NRC Generic Letter 1987-08
-s -0 UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555 May 11, 1987 TO ALL POWER REACTOR LICENSEES
Gentlemen:
Subject: IMPLEMENTATION OF 10 CFR 73.55 MISCELLANEOUS AMENDMENTS AND
SEARCH REQUIREMENTS (GENERIC LETTER 87-08)
A number of questions have been received from power reactor licensees concerning implementation of the 10 CFR 73.55 Miscellaneous Amendments and Search Requirements published on August 4, 1986 (51 FR 27817 and 51 FR 27822).
Because these questions are generic in nature, it is believed that the. answers to these questions may be informative to all concerned. Accordingly, enclosed are the generic questions received on these two new rules along with the answers. Any additional questions should be directed to your project manager.
Sincerely,
44 Associate Director for Projects Office of Nuclear Reactor Regulation Enclosure:0cnc-pt'&l PA ; SY
Generic Questions and Answers
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QUESTIONS AND ANSWERS
Question 1.
How should the "Miscellaneous Amendments Concerning Physical Protegtion of Nuclear Power Plants" and amendments concerning "Searches of Indivqduals at Power Reactor Facilities" be submitted?
Answer.
Plan amendfents should be submitted to NRC Headquarters (Director, Office of Nuclear Reactor Regulation, ATTN: Document Control Desk) as amendmentslin.
response to the new rules. They should not be submitted under the provisions of §50.54(p) or §50.90. Six copies of the plan amendments should be submitted.
Reference: §73.55 - Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage, as printed in the Federal Register on August 4,
1986 (51 FR 27817 and 51 FR MM..
Question 2.
What is-meant by the statement that, 'Certain access'controls may be suspended during emergency or abnormal plant conditions,..."?
Answer.>
10 CFR 50.54(x) states that a licensee may take reasonable action that departs from a license condition or a technical specification in an emergency when this action is immediately needed to protect the public health and safety, and no action consistent with license conditions and technical specifications that can provide adequate or equivalent protection is immediately apparent. This same authority also applies to physical security and safeguards contingency plans'
and plant procedures relating to security matters.,
Reference: Regulatory Guide 5.65, Section 3 - Control of Access to Vital Areas Under Routine Conditions, Subsection 3.1 - Access List.
Question 3.
Mlay access controls for a vital area be suspended when a life threatening emergency has occurredl'to an on-site person?
Answer.
10 CFR 73.55(d)(4) permits emergency vehicles to enter the protected area without the normal search functions being performed. There are no provisions in the regulations for suspending any vital area safeguards requirements.
However, the emergency team would be escorted by site security personnel to the location of the emergency and accordingly it would not be necessary to suspend any requirements.
Reference: 10 CFR 73.55(d)(4).
- 2 -
Question 4.
What individuals are included in the term operating personnel asi.used in Section 4.1 of Regulatory Guide 5.65? -
Answer.
The term "operating personnel means any individual (licensed operator) who is authorized to manipulate any reactor controls in order to mitigate or attempt to mitigate an emergency or abnormal condition. The term also includes any other individual who is needed to aid in the mitigation of an emergency or abnormal condition (e.g., emergency response team, security personnel, etc.).
Reference: Regulatory Guide 5.65, Section 4 - Emergency Access to Vital Areas, Subsection 4.1 - Access Keys.
Question 5.
What individuals are included in the term 'necessary personnel' as used in Section 4.3 of Regulatory Guide 5.65.
Answer.
The term "necessary personnel' means the same as the term 'operating personnel"
discussed in Item 4 above.
Reference: Regulatory Guide 5.65, Section 4 - Emergency Access to Vital Areas, Subsection 4.3 - Loss of Electric Power.
Question 6.
When should vital area hard keys which override vital area access systems be Issued to personnel?
Answer.
Vital area hard keys should be issued at the beginning of each shift and properly accounted for at the end of each shift or as currently specified in a licensee's approved security plan. The use of any such keys to enter vital areas, however, must cause a vital area alarm to be generated and a response must occur when the door is opened.
Reference: Regulatory Guide 5.65, Section 4 - Emergency Access to Vital Areas, Subsection 4.1 - Access Keys.
-3 Question 7.
Is a key card considered to be "a related access control device" subject to the requirement to be changed or rotated at least once every tvilve months?
Answer.
No. However, whenever there is evidence or suspicion of compromise, or whenever an individual is terminated for cause, the individual's access authorization should be immediately removed from the key card system.
Reference: §73.55(d)(9) - Access Controls.
Question S.
Must licensees rotate or change keys, locks, etc., if an individual's unescorted access authorization is temporarily suspended as opposed to
"revoked"?
Answer.
If an individual's unescorted access authorization is temporarily suspended pending a review, at the licensee's discretion, locking devices do not have to be rotated or changed as long as access control devices possessed by the individual are returned to management and the individual is escorted while on-site. If the individual's unescorted access authorization is permanently revoked for cause at the end of the review, locking devices must be changed or rotated.
Reference: 973.55(d)(9) - Access Requirements.
Question 9.
May all vital area doors fail open during an emergency or power outage?
Answer.
Yes. From a safety standpoint it is preferable that doors fail open during emergencies or power outages although the regulation is silent on this matter.
However, regardless of whether doors fail open or closed, in an emergency involving plant safety, i.e., threats to public/worker health and safety, vital area access controls may be suspended without compensatory measures in accordance with 10 CFR 50.54(x).
The issue of whether vital area doors should fail open or closed was studied by the Committee to Review Safeguards Requirements at Power Reactors in 1983.
The Committee's findings (documented in NUREG-0992, OReport of the Committee to Review Safeguards Requirements at Power Reactors,") emphasized the importance of licensees considering a balanced safety/safeguards approach in the design of access control systems. This consideration helps assure adequate safeguards response while maintaining adequate safety precautions.
-4- Question 9. (Continued)
It has been NRC's policy that when vital area doors are configure4 to "fail open" during a power outage and the situation does not involve pubpic/worker health and safety, the condition must be addressed in the site security/
contingency plan.
However, recognizing the potential problem of security force coupled with the need for heightened security force awareness availability in such situations, the staff is at present considering other options which may be acceptable compensation for this condition. In the interim, a licensee wishing to implement alternative compensatory measures should receive approval of the measures by appropriate NRC staff prior to implementation.
In those instances where vital area doors are configured to "fail doors should be provided with mechanisms for emergency egress and shut," the procedures should be implemented to assure prompt access by operational personnel.
Reference: Regulatory Guide 5.65, Section 4 - Emergency Access to Vital Areas, Subsection 4.3 - Loss of Electric Power.
Question 10.
Can logging of individuals granted access to vital areas be suspended during emergencies and power outages due to loss of offsite power?
Answer.
Yes.
Reference: §73.70(d).
Question 11.
Do the revised search requirements mean that every time a member of the security force leaves the protected area (PA) to perform official duties that he or she must be equipment searched for weapons, explosives, and incendiary devices prior to re-entry to the PA?-
Answer.
Members of the security force must be equipment searched on their initial entry to the PA at the beginning of their work shift. If these individuals leave the PA to perform official duties subsequent to this initial search, they need not be searched prior to re-entry into the PA if they under the direct observation or accompaniment of a member of the have been security organization while outside the PA. Security force individuals who do not meet this criterion must be equipment searched prior to their re-entry to the PA.
Reference: Past licensing policy.
- 5- Question 12.
If walk-through detection equipment alarms upon the search of an ipdlvidual, must the individual be immediately pat-down" searched or may the individual be more stringently searched by hand-held detection equipment to determine whether 'pat-down" is necessary?
Answer.
If an alarm is received when an Individual passes through a walk-through detector it is acceptable to conduct a search using hand-held equipment to assist in determining if a "pat-down" search is needed.
Reference: §73.55(d)(1) - Access Requirements.
Question 13.
What does a security plan commitment to detect explosives at the entry point to the protected area mean?
Answer.
Such a commitment means that a licensee has procured and is maintaining explosives detection equipment as set forth in Review Guideline Number 20,
Revision 1, dated April 18, 1978, attached.
Reference: §73.55(d)(1) - Access Requirements and Review Guidelines Number
20, Rev. 1, dated April 18, 1978.
Question 14.
Is the central alarm station (CAS) required to be protected as vital?
Answer.
The requirement to consider the central alarm station (CAS) a vital area was inadvertently deleted under the Miscellaneous Amendments. A final rule correction was published in the.Federal Register on April 16, 1987
(52 FR 12364) to againrequire the CAS to be considered vital.
Reference: §73.55(e)(1) - Detection Aids.
Question 15.
Does an on site secondary power supply system for a privately owned telephone system have to be located within a vital area?
Answer.
No.
Reference: §73.55(e)(1) - Detection Aids and §73.55(f) - Communications.
-6- Question 16.
Does the requirement to locate "on-site secondary power supply systems for alarm annunciator equipment and non-portable communications equipmbnt' within vital areas mean that: (a)the alarm annunciator equipment and the or site secondary power supply system for non-portable communications equipment must be located within a vital area or (b)the on site secondary power supply systems associated with alarm annunciator equipment and non-portable communications equipment must be located within a vital area?
Answer.
This requirement means that the on-site secondary power supply systems for both the alarm annunciator and the non-portable communications equipment must be located within a vital area.
Reference: §73.55(e)(1) - Detection Aids.
Question 17.
Does the secondary alarm stations (SAS) secondary power supply systems for alarm annunciator equipment and non-portable communications equipment have to be protected as vital equipment?
Answer.
No.
Question 18.
What components of the secondary power supply systems for the alarm annunciator and non-portable communications equipment have to be protected as vital equipment?
Answer.
The objective of secondary power supply systems (SPSS) is to provide auxiliary power during power Interruptions or outages. The duration of such interruptions or outages should be determined on a site-specific basis under station blackout criteria. It is necessary to protect all components of a SPSS needed to provide this site-specific period of stand-by power. Such components may include, but are not necessarily limited to, the following:
a. Batteries b. Battery chargers c. Inverters d. AC alternators e. DC generators f. Emergency buses g. Control panels
e -no a 7- Question 18. (Continued)
h. Switch gear i. Main fuel tanks or day tanks and associated plumbing/plping Reference: 173.55(e)(1) - Detection Aids and Regulatory Guide 5.65, Section 7 (Protection of Security Equipment).
Question 19.
Can the secondary power supply systems for alarm annunciator equipment and non-portable communications equipment consist of interruptible power systems (IPS)" or do they have to be "uninterruptible\power systems (UPS)"?
Answer.
The secondary power supply systems may consist of either an IPS or UPS.
However, an UPS is preferable.
Reference: §73,55(e)(1) - Detection Aids and Regulatory Guide 5.65, Section
7 - Protection of Security Equipment.
Attachment:
Review Guideline No. 20, Revision 1
LIST OF RECENTLY ISSUED GENERIC LETTERS
Generic Date of Letter No. Subject Issuance Issued To GL 87-07 INFORMATION TRANSMITTAL OF 03/ g9/e7 ALL FACILITY
FINAL RULEMAKING FOR REVISIONS LICENSEES
TO OPERATOR LICENSING-IOCFR55 AND CONFORMING AMENDMENTS
GL 87-06 TESTING OF PRESSURE ISOLATION 03/13/8,7 ALL OPERATING
VALVES REACTOR.
LICENSEES
GL 87-05 REQUEST FOR ADDITIONAL 03/12/8,7 LICENSEES OF
INFORMATION-ASSESSMENT OF OR'S,
LICENSEE MEASURES TO MITIGATE APPLICANTS FOR
AND/OR IDENTIFY POTENTIAL OL'S, AND
DEGRADATION MKI HOLDERS OF
MARK I
CONTAINMENTS
GL 87-04 TEMPORARY EXEMPTION FROM 03/06/0,7 ALL POWER
PROVISIONS OF THE FBI CRIMINAL REACTOR
HISTORY RULE FOR TEMPORARY LICENCES
WORKERS
6L 87-03 VERIFICATION OF SEISMIC 02/26/B 7 ALL LICENSEES
ADEQUACY OF MECHANICAL AND NOT SUBJECT TO
ELECTRICAL EQUIPTMENT IN USI A-46 OPERATING REACTORS, USI A-46 gfQUIREMENTS
6L 87-02 VERIFICATION OF SEISMIC 02/19/887 ALL HOLDERS OF
ADEQUACY OF MECHANICAL AND OPERATING
ELECTRICAL EQUIPMENT IN LICENSES NOT
OPERATING REACTORS (USI A-46) REVIEWED TO
CURRENT
LICENSING
CRITERIA ON
SEISMIC
QUALIFICATION
OF EQUIPMENT
GL 87-01 PUBLIC AVAILABILITY OF THE NRC 01/08/87 ALL POWER
OPERATOR LICENSING EXAMINATION REACTOR
QUESTION BANK LICENSEES AND
APPLICANTS FOR
AN OPERATING
LICENSE
GL 86-17 AVAILABILITY OF NUREG-1169, 10/17/86 ALL LICENSEES
"TECHNICAL FINDINGS RELATED TO OF BOILING
GENERIC ISSUE C-8 WATER REACTORS
BWR MSIC LEAKAGE AND LEAKAGE
CONTROL SYSTEM
Ueactor Safeguards Licensing Sranch - 3 -
iodal leanufacture/Distributor S-201 Leigh-Marsland EnSineering. Ltd.
S-301 "5C Weber Street. Iorml a:tarloo, Ontario. Canada Z-cE3 CcntUct: Securi:y Products M.arketing Cffic2 PVe ;Ymamics X-;ay [ndus:trial Zis:ributors. Inc.
- eoresenta
- ives for Pyt Coynamics
3;2 ^1tlkanna Avenue Clifton. New iersay 07014
es models .nave hetn :ts:ed by c:her agencies for de- tac-ion of mv on ;ersonnel. :actional Information cay be found in Chac:ar o of Sandia ZnZtry Control Systes Handbooxk SAND77-1033.
These .models and others art accaptabie if they mett or xcaiea 2te acvCe :rfor--anct ;e-irements.
Review Guideline Number 20, dated April 10, 197a. Is superseded by zis revision.
xeb A. Clark, Chi eact:o Saftsuards licensing 3rancX
Division of Operiting eactorn
UNITIVWTA~T5 NUCLEAR REGULATORY COMMISSION
W&SWINGTON. D.. . -u HAORANOUM FOR: Reactor Safeguards Licensing Branch FROM: R. A. Clark, Chief
- Reactor Safeguards Lfcens1ng ranch- SULEC7: SiSEUCHING FOR EXPLOSIVES -
OEVIEld GUIDELtIE NUMBER 20,
REVISION 1 Sackc-our.d naragracn (d)(l) of 10 CFX 73.55 states that the search for detection of firearms, explosives, and fncendiary devices shall be conducted ei..er by ;hysical search or by use cf equfipent cactale of detecting su:c cevices.-
The aren&eAnt t 73.55(d)(1) published in the September 3Q. 1977 Feteral ;tcjstar pnrvices interim relief frcm htaving to pit-down search reguiar plant em~loyees entering nuclear power plants provided, alsa: ecu ~ern; designed f*r detection of weepons and exzics've nae-r1al is urilized t: ;rf.orm Zhe search function on reguar pian; employees.
A c~oy of t'.e September 30, 1977 Federal Recister notice was _rtrs- miz:ed as an enclosure to a lete:.r from Ecson G. Case :o all licensees (iil2;2/7). Also included was an enclosure 0":RR Supplehentil Staff
- os1tion on Fersonnel Search Requirements", khich further clarified the staff position on perponnel searches. This pos'
- 'on paper recognized that'not all licensees possessed Vte necessary equiPent to conduct the searches on regular employees and therefore provided an alternative (random search pracedures)*to the use of such equip- cent. It was never intended however. that these random search procedures be substituted Indefinitely for the weapons and explosives detec:ir.s equijprnt. ln fact, tse staff position paper made lt explicitly clear that acceptable metal detectors and explosive searching devices of the types currently available are deemed catable of detecting firearms, explosives and incendiary devices for regular employees of the licensee at the site and that such equipment, if not currently In operation, must be ourchased and made operational as soon as possible If the licensee is to be in coiplianca with the performance requirement of 10 CFR 73.55.
Reactor Sf2uarls Licensing iranch - 2 -
The staff is not present:y aware of any additional information or factors tha: will resul: in a change to the position tha: use of explosive and metal detecting equipment will satisfy :2ie search requiremen: for regular plant employees.
!t is rec nztde tta: cr-en:tly availale Iiaoloslve detec:ton gavicts (1) art nc: ca:aWlt of de:ec:irg all :veyes of available tz;iosives and (2) egrerinly c:eara on prhnci;:es (vaoor c atc:tion)
that allow for s:raigit';rwar: 'cizanc- 1
- echnic-es by knzwegceable irc vicuals.
An ex:losives detector, or sys:en of czr:cqgnts and4or procedures, gatei.X i:orcoria~t .'r e-t:itmc:ion of a:;os.vts shaal =e: or Wtcsec ?ji e .nS ;ar':rr.anca cnarac:aris:icz:
1. Cetection of generally available types of high explosives
(.. CetcraS:atie c:FZos":ions) of U. S. or foreign
=anufac:tjrt including but no: limited to comoounds con- znain;:;: 7 os<In,'t.; ., Csi0:!
2. The device or sys a" provides high assurance of detet1lon
(;robability of detec:ion of a: leas- O.M) of high explosives (HI).
3. The mininum quanti:y of nE for which t'e required probability
5LS: tobe dwns:ratead s: be no greater than 0.5 kg. The minimum quantity of HEr must be detec:ed with required -
probability when concealed cn a parson or in hand car.-ed jarzents or packages.
CUaRENttY AVAILaL! EXPLOSIVE CETECTCRS'
Model Manufacturu/Ofstributor EXD_2 Elscint. Inc.
138-160 Johnson Avenue P. 0. Box 832 Hackensack, New Jersey 07602 Model-70 Ion Track instruments, Inc.
Thret A^ Street Surlington. assachusetts 01803