ML23192A039

Abilene Christian University, NRC Slides from April 13, 2023, Closed Meeting to Discuss Security Topics

ML23192A039
Person / Time
Site:	99902088, Abilene Christian University
Issue date:	04/13/2023
From:	Beth Reed Office of Nuclear Reactor Regulation
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ML23192A037	List: ML23192A038 ML23192A039
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Download: ML23192A039 (1)

Text

Approach to Physical Security for Non-Power Reactor Applicants Beth Reed, Security Specialist Advanced Reactor Policy Branch April 13, 2023

Purpose Discuss the NRCs approach to the physical security requirements for non-power production utilization facility (NPUF) applicants planning on possessing, utilizing, or transporting Category ll or III quantities of special nuclear material (SNM). This includes:

- Compliance with the current physical security regulations under 10 CFR 73.67

- The potential for issuing supplemental security measures as license conditions

• 2

SNM Categories

• The NRCs current approach to the physical protection of SNM is based on the quantity and type of the material (i.e., plutonium, U-233, or enriched U-235).

• There are three categories of SNM that the NRC regulates:

- Category I (formula quantity of strategic SNM),

- Category II (SNM of moderate strategic significance),

- Category III (SNM of low strategic significance)

• 3

SNM Categories II & III

• 4

Current NPUF Approach

• Regulatory Framework for Security at currently licensed NPUFs:

- Regulations

• 10 CFR 73

- Supplemental Security Measures

• Physical security

- Detect & Assess

- Delay

- Respond

- Orders

• Access Authorization Orders SSMs Regulations

• RTR Security

• Slide 5of 17

Security Regulations 10 CFR Part 73 Physical Security of Plants and Materials

- SGI Program: 10 CFR 73.21, 22, and 23; Regulatory Guide 5.79 (ML103270219); Order EA-06-203 (ML062350289)

- Physical security of SNM: 10 CFR 73.60(f), 73.67; Regulatory Guide 5.59

- Access Authorization: 10 CFR 73.57, 73.59, Order EA-07-074 (ML070750190)

- Event Notification: 10 CFR 73.71 and 73 Appendix G

• Update to requirements: Effective April 13, 2023 with 300 day implementation period

• New 73.1200, 73.1205, 73.1210, and 73.1215

• https://www.federalregister.gov/documents/2023/03/14/2023-03944/enhanced-weapons-firearms-background-checks-and-security-event-notifications

• 6

Security Regulations and Guidance (continued)

• 10 CFR 73 Physical Security of Plants and Materials

- Transportation:

• Fresh fuel: 10 CFR 73.67

• Spent fuel: 10 CFR 73.37 and 38

- Posting: 10 CFR 73.75

- Cyber Security: No regulations for NPUFs, for information purposes only refer to Regulatory Guide 5.71 (ML18016A129); Effective Practice for RTRs (ML15253A060)

• 7

Developments of Supplemental Security Measures

• Post 9/11 additional security measures

• 2015 Regulatory Basis for proposed rule

- ML#14321A007

- Risk informed and graded approach

• Commissioned approve SSMs for NPUFs producing Moly-99

- SECY-18-0063 (ML17333A161)

- Staff developed SSMs based on previous post 9/11 security measures and information from the Regulatory Basis

• RTR Security

• Slide 8of 17

Additional Security Measures for NPUFs following the Events of 9/11

• From 2002 to 2003 (following the 9/11 attacks), NRC requested most NPUF licensees develop a site-specific compensatory measures implementation plan (CMIP) that addressed additional security measures.

• The CMIPs were inspected and confirmed through the issuance of confirmatory action letters (CALs).

• In general, the CMIPs included enhancements such as vehicle barriers, personnel background checks, coordination and communication with local law enforcement, vehicle and personnel searches, and visitor escorting.

• 6

Developed to Support Rulemaking

• Regulatory Basis 2015 for Rulemaking to Enhance Security of SNM

- In ADAMS under ML14321A007

• Rule was discontinued, but approach remains

- Graded approach

- Risk informed

- Based on the attractiveness of the material

- Driven by the dilution of the material

• Commission recently directed staff to submit options for enhanced security of SNM, one option is to restart rulemaking to include previously written security measure into the regulations

• 10

Security for NPUFs for Moly-99 Production

• COMSECY-17-0008 (non-public)

- Staff request applying SSMs to NPUFs intending to produce Molly-99

• Staff develop[ed SECY-18-0063 in response to SRM-COMSECY-17-0008 (non-public)

- Staff developed SSMs and committed to using a site-specific graded approach (quantity of SNM and material attractiveness)

- The Commission approved the approach for NPUF applicants intending to produce Moly-99

• Staff intends to use the same approach for all NPUF applicants, to include material attractiveness

• RTR Security

• Slide 11of 17

Physical Security for NPUF Applicants

• The staff intends to use the SSMs from SECY-18-0063

• The regulatory framework remains appropriate at NPUFs because of the type of SNM and its location.

• The material attractiveness approach will be used

- Pure, solid ingots

- Fuel elements

- Aqueous fuel

• 13

What Could the SSMs Look Like

• Similar to what is in place now for licensed NPUFs

- Supplement the regulations

• Site specific

- Dependent on design, use, product, etc.

• Graded approach

- Accounts for type and quantity of material used

- Risk informed, consequence driven.

• RTR Security

• Slide 13of 17

Potential Supplemental Security Measures Cat I Cat I Mod Dilute Cat II Cat II Mod Dilute Cat I Highly Dilute Cat III Protective Strategy Protect against DBT of theft and diversion and radiological sabotage Prevent the removal of SNM and other unauthorized activities involving SNM Diversion Path Analysis 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 Cont.

Plan Training & Qual. Plan Physical Security Plan Safeguards Cont.

Plan Training & Qual. Plan Physical Security Plan Physical Security Plan

• 14

Cat I Cat I Mod Dilute Cat II Cat II Mod Dilute Cat I Highly Dilute Cat III Security Organization Implement Program Management System Part 26 - except Subpart I & K Part 26, Subpart I -

Manage Fatigue Implement Program Management System Implement Program Management System Implement Program Management System Physical Barrier OCA Vehicle Barrier System/blast analysis Isolation Zone Protected Area Vital Area Material Access Area Locked Processes Vault Hardened CAS 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

• 15

Cat I Cat I Mod Dilute Cat II Cat II Mod Dilute Cat I Highly Dilute Cat III Access Controls Protected & Material Access Area Access Portals Limit unescorted access Part 11 Photo Badges Escort Requirements Protected Area &

Controlled Access Area Access Portals Limit unescorted access 73.57 Photo Badges Escort Requirements Controlled Access Area Access Portals Limit unescorted access 73.57 Photo Badges Escort Requirements Controlled Access Area Access Portals Limit unescorted access 73.57 Photo Badges Escort Requirements Search Programs OCA - vehicles Protected Area -

entry (contraband) &

exit (SNM -

shielding)

Material Access Area - entry and exit (SNM - shielding)

Vault (weapons)

Protected Area -

entry (contraband) &

exit (SNM &

shielding)

Controlled Access Area - exit (SNM &

shielding)

Controlled Access Area - entry (contraband) random exit (SNM &

shielding)

None

• 16

Cat I Cat I Mod Dilute Cat II Cat II Mod Dilute Cat I Highly Dilute Cat III Detection and Assessment Protected Area &

Material Access Area Intrusion Detection System with UPS Video Capture Central Alarm Station Secondary Alarm Station Surveillance Program -

Protected Area &

unoccupied Material Access Area Periodic Patrols of outside areas Two person rule in MAA Three person rule in Vault Illumination 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 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 Surveillance Program Periodic Patrols of outside areas

• 17

Cat I Cat I Mod Dilute Cat II Cat II Mod Dilute Cat I Highly Dilute Cat III 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/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

10 Tactical Response Team -

interrupt and neutralize Deadly Force Armed Security Officers LLEA Liaison Heightened Security Deadly Force Armed Security Officers - interrupt LLEA Liaison Heightened Security LLEA Liaison Heightened Security LLEA Liaison

• 18

Cat I Cat I Mod Dilute Cat II Cat II Mod Dilute Cat I Highly Dilute Cat III

• 19 Security Program Review Annually Management Review CAP or event log Bi-annually Management Review CAP or event log Bi-annually Management Review CAP or event log Bi-annually Management Review CAP or event log Maintenance &

Testing Required Required Required None Compensatory Measures In PSP In PSP In PSP In PSP Suspension of Security Measures Allowed Allowed Allowed Allowed Records Required Required Required Required Alternative Measures Allowed Allowed Allowed Allowed