ML12314A356

Request for Additional Information, Round 2, Changes to Callaway Physical Security Plan (TAC No. D91660)

ML12314A356
Person / Time
Site:	Callaway
Issue date:	11/20/2012
From:	Lyon C Plant Licensing Branch IV
To:	Heflin A Union Electric Co
Lyon C
References
TAC D91660
Download: ML12314A356 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 20, 2012 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1- REQUEST FOR ADDITIONAL INFORMATION RE: CHANGES TO SECURITY PLAN (TAC NO. 091660)

Dear Mr. Heflin:

By letter dated August 3,2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12221A190), as supplemented by letter dated October 18,2012 (ADAMS Accession No. ML122960489), Union Electric Company (the licensee) submitted the Physical Security Plan, Revision 10, for Callaway Plant, Unit 1. The enclosure to the letter dated August 3,2012, contained Safeguards Information, and the enclosure to the letter dated October 18, 2012, contained Security-Related Information; accordingly, both enclosures have been withheld from public disclosure. The U.S. Nuclear Regulatory Commission (NRC) staff is currently reviewing the submittal to ensure compliance with Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.54(p)(2).

The NRC staff has determined that additional information, as requested in the enclosure, is needed to complete its review. Please provide a response to the questions within 30 days of the date of this letter. If circumstances result in the need to revise the requested response date, please contact me at 301-415-2296 or via e-mail at Fred.Lyon@nrc.gov.

Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

As stated cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION CHANGES TO PHYSICAL SECURITY PLAN UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. SO-483 By letter dated August 3, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12221A190), as supplemented by letter dated October 18,2012 (ADAMS Accession No. ML122960489), Union Electric Company (the licensee) submitted the Physical Security Plan (PSP), Training and Qualification Plan, and Safeguards Contingency Plan (SCP), Revision 10, for the Callaway Plant, Unit 1. The enclosure to the letter dated August 3,2012, contained Safeguards Information, and the enclosure to the letter dated October 18, 2012, contained Security-Related Information; accordingly, both enclosures have been withheld from public disclosure. The U.S. Nuclear Regulatory Commission (NRC) staff is currently reviewing the submittal to ensure compliance with Title 10 of the Code of Federal Regulations (10 CFR), paragraph SO.S4(p)(2). NRC staff has determined that the additional information requested below is needed to complete its review.

1. Section 11.1 of the PSP and Section 7 of the SCP, describes a physical barrier and associated intrusion detection and assessment equipment that are used to define the boundary of the Owner Controlled Area (OCA) at the site. Please describe how this OCA barrier and associated intrusion detection and assessment equipment meets the requirements of 10 CFR 73.SS. Specifically:

a. Please describe the function of this OCA barrier by identifying how it and the associated intrusion detection and assessment capabilities are integrated within the physical protection program and protective strategy and how these capabilities are used to support the initiation of the protective strategy. Please describe how the detection and assessment capability at this OCA barrier facilitates the initiation of operator actions that are credited within target sets.

Please describe how the implementation of this OCA barrier and associated intrusion detection and assessment equipment have been included in the drills and exercises of the site's protective strategy that have been conducted to meet the Performance Evaluation Program requirements of 10 CFR Part 73, Appendix B VI, C.3. Please describe the percentage of drills and exercises, conducted since implementation of this OCA barrier and associated intrusion detection and assessment equipment, in which initiation of the protective strategy resulted from adversary detection at the OCA barrier.

Regulatory Basis:

Consistent with 10 CFR 73.SS(c)(3), the licensee shall establish, maintain, and implement a physical security plan which describes how the performance objective and requirements set forth in this section will be implemented.

Enclosure

- 2 Consistent with 10 CFR 73.55(e)(1)(ii), the licensee shall describe in the security plan, physical barriers, barrier systems, and their functions within the physical protection program.

b. Please describe how the openings in this OCA barrier are secured and monitored to prevent exploitation of the openings.

Regulatory Basis:

In accordance with 10 CFR 73.55(e)(4), consistent with the stated function to be performed, openings in any barrier or barrier system established to meet the requirements of this section must be secured and monitored to prevent exploitation of the opening.

c. Please describe how vehicle and material access through this OCA barrier is controlled.

Regulatory Basis:

In accordance with 10 CFR 73.55(g)(1), consistent with the function of each barrier or barrier system, the licensee shall control personnel, vehicle, and material access, as applicable, at each access control point in accordance with the physical protection program design requirements of 10 CFR 73.55(b).

d. Please describe the personnel, vehicle, and material access control portals of this OCA barrier, specifically whether they are located outside of, or co-located with, the OCA barrier.

Regulatory Basis:

Consistent with 10 CFR 73.55(g)(1)(i)(A), access control portals must be located outside of, or concurrent with, the physical barrier system through which it controls access.

e. Please describe how the locking devices, intrusion detection equipment, and surveillance equipment implemented at the personnel, vehicle, and material access control portals of this OCA barrier meet regulatory requirements.

Regulatory Basis:

Consistent with 10 CFR 73.55(g)(1 )(i)(8), access control portals must be equipped with locking devices, intrusion detection equipment, and surveillance equipment consistent with the intended function.

-3

f. Please describe the search procedures that have been implemented at access control portals within this DCA barrier.

Regulatory Basis:

Consistent with 10 CFR 73.55(h)(2)(i), where the licensee has established physical barriers in the owner controlled area, the licensee shall implement search procedures for access control points in the barrier.

g. Please describe how the intrusion detection and assessment equipment at this DCA barrier provides, at all times, the capability to detect and assess unauthorized persons and facilitate the effective implementation of the protective strategy.

Regulatory Basis:

Consistent with 10 CFR 73.55(i)(1), the licensee shall establish and maintain intrusion detection and assessment systems that satisfy the design requirements of 10 CFR 73.55(b) and provide, at all times, the capability to detect and assess unauthorized persons and facilitate the effective implementation of the licensee's protective strategy.

h. Please describe how the intrusion detection and assessment equipment at this DCA barrier is designed to annunciate and display concurrently in two continuously staffed onsite alarm stations.

Regulatory Basis:

Consistent with 10 CFR 73.55(i){2), intrusion detection eqUipment must annunciate and assessment equipment shall display concurrently, in at least two continuously staffed onsite alarm stations. at least one of which must be protected in accordance with the requirements of the central alarm station within this section.

i. Please describe how the intrusion detection and assessment systems at this DCA barrier are designed to: 1) provide visual and audible annunciation of an alarm; 2) provide a visual display from which assessment of the detected activity can be made; 3) ensure that the annunciation of an alarm indicates the type and location of the alarm; 4) ensure that alarm devices to include transmission lines to annunciators are tamper indicating and self-checking; 5) provide an automatic indication when the alarm system or a component of the alarm system fails, or when the system is operating on the back-up power supply; and 6) support the initiation of a timely response in accordance with the security plans, protective strategy, and associated implementing procedures.

- 4 Regulatory Basis:

Consistent with 10 CFR 73.55(i)(3)(i) through (i)(3)(vi), the licensee's intrusion detection and assessment systems must be designed to: (i) provide visual and audible annunciation of the alarm; (ii) provide a visual display from which assessment of the detected activity can be made; (iii) ensure that annunciation of an alarm indicates the type and location of the alarm; (iv) ensure that alarm devices to include transmission lines to annunciators are tamper indicating and self-checking; (v) provide an automatic indication when the alarm system or a component of the alarm system fails, or when the system is operating on the back-up power supply; and (vi) support the initiation of a timely response in accordance with the security plans, protective strategy, and associated implementing procedures.

j. Please describe how unattended openings that intersect this OCA barrier have been addressed to detect exploitation by surreptitious bypass.

Regulatory Basis:

Consistent with 10 CFR 73.55(0(5)(iii), unattended openings that intersect a security boundary such as underground pathways must be protected by a physical barrier and monitored by intrusion detection equipment or observed by security personnel at a frequency sufficient to detect exploitation.

k. Please describe the type of illumination assets that are implemented to ensure the area of this OCA barrier is provided with the illumination necessary to satisfy the design requirements of 10 CFR 73.55(b) and implement the protective strategy.

Regulatory Basis:

Consistent with 10 CFR 73.55(i)(6)(i), the licensee shall ensure that all areas of the facility are provided with illumination necessary to satisfy the design requirements of 10 CFR 73.55(b) and implement the protective strategy.

I. Please describe how the implementation of this OCA barrier and associated intrusion detection and assessment equipment is included in security program reviews.

Regulatory Basis:

Consistent with 10 CFR 73.55(m)(1), as a minimum the licensee shall review each element of the physical protection program at least every 24 months.

m. Please describe how this OCA barrier and associated intrusion detection and assessment equipment is included in the site maintenance, testing, and calibration program and the intervals that the security equipment (intrusion

- 5 detection and assessment, access control, and if applicable search equipment) at the OCA are tested for operability and performance.

Regulatory Basis:

Consistent with 10 CFR 73.55(n)(1 )(i), the licensee shall establish, maintain, and implement a maintenance, testing and calibration program to ensure that security systems and equipment, including secondary power supplies and uninterruptible power supplies, are tested for operability and performance at predetermined intervals, maintained in an operable condition, and are capable of performing their intended function.

n. Please describe the compensatory measures that are implemented when this OCA barrier, and the associated intrusion detection, assessment, access control, and, if applicable, search equipment fails or becomes degraded.

Regulatory Basis:

Consistent with 10 CFR 73.55(n)(1)(v), licensees shall implement compensatory measures that ensure the effectiveness of the onsite physical protection program when there is a failure or degraded operation of security-related component or equipment.

Additionally, appropriate changes should be made during the next revision of the site's security plans to ensure the language clearly describes the intended function of this OCA barrier as it pertains to the implementation of certain aspects of the physical protection program (e.g., access control, initiation of the protective strategy, etc.) in accordance with 10 CFR 73.55(e)(1)(li).

Regulatory Basis:

Consistent with 10 CFR 73.55(c)(3), the licensee shall establish, maintain, and implement a physical security plan which describes how the performance objective and requirements set forth in this section will be implemented.

Consistent with 10 CFR 73.55(e)(1)(ii), the licensee shall describe in the security plan, physical barriers, barrier systems, and their functions within the physical protection program.

November 20, 2012 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION RE: CHANGES TO SECURITY PLAN (TAC NO. D91660)

Dear Mr. Heflin:

By letter dated August 3, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12221A190), as supplemented by letter dated October 18, 2012 (ADAMS Accession No. ML122960489), Union Electric Company (the licensee) submitted the Physical Security Plan, Revision 10, for Callaway Plant, Unit 1. The enclosure to the letter dated August 3, 2012, contained Safeguards Information, and the enclosure to the letter dated October 18, 2012, contained Security-Related Information; accordingly, both enclosures have been withheld from public disclosure. The U.S. Nuclear Regulatory Commission (NRC) staff is currently reviewing the submittal to ensure compliance with Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.54(p)(2).

The NRC staff has determined that additional information, as requested in the enclosure, is needed to complete its review. Please provide a response to the questions within 30 days of the date of this letter. If circumstances result in the need to revise the requested response date, please contact me at 301-415-2296 or via e-mail at Fred.Lyon@nrc.gov.

Sincerely, I RAt Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

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