ML22339A230
| ML22339A230 | |
| Person / Time | |
|---|---|
| Issue date: | 10/12/2022 |
| From: | Reed E Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML22339A230 (1) | |
Text
Break Out Session Draft Security Measures
Staff Perspective
- Proposed changes are necessary to fulfill the NRCs statutory responsibility
- The proposed changes are consistent with activities that are already being implemented through security plan and procedures
TRTR Perspective
- Changes not consistent with the Atomic Energy Act of 1954, as amended
- Minimum regulations
- Burdensome
- Impedes on research and teaching
- Status Que works fine
Goal
- Coming to a better understanding of the proposed changes and their potential impact
- Balance the requirements to protect public health and safety with requirements to only apply minimum regulations
Security Measure Comparison
- 2015 Regulatory Basis
- Not rule text, but is publicly available
- Similar to CALs and SECY for Moly production facilities
- Compare with existing Regulations, Orders, CALs and License Conditions
- Identify what is already part of the site security plans and procedures
Regulatory Basis 2015 Category II Category I - Moderately Dilute Category II -
Moderately Dilute Category III Category I - Highly Dilute Protective Strategy Immediately detect attempts to remove of SNM and provide sufficient delay through the use of barriers and/or armed responders to allow LLEA to promptly recover SNM Promptly detect attempts to remove of SNM and notify local law enforcement agencies to allow recovery of SNM Timely detect attempts to remove of SNM and notify LLEA to recovery SNM Security Plan Physical Security Plan Safeguards Contingency Plan Training & Qualification Plan Physical Security Plan Physical Security Plan
Regulatory Basis 2015 Category II Category I -
Moderately Dilute Category II -
Moderately Dilute Category III Category I - Highly Dilute Security Organization Implement Program Management System Implement Program Management System Implement Program Management System Physical Barrier Vehicle Barrier System Isolation Zone Protected Area Controlled Access Area Locked Processes Vault-type room Hardened CAS Controlled Access Area Locked Processes Vault-type room Controlled Access Area
Regulatory Basis 2015 Category II Category I - Moderately Dilute Category II -
Moderately Dilute Category III Category I - Highly Dilute Access Control Protected Area & Controlled Access Area Access Portals Limit unescorted access Access Authorization Program (§73.57, §73.59,
§73.61)
Controlled Badge Program Escort Requirements Controlled Access Area Access Portals Limit unescorted access Access Authorization Program Controlled Badge Program Escort Requirements Controlled Access Area Access Portals Limit unescorted access Controlled Badge Program Escort Requirements All RTRs must comply with 73.57 Search Program Protected Area - entry (contraband) & exit (SNM &
shielding)
Controlled Access Area -
exit (SNM & shielding)
Controlled Access Area -
entry (contraband) random exit (SNM &
shielding)
None Included in CM/CALs
Regulatory Basis 2015 Category II Category I - Moderately Dilute Category II -
Moderately Dilute Category III Category I - Highly Dilute Detection and Assessment Protected Area & Vault type room Intrusion Detection System with UPS Video Capture Central Alarm Station Secondary Alarm Station (on-site or off-site)
Surveillance Program Periodic Patrols of outside areas Illumination Controlled access area intrusion detection equipment or patrols Vault type room Intrusion Detection System with UPS Central Alarm Station Secondary Alarm Station (on-site or off-site)
Surveillance Program Periodic Patrols of outside areas Controlled access area monitored with either intrusion detection equipment or by periodic patrols to detect unauthorized penetrations or activities Surveillance Program Periodic Patrols of outside areas
Regulatory Basis 2015 Category II Category I -
Moderately Dilute Category II - Moderately Dilute Category III Category I -
Highly Dilute Communication CAS/SAS two-way redundant communication with LLEA Continuous communication between CAS/SAS and on-site and off-site response force Non-portable equipment on UPS CAS/SAS two-way redundant communication with LLEA Continuous communication between CAS and on-site and off-site response force Non-portable equipment on UPS Two-way redundant communication with LLEA Continuous communication among security force Non-portable equipment on UPS
Response
Deadly Force Armed Security Officers LLEA Liaison Heightened Security LLEA Liaison Heightened Security LLEA Liaison Heightened Security
Regulatory Basis 2015 Category II Category I -
Moderately Dilute Category II -
Moderately Dilute Category III Category I - Highly Dilute Security Program Review Biennially Management Review Issue identification and resolution program Biennially Management Review Issue identification and resolution program Biennially Management Review Issue identification and resolution program Maintenance &
Testing Required Required Required
Regulatory Basis 2015 Category II Category I -
Moderately Dilute Category II -
Moderately Dilute Category III Category I - Highly Dilute Compensatory Measures In PSP In PSP In PSP Suspension of Security Measures Allowed Allowed Allowed
Regulatory Basis 2015 Category II Category I -
Moderately Dilute Category II -
Moderately Dilute Category III Category I - Highly Dilute Records Required Required Required Alternative Measures Allowed Allowed Allowed
Self-protecting
- Comments from non-power reactor on the Draft Regulatory Basis in 2014 indicated that licensees questioned the proposed elimination of the external dose-rate threshold
- Regulatory Basis 2015 noted staff evaluated what external dose-rate level would be appropriate
- Staff revised its approach and proposed an external dose-rate threshold of 50 Gray/hour at one meter
Conclusion
- Was the goal accomplished?
- Impact better understood
- Not all items apply to NPUFs
- Parking Lot Items
- Questions