ML18324A842

IMC 2200 Appendix a Security Construction Inspection Program

ML18324A842
Person / Time
Issue date:	01/29/2019
From:	Niry Simonian NRC/NSIR/DSO/SOSB
To:
Niry Simonian 301-287-3636
Shared Package
ML18324A839, ML19029A107	List:
References
CN 19-004
Download: ML18324A842 (5)

Text

Issue Date: 01/29/19 1

2200, Appendix A NRC INSPECTION MANUAL NSIR/DSO INSPECTION MANUAL CHAPTER 2200, APPENDIX A SECURITY CONSTRUCTION INSPECTION PROGRAM Effective Date: 01/29/2019 2200-01 PURPOSE This Appendix lists the inspectable areas within the Security Cornerstone and inspection procedures (IPs) to be used when reviewing the licensee construction programs, as outlined in Section 08.01 of Inspection Manual Chapter (IMC) 2504, Construction Inspection Program:

Inspection of Construction and Operational Programs. The purpose of these inspections is to verify that the licensee has programs established and implemented to:

1. Control security activities at the site;

2. Identify problems and resolve them;

3. Report deficiencies and identify failures;

4. Ensure design requirements are translated to construction documentation; and,

5. Ensure the adequacy of inspections, tests, analyses, and acceptance criteria (ITAAC) determination packages for submittal to the U.S. Nuclear Regulatory Commission (NRC).

2200-02 OBJECTIVES 02.01 To gather information to determine whether a licensee is meeting the security programs for construction inspection and operations cornerstone (Construction Reactor Oversight Process (cROP) Security Cornerstone).

02.02 To verify and assess the adequate implementation of licensee security construction and operational programs.

02.03 To identify those significant issues that may have generic applicability or cross-cutting applicability to other cROP cornerstones.

2200-03 APPLICABILITY The program described in this IMC is applicable to all power reactors under construction that are subject to oversight under the NRCs cROP. The guidance in this IMC applies to all NRC personnel with responsibilities for oversight of security operations and programs at power reactors under construction.

Issue Date: 01/29/19 2

2200, Appendix A 2200-04 DEFINITIONS Applicable definitions are found in IMC 2506, Construction Reactor Oversight Process General Guidance and Basis Document.

2200-05 RESPONSIBILITIES AND AUTHORITIES Applicable responsibilities and authorities are found in IMC 2200, Security Inspection Program for Construction.

2200-06 REQUIREMENTS Inspectable Areas within the Security Cornerstone.

The NRCs security construction inspection program requires the inspectable areas below to be reviewed at each NRC-licensed power reactor under construction. The inspectable areas verify aspects of key attributes of the construction security cornerstone in the safeguards strategic performance area.

Inspectable Areas Inspection of ITAAC-Related Security Structures, Systems, and Components Fitness-for-Duty Program Access Authorization Access Control Performance Evaluation Program Equipment Performance, Testing, and Maintenance Protective Strategy Evaluation Protection of Safeguards Information Security Training Fitness-for-Duty (FFD) Operational Program Cyber Security Inspection for Construction Security Organization, Management Effectiveness, Program Reviews and Audits Material Control and Accounting (MC&A)

Review of New Reactor Target Sets Fixed Site Physical Protection of Special Nuclear Material of Low Strategic Significance Fitness-for-Duty Program for Construction Protection of Safeguards Information for Construction

Issue Date: 01/29/19 3

2200, Appendix A 2201-07 GUIDANCE Inspection Procedure Number Security Construction and Operational Program1 Direct Inspection Effort (DIE)2 65001.17 Inspection of ITAAC-Related Security Structures, Systems, and Components 160 71130.08 Fitness-for-Duty Program 24 81000.01 Access Authorization 32 81000.02 Access Control 20 81000.03 Performance Evaluation Program 10 81000.04 Equipment Performance, Testing, and Maintenance 38 81000.05 Protective Strategy Evaluation 100 81000.06 Protection of Safeguards Information 10 81000.07 Security Training 27 81000.08 Fitness-for-Duty (FFD) Operational Program 33 81000.09 Cyber Security Inspection for Construction 320 81000.10 Security Organization, Management Effectiveness, Program Reviews and Audits 26 81000.11 Material Control and Accounting (MC&A) 6 81000.14 Review of New Reactor Target Sets 48 81431 Fixed Site Physical Protection of Special Nuclear Material of Low Strategic Significance 11 81504 Fitness-for-Duty Program for Construction 383 81505 Protection of Safeguards Information for Construction 10 Security Construction and Operational Inspection Program Total4 913 Security Construction Cornerstone Inspection Annualized Grand Total 913 DIE 1

The Office of Nuclear Security and Incident Response (NSIR) funds the security inspection budget.

2 All time (hours) spent performing direct inspection activities by resident inspectors, region-based inspectors, and headquarters inspectors in support of the reactor inspection program.

3 Subsequent fitness-for-duty inspections occur every 2 years, with a total of 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of DIE.

4 The total does not include construction resident inspector activities that are not considered DIE. In the interim, both the Office of New Reactors and NSIR will fund the inspection budget allocation in part.

Issue Date: 01/29/19 4

2200, Appendix A 2201-07 REFERENCES IMC 2200, Security Inspection Program for Construction IMC 2504, Construction Inspection Program: Inspection of Construction and Operational Programs IMC 2506, Construction Reactor Oversight Process General Guidance and Basis Document END

Issue Date: 01/29/19 Att1-1 2200, Appendix A ATTACHMENT 1 - Revision History for IMC 2200, Appendix A, Security Construction Inspection Program Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession No.

(Pre-Decisional, Non-Public Information)

N/A ML120860224 09/07/2012 CN 12-020 Researched commitments back four years and found none. Appendix developed to support security construction inspections under IMC 2200.

Training to be covered at the July 2013 Annual Security Counterpart Meeting.

N/A N/A ML18324A842 01/29/19 CN 19-004 Administrative edits made to include:

formatting to IMC 0040 standards, updates to IP names, IP numbers, and DIE hours.

Upon completion of a SUNSI review, the staff concluded that this IMC should be decontrolled. Consistent with the staffs SUNSI determination, this IMC is now publicly available.

N/A ML18324A841