ML13165A084
| ML13165A084 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 06/13/2013 |
| From: | Wilkins L E Plant Licensing Branch IV |
| To: | Edwards M L Omaha Public Power District |
| Wilkins L E | |
| References | |
| TAC D91660 | |
| Download: ML13165A084 (6) | |
Text
1 Burkhardt, Janet From: Wilkins, Lynnea Sent: Thursday, June 13, 2013 5:29 PM To: 'EDWARDS, MICHAEL L' Cc: 'LIPPY, DONNA L'; 'HANSHER , BILL R'; Burkhardt, Janet
Subject:
DRAFT: RAI for Fort Calhoun Station Re: 50.54 Changes, Rev 21 (D91660)
Attachments:
50 54 Changes Rev 21 RAIs Email.docxMike, By letter dated May 14, 2013 (Agencywide Document s Access and Management System (ADAMS) Accession No. ML13137A059), Omaha Public Power District submitted the Fort Calhoun Station's Physical Security Plan (PSP), Training and Qualification Plan (T&QP), and Safeguards Contingency Plan (SCP), Revision 21. The enclosure to the letter contained Safeguards Information and has been withheld from public disclosure. The U.S. Nuclear Regulatory Commission (NRC) staff is cu rrently reviewing the submittal to ensure compliance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(p)(2).
The NRC staff has reviewed your submittal and has determined that the information specified in the attached Request for Additional Information (RAI) is needed for the staff to complete its evaluation.
Please contact me if a clarifying teleconference is needed for the attached RAIs.
Thanks Lynnea Lynnea Wilkins, Project Manager Fort Calhoun Station, Unit 1 Cooper Nuclear Station Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation US Nuclear Regula tory Commission Phone: 301-415-1377
10 CFR 50.54(p)(2) CHANGES TO SECURITY PLAN OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NO. 50-285
By letter dated May 14, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13137A059), Omaha Public Power District submitted the Fort Calhoun Station's Physical Security Plan (PSP), Training and Qualification Plan (T&QP), and Safeguards Contingency Plan (SCP), Revision 21. The enclosure to the letter contained Safeguards Information and has 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), Section 50.54(p)(2). The NRC staff has determined that the additional information requested below is needed to complete its review.
- 1. Consistent with 10 CFR 73.55(c)(1)(i), licensee security plans must describe how the licensee will implement requirements of this section through the establishment and maintenance of a security organization, the use of security equipment and technology, the training and qualification of security personnel, the implementation of predetermined response plans and strategies, and the protection of digital computer and
communication systems and networks.
Consistent with 10 CFR 73.55(d)(2)(ii), the security organization must include at least one member, onsite and available at all times, who has the authority to direct the activities of the security organization and who is assigned no other duties that would interfere with this individual's ability to perform these duties in accordance with the security plans and the licensee protective strategy.
Consistent with 10 CFR Part 73, Appendix C II, B.3.a., the safeguards contingency plan must describe the organization's chain of command and delegation of authority during safeguards contingency events, to include a general description of how command and control functions will be coordinated and maintained.
In Section 4.1 of the PSP, the description of the duties of the Security Shift Supervisor (SSS) and Response Team Leader (RTL) has changed. Though the purpose of this change was identified within the summary of changes, "to be consistent with the NEI 03-12, Rev. 7 format," no information was submitted to demonstrate that this change has no impact on the site-specific implementation of the protective strategy and does not decrease the effectiveness of the security plans. The second to the last paragraph within Section 4.1 of the PSP identifies the SSS or Lieutenant as being responsible for directing the security forces which seems to conflict with the changed duty descriptions of the SSS and RTL provided within Section 4.1 of the PSP. In addition, changes were made to Section 4.1.2 "Security Chain of Command/Delegation of Authority," that were identified within the summary of changes as removing redundant information. It is 2 unclear from these descriptions and changes whether the SSS would have any responsibility for directing security force actions during a safeguards contingency event.
- a. Please describe how the changes to the duties of the SSS and RTL as identified in Section 4.1 of the PSP do not decrease the effectiveness of the site security plans.
- b. Please describe whether the SSS would be responsible for directing the response actions of the security organization at any time during a contingency event.
- c. Please describe the rationale for the duty position of the SSS not being included within Section 4.1.2, "Chain of Command/Delegation of Authority."
Additionally, please confirm that appropriate changes will be made during the next revision of the security plans to clearly describe the duties and responsibilities of the SSS during a safeguards contingency event and (as applicable) to identify the SSS within the security organization's "Chain of Command/Delegation of Authority," listing.
- 2. Consistent with 10 CFR 73.55(c) (1) (I), licensee security plans must describe how the licensee will implement requirements of this section through the establishment and maintenance of a security organization, the use of security equipment and technology, the training and qualification of security personnel, the implementation of predetermined response plans and strategies, and the protection of digital computer and
communication systems and networks.
Consistent with 10 CFR 73.55(d) (2) (ii), the security organization must include at least one member, onsite and available at all times, who has the authority to direct the activities of the security organization and who is assigned no other duties that would interfere with this individual's ability to perform these duties in accordance with the security plans and the licensee protective strategy.
Consistent with 10 CFR 73.55(k)(5)(iii), armed responders shall be available at all times inside the protected area and may not be assigned other duties or responsibilities that could interfere with their assigned response duties.
Consistent with 10 CFR Part 73, Appendix C II, B.3.a., the safeguards contingency plan must describe the organization's chain of command and delegation of authority during safeguards contingency events, to include a general description of how command and control functions will be coordinated and maintained.
Section 4.1 of the PSP provides descriptions of the duty positions within the security organization. Section 4.1.1 of the SCP also provides duty descriptions for members of the security response organization. The second to the last paragraph within Section 4.1 of the PSP identifies the SSS or Lieutenant as the one full time member of the security force that has the authority to direct security forces and is on site at all times consistent with 10 CFR 73.55(d)(2)(ii). Section 4.1.2 of the SCP identifies the duty position of Lieutenant within the Chain of Command/Delegation of Authority table as being RTL qualified. Neither Section 4.1 of the PSP or Section 4.1.1 of the SCP provide a description of the duty position and duties of the Lieutenant or directly correlate this duty position to the duty positions and duty descriptions of SSS or RTL. Within the critical 3 task matrix (CTM) of the T&QP, the training and qualification criteria for the duty position of Lieutenant is not identified or directly correlated to the duty position of SSS or RTL.
- a. Please describe the duty position and duties of the Lieutenant within the security organization to include any interrelation to the duties and responsibilities of the SSS and RTL during normal operations and safeguards contingency events.
- b. Please describe the training and qualification criteria for the duty position of Lieutenant and how this criterion enables an individual performing within this duty position to fulfill all assigned duties and responsibilities.
- c. If this duty position is responsible to perform the duties of the SSS and RTL, please describe how an individual within this duty position discharges those duties without conflict consistent with 10 CFR 73.55(d)(2)(ii), 10 CFR 73.55(k)(5)(iii), and the regulatory position demonstrated in Security Frequently Asked Question (SFAQ) 10-
- 13.
Additionally, please confirm that appropriate changes will be made during the next revision of the security plans to clearly describe the duty position, duties, and training and qualification criteria for the duty position of Lieutenant within the site's security organization.
- 3. Consistent with 10 CFR 73.55(c)(3), the licensee shall establish, maintain, and implement a PSP which describes how the performance objective and requirements set forth in this section will be implemented.
Consistent with 10 CFR 73.55(h)(3)(i), the search for firearms, explosives, incendiary devices, or other items which could be used to commit radiological sabotage shall be accomplished through the use of equipment capable of detecting these items, or through visual and physical searches, or both, to ensure that all items are clearly identified before granting access to PAs. The licensee shall subject all persons except official Federal, state, and local law enforcement personnel on official duty to these searches upon entry to the PA. Armed security officers who are on duty and have exited the PA may re-enter the PA without being searched for firearms.
Section 14.4.4 of the PSP describes protected area (PA) vehicle sear ch and the process for armed security officers to re-enter the PA. In Revision 19, Section 14.4.4 of the PSP, the language used to describe this process was consistent with the suggested language within the resolution of Security Frequently Asked Question (SFAQ) 12-06; however, in Section 14.4.4 of the PSP, Revisions 20 and 21, the suggested language within the resolution of SFAQ 12-06 has been removed and replaced with a reference to specific security measures that are documented in site procedures. Please describe the specific security measures implemented for armed security officer re-entry into the PA that are documented in site procedures as referenced in Section 14.4.4 of the PSP and how these measures meet the requirements of 10 CFR 73.55(h)(3)(i). See SFAQ 12-06.
Additionally, please confirm that appropriate changes will be made during the next revision of the security plans to clearly describe the security measures for maintaining the search integrity of armed security officers re-entering the PA.
4 4. Consistent with 10 CFR 73.2, "Definitions," vital equipment means any equipment, system, device, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. Equipment or systems which would be required to function to protect public health and safety following such failure, destruction, or release are also considered to be vital.
Consistent with 10 CFR 73.55(e)(9)(i) through (e)(9)(vi)(B), (i) vital equipment must be located only within vital areas, which must be located within a protected area so that access to vital equipment requires passage through at least two physical barriers, except as otherwise approved by the Commission and identified in the security plans; (ii) the licensee shall protect all vital area access portals and VA emergency exits with intrusion detection equipment and locking devices that allow rapid egress during an emergency and satisfy the vital area entry control requirements of this section; (iii) unoccupied VA must be locked and alarmed; (iv) more than one VA may be located within a single protected area; (v) at a minimum, the following shall be considered vital areas: (A) the reactor control room; (B) the spent fuel pool; (C) the central alarm station; and (D) the secondary alarm station in accordance with Section 73.55(i)(4)(iii); (vi) at a minimum, the following shall be located within a vital area: (A) the secondary power supply systems for alarm annunciation equipment; and (B) the secondary power supply systems for non-portable communications equipment.
Section 14.5 of the PSP includes a vital area (VA) listing that identifies the VAs at the site. The list of VAs in the current revision of the PSP has changed from the list that was contained in the previous revision of the PSP. A specific location was removed from the VA listing along with the list of front line vital systems and support systems which includes a component/area (Item 7 of the front line vital systems list) that is required to be considered a VA consistent with 10 CFR 73.55(e)(9)(v). Though the changes to remove the specific location and the front line and support systems list was identified in the summary of changes, the rationale for these changes, and how these changes were evaluated to ensure they did not decrease the effectiveness of the security plans was not provided. Please provide an explanation of the rationale for these changes which demonstrates that these changes do not constitute a decrease in the effectiveness of the security plans, specifically:
- a. Please describe the rationale for previously designating and protecting the area that was removed from the VA listing, as a VA.
- b. Please describe the rationale for removing the site specific information (front line vital systems and support systems lists) that included the identification of a component/area (Item 7 of the front line vital systems list) that is required by 10 CFR 73.55(e)(9)(v) to be considered a VA. This description should include identifying the location of Item 7 of the front line vital systems list within the PA (e.g. located within Item b of the VA listing), and confirming that it is provided the protection of a vital area consistent with the requirements of 10 CFR 73.55(e)(9).
Confirm that the areas containing the vital equipment identified on the front line vital systems and support systems lists are still designated and protected as VA consistent with the requirements of 10 CFR 73.55(e)(9).
- c. Please confirm that an evaluation of the equipment within the area that was removed from the VA listing was conducted and that consistent with the definition of "vital 5 equipment" in 10 CFR 73.2, "Definitions," there is no vital equipment (to include the secondary power supplies for alarm annunciation equipment and non-portable communications equipment) within the area.
- d. Please describe whether the area that was removed from the VA listing is still designated as a controlled area (i.e. access restricted to certain plant personnel) or has been designated as an uncontrolled area (i.e. allowing unrestricted access). If this area is still designated as a controlled area, please describe how access to this area is controlled (e.g. card reader, locking mechanism, intrusion detection equipment, surveillance equipment, etc.).
- 5. Consistent with 10 CFR Part 73, Appendix B VI, A.3., the licensee shall establish, maintain, and follow a Commission-approved training and qualification plan, describing how the minimum training and qualification requirements set forth in this appendix will be met, to include the processes by which all individuals, will be selected, trained, equipped, tested, and qualified.
The CTM within the T&QP does not identify whether any duty position within the site's security organization is trained and qualified to perform Critical Tasks 2, 3, 4, 5, 6, 7, 8, 11, 12, and 14. Though the summary of changes identifies that the site's CTM was changed to be consistent with the security plans of the rest of the Entergy Fleet, and the NEI 03-12, Revision 7, template for security plans, the site's implementation of the minimum training and qualifications for the duty positions within the security organization are not demonstrated within the CTM of the T&QP..
Please describe the duty positions within the security organization that "at a minimum" are trained and qualified to perform Critical Tasks 2, 3, 4, 5, 6, 7, 8. 11, 12, and 14.
Additionally, please confirm that appropriate changes will be made during the next revision of the security plans to identify the minimum training and qualifications of each duty position within the site's security organization.