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 II - Category III Moderately Dilute Category I - Moderately Category I - Highly Dilute Dilute Protective Immediately detect attempts Promptly detect Timely detect Strategy to remove of SNM and attempts to remove attempts to remove provide sufficient delay of SNM and notify of SNM and notify through the use of barriers local law LLEA to recovery and/or armed responders to enforcement SNM allow LLEA to promptly agencies to allow recover SNM recovery of SNM Security Physical Security Plan Physical Security Physical Security Plan Safeguards Contingency Plan Plan Plan Training & Qualification Plan
Regulatory Basis 2015 Category II Category II - Category III Moderately Dilute Category I - Category I - Highly Moderately Dilute Dilute Security Implement Program Implement Program Implement Program Organization Management System Management System Management System Physical Barrier Vehicle Barrier System Controlled Access Controlled Access Isolation Zone Area Area Protected Area Locked Processes Controlled Access Vault-type room Area Locked Processes Vault-type room Hardened CAS
Regulatory Basis 2015 Category II Category II - Category III Moderately Dilute Category I - Moderately Category I - Highly Dilute Dilute Access Protected Area & Controlled Controlled Access Area Controlled Access Area Control Access Area Access Portals Access Portals Access Portals Limit unescorted access Limit unescorted access Limit unescorted access Access Authorization Access Authorization Controlled Badge Program (§73.57, §73.59, Program Program
§73.61) Controlled Badge Escort Requirements Controlled Badge Program Program All RTRs must comply Escort Requirements Escort Requirements with 73.57 Search Protected Area - entry Controlled Access Area - None Program (contraband) & exit (SNM & entry (contraband) Included in CM/CALs shielding) random exit (SNM &
Controlled Access Area - shielding) exit (SNM & shielding)
Regulatory Basis 2015 Category II Category II - Category III Moderately Category I - Moderately Dilute Category I - Highly Dilute Dilute Detection and Protected Area & Vault type Controlled access Controlled access area room Intrusion Detection System area intrusion monitored with either Assessment with UPS detection equipment intrusion detection Video Capture or patrols equipment or by periodic Central Alarm Station Vault type room patrols to detect Secondary Alarm Station (on-site Intrusion Detection unauthorized or off-site) System with UPS penetrations or activities Surveillance Program Central Alarm Station Surveillance Program Periodic Patrols of outside areas Secondary Alarm Periodic Patrols of Illumination Station (on-site or off- outside areas site)
Surveillance Program Periodic Patrols of outside areas
Regulatory Basis 2015 Category II Category II - Moderately Category III Dilute Category I - Category I -
Moderately Dilute Highly Dilute Communication CAS/SAS two-way CAS/SAS two-way redundant Two-way redundant redundant communication with LLEA communication communication with LLEA Continuous communication with LLEA Continuous between CAS and on-site Continuous communication between and off-site response force communication CAS/SAS and on-site and Non-portable equipment on among security off-site response force UPS force Non-portable equipment Non-portable on UPS equipment on UPS Response Deadly Force LLEA Liaison LLEA Liaison Armed Security Officers Heightened Security Heightened LLEA Liaison Security Heightened Security
Regulatory Basis 2015 Category II Category II - Category III Moderately Dilute Category I - Category I - Highly Moderately Dilute Dilute Security Program Biennially Biennially Biennially Review Management Management Management Review Review Review Issue Issue Issue identification and identification and identification and resolution program resolution program resolution program Maintenance & Required Required Required Testing
Regulatory Basis 2015 Category II Category II - Category III Moderately Dilute Category I - Category I - Highly Moderately Dilute Dilute Compensatory In PSP In PSP In PSP Measures Suspension of Allowed Allowed Allowed Security Measures
Regulatory Basis 2015 Category II Category II - Category III Moderately Dilute Category I - Category I - Highly Moderately Dilute Dilute Records Required Required Required Alternative Allowed Allowed Allowed Measures
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