicant has no medical or general health condition that alght cause operational errors endangering pubite health and safety. Paragraph (1) of 5 55.53, " Conditions of Licenses," requires that an examination be conducted every 2 years.
Section 55.D, " Incapacitation Because y Otsability or Illness," deals with an operator or senior operator who becms incapacitated because of a sental or physical condition that sight cause impaired judgment or motor coordinatfoa.
Section 55.27, " Documentation," requires that the facility Itcensee docu-ment and saintain the medical qualifications data, current test results, and each operator'r medical history and provide these to the NRC upon its request.
This guide describes a method acceptable to the NRC staff for providing the information needed by the staff for its evaluation of the medical qualifications of applicants for initial or renewal operator or senior operator licenses for nuclear power plants and for providing notification to the NRC of the disability.
8703120178 870310 4
46428 PDR
Any information collection activities sentioned in this regulatory guide
)
are contained as requirements in 10 CFA Part 55, dich provides the regulatory basis for this guide.
1 information collection requirements of Part 55 have i
been approved by the 0.
e of Management and Budget, neer 3150-0018 as appro-priate under the Paperwork Reduction Act.
B.
015CUS$10N Section 55.23, " Certification," of Subpart C, " Medical Requirements," of 10 CFR Part 55 requires that a physician examine the applicant in accordance with NRC's regulatory guidance and determine that the examinee's medical condition and general health meet the requirements for granting or renewing an operator license. The physician must send a full medical examination report '.o the facility licensee, which will then transmit a completed Fors 396 to the NRC.
The intent of Mese requirements is to have the factitty Itcensee certify the health of its operators. However, the facility licensee is expected to maintain those records that may be reviewed by the NRC. Therefore, 5 55.27 requires the facility licensee to document and maintain the full medical exas-ination report, including the results of medical qualifications data, test
(
results, and each operator's medical history. In addition, 5 55.27 requires the facility licensee to retain the most recent medical information as a result of the biennial physical examination and provide that information to the NRC on request. The certification form would be sent by the facility licensee to the NRC.
There are two instances in which medical infonnation must be sent to the 4
NRC. One is when a conditional license based on medical evidence is requested under the provisions of paragraph 55.33(b). The second instance is when a licensed individual has become senta11y or physically unable to perforn job dut ie s.
In this case, the facility licensee must notify the NRC within 30 days after learning that the diagnosis has been made. The fac111ty licensee must forward to the NRC Form 396 and medical records describing the disability.
This related information is required by $ 55.27 to be documented and maintained by the facility.
An American National Standard developed by the American Nuclear Society, ANSI /ANS-3.4-1983, "fiedical Certification and Moritoring of Personnel Requiring 2
j
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Operator Licenses for Nuclear Power Plants,"1 prescribes einfam requirements necessary to deterstne that the medical condition and general health of nuclear reactor operators will not cause operational errt s.
The criteria presented in this standard provide an examining physician a t als for determining whether a potentially disqualifying abnormal health cont. fon exists. Establishing eini-
{
aus health requirements should aid in ~ ra av fors medical evaluations. However, i
it is necessary to recognize that, although it is the physician's responsibility to identify and evaluate any potentially disqualifying medical conditions, NRC sakes the final determination of the applicant's medical fitness.
Nothing in AN51/MS-3.4-1983 or this guide should be construed to mean that such matters as (n individual's reading habits, political or religious
{
beliefs, or attitudes on social, economic, or political issues should be investigated or judged.
C.
REGtlLATORY POSITION The requirements contained in ANSI /ANS-3.4-1983, " Medical Certification and Monitoring of Personnel Requiring Operator f.fcenses for Nuclear Power Plants,"1
(
provide a method acceptable to the NRC staff for determining the sedical qualifications of applicants for initial or renewal operator or senior operator licenses.
D.
IMPLEMENTATION j
The purpose of this section is to provide information to applicants and licensees about the staff's plans for using this regulatory guide.
Except in those cases in which the licensee proposes an acceptable alter-native method for complying with specified portions of the Commission's regula-tions, the methods described in the guide will be used in evaluating the part of an application for initial er renewal operator or senior operator licenses on NRC Fors 396,
- Certificate of Medical Examination by facility I.icensee."
3 Copies may be obtained from the American Nuclear Societys 555 North Kensington Avenue, La Grange Park, Illinois 60525.
i 3
3
=
k VALUU!MPACT ANAlys]s I
A separate valve /fapact analysis has not been prepared for this regu'tatory gutde. A value/fapact analysis was included in the regulatory analysis for the amendments to 10 CFR Part 55 published on [date of FR notice) a copy of which was placed in the Public Document Rcom at that time. This analysis is also appropriate to Revision 2.cf Regulatory Guide 1.134.
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1 I.
ANSIIANS 3.41983 l
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American National Standard Medica! Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants Secretariat American Nuclear Society Prepared by the American Nuclear Society Standards Committee i
Working Group ANS3.4 Published by the American Nuclear Society 555 North Kensington Avenue La Grange Park,Ihols 60525 USA Approved April 29,1983 by the American National Standards Institute, Inc.
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4 American An American National Standard implies a consensus of 'those-substantially concerned with its scope and provisions.
An N LIO"*I American National Standard is intended as a ' guide to aid
.(
Standard the : rnanufacturer, the consumer, and the-general public.
The existence of an American National Standard does not in, any respect preclude. anyone, whether he has approved the standard or not, from manufacturing, marketing, purchasing, or using products, processes, or procedures ' not conforming to the standard.
American National Standards are subject.
to periodic review and users are cautioned to'obtain the latest -
editions.
cat > TION NOTICE:
This American National Standard may be revised or withdrawn at any time. The procedures of the American National Standards institute ~ require that action be taken to reaffirm, revise, or - withdraw this standard no later than five years from the 'date of publication.. Purchasers of this - standard may receive current information, including interpretations, on all. standards published by ' the American Nuclear Society by calling or writing to the Society.
..(
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Published by Amerienn Mclear Society
$55 North Kensington Avenue, La Grange Park, Illinois 60525 USA Price: $10.00 Copyright C 1983 by American Nuclear Society.
Any part of this standard may be quoted. Credit lines should read " Extracted from American National Standard, ANSI /
ANS-3.4-1983, with permission of the publisher, the American Nuclear Socie ty."
Reproduction prohibited under copyright convention unless written permission is granted by the American Nuclear Society.
I Printed in the United States of Americe
h 1
L Foreword
- This Foreword is not a part of American National Standard Medical Certification and Monitoring of Personnel Requiring Operator Licenses g
for Nuclear Power Plants, ANSI /ANS-3.41983.)
f
. The organization which operates a nuclear power plant has the responsi-bility for safe and efficient operation of the plant.
Inherent in this overall responsibility is the responsibility to select and retain operators
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and senior operators that rre physically capable - of such operations.
The selection of operators and senior operators is of great importance
'since they perform and direct the manipulations of mechanisms and controls that af fect the safe operation of the reactor. This standard provides the minimum requirements necessery for en examining physician -
to determine that the physical condition and general health of the opera-tors are not such as might cause operational errors.
This standard was developed by Working Group ANS-3.4 of the American Nuclear Society Standards Committee which had the participation of the following members during the period it prepared and approved the -
standard:
R. L. Craig, M.D., Chairman J. L. Craig, M.D.
Tennessee Valley Authority General Mills, Inc.
W. R. Albers, M.D.
T. J. Doyle, M.D.
U.S. Department of Energy Consolidated Edison Company P. F. Collins G. A. Poda, M.D.
'i U.S. Nuclear Regulatory E. I. duPont deNemours and -
Commission Company M.
J. Coov y Philadelphia Electric Company i
The membership of Subcommittee ANS-3. Reactor Operations, at the time of its approval of this standard was:
J. E. Smith, Chairman R. J. Rodriquez Duke Power Company Sacramento Municipal Utility S. E. Bryan District U.S. Nuclear Regulatory J. D. Shiffer Commission Pacific Gas and Electric F. A. Dougherty D. J. Skovholt Tera Corporation U.S. Nuclear Regulatory N. S. EIi1ott Commission Babcock & Wilcox Company E. L. Thomas T. W. Fitzgeraid Iristitute of Nuclear Power American Nuclear Insurers Operations H.
J. Green W. T. Ullrich Tennessee Valley Authority Peach Bottom Atomic Power F. L. Kei1y Station PGA Corporation P. F. Walzer R. L. Ottoson Washington Public Power Southern California Edison Supply System F. A. Palmer G. K. Whitham Commonwealth Edison Company Argonne National Laboratory
The American Nuclear-Society's Nuclear Power - Plant Standards Committee
(
(NUPPSCO) had the following membership at the time of its approval of this standard.
L. J. Cooper, Chairman M. D. Weber, Secretary Name of Representative Organization Represented General Atomic Company R. G. B'enham.
(for the Institute of Electrical and Electronics Engineers, Inc.)
. Duke Power Company B. M. Rice (Alt.).
(ice the Institute of Electrical and Electronics Engineers, Inc.)
Pacific Gas and Electric Company R. V. Bettinger
. Westinghouse Advanced Reactor Division P. Bradbury.
Westinghouse Electric Corporation D. A. Campbell Pacific Gas and Electric Company C. O. Cof fer Nebraska Public Power District L. J. Cooper
............ (for the American Nuclear Society)
. - General Electric Company W. H. D' Ardenne.
.NUS Corporation
- 5. G. Gerges
. Bechtel National, Inc.
C. J. Gill.
.U.S. Nuclear Regulatory Commission C. E. Johnson.
GPU Services Corporation R. W. Keaten
. Portland General Electric Company J. W. Lentsch.
NUTECH Engineers *
(*'
J. F. Mallay.
. Tennessee Valley Authority
\\
L. M. Mills United Engineers and Constructors, Inc.
a:
Individual Tl A. T. Molin.
T. J. Pashos.
Catriytle, Inc.
P. T. Reichert.
. Institute of Nuclear Power Operations S. L. Rosen.
. Duke Power Company -
.z.
J. E. Smith.
Yankee Atomic Electric Company J. W. Stacey
. Stone & Webster Engineering Corporation S. L. Stamm
. Quadrex/tWelear Services Corporation L. Stanley
. Structural Mechanics Associates J. D. Stevenson (for the American Society of Civil Engineers)
Yankee Atomic Electric Company C. D. Thomas, Jr.
. Commonwealth Edison Company G. P. Wagner
. Torrey Pines Technology G. L. Wessman.
. Southern Company Services, Inc.
J. E. Windhorst.
- Formerly with Babcock & Wilcox Company I
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CONTENTS Sect. son Page M
l.
Scope.
.' l L
- 2. Definitivis.
.I I
.1 2.1 Limitations 1
.1 -
2.2 Glossary of Terms.
- 3. Health Evaluation Responsibility.
.1 l
.1 3.1 General Aspects 3.2 Facility Operator's Report to the Designated Medical Examiner.
.I 1
4.
Medical Examination Frequency
.2
)
i
- 5. Health Requirements and Disqualifying Coriditions
.2 1
5.1 Basis of Requirements.
.2 5.2 General Requirements
.2
.2 5.3 Disqualifying Conditions 5.4 Specific Minimum Cspacities Required for Medical
' ~(
Qualifications
.4
- 6. Waiver or Specifically Limited Approval.
.6
.6 6.1 Application Requirements and Criteria.
.6 6.2 Specifically Limited Approva!
- 7. References.
.6
?
l l
a Medical Certification ano mumui n.y u,
n.
for Nelur Pow:r Plants nuclear reactor. Any assembly of fissicito l
self-sust(atning desigm l
I.
Scope material wM is a e controlled, This standard defines the physical achieve a h
)
and mental requirements for licensure mWm eah readon.
(
l as a nuclear reactor operator.
It An individual nuclear reactor operator.
also addresses the content, extent, who manipulates the controls or directs others to manipulate the controls.
and methods of examination.
J The word "shall" shall, should and may.
is used to denote a requirement; the a
2.1 Limitations.
The definitions given word "should" to denote a recommenda-ti ni and the word "ma y" to denote below are of a restricted nature permission, neither a requirement nor for the purpose of this standard, a recommendation.
8 Pe n n. @ab f W cWM, 2.2 Glossary of Terms controls.
Apparatus and mechanisms including monitoring of instrumentation steady station operations, with the manipulation of which directly during af fect the reactivity, power level, ther qualified person in the control n
- cooling, containment, and other r other specified control
- areas, r m requirements for safe operation such as the refueling console, of the nuclear reactor, designated medical examiner.
A li-3.
Health Evaluation Responsibility censed medical practitioner designated by the facility operator to perform 3.1 General Aspects.
The primary nuclear reactor operator medical responsibility for assuring that qualified are on duty rests with the personnel The health require-examinations.
facility operator.
discpalifying cc dis @elifying condition.
the minimum ucessay to MennMe Something that precludes medical approval for nuclear reactor operator that the physical condition and general licensure.
health of the indivichst are not such An authorized as might cause operational errors en-representative of a holder of a license dangering public health and safety.
facility operator.
pursuant to Title 10, Code of Federal Regulations, Part 50,
" Licensing The designated medical examiner shall of Production and Utilization Facil-be conversant with this standard and should have a general understanding ities" [1]I, or any government, public, of activities required of a nuclear reactor or private organization which is the owner and operator or is the
- operator, designated responsible operator of 3.2 Facility Operator's Report to tte a nuclear reactor facility.
agu ed M al Ewniner.
N multi-person f acility. A f acility where fac M y opera W sM had 2 We designated medical examiner a report it is mandatory that more than one in the n each employee referred for a nuclear qualified individual be present control room or other specified control reador opera w Meal egmah This report areas when the reactor is operating.
prior to the examination.
nuclear power plant.
A nuclear shall include information specified by the designated medical examiner power plant is any plant using a and should address areas such as work nuclear reactor to produce electric performance, attendance, and behavioral power, process heat, or space heating, changes noted since the previous review.
incidents of ineptness, poor judgment, s
jNumbers in brackets refer to corre-p lack of physical or emotional stamina sponding numbers in Section 7, Refer-noted.
Unusual absence or I
,hould t>e s
ences.
i
American National Standard ANSl/ANS-3.41983
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lateness and accident experierce individual in question is performini; h
should be recorded.
his assigned duties.
Potential psychological or medical problems that could impair judgment 5.2 General Retirements or ability to perform assignments are more likely to be identified 5.2J Capacity.
The examinee shall by the designated medical examiner demonstrate stability and capacity if he is provided with this background for all of the following:
&nformation.
(1) Mental alertness and emotional stability:
- 4. Medical Examination Frequency (2) Aculty of senses and ability of expression to allow rapid, accurate Nuclear reactor operators shall be communication by spoken,
- written, examined biennially for continued and other audible, visible, or tactile medical qualification.
signals; (3) Physique, stamina, motor power,
- 5. Health Requirements and Dis.
range of motion, and dexterity to allow qualifying Conditions ready access to and safe execution of assigned duties.
SJ Basis of Requirements.
The 5.2.2 f reedom from Incapacity.
physical condition and the general The t-xaminee shall be free of any health of nuclear reactor operators who have the responsibility for the of tne following conditions that are safe operation of a nuclear reactor considered by the designated medical examiner as significantly predisposmg
.e --
shall be such that they are capable
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of properly operating under normal, to incapacity for duty:
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abnormal and emergency conditions (1) Mental or physical impairments; and able to perform the associated (2) Any medical, surgical, or other tasks.
Consequently, any physica; professional treatment; condition or corrective device that (3) Any other source or use.of restricts the mobility of the individual treatment,
- drugs, chemicals,
- diets, or precludes the wearing of protective or other egents; f
clothing and equipment is a liability (4) Any condition, habit, or praetlee I
to safe operation.
Any condition which might result in sudden or unex.
that can cause sudden incapacitation pected incapacitation.
such as epilepsy, mental disorder, diabetes, hypertension, cardiovascular 5.3 Dispatifying Canditions.
A history disease, fainting spells and defective or other indication of any disqualifying hearing or vision is also a liabihty condition shall be considered disqualifying unless adequate supplemental findings to safe operation.
The potential demonstrate that no disqualifying con-consequences of insidious incapacitation dition exists.
Such demonstration shall are most serious in solo operation, Include at least the, specific narrative but shall be considered at any facility.
entries by the designated medical exam-Many of the conditions indicated iner and relevant aspects of medical above may be accommodated by history and physical examination.
The restricting the activities of the indi-designated medical examiner shall
- vidual, requiring close surveillance determine the need for additional exam-of the condition, imposing a temporary ination procedures or specialty evaluations.
medical regime, or requiring another The presence of any of the following individual to be present when the conditions, unless adequately compensated 9
2
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-I Ameriern National '..tndard ANSI /ANS-3.41983 j
1 by the methods specified in subsections such duties are within their physical (L
5.3.l' through 5.3.9, shall disqualify capacity and that such duties and sched-
{
the individual.
uling do not-interfere with control i
measures for their diabetes.
5.3.1 Respiratory (b) Stable diabetics adequately 1
controlled by diet or oral medication l
(1)
Frequent severe attacks of asthma within the previous two may be qualified for solo operation.
(2) Other conditions requiring years or a history that indicates a need for continued or prolonged the continued or frequent use of steroids, use of' medication for relief, preven-tion, or control of attacks; 5.3.4 Integumentary.
Recurrent i
severe de rmatitis or hypersensitivity
)
(2)
Tracheostomy or laryngectomy; to irritants or sensitizers sufficient (3)
Incapacitating chronic pulmo-to interfere with wearing of personal nary disease.
l rotective equipment or likely to be 5.3.2 Cardiovascular aggravated by personal decontamination procedures.
(1)
Ischemic heart
- disease, myoc'ardial infarction, coronary insuf-5.3.5 Hematopoietic Dysfunction.
f'.ci e nc y or angina pectoris shall (1)
Polycythemia.
disqualify for solo operation.
If thorough history, physical examination, (2) Agranulocytosis.
(3) Leukemia and.Lymphoma.
electrocardiogram, (ECG), and other (4) Other significant hematopoietic test procedures indicate satisfactory dyscrasia.
cardiac function and reserve, the
( 3-examinee may be considered for 5.3.6 Malignant Neoplasms. Malignant qualification as an operator in a neoplasm shall disqualify unless review multi-person f acilit y provided it of medical history and current medical is demonstrated that all duties of evaluation indicate clinical remission such an assignment are within the that renders the examinee capable physical capabilities of the examinee.
of meeting all other requirements of (2)
Heart failure.
this standard.
(3)
A r rh y t hmia other than benign extrasystoles.
(4)
Prosthetse valve.
5.3.7 Neurological (5)
Artificial pacemaker.
(1)
History of epilepsy shall dis-(6)
Peripheral vascular insu f-qualify for solo operation.
Examinee ficiency.
(7)
Arterial aneurysm.
may be considered for qualification for a multi-person facility if he has remained seizure free for at least the 5.3.3 Endocrine, Nutritional, y,
gg previous five years with medication or has remained seizure free during (1)
Diabetes mellitus.
Uncon-the previous two years without medica-trolled diabetes, ketoacidosis, diabetic tion.
Before considering such qualifi-coma, or insulin shock within the cation, history and examination findings previous two years.
must document the fact that the residuals (a) Requirements for use of of, or medication to control the seizure insulin shall disqualify for solo oper-disorder do not impair the examinee's ation. Well-controlled stable diabetics capacity to perform all required duties.
who require insulin mt y qualify for Evaluation and prognosis by a neurologist a
multi-person facility if history should be considered.
I and e xamina tion findings indicate (2) History of a disturbance of 3
American National Standard ANSl/ANS-3.41983 i
consciousness within the past five character, behavior or personality dis-years without satisfactory medical order includir g
- anxiety, obsessive-explanation of the cause shall dis.
compulsive, conversion, disassociative, qualify for solo operation.
depressive, or phobic reactions shall I
(3)
Organic brain syndrome, disqualify if the designated medical (4)
Any other convulsive dis-examiner finds that the condition or
- order, disturbance of consciousness any treatment thereof makes the exam-or neurologic condition that the inee potentially unable to safely perform designated medical examiner finds all operator duties, makes the examinee unable to safely perform all operator duties.
5.3.9 Medication.
Any medication taken in such a dosage that the taking 5.3.8 Mental.
An established or temporary delay of taking might history or clinical diagnosis of any be expected to result in incapacity, of the following:
for example, certain dosages or require-(1)
Any psychological or mental ments for
- steriods, anticoagulants, condition that could cause impaired antierrhythmies, sedatives, tranquilizers, alertness, judgment or motor ability or insulin.
shall constitute suf ficient cause for disqualification.
A history of SA Specific Minirnum Capacities Re-clinically significant emotional or quired for Medical Qualification behavioral problems shall
- require, 5A.1
- Head, Face,
- Neck, Scalp.
thorough clinical evaluation that Configuration suitable for fitting and
- include, but not necessarily effect ve use of personal protective may be limited to, psychological ;est,ng equipment.
[
i and psychiatric evaluation.
(2)
A personality disorder that SA.2 Nose.
Ability to detect odor is severe enough to have repeatedly of products of combustion and of tracer manif este d
,tself by overt acts.
i or market gases.
(3)
History or threat of suicide attempt.
5A.3 Mouth and Throat.
Capacity (4)
History of a
psychotic for clear speech.
disorder.
(5)
Alcoholism is used in this SAA Ears.
Puretone audiometric section to mean a condition in which threshold average better than 30 dB e person's intake of alcohol is great (American National Standard Specifi-enough to damage his physical health' cations for Audiometers, ANSI S3.6-1973 and personal or social functioning;
[2] or International Organization for or a
condition when aleohol has Standardization, Standard Reference become a prerequisite to h,s normal 0 for Calibration of Pure Tone Audio-i functioning.
used meters, ISO 389-1975 [3), for speech (6)
Drug dependence is frequencies 500, 1000, 2000 Hz in better in this section to mean a condition ear. If audiometric scores are unaccept-in which a person is addicted to, able, qualification may be based upon or dependent on, drugs other than cnsite demonstration to the satisf action alcohol, tobacco, or ordinary caf feine-of the facility operator of the examinee's containing beverages, as evidenced abilit y to safely detect, interpret, by non-prescribed habitual use of and respond to speech and other euditory the drug, signals.
(7)
History or presence of any other clinically significant mental, Qualification should be considered if 4
i
1-Am;rican Nstion:1 S d:rd ANSI /ANS-3A-1983 a hearing aid is reovired to meet abnormality, a report of an evaluation
(
hearing requirements.
by a physician proficient in cardiovascular evaluations shall accompany the medical SA.5 Eyes.
examination report.
This consultation sfiall include, but is not limited to, (1)
Near and distant visual an interpretation of an ECG and chest acuity 20/40 in better eye, corrected X-ray.
or uncorrected.
(2)
Peripheral visual fields 5A.8 Abdomen and Viscera. If hernia by confrontation to 1208 or greater.
la present it shall be adequately supported (3)
Color vision adequate to by appropriate device or not be of l
distinguish amung red, green, and such nature as to interfere with the orange-yellow signal
- lamps, and performance of assigned duty or present any other coding required for safe significant potential for incapacitation, operation of the particular facility as defined by the facility operator.
5A.9 Musculo-skeletal.
Normal (4)
Adequate depth perception, symmetrical structure, range of motion either by stereopsis or secondary and power.
If any impairment exists, clues as demonstrated by practical the applicant shall demonstrate ability test.
to effectively complete all expected du ties.
5A.6 Respiratory.
Capacity l
and reserve to perform strenuous 5A.10 Skin.
Capability to tolerate physical e xertion in emergencies, use of personal protective covering l
and ability to utilize respiratory and decontamination procedures.
,A protective filters and air supply masks.
Pulmonary function studies SA.ll Endocrine, N.stritional, Meta-(
that include a forced vital capacity bolic. Normal. Ability to change sched-and forced expiratory volume at ule or delay meals without potential i second would be helpful to the incapacity.
examining physician in determining the candidate's ability to perform SA.12 Hematopoietic. Normal function.
assigned work.
SAJ3 Lymphatic.
Normal function.
5A.7 Cardiovascular.
Normal configuration and function including SAJ4 Neurological!.
Normal central normal blood pressure with tolerance and peripheral nervous system function.
to postural changes and capacity Tactile discrimination (Stereognoslo) for exertion during emergencies.
sufficient to distinguish among various The examining physician shall report shapes of control knobs and handles whether asymmetrical neck and by touch.
peripheral pulses or resting pulse rates less than 50 or more than 5AJ5 Psychiatric.
Normal mental 100 beats per minute are normal status including orientation.
Ability for the individual and of no signifi-to function in emergencies and unusual cance.
If the examination reveals environments such as:
confined or significant cardiac arrhythmia, murmur, crowded spaces, alone in darkness, untreated hypertension (over 160/100 on elevations, on open metal grids, mm Hg),
intolerance to postural and on ladders.
This ability is to be
- changes, cardiac enlargement or determined by the clinical judgment other evidence of cardiovascular of the examining physician, k
i 5
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4-erican National Stanoud ANSI /ANS 3.4-1983 5AJ6 Laboratory, be reasonably expected to be affected h
(
by the impairment; (1)
Normal hemoglobin, white (4)
Certification from the desig-blood cell count, and dif ferential.
nated medical examiner and facility '
(2)
In urinalysis, absence of operator indicating that the individual proteins and glycosuria unless the can safely perform his assigned duties, absence of a disqualifying systemic or genitor-urinary condition has 6.2 Specifically Limited Approval.
been demonstrated.
Examinees who do not meet all require-i (3)
Normal ECG.
ments for either qualification or waiver (4)
Other medical investigative for unrestricted nuclear reactor operator procedures, including chest X ray, duties may request specifically limited that the designated medical examiner approval.
Consideration of any such I
considers necessary for adequate request shall require the facility opera-medical evaluation.
tor's concurrence and recommendations and all other information necessary
- 6. Walver or Specifically Limitad for a waiver application (see 6.1). The Approval f acility operator shall also propose the exact wording of any such specific 6J Application Requirements and limitation.
Criteria.
If an examinee falls to meet any of the above specified minimum requirements but can demon-7.
References strate to the satisfaction of the facility operator complete capacity
[1] Title 10, Code of Federal Regulations i
('
to perform operational duties, the Part 50 " Licensing of Production g
designated medical examiner may and Utilization Facilities," Govern-T recommend waiver of that portion ment Printing Offlee, Washington, of this standard. It is the examinee's D.C.
responsibility to supply additional information necessary for consideration
[2] American National Standard Specifi-of the granting of such a waiver.
cations for Audiometers, ANSI Documentation supporting the waiver 53.6 1973.
American National shall include:
Standards Institute, Inc., New York, (1)
Medical history and results N.Y.
of physical examination and other pertinent medical findings;
[3] International Organization for (2)
Specific statements by Standardization, Standard Reference the designated medical examiner 0 for Calibration of Pure Tone as to the individual's capacity and Audiometers, 150 389-1975.
Ame r-the potential effects of any medical ican National Standards Institute, i
impairment on the individual's ability Inc., New York, N.Y.
j to perform nuclear reactor operator duties; When the preceding American National (3)
Description by the facility Standards referred to in this document operator of specific practical tests are superseded by a revision approved and demonstrations of ability to by the American National Standards perform those duties which might Institute, Inc., the revision shall apply.
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U.S. NUCLt:AR REGULATORY COMMISSION Nonmber 1987 R; vision i 4 $....4) REGULATORY GUIDE OFFICE OF NUCLEAR REGULATORY RESEARCH i
REGULATORY GUIDE 6.62 (Task SG 9014)
REPORTING OF SAFEGUARDS EVENTS A. INTRODUCTION discoetry of the event, and a detailed writtra report mnt follow wittua 30 days.
In 10 Cl R Part 73. "Physseal Protectson of Plants and Matenals," paragraphs 73 7t(s) through (c) have eteently Certain other ten eignifecant safeguards events are been amended. Sectson 73.71 tequires incetaces to report required to be recorded in a log and copics of the to the Operations Center of the NRC or to record for recorded los submitted to the NRC every 3 months. Whale quarterly transtruttal to the NRC sertaAn ufeguards these events are less s,gnificant than those reportable
. events. These events are tho e that threates nuclear wittun I hour, they are required to be reported to the activatics or lenen the effectiveness of a secursty systero as NRC on a quarterly basis for review and long. term trend estabbshed by safeguards regulations or an approved analysis. If an event occurs repeatedly at one facihty or scrutity or contingency plan.
th.oughout the mdustry, it may represent a defect in the secunit, program or a generic trend Not all genene Thu regulatory gu:de provides en approach acceptable desects or trends require action on the part of the NRC, to the hMC staff for use by the beensee for determmits however, this decision cannot be made unless the events when and how an event should be esported The esemples are reported to the NRC. Licensees have been require:J to provided represent the types of events that shou!d be maintain a separat. los to re ord events reportshic under reported and are not inten&d to be all.inclusae. The i 73 71 in the past. but are now required to subrnst a apphcabdity nf eventa may vary from site to site copy of that log to the NRC on a quarterly basis Any mformation collection estivities mentioned m For the purposes of this guide and for understandmg tho regulatory guide are contained as requirements an the regulations, a glouary is g>ven m Appenda A of tha 10 0FR Part 73, wiush provides the regulatory basis for guide. Table i presents a summary of repr'rtabic events tha guide The mformation collection requirements in and reportsns times 10 01 R Part 73 have been cleared under OMB Clearance No 3150 0002 C. REGULATORY POSITION B. DISCUSSION
- 1. LICENSEES SUBJECT TO t 7).71 The mformation reportable under l 73 71 as required Licensees who are subject to the t.o..sinns of so the NRt udl be infornied of ufeguarda related events ll 73.25, 73.26, 73 27tc). 73.37, 73 67(c), or 73 67(s) that have the potential to endanger pubbe health and of 10 CFR Part 73 are subject to the provisions of pare.
fety or national security The required mformatson se graph 73.7l(s) aim uwd to monitor trends an safeguards system ef fective '- is Lhensees who are subje64 to the provismns of l l 73.20, 73 37, 73 50, 73 55. 73 60. or 73 O are 16c6.w c certain signifssant safeguards events warrant subject to the provisions of patagraph 7311th) for events a
immediate involvement by the NTC and posalbly other dessribed m paragraph tlMs)(l) of the new A,.pendia G lu government agenc6es such as the FBI. these events must he Part 73 Licensees subject in the provision, of [ 6 73 20, reported by telephone to the hML wsthin I hour nf 73 J7. 73 50, 73 55, 73 eto or rain bocesee pouessing
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Table 1 Surnmary of Reporting Requirements Requirad Reports Description of Safeguards Event Telephone report within I bout fouowed by a wntten I.
Loss of shipment of SNM or spent fuel.
report within 30 days 2.
Recovery or accounting oflost slupment of SNM or spent fuel 3.
Threatened, attempted, or actual:
- a. Theft or un!swfuldiversion of SNM,
- b. Significant physical damage to a reactor or faclI4ty or earner possening SSNM,
- c. Unauthorued interruption of normal operations at a power reactor.
4 Actual entry of unauthorued person into a PA, MAA. CAA, VA, or transport.
S.
Uncompensated fatture, destadation, or ducovered vulnerability in a safcpards sy stem that could allow unauthorized or undetected access to a PA, M AA, CAA, VA, or transport.
6.
Actualor attempted introduction of centraband
{
into a FA, MAA, VA, or transport.
$sfenards event los cubmitted every 3 months 1.
Compenuted fa!!ure, degradation, or discovered ruinerability in a safeguards system that if uncom-penuted could have allowed unauthorued or undetected access to a PA, MAA, CAA, VA, or transport.
2.
Any other threstened, attempted, or committed act not previously defined in Appendix G of 10 CFR Part 73 that has the potential for reductng the effectiveness of the safeguards system below that committed toin a Ucensed physical security or continge.ncy plan or the actual condition of such reduction in effectiveness PA
= protected arts MAA = materialaccess area CAA
- controUed access tres VA
= vitalares SNM
= specialnuclear material SSNM
- strategic special nuclear material G.
5.62 2 u,
_ _ _ _ _ ~ -. _ - - - - _ - - - ' - - - - " - - ' " " - - - " ^ - - ~ - - ^ - ~ - - - - - ' '
i strategic special nuc1 car material ($$NM) and subject to To clarify, safeguards system failures include not only pararaph 73.67(d) are sub;cct to the provisions of pare-snechanical or electrical system failures but also irnproper
,4 su(raph 73.71(b) for events described in parspaphs 1(a)(2),
g security procedures or personnel pracucca. Discovered 1 aX3),1(b), and f(c) of Appendix G to Part 73. Ucenaces vulnerabilities include incWents in which the accurity b;cci to the provaions of ll 7310, 73.37, 73.50, 73.S $,
tystem has not failed, but some flaw in the security system I
or 73.60 are subject to the prorujons of paragraph 73.7)(b) that had existed without being noticed has been dascovered.
for events dennbed in paragraph 1(d) of Appendix G to Part 73 2.2 Examples of Safeguards Events To Be Repoeted Witido i Hour twensees subject to the provaions of $ $ 73.20,73.37, 73.30,73.55,7J 60, or each licerwe possessing SSNM and The foDowir g are exampics of events that should be sabject to parapsph 73.67(d) are subject to the provisions reported to the NRC within 1 bout because of their of pararaph 73.71(c).
potential to endanger pubuc health and safety or national secunty. This list should not be considered allinclusive.
- 2. REPORTABLE EVENTS The appucable reguladon is cited for each event, and competastory measures are discussed if appropriate.
2.1 Safeguuds Events To Be R s) Y. s Witido I Hour
- 1. Credible bomb or extortion threats. In addition Parspaphs 73.7)(a) and (b) require certain events to to the initial telephone report, a telephone report of the bc scported within I hour of discovery. Events under results of a bomb search should be made within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of paragraph 73 711a) involve incidents in which theft, loss, completion of the watch. Unsubstantiated threats need or divernon of a slurment of special nuclear instenal not be reported irnmediately utdess a specific organization (SMll or spent fuel has occurred or is believed to have or group c!dms responsibWty or the threat is one of a ouvrred A written report should be submitted to the pattern of harasstng threats, in these cases, the threat NRC mithin 30 days on each event that is reported wittun must be reported wittun i hour. (Parspaph l(aKI), (2),
Ihouf Safeguards events reporta ble under para.
or(3)of Appendix G)There are no compensatory measures graph 73 71(b) and desenbed in Appendix G to 10 CFR that would preclude the reporting of a substantiated threat Part 73 include within I hour. If a threat cannot be substantiated (no organization et group identified, negative search results,
- 1. A$ts attempts, or thrests to commit:
and no additional evidence other than the threat message),
the event need only be logged. (Aho see number 13 in tal Theft or urdswfut diversion of SNM or spent Section 2.4 of this guide.)
fuel.
(
- 1. Discovery of a criminal ace tercivtag indfrteeses thi Significant physJcal damage to s power reactor, granted unescorted protected area or vital arts access to any facWty possessti:s S$NM or such face that, in tha judgment of the beenue, adversely affects st y's equipment, to the carrier equspment radiological safety in Ucensed activides or facaty opera.
transpones nuclear fuel or spent nuclear fuel, uons (e.g., felonious acts, descovery of a sonaparasy to of to the nuclear fuel or spent nuclest fuel a bomb the facihty or disturb its ystal components, vandaham facday or carner possesses, of vital aquipment, reasonable suspictee of Allegal sale, sac, possesaloa, oc Arttrodoetion of a contropod embstamos hl interruption of normal operation of a bcensed or sitet (Paragraph !(sX2) or (3) of Appendix G) Because nuclest power reactor through the unsuthor.
of the serious nature of such an event, dacovery of the ired use of or tampenns with its machinery, event should be reported wittun I hour even af the indi.
.urnpcnents, or controls includmg the secunty vidual's unescorted access authorustson as canceDed. (Also s, mrn see number 3 in this section1 1 Any actus) entry of an unauthortred person into a
- 3. Discovery of a criminal est antoiving a person stanted prntested area, rnsterial secess ares, controUed unescorted protected area or vita! ares access if the act has auess ares. vital ares, or stansport equipment.
the potential for adversely affecting the pubuc health and safety, e.g.,IBegal un of a controDed substance offs &te by a 3 Any uncompensated failure, degradstaon, or dis-reactor controt room operator. (Paragraph l(s)(2) or (3) of covered vulnerabibly in a safeguards system that Appendix 0) ucenaces should exercise judgment &c deter-could sUow unauthorized or undetected access to a mirdng the deportability of criminal seta conducted offatte.
I protected area, material access ates,controDed access Only those acts with the potential for affecting the radio-I stes, vital arts, or carrier transporting nuclear fuel, logical safety of licensed actsviues need be reported.
spent fuel, or formula quantitles of SSNM.
Criteria that can be used to Jedge reportsbility of thew types of events include (1) the event indicates a faDure en 4 Any utual of attempted introducuon of contre-program dealsn or implementauon,(2) the person involved band cnto a protected arts. material access arra, has safety related responsibilities, or (3) the event is reoch.
l vital arca. or transport equipment ing media attention Positsve drug screens should be 4
5.62 3 l
I 3
4
vahdated pnot to determnity reportabibly lo the NRCdf
- 10. Crvil disturbance near the plant ute that nia) the event is properly comperrsated,tfg., the program failure,
pose a threat to the facihty. (Paragraph f(a M *) or (.4
,~
is corrected oc the individual's unescorted necess. as of AppendAx G) suspended, then the event ased only be logged.
II, Conrarmed tempenas of suspiuous ongin with
(
- 4. Dacovery of theft or loss of classified documents safety of aceunty equspment. (Parapaph Ita)(3), (2). or perta.irung to facihty or transport safeguards. (Paragraph (3) of Appendix Gl 1(a) of Appendix C) (Note: This is also reportable under i 95.57 of 10 CFR Part 95.) This type of event as consid-
- 12. An anault on a power r: scior, farthly, or stans-tied a credible threat to the proper safeguardma of a port possessing or transporting $$NM reptdleu of v hether factbty or transport, By the nature of ttus event, its da-penmeter penetration ss actueved. (Parapaph l(aX.l. (21, covery can occur only after a significant degradation or(3)of Appenda G) of the safeguards system dessaned to protect the classifico documents. No measure can adequately compensate for
- 13. Confirmed intrunons by unauthonted ande such an event, and events of tMs type should always be viduals anto the protected area, anaterial acceu area, con-reported withtn I hour of discovery. After the discovery, trrUed access area, vital area, or carner transportmg the beensee should endeavor to locate the missing or formula quantities of $5NM. (Paragraph 1(b) of Appen-stolen document, take measures to help ensure the event dis G) Measures should be taken to pregiude the recurrente is not repeated, and take whatever steps are possible to of such events. $mce any compensatory rnessures for suth rmntrnize the consequences of the event.
an event would be after the fact of a serious safeguards degradation, there are no compensator) measure:, that
- 5. Fire or esplosmn of suspicious or unknown origin would preclude reporting such an event within I hout ut withan the tsolation zone, protected area, matenal access dacovery. The violation of beensec.cstabhshed work rules area, or vit al area (Note Events reportable under (e g., area soning) within an eres by an authonred mde
{ { 50 72 or 50 73 do not requtre duplJeste reports under vidual need not be reported or logsed as a safeguardi event
$ U 71 )(Parapaphs 1(s)(1), C), (3), or 1(d) of Appendta
( Also we number il m Section 2A)
G) If the ongin of a fue or caplosion can be determmed within I hout to be nonsuspicious and the fcctbty sustams 14.
Uncompensated suspension of safeguards. dtfois no sigmfwant damage, the event as not considered a secunty durms either radiolog; cal or nonradiolognal emergnues threat to the factbty and need not be reported or logged that could adow undetected or unauthunted attess (Note (Also see number 4 in Section 2 5.)
F. vents reportable under il 50.72 or 50 73 do col require a
dupucate reports under l 73.71.) (Parapsph 1(c) nl 6 Dusovery of a suspicious vetucle followmg a lacensed Appendta G) Section 5 3." Controls that Can lic Suspended
{
carner transporting formula quantities of $5NM. (Paragraph Durms an Ernergency," of Regulatory GusJe 5 fi5. "Vit.nl f(a x l } of Appendia G) In tNs situation, armed escorts of Area Access Controls. Prntestion of Phyucal Sciurity other responsible personnel should determme whether or Fquipment, and het and Lrwk (mtrols " dragrahes sair not a threat esists and aness the entent of the threat, if guards measures that may he suspended during nonraJm any if a thtcat exists, at should be reported to the NRC logical e mergencscs within I hour of confirmation and the provtsions of pars-g.raph 73 26(c) should be followed If no threat entsts, the event need not be reported or logged
- 15. Dacovery of intentionally talufsed identitaation badges or key cards. (Paragraph IM nf Appendia t,1 lhis 7 Mechamtal breakJown of transport velucle carryms formula quantities of SSNM. (Paragraphs f(a)(l),.2) of event is considered a safeguards threat in the f aoht) and should always be repurted within I hour ut discover)
Appendin G) Smce it is difficult to readdy determine af a Meuures should be taken immediately to 6ancel the haJus mecharu6 al breakdown a random or intentional, and or key cards from the access system and tu deternnne to because of the strategJe sjyrufscance of the matenal, that entent the badges or ke) 6stds have hern used mechanssal breakdowns of transports carrytng formula quantities of SSNM should always be reported to the NRC wilfun I hour of dissovery
- 16. Discovery of uncornpensated and unanounted for, lost, or stolen key cards 1 D tard blanks, krys. or 8 Complete loss of offsite communications (Para
- any acteu device that enuld allom unauthoraird or paph l(aM21 or (3)of Appendta G)lf pnuible the 1 6ensee undetected anens to protetted arras rna t r ra.il auru should report the cntnplete loss of communications from areas controlled surns areas. ne vital arras (Paraginh the site within i hour or immediately after restoration of lict of Appendia G) $uth eventi nerd not he reportcJ communications if communications from the site are lost within I hour af measures are taken unthm 10 mmutes ut and cannut be restored wittun I hour, the brensee should the dissovery of the loss to prethide the use of the Imt ne use cominunications located offsite in notify the NR(-
stolen device for punirig auens to a inntrolled arra and to ensure that the lost ne stolen devnr has not been utrd
- 9. Mass dernonstration at plant site that may pose a in an unauthorsted ruanner prior in soint etion ot astiom l
threat to the farlbty (Paraparh l(a)(2) or (3) of Araen-to prevent una uthotired use of the desar tAlm ser l
din G) number 6 in Section 2 4 )
5.62-4 o
J
v
- 17. Compromae cf safegunds Irrmati:n (including are espected to discer tius type of event upon occur.
loss or thef t) that would sigruficantly aastst a personin an act tence. (Also see number 3 m Section 2.4.)
of radiological sabotage or theft of SNM. (Paragraph f(a) of 4
Appendn Gl There as no measure that would adequately
- 22. Loss of alarm capabthty or locking mechanism compenute a cornpromise of safeguards informat.on once on a material access area or. vital area portal (Paragraph the event has onurred A beensee should a! ways report thaa l(c) of Appendut G) A bolt position alarm capabihty is t> pe of ncnt wittun I hour of discovery, and fo!!ow up not a proper compensatory measure for loss of a balanced-measures simdar io those for thef t orloss of a classified docu.
magnetic alarm because it is not tamper resistant. Proper ment should be taken. (Also see number 4 sn this section.)
compensation for either of theu events rneans immediate (within 10 rrunutes of discovery) postaris of a dedicated itL Un60mpensated loss of the abdity to snorutor or observer for loss of an alarm or posting an armed enember remotely asica protected area alarms through loss of both of the secunty force for loss of a lock. The posted oburver sentral and secondary alarm stations. (Paragraph 1(c) of or guard should have appropnate commusucations equip-Appendia G) 11 the f. vent invohes an outage of the alarms, ment.t In additaon, a thorough search of the effected area 6Losed orcuit television, or secunty computers, the event should t,e stutisted immedsstely and completed as soon as n 6onuJered properly cornpensated if the onstnal capabd-practicable. Licensees are espected to discover this type of ity is restored wittun 10 minutes of discovery of the event event upon occunence. (Aiso see number 8 m Section 2.4.)
or it dedaaled observers with appropnate communaca-tions equipment are an place within 10 mmutes of the
- 23. Dacovery of the actual or attempted introduc-di e very to provide total observation of caeh area.8 tion into or poueuson wattun the protected area, matenal Licensers ste carected to discover this type of event upon access area, or vital area of unauthonard weapons, emplo-ouurten6e if immediate restoration of system capabi'ity as aives, or incendiary devaces. (Paragraph l(d) of Appenda G) provided by activating secondary computers, the loss of There are no compensatory measures that would preclude b.s kup. pabibty need not be reported withm I hour.
reporting thss event withm j hour. If an actualintroduction i A,sv see nun her 10 in Section 2.4.)
of contraband is made, steps should be taken to correct the vulnerabihty that a!! owed the introduction. The dacovery 19 Una* 4dabtht) of a marumum number of usunty of vehicular emergency equipment such as safety flares Mrvnnel or an actual or iniminent sinke by the Mcunty dunng entrance warches need not be reported of logged.
tor 6e iraray.raph its) of Appenda G) If an unenpected (Also we number 5 in alus section.)
u n n a 0 4bibt) of a niinimum number of secunty personnel mura, prosedures pre approved by the NRC may be used,
- 24. Loss of secunty weapori at the site. (Paragraph or "on.all" guards or tratned management, supervuory, or 1(aX3) of Appenda G) operations permnnel avadable withm 10 munutes may be uwd to suprkment the on duty security Inese if minimum 2.3 Esteguards Events To Be Repoeted and Subtnitted
(
remorements sannot be met, the event should be reported Quarterly in a Log milhoi i hour of den otery s
The following safeguards events reportable under 20 I nsorurensated luss of all a6 power supply to paragraph 73 71(c) need ordy be logged withan 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> scs u rit s erm> that 6uuld allom unauthonted or unde-of their dacovery and submitted quarterly to the NRC suicd auen N a protected ares, matenal access area, wurtolkd ausu area. or vital area (Paragraph l(c) of
- 1. Any faDure or degradation of a safeguards system Ap; rnJn M If the accurity system anlegnty can he maJn-or dacovered vulnerabahty m a system that could tanned l's af anJb) power, the event is considered properly have allowed unauthorned or undetected access to a 6ompenwted and need only be logged flowever, sf standby protected area, matenal accen area, controlled r a ct lath prior to restoration of ac power, the event access area, vital area, or transport equipment d enuhl be rcrorted within I hour of loss of standby power.
compensatory measures had not been estabbshed i nensers are carected to dis 6over this type of event upon (Logsms u not required for preplanned situations ouvrrerne t Alm src nurnher 7 m Sc6tson 2 4 )
that requite compensatory incasures, such as special outage work, equipment relocation, exercaes and
?!
t.nmmpensated loss of shably to detect withm a drdis, and other situations that are not the result of smee intruen dete, tion intem inne. (Paragraph l(c) of a safeguards system fadure i Apperalia I.) proper 6pmpensation for thJs event means nun.ediate drployrnent twithin 10 minutes of discovery) 2 Any other threatened, attempted, or committed a6t or Neur intruuori detutmn equipment of posting a not prevsously defsned m Appenda G that has the ikdasted oMerver with a view of the entire area and potential for reducing the effectiveness of the safe-
.aparuhty to 60mmunnste with alarm stations 8 lscensees guards system below that committed to m a hcenud physical secunty or contingency plan of the actual
':%stina personnet es a compensstrw me asure i Des that the Certonnel are eershle of performing the ust or degr ed tunellon.
h S
m.en ther rennot perform shot function. such as een ther areN3rNS$f$cI[e" Wsth respe:t to the proper compensation of an event, i
1 cornpensatory mesaures need to be implemented promptly erH ed m "i arpr..eed seresver plans to be effective For example, measures used to compensate t
S.62 5 e
1 l
for a design f!aw or vulnerabibty in a safeguards barner that immediately and completed as soon as practicable.
has esisted for some period of tirne and that could allow unauthorized or undetected access are not considered Ucenaces are espected to dacover sfus type of event upon occurrence.
effective if irnplemented rnore than 10 minutes after the flaw or vulnerabibty occurs; such events require isnmediate
- 3. Properly comperaated sjarm fadures. (Parsgraph t
reporting. Prompt implementation will aninimize any period of degradation that may exist between the occurrence and fl(s) of Appendix C) For stus event, proper cornpensation means deployment of back-up alarm equspment (a bolt.
proper compertsstion after discovery of certain events.
position alarm capabibty as not considered bacbup alarm Proper compensation after discovery of an event does not equipment because it is not tamper resistant) or posting a rebeve the hcenset from the responsibibty for taking dedicated observer withm 10 mmutes of dacovery.' The long-term corrective action, nor does it reheve the licensee dedicated observer should have apprornate cornmuruca.
from possible enforcement action by the NRC for non-tions equipment and should be able to observe the entare comphance dunna the penods of safeguards system affected area of the portal in addition, a thorough search degradation. However, bcensees are not ordinardy cited for of the affected area should be iruttated unmediately and violations resulting from matters not within their control, completed as soon as practicable. Licensees are capreted to such as equipment faalutes that occurred despite reasonable discover thu type of event upon oscurrence. (Also see bcensee quably anurance measures, testing and mainte.
number 21 m Section 2.2.)
mance programs, or management controls. (See 10 CFR Part 2, Appenda C, paragraph V.A.)
i
- 4. Properly cornpensated closed circuit televuion I
failure an a smgle zone whde the mtrusion detectson system l
False alarms (those generated without any apparent ternains operational (Paregraph Il(s) of Appenda G) cause) and nuisance alarms (those generated by an identi-Properly compensated means providing other assessmeni fled input that does not represent a safeguards thnat) capabibty, such as posting a dedicated observer with generally need not be reported or logged. However,1f false commurucations equipment to assess the entire zone or nuisance alarms are to frequent that the effectiveness of within 10 minutes of dacovery of the fadure.8 Licensees the alarm system is degraded or a pattern of false or nus-sance alarms emerges, the bcensee shou!J take corrective are expected to discover ilus type of event upon occurrence.
action and note the degraded status and compenutory
- 5. Properly compensated failure or degradation of measures taken an the safeguardi event log.
smgle perimeter bghting zone af the antrus on detretson system remams operational (Paragraph Il(s) of Appen-2A Examples of Safegua2ds Eventa To Be Reported din G) Measures to properly compensate for fadure or and Submitted Quarterly in a Log degradation of a hghttng zone must be implemented withm i
l The foUowmg are examples of events that are less 10 mmutes of dacovery and may include (1) using standby power, (2) using low-bght level survedlance devices.
{
s23rufscant than those reportable within I hour, and accord-
- 0) usms portable bghtmg systems, or (4) posting dednated ing to the rule are requtred to be logstd within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> observers with appropnate communications equipment to and submitted quarterly to the NRC. Tha hst should not be provide an equivalent level of protection.
considered all tnclusive. The appbcable regulation u cited for each event, and compensatory measures are dacussed
- 6. Properly comperasted accidental removal offsite where appropriate.
or loss of badge by emplo.yce (Paragraph Il(s) of Appen-dtn G) For thu event. proper compensation is sancellmg
- 1. Properly compensated security computer fadures the badge from the access control system within 10 minutes (Parag.raph I!(s) of Appendta G) Properly compensated of onsite personnel dacnvenng that the badge is nuuing means that within 10 minutes of the dacovery of the Measures must be taken to be sure the badge has not been fadute the system u restored to operation, the backup used in an unauthonzed manner whde it has been missing.
system ts operational, or other resources (e.g accurity (Also see number 16 in Section 2.2.1 personnel with appropnate cornmutucations equiprnent) are posted to provide an equivalent level of protection in all cases, a thorough search of au areas where ajarms or access controls may have been compromaed by the fadure 7 Properly compensated loss of the a poner supply should be trutsated untnediately and cornpleted as soon as for the enttre mitunaon detection system that. if unsom.
practicable. Licensees are espected to ducover thu type penssted, would allow unauthortred or undetesled access of event upon occurrence.
(Paragraph !!(a) of Appendia G) Proper compensation for this event is trnmediately avadable emergency powc r
- 2. Properly compensated vital area card reader failures through an uninterruptible power source such as a batter)
(Paragraph fl(a) of Appendix G) For this event. proper supported by a generator. If back up power u not avadable.
compensation sneans posting appropriate personnel (i.e..
security personnel with communications equipment should armed guard if door is unlocked, dedicated obserrer if door be posted within 10 minutes of dacovery, however, this remains locked but access is required) within 10 minutes of action u not considered proper compensation for the event discovery.' The appropriate personnel must have a current and does not excuse a bcensee from reporting the event access hst and communications capabthty to alarrn stations within I hour. Licenseen are capected to dtwover thn type A thorough search of the affected area must be anitssted of event upon occurrence ( Also see number 20 in Sc6tmn 2.2 )
5.62-6
1 l
)
- g. Properly cernpensated lo:s c:t either alarm et locking
- 3. Infrequent nuisance alarms caused by mechanical mechanism on a matenal access area or a vital area portal.
or environmental problems and false alarms that do not (Paragraph !!(a) of Appenda G) A bolt. position alarm exceed the rates committed to in the Lcensee's approved capability is not conndered a proper compensatory rnessure security plan or do not degrade alarm system effectiveneu, twause it is not tamper reostant. Proper compensation for j
thu event u irntnediate (wittun 10 mmutes of dacovery)
- 4. When the ongin of a fire or caplosion can be deter-posting of a dedicated oburver for a loss of alarm or an rnined within I hout to be nonsuspicious and the facility f
armed member of the ucunty fcce for loss of a lock.8 The sustains no sigmficant damage.
posted personnel should have appropnate communications l
equipment. In additior., a thorough search of the affected 3, PROCEDURES 1
area should be mitiated immediately and compieled as soon as practicable. Licensees are capected to dacover th4s type The determination for reporting aci event under para-of event upon occurrence. (Abo we number 23 sn Section l~
2.2.)
staphs 73.71(a), (b), and (c) should be made by onsite i.
security management or their equivalent. flowever, du-covery of such an event is not hmited to members of
- 9. Secunty computer fadures that may not enable the secunty orgaruzatJon. It is recommended that all unauthorued or undetected acceu. (Paragraph II(b) of regular sate employees receive wcurity orientation by the
(
Appenda G) security orgstdration to foster an awareness of site security 10 Lou of the capabtbty of a sangle alarm station and to be briefed on their responsibibly to immediately notify s!!s secunty of ufeguards anornabes.
to rnonitor or remotel) aucu ajarms but monitoring or aucument capability remams in other stations (Paragraph Events of a dual nature (Lc., having both safety and ll(b) of Appendia G)(Also we number 18 an Section 2.2.)
aafeguards implications and sutgect to the requirements of ll 50.72, 50.73, and 73.71) do not require dupbcate i1.
Tadsatmg by a bcenwe or contractor employee to reports under the requirements of i 73.71. If a power gam access to an area to which he or she se authorued tesclor licenue reports an event that u reportable in dacu (Paragraph illb) of Appendu G)l Also we Nmber accordance with both 6 6 50.73 and 73.71, the proce-13 tn Section 2 2 )
dures described in 5 50 73 (Le., submittal of a licensee event report (LER)) rnust be fouowed The procedures 12.
For stupments of formula quantities of SSNM, con tained in NURECr!022, "bcenwe Event Report in tra-ennvo) commuracations abibly a lost, but absbty to S ystem,"8 describe how to indicate that an LER meets e trarastaph lilbint Appendia U) commun* ate with movement control center remains.
multiple reportmg requirements When submitting reports of events reportable solely under the provisauns of l 7J 71,
(
13.
Unsubstantiated bomb or extortion threa t.
Ucensees should wnte a letter. If t.4 entten report contains power tsactor beenwes should uw y R Forrn 366, all other (Paragsaph Iltb) of Appendia G) An unsubstantiated teatricted data, e s., unclaulfied ufeguards information., the bomb or estortion threat u a threat in which no specific report must be appropf tstely marked. !f NPC Form 366 or orpnif ation of group cla2ms responsibtuty, the search 366A is used, testricted data may be included only in the result u negattve, and no evidence u avstlable other than test section (!!cm 17 of the forrn). Restricted dats should the threat menage. If a threat u one of a pattern of not be included in the abstract section (Item 16) or any harassms, even af uraubstantiated, it should be reported other uction of the form other than the text section. In within I hout addition, the text should clearly indicate the infortnation 2.5 Events Not Required To Be Logged or Reported that is restricted. Finally, the requirements of paragraph 7? 21(g) must be met when transmittmg written pro.
prjetary information.
Certain fatlures of the safeguards system that do not and could not reduce the effe6tiveness of the system have it is recognized that not allitema of NRC Form 366 httle or no ufeguards agruficance, events having httle may apply when safeguards events are reported. Power or no safeguards stgmfkance need not be reported or reactor licenwes should be sure that all the information logged The following are esemples of events that are not needed by the NRC for analysis and evaluation, sa described required to be lourd or reported Th4s bat should not be in section 3 2 of this guide, is included on the form, considered all mslusive whether under a specific stem or in the test section.
- l. Cuts rnade by authorued maintenance personnel Procedures for the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> report, the 30 day foUowup through a vrtal area betrier for a legJtirnate reason (e s,
report, and the quarterly los are discuued in the fouowing to testaD pipe)If pnot approval, coordit ation with secunty, sections.
and proper compensatory measures have been estabbshed
- 2. A r*erson ettempting to chmb a protected afee
~a p l{,d].[M, g,,,,
, 3,,,,, a y,3, y,cg,
fence af the person la obviously a ctuld Regulatory commas 4an, Nuns clo223, p,,tember i a).
5.62 7
3.1 1 Hour Reports 5.
Type of secunty force onsite (proprietary or When a licenue, licensee employee, or contract employee discovers an event reportable under paragraph 73.7)(a) or 6.
Number and type of penonnel involved, e.g.,
(b), teltphone notification to the NRC Operations Center contractors, ucunty, visitors, NRC penonnel,
{
listed in Appendtx A to 10 CFR Part 73 should be made other (specify).
within I hour of the discovery. Telephone notification should be made via the Emergency Notification System 7.
Method of discovery of incident, e.g..
routine (ENS)if the beenue is party to that system. If the ENS is inspection, test, maintenance, alarm, chance, inoperative or unavaDable, a commercial telephone should informant, communicated threat, unusual circum-be used to ensure that the required notification is received stances (give details).
by the NRC Operations Center within I hour of discovery of the event. The comme cial telephone number that may 8.
Procedural errors involved, if applicable, be uwd to contact the NRC Operations Center is (301) 951 0550. Other methods that may be used to ensure 9.
Immediate actions taken in response to event.
notification within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> include televam, maapam, or factamile. Tc!cuams and mai!pams should be hand delivered
- 10. Corrrctive actions taken or planned.
to the Operations Officer at the NRC Operations Center, Maryland National Bank Budding, 7735 Old Georgetown
- 11. Local, State, or Federal law enforcement agencies Road, Bethesda, Maryland 20814. For information con-contacted.
cernu g facsimiles, telephone the NRC Operations Center at (301) 492 8893 II perttnent information or enors are
- 12. Desenption of rnedia interest and press release.
uncovered after the initial telephone report but pnot to I
submittal of the wntten report, the licensee should notify
- 13. Indication of previous sunilar events.
the NRC Operations Center of the information or error by teleph ;ne.
- 14. Knowledgeable contact.
Under the provisions of parapaph 73.71(a), the beenwe For accurity system failures, provide the foUowing in (or agnt) should aho notify the NRC Operations Center by addition to Itema 1 through 14.
telephone withe j hout of the recovery of or accounting l
for a shipment with infonnation on the materiallocated,
- 15. Desenption of failed or malfunctioned equipment known reason for loss. ett (includtng manufacturer and model num ber).
(
Telephone reports made pursuant to i 73 71 may be
- 16. Apparent cauw of each component or system transmitted over unprotected bnes as permittec by the failure (For uncompensated security computer esemption in paragrarh 13 :l(gM3) fadures, atste the reason the event could not be compensated and bst specific components affected, 3.2 30 Day Fonowup written Reports e s., central processur, peripheral / terminal equip-i ment, software )
A foUomup wntien report must be submitted within i
30 days of a l hout report. Power reactor b6ensees should
- 17. Status of the equipment ptsor to the event (e s.,
use the Lisensee I. vent Report forrn, NRC l'orm 366, in operating, being mainta ned, made securel and subrnitting their reports. all other bcensees should use a compensatory measures an place letter format. For all beenwes, the information dessnbed below is suffscient for NRC analysts and evaluation and
- 18. Secorslary furctions affected (for multiple function should be included in the report as a minimum. Reports components) of evem must be legjble and reproducible and should inclu e the fouontrig.
- 19. Effect on plant afety.
1.
Date and itme of event (start and end time)
- 20. Unusual conditions that may have contributed to failure, e g., enttronmental entremes.
2.
Lo6ation of actual of threatened event in a pro-tc6ted area. matenal accesa area, controUed f or threst related incidents, provide the fouowing in acteu area, vital area, or other (specify area),
addition to items I through 14 3 Int pnwer re ac t ors, the operating phase, e g,
21 Number of perpetrators shutdown, ore rstmg 4 Safety systems affected of threatened, direstly or indirectly 23 Means of communication e p., letter. telephone.
4 5.62 8 I
w -
24 Text of threat.
I, Date and time of the event;
- 25. Mode of operation.
- 2. Brief(one-line) description of the event;
- 26. Clear photxopy of threat letter and accompanying
- 3. Brief (one41ne) description of compt.nsstory or f
envelope s! appbcable.
corrective actions taken; Licinues should submit one copy of each written
- 4. Area affected, e.g.,
vital ares, protected ates, report to the U.S. Huclear Regulatory Cornmission, ownet controlled, transport; snd Document Control Desk, Washington, DC 20555, and one copy to the appropnate Regional Office listed in Appen-5,How detected, e.g, alarm, routine inspections, dn A to 10 CFR Part 73. If pertinent information or patrol, informants.
errors are uncovered after the initial telephone report or the written report as submitted, the licenses should notify Every 3 months, the licerace is requind to submit one the NRC Operations Center by telephone of the informs-copy of all log entries not previously submitted to the tion or errors !! the information is uncovend after the NRC Document Control Desk. The los entries need not be winten report ha. been submitted, the licensee should typed as long as they an legible, a photocopy is accept-submit a complete revised wntien report with revisions able. Ucensees are permitted a 3Nsy grace period for indicated to the Docurnent Control Deak and the Regional all ios submittala.
Office. The revised report shouid be complete and should not contain only the supplementary or revised information.
Events of a similar nature that are lossed and sub-3.3 Maintenance and Quarteriy Submittal of Log rnitted to the NRC under parspaph 73.71(c) may be consoudsted into a single los entryif they occur repeatedly Events reportable under parapsph 73.71(c) only need within the quarterly submittaj period. The date and time to be loyed in maintauung the log, it as recommended should be specified for sach occunence of the event. For that the b6cnsee log the mformation as received and then example,1f there is a repeated occunence of a compensated suminarue and update the los entry when the event computer failure and each failure is the result of the same terminates llowever, bcensees are required by parspaph problem, ordy one los entry providing the deta!!s of I l
73.71(c) to les entnes withan 24 houri of the discovery of through 5 above need be made. However, the date, time, the event. Strue the bcensee would immediately investigate and durstjon of the event should be recorded in the log all events that threatened nuclear actrvatics or lesuned the for each occurrence.
i rifectivericss of the secunty system, the details would
(
generau) be avu!able when the entry was made an the los Each los must be retained for 3 years after the last Los entries should include as a minimum entry to that log.
t 5.62 9
d APPENDIX A
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GLOSSARY NOTE: Tha glossary ordy appbes to the requirements of $73.71 of 10 CFR Part 73.
Anylatlure degradation. or dlttorertd rulatrebtitty: The Nulsantr olarm: An alarm genersted by sn identified cessation of proper functionmg or performance of equip-input that does not represent a safeguards thnst. Nulsance ment, personnel, or procedures that compose the physical alstms may be caused by environmental (rain, slect, snow, protection program neceuary to meet Part 73 require-laghtrdng) or mechanical (natural objects such as animals ments, or a discovered defect in such equipment, personnel, or tall grass) factors.
or procedures that degrades function or performance.
Properfy comptnasted. Measures, including backup equip-Crrdib/r rArter A threat should be considered credible ment, additional accurity penonnel, and spwcific proce-when t1) physical evidence supporting the thnst esists, dures, taken to ensure that the effectsvenen of the accurity (2) mformation independent from the actual threat system as not reduced by failure or other contingencies inessJge eltsts that supports th threat, or (3)s specific affecting the operation of the security related equipment g.roup or organization claims responsibiUty for the threst.
or structures. Preplanned compensatory measures are normally described in NRC spproved safeguards plans.
Drdiestad observer. A person, not necessardy a member of the se6urity force, posted as a temporary compensatory Seftrverdstwnt: Any incident representing an attempted, rnessure for a degraded auessment or detection capabihty thnstened, or actual breach of the safeguards system or both Whde performms this function, duties must be or reduction of the operational effectivenen of that
{
bmited to detection and sucument. As a mirimum, the system.
person must be able to view the entire ans affected by the degradation and rnust be able to communicate with Seftfuerds frentlor: A compdation of log entries for the the central a; arm stahon events desenbed in Section !! of Appendtx G to 10 CFR Part 73. Entnes must include the date and time of the Derenson o/SMI Unauthortred movement of SNM byindb event, a description of the event, and any action taken.
vidush authorized accru to or control over the material.
Repeated events may be consolidated into a single los entry j
with the date, time, and duration of each event recorded
\\
Felse storm An alarm generated without an apparent for each occurrence. The ongoms safeguards event los may inveshgation dis,; loses no evidence of a vaud alarm be maintained in more than one location onsite. The log sauw con & tion msludmg tamperms, no nuisance alstm ccndi-may be typed or handwntier as long as it is legible and tions and no equipment malfunction.
reproducible. Entnes in a safeguards event log submitted to the NRC need not be in time 4equentist order, forerrut,tonn of normaloptretton The cessation of norms) operatmn that, if accomphshed, would result sn sub-Seftruards system: The equipment, penonnel, and stantial emnomi6 harm of cost to the licensee.
Procedures that make up the physical protection program nectuary to meet Part 73 requirements.
l.em of.H LI i l } A f ailure to rnessure or account for matettal h) the material control and accounting system approved for the faulit) when the maternalis authortied to beposesud Slgn(ficent paps /tsi dsmagt Physacal damage to the by the lisensee and sa not confirmed siolen or dtverted or(2) salent that the facility, equipment, transport, or fuel an 6udental o e, unplanned)offsite releau or dispenal of cannot perform its normal function (appbes to a power Mat knnan or suspected to be 10 times greaterthan normal reactor, a fact! sty ponesatng SSNM or its equipment, operanny loves for the time in question,whether or nnt the estner equipment transportmg nuclear fuel or spent relesw a measured The term losa impbes that a watch has nuclest fuel, of to the nuclest fuel or spent nuclear fucI a l
hern sonJusted to confirm the materialts misates. For flaed facility or carner poueuest.
sites, this scar 6h should be conducted within the I hout time for rernrting Tampering: When used in connection with Appendia G to "1.nst" versus "unaccountedfor" to rtserd to rrensporte-10 CFR Part 73, alter 1ng for improper purposes or in an
]
tron of marrraal The term " lost" covers material that is rio improper manner.
1 longer an the popession of the party authortred to poucas tr during a specific time period, and a March for the mate-Tht/t of SNM. The unauthortred taking of $NM for real has verified the loss " Unaccounted for" refers to unauthorized use.
maleri.d in transit that has not attrved at its delivery point 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or more after the estimated arrival time, however, e
(/nauthortrad person Any unescorted penon in an area warth has not confirmed the matettal to be lost.
to which the person is not authorized unescorted access.
5.62 10 E
l 1,
APPENDIX B RAMPLE LOG ENTRIES Safeguards events reportable under paragraph 73.71(c) of 10 CFR Part 73 need only be logged within 24 houn of mitted to the NRC every 3 months does not have to be their discovery. The copy of the log (photocopy) sub-typewritten, but 11 must be legible. The sample los items presented here thould not be considered all-inclusive.
LOG ENTRY EVENT DATE/ TIME DATE/ TIME EVENT
RESPONSE
1.
18 87/0140 14 47/0130 CAS operstor received telephone bomb Area search snitsated at 0135 hrs, threat from unidentified male. Bomb completed 0140 hn, nothing reported near diesel generator, found.
2.
1 8 87/1245 14 47/1043 Delfvery truck significantly dsmaged PA Guard posted at 1050 hrs, relienng fence in zone No. 4. Discovered at 1047 patrol (immediate comp), PA by security patrol, no FA or VA alanns
- searched, received.
3.
1 947/1605 1 947/1433 Card reader failure at VA portal No. 2.
At 1440 hrs, posted guard with cunent access list. System failure corrected and opera-tional at 1600 hrs.
4 1 987/1815 1 987/1730 f.D. badge No. 342 lost onsite.
Badge cancelled 1732 hrs Badse (cund on employee'sJacket at 1745 hrs.
V 5.
1 9 87/2055 l 947/2025 Secunty system failure, single CPU Determined caused by electrical
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- outast, storm / power surse. System back on line at 2028 hrs All VA portals confirmed locked and alarmed by secunty.
6.
1 10 87/1410 1 10 41/1405 Fence repaired. (See Entry No. 2.)
Compensatory post discontinued at 1405.
7.
1 124 7/1100 1 1347/0812 Perimeter fence alarms resolved Area searsned by secunty ratrol.
1 1247/0815 aone No. 4.
No apparent cause for alarins.
1 1247/0817 1 12 87/0819 Security posted after third alarm 4 124 7/0823 and maintenance called tu check system. System function venfied through test each occurrence At actions completed 1035 8.
1 124 7/1610 1 124 7/1443 CCTV failure, perimeter tone No. 2 Dedicated observer in place 1450 (IDS operational),
hrs. No alarms received. Camera reg.;0 'snd operational at 1610.
9.
1 124 7/2015 1 12 87/2007 See No. 5 above.
Same as No. 5 above. System erbline at 20l! hrs 10.
1 1247/2350 1 1247/2230 Latch alarm received on VA portal Guard poeted at 2238 Area No. 6. Responder found door slightly searched, no abnormalities found, afar.
Maintenance request snatiated at 2315.
t
.v. s.sevtsaster estattec err ecc ettav ter.rer. sort' 5.62 11
4 VALUE/ IMPACT STATEMENT A separate value/ impact statement has not been for the proposed revisions to { 73.71 and was made prepared for this regulatory guide. The guide was tuvised evallable in the NRC PubUc Document Room at the time to provide guidance on reporting physical security events of pubucation (August 27,1983-30 FR 34708). This in accordance with paragraphs 73.7)(a) through (c) of regulatory analysis is also appropriate for thas regulatory 10 CFR Part 73. A regulatory analysis was prepared guide.
I 1
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UNITED STATES
,,.s, ca s...
NUCLEAR REGULATORY COMMISSION Pos' *o' * 's * * **'o WASHINGTON, O.C. 20555 re nun a,. o s, CFFICIAL BV$1NIS$
PENALTY FOR PRIVATE USE. 4XC 120555064215 US NRC=0 ARM-TRM1 10P11S11R g DIV 0F INFO SUP SVCS DOCUME*l7 CONTROL RPANCH l
DOCUMENT CONTROL OCSK 042 WASHINGTON OC 20555 1
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9 5.62 12
A VALUE/ IMPACT 8TATEMENT A separate value/ impact statement has not been for the proposed revisions to { 73,71 and was made prepand for this regulatory guide. The guide was revised siaDable in the NRC Public Document Room at the time to provide guidance on reporting physical security events of publication (August 27,1985-50 FR 34708) This in accordance with paragraphs 73.71(a) through (c) of regu'atory analysis is also appropriate for this regulatory 10 CFR Part 73. A regulatory analysis was pnpared guide.
UNITED STATES
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NUCLEAR REGULATORY COMMISSION
. 81 CMS $ Malt
"l,, g' ' 8 WASHINGTON, D.C. 20566 eenurt. e n OF.
,,AL BUSINES$
P[NALTY FOR PRIVAT ( U$f. 82 bk kbh h2 nM 1
t 10P11Sl}o g DIV 0F INFO SUP SVCS 0 0 C UM E 's t CONTROL RPANCH UNENT CONTROL DESK 6tASH!NGroN OC 20555 l
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$.6212 k -w.
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~l NUREG 1304 l
Reaorting o" Safeguarcs Events 1
l i
1 Man scoot Compieten SeDruan 1988 u
D.itr Put* sher 1 Feb'very 1988 PA Dme' N E E sin Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation U S. Nuclear Regulatory Commission i
Washington DC 20555
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+ + " '
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I ABSTRACT On June 9, 1987, the Commission published in the Federal Register a final rule revising the reporting requirements for safeguards events.
Safeguards events include actual or attempted theft of special nuclear material (SNM); actual or attempted acts or events which interrupt normal operations at power reactors due to unauthorized use of or tampering with machinery, Components, or controls, certain threats made against facilities possessing SNM, and safeguards system failures impacting the effectiveness of the system.
The revised rule was effective October 8, 1987. On September 14, 1987, the NRC held a workshop in Bethesda, MD to answer affected licensees' questions on the.
final rule.
This report documents questions discussed at the September 14 meeting, reflects a comDIeted staff review of the answers, and supersedes previous oral comment on the topics covered.
Answers that have been revised are identified by an asterisk next to the questeon number. After additional ~
experience is gaineo ur. der the new reporting regulat nns in 10 CFR 13.71, the i
NRC staf f also intends in revise its formal guidance in Regulatory Guide 6.62, as appropriate.
l 3
1 111
I c.
- i CONTENTS tue ABSTRACT iii i
- 1. 0 INTRODUCTION 1
I 2.0 REPORTABLE EVENTS (GENERAL).
3
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2.1 SAFEGUARDS EVENTS TO BE REPORTED WlTHIN ONE HOUR (GErrQA 3
l 2.2 EXAMPtr5 0F SAFEGUARDS EVENTS TO BE REPORTED WITHIN ONE HOU 4
q 2.3 SAFEGUARDS EVENTS TO BE REPORTED AND SUBMITTED QUARTERLY IN A LOG { GENERAL).
16 2.4 EXAMPLES OF SAFEGUARDS EVENTS TO BE REPORTED AND SUBMITTED QUARTERLY IN A LOG 17 1
_ _ _ _ _ _ _ _ _ _ _ _ _ _. - _ _ _ - - - - - - - - - - - - - - - - - - - ^ ~ - - - ~
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1.0 INTRODUCTION
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On September 14, 1987, the NRC staff conducted a workshop to respond to affected licensees' questions on revisions to 10 CFR 73.71, " Reporting Requirements for Safeguards Events", published on June 9,1987 (52 FR 21651),
effective on October 8, 1987. Many questions were also directed at the rule's supporting regulatory guide, Regulatory Guide 5.62, " Reporting of Safeguards Events", Rev.
1.
This report documents questions discussed at the September 14 meeting, reflects a completed staf f review of the answers, and supersedes previous oral comment on the topics covered. Answers that have been revised are identified by an asterisk next the the question number. Af ter additional experience is gained under the new reporting regulations in 10 CFR 73.71, the NRC staff also intends to revise its formal guidance in Regulatory Guide 5.62, as appropriate, The organization of this report is based on Sections 2.2 and 2.4 of Regulatory Guide 5.62; questions and responses are grouped under either " General" I
categories or appropriate regulatory guide examples of items to be reported or logged
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i 1
-_ = - _ _ _ -
2.0 ReportableEvents(General,}
t Q. 2.0.1.
If a report is made under 10 CFR 50.72 or 10 CFR 50.73 tor an event that is also reportable under 10 CFR 73.71, is a duplicate report required under 10 CFR 73.71?
A.
No.
- Q. 2.0.2.
If a report is made under 10 CFR 73.71 for an event that is also reportable under 10 CFR 50.72 or 50.73, is a duplicate report under 10 CFR 50.72 or 50.73 required to be made?
A.
No.
Duplicate reports are not required.
"Q. 2.0.3.
Does guidance found in a regulatory guide supersede approved security plan commitments?
A.
No.
Q 2.0.4 Must plan amendments be submitted which commit to implement the revised 10 CFR 73.71?
A.
No.
However, if certain provisions in licensees' plans are no longer authorized under the new 73.71 rule, licensees should make conforming revisions to their plans through 10 CFR 50.54(p) or 10 CFR 70.32(e) changes, as appropriate.
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Q. 2.0.5.
Is there a relationship between the safeguards severity levels in Appendix C to 10 CFR Part 2 and the revised 10 CFR 73.71?
A.
No.
However, the staff did attempt to ensure consistency in philosophy, 2.1 Safeguards Events To Be Reported Within One Hour (General)
Q. 2.1.1.
Can a one hour report be converted to a log item if a licensee erroneously reports an item that should be logged as a one hour report?
A.
Yes.
Q. 2.1.2.
If pertinent information is uncovered after an initial telephon k notification, should the pertinent information be telephoned tv the NRC Opera-tions Center?
A.
Yes, but only if the information is signi'icant. Significant information is that which would affect licensee or NRC response to the event.
'Q. 2.1.3.
What procedures should licensees follow if compensatory measures in approved security plans are different than compensatory measures described in the guide?
A.
The guidance in Regulatory Guide 5.62 is not intended to supplant any regulation or NRC-approved licensee safeguards plan. Accordingly compensatory actions taken by licensees in accordance with approved security plans will I
permit the logging of certain events in lieu of reporting them within one hour.
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1 u---_.m_
__.mm_ _ _ _ _ -. _ _ _ _ _
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The regulatory guide contains examples of acceptable compensa' tory measures to guide licensee reporting in situations not covered by approved safeguarcs g
plans.
Q. 2.1.4.
involving interruption of normal operation begin?When does the o l
A.
The clock begins when there is reasonable suspicion that the incident is the result of unauthorized use of or tampering with equioment, controls, etc.
"Q.
2.1. 5.
The LER fore has a " block" where you provide a sequential number for events.
Should we use the same numbering system for security events as for safety events?
i A.
No.
The sequential numbering system for security events should start with the letter "5", f ollowed by a two digit sequential number.
(See the following example.)
EKAMPLE:
~~
LER NUMBER {dT~
~
REPORT DATE (7) l!AR SEQ. NUMBER Rt V.
NUMB E R_ __
MONTH DAY YEAR I t
On1 Sr0:1 0:0 10 0,9 8 7 l i
g 11 ynu exceed 99 events in one year, replace the "5" with a "T" 22 E=amples of Safeguards Events that Should Be Reported within One Hour 222 Credible bomb or extortion threats.
In addition to the initial telephone report, a telephone report of the results of a bomb search should be made within one hour of completion of the search.
Unsubstantiated threats need not be reported immediately unless a specific urbanization or group claims responsibility or the threat is one of a pattern of harassing threats; in these cases, the threat must be reported within one hour.
(Paragraph 1(a)(1), (2), or (3) of Appendix G. ) Ihere are no compensatory measures that would preclude the reporting of a substantiated threat within one hour.
If a threat cannot be substantiated (nu organization or group identified, negative search results, and no additional evidence other than the threat message), the event need only be logged.
( Also see number 13 in Section 2.4. )
Q 2?Ia Does this example include credible threats to commit cert *in actions' A.
Yes, if the threatened actions are as described in Appendix G Paragraph 1, of 10 CFR 73.71, as events to be reported within one hour
- Q 2 2 1 b.
If a bomb threat is apparently unsubstantiated but search results cannot be obtained within an hour, should the threat be reported within one hour' If so, can the event status be changed if the resu't of subsequent j
search is negative) 4
..-m-um
A.
If a specific organization or group has not claimed responsibility and the threat is not one of a pattern of harassing threats, the decision to report or g
log can await the results of the search if the search can be completed within a reasonable time.
If the threat cannot be substantiated (no organization or group identified, negative search results, and no additional evidence other than the threat message), the event need only be logged.
It should always be reported within one hour if substantiated.
2.2.2 Discovery of a criminal act involving individuals granted unescorted protected area or vital area access that, in the judgment of the licensee, adverstly affects radiological safety in licensed activities or facility operations (e.g., felonious acts, discovery of a conspiracy to bomb the facility or disturb its vital components, vandalism of vital equipment, reasonable suspicion of illegal sale, use, possession, or introduction of a controlled substance onsite). (Paragraph 1(a)(2) or (3) of Appendix G.) Because of the serious nature of such an event, discovery of the event should be reported within one hour even if the individual's unescorted access authorization is cancelled. (Also see number 3 in this section.)
Q. 2.2.2.a.
Is this example intended to cover only criminal acts onsite? If so, how.is onsite defined with respect to the facility's protected area and the introduction of a controlled substance?
A.
Yes, this example if, intended to cover only criminal acts onsite. Onsite is defined as inside the protected ares. Detection of a controlled substance at an entry point to a protected area or within the owner controlled area outside of the protected areas should be logged.
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Q. 2.2.2.b.
Does the term " criminal act" imply conviction of the individual?
A.
No.
Acts of concern are those judged by licensees to adversely affect radio!ogical safety in licensed activities or facility operations.
Q. 2.2.2.c.
If management decides to perform drug screening on an individual based on reasonable suspicion for cause, does the time clock for deportability begin when initial tests give positive results or when the results are confirmed? If the individual's unescorted access is suspended, does the event need only be logged? Assume this person has safety-related responsibilities.
A.
The time clock begins when the licensee has reasonable suspicion that an irdividual is abusing drugs onsite or is under the influence while onsite. Any illegal sale, possession, or use of a controlled substance onsite is reportable within one hour regardless of the responsibilities of the individual involved.
For further discussion of the offsite aspects of this question see paragraph 2.2 3 below.
Q. 2.2.2.d.
If a suspected controlled substance is found casite, does the one hour time clock start when the discovery is made, or, af ter laboratory tests have confirmed that the material is a controlled subt,tance?
A.
The time clock begins when there is reasonable suspicion that the material is a controlled substance.
I 5
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Q. 2.2.2.e.
Do allegations of (liegel sale, use, possession, or introduction of a controlled substance onsite constitute reasonable suspicion, thus.. m i
the. allegation itself reportable within one houe?
A.
No.
licensee's judgment, the allegation is valid.Such an allegation shoul Q. 2.2.2.f.
Can the apparent validity of the allegation be used to determine by a known individual, or by a private citizen versus a law e officer?
A.
Yes.
The credibility of the source can be used to evaluate the reasonable suspicion factor.
Q. 2.2.2.g.
Could not the reporting of suspicion of illegal use of a controlled substance undermine or compromise police undercover activities?
A.
Licensees are expected to maintain liaison with local law enforcement Submission of 6-itten reports can be delayed, with appro NRC Regional of fice, to minimize the possibility of compromise Q. 2.2.2.h.
Define the term " reasonable suspicion."
A.
for believing that something is true. Reasonable suspicion implies that k
2.2.3 Discovery of a criminal act involving a person granted unescorted protected area or vital area access if the act has the potential for adversely af fecting the public health and safety, e.g., i!iegal use of a controlled substance of fsite by a reactor control room operator.
(Paragraph 1(a)(2) or (3) of Appendix G. ) Licensees should exercise judgment in determining the deportability of criminal acts conducted offsite.
radiological safety of licensed activities need be reported.Onl (1) the event Indicates a failure in program design or imple Criteria (2) the person involved has safety-related responsibilities, or (3) the event is receiving media attention.
validated prior to determining deportability to the NRC. Positive drug screens sh properly compensated, e.g., the program f ailure is correcte6 or, forIf the event is individuals with no safety-related responsibilities, the individual's unescorted access is suspended, then the event need only be logged.,
Q. 2.2.3.a.
15 offsite?
this example intended to cover only criminal acts committed A.
Yes.
Q. 2.2.3.b.
Why is " media interest" required to be reported within one hour?
A.
Media interest by itself is not required to be reported within one hour to the NRC ticensees are encouraged to use media interest in a safeguards event 6
__________.__m..._.___
l l
l as one criterion for determining deportability of an event where licensee I
judgment must be exercised.
i "Q. 2.2.3.c.
If an employee turns himself or herself in to an employee assistance program because of drug or alcohol abuse, should this be reported,or logged? Wouldn't this impact confidentiality of the program?
A, if continued performance in the individual's state constitutes a hazard to i
the public health and safety, including fellow employees, then the EAP has the f
obligation to inform appropriate management who should withdraw unescorted access and log the event. Presumably, licensees will handle such cases with due regard for confidentiality and privacy. However, public health and safety consideratfors must outweigh all other considerations in such cases.
I "Q. 2.2.3.d.
What steps should a licensee take when an allegation of drug use offsite is received?
A.
(1) Attempt to verify the allegation, (2) if reasonable suspicion eAlsts, log the item and follow normal procedures for handling an allegation.
"Q. 2.2.3.e.
What does the term "... person involved has safety-related responsibilities" mean?
A.
Actions of the person have the potential for affecting tne radiological safety of licensed activities.
- Q. 2.2.3.f.
If results of an individual's annual drug screen are positive should the event be reported or logged?
(
The event may be logged if their unescorted access is suspended pending A.
completion of any additional confirmatory tests and reviews.
2.2.4 Discovery of t Ac f t or loss of classified documents pertaining to facility or transport safeguards.
(Paragraph !(a) of Appendix G.)
(Note: This is also reportable under 5 95.57 of 10 CFR Part 95.) T5is type of event is considered a credible threat to the proper safeguard.ng of a facility or transport. By the nature of this event, its discovery can occur only after a significant degradation of the safeguards system designed to protect the classified documents has occurred. No measure can adequately compensate for such an event, and events of this type should always be reported within one hour of discovery. Af ter the discovery, the licensee should endeavor to locate the missing or stolen document, take measures to help ensure the event {$ not repeated, and take whatever steps are possible to minimize the consequences of the event.
No questions were received on this item 2.2.5 Fire or explosion of suspicious or unknown origin within the isolation zone, protected area, material access area, or vital area.
(Note: Events reportable under $$ 50.72 or 50.73 do not require duplicate reports under 5 73. 71. ) (Paragraphs !(a)(1), (2), or (3), or 1(d) of Appendix G.)
If the origin of a fire or explosion can be determined l
within one hour to be nonsuspicious and the facility sustains no 4
i 7
_ l
4
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y damage, the event is not considered a security threat to the i
d n-
- not, be reported or logged.
- ransport possessing l
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penetration is
'd e rs..tved or, this item, x G'.)
i overy of a suspicious vehicle following a licensed carrier g formula quantities of SSNM.
(Paragraph 1(a)(1) of
) In this situation, armed escorts or other responsible sais into the l
nuld determine whether or not a threat exists and assess the
!ss area, vital area, u threat, if any.
If a threat exists, it should be reported (Paragraph 1(b) of
<ithin one hour of confirmation and the provisions of paragraph ie recurrence of such puld be followed.
if no threat exists, the event need not be event would be after Icgged.
are no compensatory
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within one hour of received on this item, k rules (e.g., area ed not be reported or nical breakdown of transport vehicle carrying formula i Section 2.4.)
f SSNM.
(Paragraphs f(a)(1), (2) of Appendix G. ) Since it is readily determine if a mechanical breakdown is random or i an escort while that he or she and because of the strategic significance of the material, reakdowns of transports carrying formula quantities of SSNM ted?
s be reported to the NRC within one hour of discovery.
access promptly r2ceived on this item.
minutes of not be maintained ate loss of offsite communications.
ess. Otherwise, the (Paragraph 1(a)(2) or (3) sitor has not been
- i. )
If possible, the licensee should report the Complete loss (or N om the site within one hour or immediately after f(
.nications.
If communications from the site are lost re nored within one hour, the licensee should use work rules (e.g.. area s located offsite to notify the NRC.
in which offsite communications this example refers to, d for reasons other ed at fuel facilities of offsite communications means loss of telephone and radio except with respect ch be or she is tmonstration at plant site that may pose a threat to the tragraph !(a)(2) or (3) of Appendix G. )
ess device intended he area, should the i demonstration directed at other than nuclear related ility need to be reported to the NRC?
corted vital area as no impact on nuclear activities.
explained need be disturbance near the plant site that may pose a threat to (Paragraph 1(a)(2) or (3) of Appendix G. )
otected area but is stopped before tceived on this item.
I or logged?
ied tampering of suspicious origin with safr.ty or security tragraph 1(a)(1)., (2), or (3) of Appendix C. )
ce' on this item.
8 r
2.2.14 Uncompensated suspension of safeguards controls during either radiological or nonradiological emergencies that could allow undetected or
(
unauthorized access.
(Note: Events reportable under SS 50.72 or 50.73 do not require duplicate reports under i 73.71.) (Paragraph 1(c) of Appenoix G.) Section 5.3, " Controls that Can Be Suspended During an Emergency," of Regulatory Guide 5.65, " Vital Area Access Controls, Protection of Physical Security Equipment, and Key and Lock Controls "
describes safeguards measures that may be suspended during'nonradiological emergencies.
No questions were received on this item.
2.2.15 Discovery of intentionally falsified identification badges or key cards.
(Paragraph 1(a) of Appendix 0.) This event is considered a safeguards threat to the facility and should always be reported within one hour of discovery. Measures should be taken immediately to cancel the badges or key cards from the access system and to determine to what extent the badges or key cards have been used.
No questions were received on this item.
2.2.16 Discovery of uncompensated and unaccounted for, lost, or stolen key cards, 1.0. card blanks, keys, or any access device that could allow unauthorized or undetected access to protected areas, material access areas, controlled access areas, or vital arees.
(Paragraph 1(c) of Appendix G.) -Such events need not be reported within one hour if measures are taken within 10 minutes of the discovery of the loss to preclude the
(
use of the lost or stolen device for gaining access to a controlled area and to ensure that the lost or stolen device has not been used in an unauthorized manner prior to completion of actions to prevent unauthorized use of the device.
(Also see nurber 6 in Section 2.4.)
- Q. 2.2.16.a.
If an access device is lost or stolen, must two actions be taken. e.g., action to preclude the use of the lost or stolen device and action to ensure that the lost or stolen device has not been used in ac unauthorized manner, in order to log the event?
A.
If action to preclude the use of the lost or stolen device is Completed within 10 minutes of discovery, and action is initiated to ensure that the device has not been used in an unauthorized manner, the event should be logged.
2.2.17 Compromise of safeguards inf)rmation (including loss or thef t)
{
that would significantly assist a person in an act of radiological sabotage or theft of SNM.
(Paragraph 1(a) of Appendix G. ) There is no measure that wosid adequately compensate a compromise of safeguards information once the evn t has occurred. A licensee should always report this type of event within s e hour of discovery, and follow-up measures j
similar to those for the't or loss of a classified document should be (Also see number 4 in Section 2.2 above. )
)
taken.
Q. 2.2.17.a.
What does the term "
significantly assist in an act of radiological sabotage.
" mean with respect to loss of safeguards information?
i 10
1 e*
A.
This term means information that could be used to gain unauthorized or undetected access to a facility or information which would significantly assist q
an individual in damaging the facility or in thef t of SNM.
{
(
Q. 2. 2.17. b.
Beyond verbal compromise, is there a difference between I
)
compromise of safeguards information and theft or loss of a classified document?
A.
Yes. Classified documents are national security information. Theft or f
loss of these documents is always required to be reported within one hour of i
discovery.
If lost safeguards information could significantly assist an l
individual in an act of radiological sabotage or theft of SNM, it is also required to be reported within one hour. However, if the lost safeguards j
information could not significantly assist in these acts, the event should be i
logged and the system failure corrected.
Q. 2. 2.17. c. How long can safeguards information be missing before it is considered losti A.
The NRC staf f expects a report to be made within one hour of discovery that 1
the document is missing.
Q. 2.2.17.d.
In view of the regulatory reference in Appendir G to Part 73 which allows for reduced reporting if the event is compensated, why can't a significant loss or theft of safeguards information be compensated and logged?
A There is no adequate compensatory measure. The reference to Appendix G contained a typographical error which has since been corrected.
The reference has been changed to Appendix G.I.(a).
(
2.2.18
(
Uncompensated loss of the ability to monitor or remotely assess protected area alarms through loss of both central and secondary alarr1 stations.
(Paragraph 1(c) of Appendix G.) If the event involves an q
outage of the alarms, closed circuit television, or security computers, 1
the event is considered properly compensated if the original capability is restored within 10 minutes of discovery of the event or if dedicated cbservers with appropriate communications are in place within 10 minutes of the discovery to provide total Observation of each area.8 Licensees are expected to discover this type of event upon occurrence.
If immediate restoration of system capability is provided by activating secondary computers, the loss of backup capability need not be reported within one hour.
(Also see number 10 in Section 2.4.)
i Q
2.2.18.a.
Does immediate restoration of system capability mean restoration within 10 minutes?
A.
- Yes, IPosting personnel as a compensatory measure implies that the personnel are capable of performing the lost or degraded function. When they cannot per-form that function, such as when they are asleep, there is an uncompensated loss that must be reported within I hour of discovery.
Preplanned compensatory meawres are normally described in NRC-approved safeguards plans.
I 11
t e
P lot both the central alarm station and the secondary an actual or imminent erl,.ampensated as described in item 18, should the event i require immediate condary computer is lost also, should the event be sorting? This is our?
ar dealing with a strike 5 ceant by the term "back up capability" in item 18?
Its responsibility for
- llity during a strike by
- 1. this term means secondary computers.
accomplished through a
'd:dicated observer" receive security training?
1 ability of a minimum er must be trained in and capable of performing any getting additional uard force members have tion. However, dedicated observers are not required to rity force.
10 minutes, urity systems are designed with built-in redundancies nt of the system fails, such as a central processing unit sures and unique RC staff to arrive at
, another one instantaneously functions in its place.
Is h redundant element reportable under 10 CFR 73.71?
cing a sick security is automatic such that there is no loss M system gradation, the event is not required to be reported or strike is going to occur, y does occur?
!d s phrase "... licensees are expected to discover i ocu rrence.
, it is recognized that in most cases, ecurity electronics systems will be discovered upon lure can be detected by line supervision cesign, etc.
to security systems that 5 due to a loss in sensitivity, the event will not be a protected area, vital area.
nce, but rather when a test is made of that component, mean "upon :'iscovery" when the failure of the alarm is system integrity can be ity?
red properly compensated er fails prior to rted within one hour of red to monitcr the functioning of their alarms and discover this type of eness through proper maintenance and testing programs, tion 2.4.)
dic recalibrations. Regardless of when it may have falls" due to loss of sensitivity it should be immediately than 10 minutes) should ninutes of discovery) and the event should be logged.
ited within 10 minutes of discovery it fhould be integrity is not ity of a minimum number of security personnel or an ted within one hour, security plan.
strike by the security force.
(Paragraph 1(c) of unexpected unavailability of a minimum number of ithin a single intrusion occurs, procedures pre-approved by the NRC may be used; ix G.) Proper or trained management, supervisory, or operations yment (within 10 minutes within 10 minutes may be used to supplement the tent or posting a l
If minimum requirements cannot be met, the event rce.
within one hour of discovery.
and capability to I
th m " imminent" mean with respect to a security I
l 12 puum e a_
r y.p.
.I k s
communicate with alars stations.1 (Also see number 3 in Section 2.4.)
Licensees are expected to discover this type of ev.nt upon occurrence.
No questions were received on this ites.
2.2.22 Loss of alarm capability or locking mechanism on a material access area or vital area portal. (Paragraph !(c) of Appendix G.) A bolt position alarm capability is not a proper compensatory measure for loss of a balanced-magnetic alars because it is not tamper-resistant.
Proper compensation for either of these events means immediate (within 10 minutes of discovery) posting of a dedicated observer for loss of an alarm or posting an armed member of the security force for loss of a lock.
The pot,ted observer or guard should have appropriate communications equipment.:
In addition, a thorough search of the affected area should be initiated immediately and completed as soon as practicable. Licensees are expected to discover this type of event upon occurrence.
(Also see number 8 in Section 2.4.)
"Q. 2.2.22.a.
Does "upon occurrence" mean "upon discovery" when the ' ' lure of a locking device is due to mechanical breakdown?
A.
Regardless of cause, actions to compensate for loss of locking mechanism should be initiated upon discovery.
"Q. 2.2.22.b.
If a lock fails on a vital area door but the alarm remains operational should this event be reported or logged?
A.
togged, if properly compensated. Proper compensation means immediate (within 10 minutes of discovery) posting of an armed member of the security force or other measures as described in the licensee's NRC-approved security plans, as applicable.
'Q. 2.2.22.c.
1he requirement to post an armed member of the security force for the loss of a lock is inconsistent with T CFR 73.55(d)(8) which allows an unarmed watchman to control access to a reactor containment building and NUREG-1045 which allows watchpersons to provide access control to protected and vital areas.
A.
NUREG-1045 and RG 5.62 both call for an armed member of the security force as a compensatory measure whenever barrier integrity is reduced, including doors and appropriate hardware.
NUREG-1045 does allow security personnat, including watch persons to be used where barrier integrity is maintained but the computer is not able to verify the identity and maintain the required log.
The first example cited, 10 CFR 73.55(d)(8), refers to an outage situation when the reactor is not operating. Preplanned compensatory measures are normally described in NRC-approved safeguards plans.
Q. 2.2.22.d.
What is proper compensation for an open vital area door during a planned maintenance evolution with the reactor operating?
2 Posting personnel as a compensatory measure implies that the personnel are capable of performing the lost or degraded function. When they cannot perform
(
that function, such as when they are asleep, there is an uncompensated loss that must be reported within I hour of discovery. Freplanned compensatory measures ai no mally described in NRC-approved safeguards plans.
1 14
1 P
A.
Armed guards should be posted with appropriate communication devices.
2.2.23 Discovery of the actual or attempted introduction into or possession within the protected area material access area, or vital area of unauthorized weapons, explosives,,or incendiary devices.
(Paragraph 1(d) of Appendix G.)
would preclude reporting this event within one hour.There are no compensato If an actual introduction of contraband is made, steps should be taken to correct the vulnerability that allowed the introduction.
section.) The discovery of vehicular emergency (Also see number 5 in this flares during entrance searches need not be recarted or Icgged.eculpment su Q. 2.2.23.a.
" Cad weld" material is frequently used for installation and repair at most nucleat sites.
of this material be reported? If authorized for onsite use, should discovery or logged?
If not authorf2ed, should discovery be reported A.
Discovery of material such as " cad weld" that is authorized for onsite use and properly controlled should not be reported er logged. If the event can be devices during routine entrance search should be logged. sati or incendiary devices (including materials such as " cad weld") not authorizedWeapons, e onsite and discovered within the PA should be reported within one hour.
Q. 2.2.23.b.
Define tne term " contraband."
A.
i instrument or material likely to produce substantial injury or
(
persons or property.
Safety flares carried on vehicies as emergency road equipment need not be considered incendiary devices for the purpose of deportability, Q. 2.2.23.c.
If a vehicle operator fails to turn in a weapon stored in the vehicle prior to search and the weapon is not found during the search, but is found later, should the event be reported within one hour?
A. Ye5 Contraband has entered the protected area.
Q. 2.2.23.d.
If a weapon is found in a vehicle 1ccated in a parking lot outside the protected area, should it be reported within one hour?
A.
Generally, the discovery of a weapon in a vehicle parked in a lot outside of the PA need not be reported or logged.
Q. 2.2.23.e.
If a weapon is found on a vehicle during an entrance search should it bs reported or logged?
A.
Logged, unless malevolent intent is established, Q. 2.2.23.f.
If a weapons contractor ships a licensee one more weapon than ordered, is the extra weapon considered unauthorf2ed and should it be reported?
A.
If there is reasonable suspicion that this constituted a deliberate attempt to introduce an unauthorized weapon onsite, a one hour report should be made.
15
~
l i
s
i Q. 2.2.23.g.
If a driver turns in a weapon upon request prior to search, should it be reported?
A.
No.
Q. 2.2.23.h.
Does the term " weapon" refer strictly to firearms.
A.
No.
2.24 Loss of security weapon at the site. (Paragraph 1(a)(3) of Appendix G.)
No questions were received on this item.
- 2. 3 Safeguards Events To Be Reported and Submitted Quarterly in a Loo (General)
- Q. 2.3.1.
Must a licensee maintain backup documentation for follow up inspections resulting from NRC review of log entries? How long must this backup documentation be maintained?
A.
A licensee should maintain information which resolves log entries for three years.
^Q. 2.3.2.
Paragraph II.b. of Appendix G requires logging of events which reduce capabilities below that committed to in a licensed physical security or contingency plan.
Certain compensatory measures may go beyond what has been i
approved in a licensee's security plan. What takes precedence?
I The guidance in Regulatory Guide 5.62 is not intended to supplant any A.
regulation or NRC-approved licensee safeguards plan. Accordingly, compensatory actions taken by licensees in accordance with approved security plans will permit the logging of certain events in lieu of reporting them within one hour.
The regulatory guide contains examples o'f acceptable compensatory measures to guide licensee reporting in situations not covered by approved safeguards plans.
Q. 2.3.3.
When must f alse or nuisance alarms be logged?
A.
False or nuisance alarms should be logged if a pattern of such alarms emerges or when their frequency is such that system effectiveness is degraded below that committed to in an approved security plan.
Q.
2.3.4 The regulatory guide states that log entries should be updated when the event terminates. Define the term "... when the event terminates..."
This term means when compensatory measures are established or the original A.
system capability is restored.
Q. 2.3.5.
Define "end of the quarter" with respect to quarterly submittal of the safeguards events log.
A.
1he end of the quarter is defined as December 31, March 31, June 30 and September 30.
Safeguards event logs should be post. marked within 30 days of the end of each quarter.
16 I
w- __
l "Q. 2.3.6.
If an audit conducted under provisions of 10 CFR 73.55(g)(4) or t
Appendix B to 10 CFR Part 50 uncovers events not previously reported or logged, should a licensee make a report?
A.
No.
It should not be reported or logged under 10 CF R /3. 71.
However, it I
would be a licensee-identified finding which should be brought to the attention I
of the appropriate NRC Regional Of fice.
)
2.4 Examples of Safeguards Events To Be Reported and Submitted Quarterly in a log 2.4.1 Properly compensated security computer failures. (Paragraph II(a) l of Appendix G.) Properly compensated means that within 10 minutes of the discovery of the failure the system is restored to operation, the backup system is operational, or other resources, e.g., security personnel with appropriate communications equipcient, are posted to provide an equivalent level of protection. In all cases, a thorough search of all areas where alarms or access controls may have beer, compromised by the failure should be initiated immediately and completed as soon as practicable.
Licensees are expected to discover this type of event upon occurrence.
Q. 2.4.1.a.
For fuel cycle facilities, what constitutes a " thorough search"?
A.
This term means a search for unauthorized individuals, tampering, or unauthorized packages.
It does not usually mean ;quipment search for SNM.
"Q. 2.4.1.b.
Must a guard be posted at every vital area portal when a security computer fails?
A.
Unless compensated by some other means described in an NRC-approved safeguards plan, guards must be posted at all vital area portals that fail open or are used for access.
2.4.2 Properly compensated vital area card reader failures.
(Paragraph ll(a) of Appendix G.) For this event, proper compensation means posting appropriate personnel (i.e., armed guard if door is unlocked, dedicated observer if door remains locked but access is required) within 10 minutes of discovery. 8 The appropriate personnel must have a current access list and communications capability to alarn stations. A thorough search of the affected area must be initiated immediately and completed as soon as practicable. Licensees are expected to discover this type of event upon occurrence.
Q. 2.4.2.a.
If a vital area card reader fails, is it a sufficient compensatory measure to post a guard with an access IIst and check 1.D. cards as badged individuals enter the area?
2 Posting personnel as a enmpensatory measure implies that the personnel are capable of performing the lost or degraded function. When 'he" cannot perform that function, such as when they are asleep, there is an ut.. vensated loss that must be reported within I hour of discovery.
Preplanned compensatory
)
measures are normally described in NRC approved safeguards plans.
I 17
/
1 1
1
~3 b
^
A.
The guard would also be required to maintain a log of individuals in the i
affected area.
This is required under the Miscellaneous Amendments issued r
l August-4, 1986, (51 FR 27817).
1 Q. 2.4.2.b.
Can coded badges be used in lieu of an access list when seeking access to areas during card reader failures?
j A.
Coded badges may be used in lieu of an access list. However, a record must l
sti'l be kept of entries to and exits from the vital area.
- Q. 2.4.2.c.
The example states that licensees are expected to discover this type of event upon occurrence.
Is it correct to assume that "upon occurrence" means at the time someone attempts to use the card reader?
A.
It is possible that this event may not be discovered until somec e attempts i
to use the card reader. Regardless of when the failure may have occurred, it should be compensated within 10 minutes of discovery and logged.
If it cannot be compensated within 10 minutes of discovery it should be reported within one hour.
- 0. 2.4.2.d.
If a CCTV system has a failure and the approved security plan does not require the posting of a dedicated observer, (it commits to an armed response to an alarm, only), must a one hour report be made if a dedicated ubserver is not posted?
A.
No.
Licensees are expected to take compensatory actions in accordance i
with NRC-approved safeguards plans and log such events as " compensated" 2.4.3 Properly compensated alarm failures.
(Paragraph !!(a) of Appendix G.) For this event, proper compensation means deployment of backup alarm equipment (a bolf-position alarm capability is not considered j
backup alarm equipment because it is not tamper-resistent) or posting a dedicated observer within 10 minutes of discovery.8 The dedicated 3
observer should have appropriate communications equipment and should be able to observe the entire affected area of the portal.
In addition, a thorough search of the affected area should be initiated immediately and I
completed as soon as practicable. (Also see number 21 in Section 2.2.)
}
Licensees are expected to discover this type of event upon occurrence.
No questions were received on this item.
2.4.4 Properly compensated closed circuit television failure in a single rone while the intrusion detection system remains operational.
(Paragraph ll(a) of Appendix G.) Properly compensated means providing other assessment capability, such as posting a dedicated observer with communications equipment to assess the entire zone within 10 minutes of i
discovery of the failure.3 Licensees are expected to discover this type of event upon occurrence.
8.
1 Posting personnel as a compensatory measure implies that the personnel are capable of perfoming the lost or degraded function. When they Cannot perform that f unction, such as when they are asleep, there is an uncompensated loss that must be reported within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery. Preplanned compensatory 7
measures are normally described in NRC approved safeguards plans.
18 t -
I.
\\
s.
Q. 2.4.4.a.
with observation of all Zones?May multiple failed Zones be compensated by one d
{
A.
Yes, if the inuividual can observe all affected zones.
"Q. 2.4.4.b.
If a CCTV system assessing multiple zones has been approved for use at a site, must dedicated observers be posted at each zone if the CCTV fails?
A.
Some site-specific unique situations may permit fewer than one dedicated observer per zone.
is believed their situation is unique. Licensees should consult with appropriate Licensees are expected to take compensatory actions in accordance with approved security plans if applicable to an event and log it accordingly.
2.4.5 Properly compensated failure or degradation of a single perimeter lighting zone if the intrusion detection system remains operational.
(Paragraph !!(a) of Appendix G.)
Heasures to properly compensate for failure or degradation of a lighting zone must be implemented within 10 minutes of discovery and may include (1) using standby power, (2) using i
low-light-level surveillance devices, (3) using portable lighting systems or (4) posting dedicated observers with appropriate communications equipment to provide an equivalent level of protection, Q. 2.4.5.a.
If some lighting is lost but not enough to go below the level committed to in the security plan (e.g., 0.2 foot candles), is a report required or can the event be logged?
J A.
Neither a report within one hour nor a log entry need be made.
Q. 2.4.5.b.
With respect to this example, what if failure is less than system wide but more than a single Zone?
logged?
How should this be reported or A.
Use the reporting criteria as if it was a single zone.
2.4.6 properly compensated accidental removal offsite or loss of badge by employee.
(Paragraph II(a) of Appendia, G. ) For this event, proper compensation is cancelling the badge from the access control system within 10 minutes of discovery by onsite personnel that the badge is missing.
Measures must be taken to be sure the badge has not been used in an unauthorized manner while it has been missing. (Also see number 16 in Section 2.2.)
No questions were received on this item.
4 2.4.7 Properly compensated loss of the AC power supply for the entire 4
intrusion detection system that, if uncompensated, would allow unauthorized or undetected access. (Paragraph II(a) of Appendix G. )
- {
Proper compensation for this event is immediately available emergency power through an uninterruptible power source such as a battery supported 19 h
_ _ _ _ _ - _ _ _ - - - - - - - - - - - - - - - - - - - - ~ - ^ -
{t by a gensrator.
If backup power is not available, security personnel with M
communications equipment should be posted within 20 minutes of discovery; however, this action is not considered proper compensation for the event I
and does not excuse a licensee from reporting the event within one hour.
g Licensees are expected to discover this type of event upon occurrence.
if (Also see number 20 in Section 2.2.)
.s d
Q. 2.4.7.a.
Why is timely posting of properly equipped security personnel not g
considered proper compensation for loss of AC power supply to the entire intrusion detection system?
M,,
f A.
A significant degradation that cannot be properly compensated has occurred.
W The level of effectiveness existing prior to the loss cannot be maintained only
'f throug5 posting.
4 L
2.4.8 Properly compensated loss of either alarm or locking mechanism on a material access area or a vital area portal. (Paragraph II(a) of Appendix G.) A bolt position alarm capability is not considered a proper compensatory measure because it is not tamper-resistant. Proper compensation for this event is imediate (within 10 minutes of discovery) posting of a dedicated observer for a loss of alarm or an armed member of the security force for loss of a lock.8 The posted personnel should have appropriate communications equipment.
In addition, a thorough search of the af fected area should be initiated imediately and completed as soon as practicable. Licensees are expected to discover this type of event upon occurrence. (Also see nuevwe 22 in Section 2.2.)
No questions were received on this item.
- 2. 4. 9 Security computer failures that may not enable unauthorized or undetected access.
(Paragraph !!(b) of Appendix G.)
Q. 2.4.9.a.
What type of events are security computer failures that may not enable unauthorized or undetected access?
A.
Such things as loss of printing capability only, or when a computer fails to store entries on a disk, are security computer failures of this type.
'Q. 2.4.9.b.
Should a security computer data base failure that does not impact effectiveness be reported?
A.
No.
2.4.10 Loss of the capability of a single alarm station to monitor or remotely assess alarms but monitoring or assessment capability remains in other stations.
(Paragraph 1](b) of Appendix G.) (Also see number 18 in Section 2.2.)
I i
1 Posting personnel as a compensatory measure implies that the personnel are capable of performing the lost or degraded funr. tion. When they cannot perform j
that function, such as when they are asleep, there is an uncompensated loss that must be reported within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery. Preplanned compensatory l
measures are normally described in NRC-approved safeguards plans.
! 1 20 t.
iE
[
g 5
Q. 2.4.10.a.
Does this example imply that all vital area portal alarms should be logged, or only those alarms which are caused by actual problems?
A.
This example implies neither.
actual problems may require one hour reporting.In some cases vital area al event is properly compensated, it need only be logged.In most cases,.if a reportab 2.4.11 Tailgating by a licensee employee or contractor to gain access to an area to which he or she is authorized access. (Paragraph !!(b) of Appendix G.) (Also see number 13 in Section 2.2.)
"Q. 2.4.11.a.
Does specific intent affect deportability of tailgating?
A.
Yes.
For example, if tailgating is committed by an authorized employee or contractor, it is considered an administrative matter that should be corrected and the event should be logged.
If tailgating is committed by unauthorized individuals, the event should be logged if it can be satisfactorily explained and their level of screening would qualify them for unescorted access.
Otherwise, the event should be reported within one hour.
Licensees are expected to investigate the matter and correct any deficiencies in programs and procedures.
2.4.12 For shipments of formula quantities of SSNM, intra-convoy communications ability is lost, but ability to communicate with movement control center remains.
(Paragraph !!(b) of Appendix G.)
{
No questions were received on this item.
I 2.4.13 Unsubstantiated bomb or extortion threat.
(Paragraph II(b) of Appendix G.)
An unsubstantiated bomb or extortion threat is a threat in which no specific organization or group claims responsibility, the search result is negative, and no evidence is available other than the threat If a threat is one of a pattern of harassing, even if message.
unsubstantiated, it should be reported within one hour.
No Questions were received on this item.
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Technical Report
,;.I' On June 9. 1987, the Cocnission publishe in tie Federal Register a final rule revising the reoorting requirements for s i
egdards events. Safeguards events include actual or attempted theft of speci 7 nuclear material (SNM); actual or
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attempted acts or events which interrupt no al operations at power reactors due to unauthorized use of or tampering,ft chinery, components, or controls; certain threats made against facilitie poss sing SNM; and safeguards system failures impacting the effectiveness o the sy tem. The revised rule was effective October 8. 1987. On September 14 19. the N held a workshop in Bethesda, MD to answer affected licensees' ques,ti s on the al rule. This report documents Questions discussed at the Sectemb 14 meeting, flects a completed staff review of the answers, and supersedes pr ous oral corne t on the topics covered.
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Drug and Alcohol Abuse:
The Bases for Emaloyee Assistance Programs in the Nuclear Utiity Inc ustry i
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U.S. NUCLEAR REGULATORY COMMISSION March 1979 hs, ) REGULATORY GUIDE
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OFFICE OF STANDARDS DEVELOPMENT 0]*D D
REGULATORY GUIDE 1.134 E
MEDICAL EVALUATION OF NUCLEAR POWER PLANT PERSONNEL REQUIRING OPERATOR LICENSES A.
INTRODUCTION horking Group ANS 3.4 of Subcommittee ANS 3. Resetor Operations, of the American j
Section 55.10. " Contents of Ap pbea tions."
i and f 55 33, " Renewal of Licenses." of 10 CFR Nu: lear Society has developed a standard pre-
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scribmg minimum requirements necessary to Part 55. " Operators' Licenses." require that determme that the physical condition and each appl.ication for an mitial or renewal opera-general health of nuclear reactor operators are
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ter or senior operator bcense contain a report not such as might cause operat.ionaj errors, of medical exammation by a beensed tr.edical Th:s standard was approved by the American practitioner m the form prescribed in 5 55 60, National Standards Committee N18 Nuclear
Examination Form.' Section 55.11. ' Require-Design Cra t eria. and was subsequently ap-ments for the Approval of Appbeations." and i 55.33 of 10 CTR Part 55 state that an appb-prcred by the American National Standards In-statute ( ANSI) on April 12. 1976. The criteria cation for an initial or renewal operator or senior operator brense will be approvsd it.
presented in ANSI N546-1976.i " Medical Certi-tmong other things, the physical condition and fication and Monitormg of Personnel Requiring general health of the applicant are not such as Operator Licenses for Nuclear Power Plants."
sht,uld provide an tsamining licensed medical migh t cause operanonal errors endangering practitioner with a basis for determining if an pubbe health and safety This guide describes abnormal health condition exists and tf that a method acceptable tc the NRC staff for pro-cond:non is potentiaUy disqualifying. Estab-viding the infomation needed by the Cetnmis-ston for its evaluation of the medical quahfica-hs.mr minimum health recluirement. should aid m the more untfor7n and complete preparatier, nons of applicants for mitia! or renewal opera-of Form NRC 396 and should reduce instances t~
wr senior operator beenses for nuclear wh.n the NRC has to request additional medical
.p r plan t s. The Advisory Cemn.;ttee on Reactor Safeguards has been consulted con-information. However. 2t should be recognized that although it is the Lcensed medical practi-cerntr.g this guide and has concurred m the tiener's responsibibly to identify and evaluate regulatory position potentiauy disquahtying physical conditsens.
B.
DISCUSSION the final determinanon of the appbeant's medi-ev. qushfici, tion is c>ade by the NRC Section 55 60 of 10 CFR Part 55 seguires the section 3.'
of ANS! N54619*6 J
beensed medical practitioner and the appheant requires that for an mitial or renewal operator or sentor ep-the facibly operator forward to the designated medical examiner a report on each employee crator beense to complete and sign Form NRC-referrec for a reaeter operator medical exami-396. ' Certificate of Medical Exa:rmatior The r.auen prior to the examination. This teetion exammation form is th:n sent to ins.hC and pes wn to recorr. ment. that the re t,ecorr.es. part of the beense appheattor. The NRC often has to request additional information su:". areas as work perfomance, port address a tten dance.
ar.c behavioral changes noted since the pre-bee m,. s e the beensec medical practitioner r's vic.is evaluation h is recornned that the re-sO evaluaty n of the appbeant s medical h:stcry or porte, of periment observations to o brensed tn physita! condition af, not sufficiently detaJed to fredical practitioner by factbty supervisor)
(frierwr.e an appbeant s quabficat on
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. personnel can provide valuable background in-tions of appucants for tnitial or renewal opera-forma tion to support the medical evaluation.
tor or senior operettor Ucenses for nucitar j
,However, there is a concern for potential power plants suWeet to the followmr a bu se. in that observa tions by supervisory
. personnel may be biased and extend mto areas
- 1. Section 3 2 of ANSI N546197G requirn not pertment to the evaluation. In regard to that the factbty operator fo r". a rd to the the provisiens of Section 3.2 of ANSI N546-
- 1976. responsible facthty supervisory personnel designated medical examiner a report on sach employee referred for a reactor oper tor med:-
.should determine from the Ucensed medical cal exammation prior to the examination and practitiern what informa tion. including such that the report include information specified by items as those identified m Section 3.2.
is the designated medical examiner ANSI N546-needed to make the judg nents required by 1976 further presents recommendations as to For= NRC-396 and should forward only the m-what other type of mformation is to be formation specified or requested Information addressed The facibty operator should deter-p rovided by the facility operator should be mine from the licensed medical practitioner used only as background mformation and what mformation meludmg such items as those shot.:d be,t.bject to evalu a tion.
identifia n Section 0 0 of the standard are needed to make the judgments required by Paragraph 55 11(a)(1) s pectfies, in part.
Fonn NRC-396. " Certificate of Medical Examina-that any mental or physical condition that tion." and should forward only the mformation might cause impaired judgment or motor specified or requested. Information submitted cocrdinati n may consutute safficitat cause fer uenid af a cperatur bcease.appbcation. L#d-by the f.icihty operator should be used only as backgiand 1.. formation and should be subject ANSI N5h-1976 addresses in some detail the to evaluation physical con ditions that may be cause for denial of an appbeation. the standard is more
- 2. If. to the medical evaluation of the reactor general in iden tifying the mental conditions operator. there is an mdication of a potentiauy that may be cause for de ntal. Because of disquabfvmg condition m areas such as those inherent JJficulties in evaluateg mental condi-specifica m Sections 5 3.8 and 5.415 of ANSI tions and t.ecause of the broad nature of po-N546-1976, evaluation of the et dition should tentiaUy disquahfymg mental conditions pre-be conducted by a licensed psychologist. psy-sented e
- NSI NME 976 potenths!?y disqt. 'r
. h ia t ris ' W physic:an professionaUy trained to fymg mental conditions should be evaluated by identtfy and evaluate such conditions.
a beensed psychologist, psychiatrist. or physi-clan professionaUy tramed to identify the con-ditic a O.
IMPLEMENTATION None of the provisicns of ANSI N5461976 or TN purpose of this section is to provide m-this guide should be construed to mean that formate to applicants and beensees regardtng the readmg habit s. pobtical or religious the staff 5 plans for uttb2tng this regulatory b elie f s. cr attitudes on social, economic. or guide pohtical issues cf an tndividual should be investigated or judged.
Except in those cases m which ar acceptat.le C.
REGULATORY POSITION alternati.e method for complymg math spectfied portions of the Com:lission's regu!stions is pro-posed, the method described herem wtu be The requirements co6tained m ANSI N546-used m the evaluation of Form N R C-:196, 1976. " Medical Certification and Monitortng of
" Certificate of Medical Exammation." submittals Personnel Requiring Operator Lic ens es for m connection with appbeations for tnitial or re-Nuc! car Poi.er Plants."' provide an acceptable newal operator or senior operator licen ses method for determming the medical quahtica-received after June 1979.
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'/0433 dave dp fo2a' to NRC 010. 5 IN 09/20 11: 36 DATE: S'e p t. 27, 1989 FREEDOM OF INFORMAT10N ACT REQUEST 0
FROM. David Parrish Stoff Writer _ Blade-Tribune N'd d*t7 a
92054 n id (619) 433-7333, e r t.
454 70; U. S.
Nuclear Regulatory Commission Washington.
D. C.
20555 D9er Linda Robinson, This request for information.s made under the f ederal Freed om of Information Act. 5 U.S.C 552.*
Please send'me copies of any and all studies, reports, audits, investigations,
' inspection reports and other documents dealing with drug use and distribution, cicohol.use or fitness for duty issues at the San Onofre Nuclear Power Station, California Also include any information on drug and alcohol testing programs at San Onofre.'
At this time, only information gathered or processed into d oc ument f orm s inc e pn.
1, 1982 is requested.*
If in complying with this FOIA request some informaton becomes immediately ovoilable, please send those documents while the search continues for other documents.*
Because this request is part of continued.research for a newspaper artical, I cek thg all fees be waived, as the FOIA allows._If there is a fee of more than 550 c1=ase contact me by telephone.'
If you have any question about my FOIA request please feel free to call me.*
I Sincerely, David Parrish k
THE BLADE-TRIBUNE DAVID PARRISH Staff Writer 1722 sou et oceenside, california 92054 (619) 433-7333 2 KMLm. DA