NRC Generic Letter 1989-20

NRC Generic Letter 1989-020: Protected Area Long-Term Housekeeping

ML031150351
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Washington Public Power Supply System, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Clinch River
Issue date:	09/26/1989
From:	Mccorkle G Office of Nuclear Material Safety and Safeguards
To:
References
GL-89-020, NUDOCS 8909280098
Download: ML031150351 (4)

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SEP 2 6 798g FORMULA

TO ALL FUEL CYCLE FACILITY LICENSEES WHO POSSESS, USE, OR PROCESS

QUANTITIES OF STRATEGIC SPECIAL NUCLEAR MATERIAL

SUBJECT: PROTECTED AREA LONG-TERM HOUSEKEEPING (GENERIC LETTER 89-20)

that objects, This generic letter is being issued because of a growing concern have the potential materials and general clutter within the protected area (PA)

guards in assessing and responding to of adversely impacting the capability of Teams (TRT),

alarms. Specifically, the effectiveness of the Tactical Response by the lack as required by the new comparability rule, may be directly impacted of unrestricted movement throughout the PA.

Current regulations require that each fuel cycle facility 73.46(b)(9);subject to the TRT exercises under have requirements of 10 CFR 73.46 perform either side adequate isolation zones for observing activities and people on illuminate the isolation zones and all of the PA barrier under 73.46(c)(3); observation exterior areas within the PA to allow for-the monitoring and isolation requirements under 73.46(c)(4); detect penetration through the or periodically zones to permit response action under 73.46(e)(1); monitor guards *

check all exterior areas within the PA under 73.46(e)(8); require for purposes of..-

to interpose themselves between any adversary attempting entryand provide assess- theft of special nuclear material under 73.46(h)(4)(iii)(A); limit exposure of;

ment capabilities either by CCTV or other suitable means which responding personnel to possible attack under 73.46(h)(6).

have Recent performance-oriented team inspections at fuel cycle facilities security system identified PA clutter as having a negative impact on overall potential cover and concealment for adver- ' -

effectiveness. PA clutter provides and restricts saries, reduces illumination levels and assessment capabilities, of these the movement of responding forces. We believe that the presence to meet the system cluttered areas inside the PA reduces the licensee's ability performance objectives of 10 CFR 73.20(a).

or concealment In general, the condition of the PA should not provide cover CCTV or a responding for an adversary, it should not hinder assessment by either the 0.2 footcandle guard, and it should not cause the illumination to fall below zone.

level required of the exterior portions of the PA and isolation include:

Concerns and possible corrective actions covered by this letter o Construction within the PA

- Physically separate construction activities from the rest of the PA with a temporary barrier.

- Control access to and from the construction site.

be Upon completion of the construction the area should immediately cleared.

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o Previous construction areas

- Clear any lay-down areas leftover from prior construction activities.

-- Fill in and grade earthworks.

- Remove any temporary fencing or other obstructions.

O Scrap and Waste storage areas Process promptly if scrap, or move offsite if waste, if these areas interfere with the effectiveness of the security system.

- Any scrap maintained should be in a separately fenced area, no closer than 25 feet to inner PA fence, but within the PA.*

o Vehicle storage

- Establish areas within the PA where all designated licensee vehicles are stored and controlled when not in use.

- Establish this area in a manner that does not add clutter.

In response to this letter licensees should provide a report describing site conditions relating to isolation zones, protected areas, construction, waste and scrap storage, and vehicle storage or other activities that may obstruct obser- vation or reduce illumination levels. The report should include a description of the security maintenance program for the prevention of obstructions which may degrade security system performance.

Pursuant to the Commission's authority in 10 CFR 70.22(d), licensees are requested to submit this report and a schedule for correcting deficiencies within 90 days of the date of this Generic Letter to:

Donald J. Kasun Acting Chief Domestic Safeguards and Regional Oversite Branch Nuclear Regulatory Commission WFN 4-E-4 Washington, D.C. 20555

• (Note that scrap storage may have no more that .25 gms. of U-235 per liter in 30 gallon or larger containers (73.46(c)(6).

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This reporting requirement has been approved by the Office of Management and Budget under control number 3150-0009 (see 10 CFR 70.8(a)).

If you have any questions about this matter, please contact C. E. Gaskin at

(301) 492-0649 or Rocio Castaneira at (301) 492-0392.

Sincerely,

/S /

George W. McCorkle, Acting Director Division of Safeguards and Transportation, NMSS

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This reporting requirement has been approved by the Office of Management and Budget under control number 3150-0009 (see 10 CFR 70.8(a)).

If you have any questions about this matter, please contact C. E. Gaskin at FTS

492-0649 or Rocio Castaneira at FTS 492-0392.

Sincerely, George W. McCorkle, Acting Director Division of Safeguards and Transportation, NMSS

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