ML20211F922

Draft Inspection Procedure 71130, Physical Protection

ML20211F922
Person / Time
Issue date:	08/13/1999
From:	NRC
To:
Shared Package
ML20211F885	List: ML20211F882 ML20211F896 ML20211F922 ML20211F929
References
71130-01, NUDOCS 9908310103
Download: ML20211F922 (15)

Text

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l NRC INSPECTION MANUAL IIPB INSPECTION PROCEDURE 71130 PHYSICAL PROTECTION PROGRAM APPLICABILITY: 2515 CORNERSTONE: Physical Protection I

INSPECTION BASES: See inspectable area attachments.

LEVEL OF EFFORT: See inspectable area attachments.

71130-01 INSPECTION OBJECTIVE The objective of this procedure is to gather information to determine whether a licensee is meeting the objectives of this cornerstone which are to provide assurance that the physical security system can protect against the design' basis threat of radiological sabotage.

71130-02 INSPECTION REQUIREMENTS 02.01 Baseline inspection requirements are identified in each of the attached in'spectable areas of:

a. Access Authorization (Attachment 01)

b. Access Control (Attachment 02)

c. Res)onse to Contingency Events (Attachment 03)

d. Pro)lem Identification and Resolution (included as part of each '

inspectable area) 02.02 These requirements represent the minimum inspection activity to be conducted at each reactor site at the frequencies shown in each inspectable area.

02.03 The effectiveness of each licensee to identity and resolve problems in this cornerstone area will also be inspected biannually using the baseline inspection program procedure for evaluating licensee Problem Identification and Resolution programs.

02.04 Evaluations of physical security plan changes are conducted under the Reactor Safety inspectable area: Changes to License Conditions and Safety Analysis Report.

Issue Date: August 13, 1999 DRAFT 71130 DRAFT l 9908310103 990818 PDR ORO fGtRA

1 o e 71130-03 INSPECTION GUIDANCE 03.01 Three performance indicatcrs exist in this cornerstone..

a. One Performance Indicator in this cornerstone monitors the effectiveness of the maintenance process and equipment degradation of components of the perimeter barriers. '

b. One Performance Indicator monitors program degradation in the Access Authorization program.

c. One Performance Indicator monitors program degradation in the Fitness For Duty program

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71130-04 INSPECTION RESOURCES 04.01 Estimates of inspection resources are identified within each inspectable area.

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I 71130 DRAFT Issue Date: August 13, 1999 DRAFT

ATTACHMENT 71130.01 INSPECTABLE AREA: Access Authorization (AA) Program (Behavior Observation only)

CORNERSTONE: Physical Protection INSPECTION BASES: Failure in program can compromise the licensee *s ability to protect against the insider threat of radiological sabotage. The consequences due to radiological sabotage can be high if the program fails.

LEVEL OF EFFORT: Inspection of Access Authorization Behavior Observation program is conducted annually.

71130.01-01 INSPECTION OBJECTIVE ,

Verify that the licensee is properly implementing the behavior observation

. portion of their personnel screening and fitness for duty program.

~71130.01-02 INSPECTION REQUIREMENTS 02.01 Insoection Plannino During review of the semiannual fitness for duty reports note the number of tests for cause and number of confirmed positives during random testing. If there were a number of positive test results in the random testing and no individuals were identified by supervisnrs - to be tested for cause, the inspector should concentrate on this area when interviewing supervisors / managers to determine

. their understanding of the behavior observation program and are they having daily contact'or more frequent contact with individuals they are supervising.

a. Review any open licensee event reports associated with the Access Authorization and Fitness For Duty Behavior Observation Program for follow up on site if necessary.

b. Review current regulatory requirements on behavior observation and identify licensee procedures that were changed since the last inspection to review during the inspection.

c. Determine the number of supervisors, managers and escorts to interview.

The number selected should not be less than a total. of five supervisors / manager's including contractors and five designated escorts.

A minimum of three different disciplines (i.e. . Operations. Maintenance.

Radiation Protection) should be selected. The sample should be targeted toward those supervisors who have not identified any member of their staff to be tested for cause. The inspector should vary the selection of supervisors by group each year.

Issue Date: August 13. 1999 DRAFT - 1.- 71130.01 DRAFT

02.02 Conductina the Insoection

a. Through interviews determine if the knowledge level of supervisors and managers, including contractor supervisors. and escorts concerning:

1. Their FFD/AA responsibilities and authorities specified in the program procedures.

2. Techniques for recognizing drug use, possession, and sale.

3. Indication of alcohol and aberrant behavior by employees.

4. When "for cause" testing is indicated.

5. Procedures to follow for reporting concerns to management or security personnel.

6. Supervisors are complying with program requirements if individuals are called out after duty hours,

b. Determine by interviews of supervisors. Fitness for Duty supervisors, and a review of records why " testing for cause" may not have been implemented by supervisors or plant management when aberrant behavior was observed or an on-site accident involving human error occurs.

c. Interview at least five individuals who perform escort duties and determine if they are knowledgeable and understand of their responsibilities concerning the bohavior observation program. All individuals should as a minimum be ale to recognize aberrant behavior and know who to report concerns to.

d. Verify through review of procedures and records that the licensee has implemented a method for new supervisors and escorts to receive behavior observation training in accordance with 10 CFR 26.22.

02.03 Identification and Resolution of Problems The inspector (s) should select a sample set of information comprising, for example, 2 licensee self-assessments, 3 security event reports,1 or more audits, and 3 quarters loggable events involving the Access Authorization / Fitness For Duty Program, especially those records that could involve the behavior observation program. The sample set should cover the period back initially no more than two years. The inspector (s) should use this information to verify that:

a. The licensee's assessments of problems and issues were of sufficient j scope to correctly identify nonconformance with the implementation of the behavior observation program within the Access Authorization System ,

inspectable area. l l

b. The risk significance of the findings were properly addressed. j

c. Identified nonconformances in the program were evaluated against the ability of an insider to successfully commit radiological sabotage resulting in a danger to the public's health and safety.

71130 DRAFT Issue Date: August 13, 1999 DRAFT

d. Root cause analyses ( if required depending on risk significance) and corrective action were timely and adequate to prevent recurrence.

e. Industry and NRC generic issues were considered. -

f. Required reports were made to the commission or inputs to the correct PI were made.

g. The performance trend indicated by the sample set was consistent with the applicable Pls.

h. The licensee implemented immediate short term corrective actions.

71130.01-03 RESOURCE ESTIMATE Ten hours are allocated for inspection effort of the Behavior Observation portion of the program and two hours are allocated for Identification and Resolution of Problems / Issues.

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Issue Date: August 13. 1999 DRAFT 71130.01 DRAFT

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ATTACHMENT 71130.02 INSPECTABLE AREA: Access Control (Search of Personnel. Packages, and Vehicles: Identification and Authorization)

CORNERSTONES: Physical Protection INSPECTION BASES: Failure of program compromises security barriers in place to protect high risk plant equipment and activities. Risk consequence to radiological sabotage is moderate.

LEVEL OF EFFORT: Inspection of Access Control functions is conducted annually 71130.02-01 INSPECTION OBJECTIVE Verify that the licensee has effective access controls and equipment in place designed to . detect and prevent the introduction of contraband (firearms. i explosives, incendiary devices).into the protected area that could be used to commit radiological sabotage. Verification of the identification and authorization process is used to confirm that only those who have been properly {

screened are granted unescorted access to the protected and vital areas.

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71130.02-02 INSPECTI0N REQUIREMENTS 02.01 Insoection Plannino

a. Review any open licens,ee event reports associated with access control requirements for followup on site if necessary.

b. Review Quarterly event logs su'bmitted since last inspection to determine equipment' and/or testing problems associated with specific items of equipment.

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c. Establish times to observe access control of personnel, packages and vehicles.

d. Establish times to observe licensee testing of equipment.

02.02 Conductino the Insoection

a. Review licensee *s procedures that have had changes made since the last ]

inspection on equipment testing and maintenance to determine if testing )

.is performance based. challenges the detection capabilities of the '

equipment and is inaccordance with the physical security plan. Confirm that the procedure describes testing that is performance based and challenges the equipment as it is presently installed and configured at the facility.

Issue Date: August 13. 1999 DRAFT 71130.02 DRAFT

b. Observe a licensee individual conduct testing of all the access control equi) ment in use or on in-service standby at all of the access locations at t1e site according to the 1icensee's procedures.

c. On at least two occasions observe in-processing searches of personnel.

Jackages and vehicles at all access locations during aeak ingress times.

Jetermine whether security personnel can effectively do all assigned tasks without compromising one task while doing another by observing security personnel doing their duties during peak ingress times in the morning and shift change in the afternoon.

d. Verify that the licensee has not added more security staffing for the inspection at the access control points than normal. This 'can be accomplished by interviewing security staff and reviewing security posting records.

e. Verify that biometric hand readers and the card readers at the protected area access points do not allow a user multiple entries into the protected area without logging back off site.

f. Verify that the licensee has a procedure that adequ'telya describes the method to immediately notify security to block badges for personnel who have had their access temporarily suspended. Verify by records checks and interviews that individuals responsible for notifying security are knowledgeable of how to effectively implement this program requirement.

g. Determine if the licensee has a process for granting access to pla.nt ecuipment, including vital equipment to authorized personnel who have an icentified need for that access. Select a random sample of employees and contractors authorized for access to several vital areas and com)are their areas actually accessed over the past 6 months against t1eir authorized areas. Difference should be evaluated to determine if the program is effective in limiting vital area access.

h. Verify that the licensee has a program in olace for controlling and accounting for hard-keys to vital areas and t1e replacement of locks if akeyisJostorcompromised.

1. Verify that the security computers can not have personnel data input or changed from any location outside the protected area.

02.03 Identification and Resolution of Problems The inspector (s) should select a sample set of information comprising, for i example, two licensee assessments, three security event reports, one or more audits. three quarters of security drills and exercises conducted with access control equipment operators, and 3 quarters of maintenance work recuests and loggable events. The sample set should cover the period back initially no more i than two years. The inspector (s) should use this information to verify that:

a. The licensee's assessments of problems and issues were of sufficient sco)e to correctly identify nonconformance with . search of personnel, i paccages and vehicles, and identification and authorization of personnel  !

for unescorted access into the protected area within the Access Control System inspectable area. .

b. The risk significance of the findings was properly addressed.

71130.02 DRAFT Issue Date: August 13, 1999 DRAFT

c. Identified nonconformances in the program were evaluated against the ability of an insider to successfully commit radiological sabotage resulting in a danger to the public's health and safety.

d. Root cause analyses. ( if required depending on risk significance) and corrective actions were timely and adequate to prevent recurrence.

e. Industry and NRC generic issues were considered.

f. Required re were made ports were made to the commission or inputs to the correct PI

g. The performance trend indicated by the sample set was consistent with the performance levels reported by the licensee for the applicable PI. -

02.04 During the inspection. note whether issues that occur are evaluated for identification to a corrective action system and that significant issues are input to the system.

02.05 During discussions with licensee personnel, ascertain whether issues have occurred which were not evaluated for identification to the corrective actions system and determine whether the issues meet the criteria for input to the system.

! 02.06 Verify that corrective actions have been properly implemented for five

! risk significant issues identified since the last inspection.

71130.02-03 RESOURCE ESTIMATE ,

The estimated resources to perform attachment 021s 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of direct inspection each year.

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i Issue Date: August 13. 1999 DRAFT .3- 71130.02 DRAFT

Attachment 71130.03 INSPECTABLE AREA: Response to Contingency Events (Protective. Strategy and Implementation of Protective Strategy)

CORNERSTONE: Physical Protection INSPECTION BASES: This is a risk significant system necessary to protect against the external Design Basis Threat (DBT). The licensee should be able to demonstrate the ability to respond with. sufficient force, properly armed, appropriately trained and within the aparopriate time to 3rotected positions to interdict and cefeat the design

) asis adversary force in order to protect vital equipment necessary for the safe shutdown of the ~ plant. The consequence to radiological sabotage if an attack is successful is high.

LEVEL OF EFFORT: 'This inspection effort will be accomplished every two years. As determined by performance, events and regional staff, this baseline inspection effort may be completed anytime during the inspection period. This inspection

. effort will be managed by regional staff and generally led by regional inspectors. The composition of multi-person inspections may include regional security inspectors (including from other regions), headquarters specialists

'and contractors capable of evaluating response, alarm and assessment equipment, small unit tactical response and defensive strategies. depending on the scope of the inspection. However, every six years each plant shall be inspected using a team composed of regiona.1 security inspectors headquarters specialists and contractors. This inspection will also satisfy the annual requirement 'for the Performance Indicator for the Physical Protection.

System.

@_TE: Until further notice, this inspection effort shall not include force-on-force exercises.

71130.03-01 INSPECTION 0BJECTIVE Verify through licensee drills and NRC evaluated exercises that the licensee's protective strategy works and it can protect its vital area target sets against the design basis threat.

Issue Date: August 13, 1999 DRAFT 71130.03 DRAFT

71130.03-02 INSPECTION REQUIREMENTS 02.01 Insoection Plannina

a. Coordinate NRC Inspection team composition, usage and responsibility as necessary. . Equipment requirements, such as video cameras or radios should be identified and arranged for with NRR Safeguards Staff.

b. Coordinate the conduct of the inspection with the licensee's staff at least two weeks before the inspection.

c. Review, at the site, the current Protective Strategy, including the licensee's target set analysis and response program procedures if changes have been made since the last inspection.

d. Review all licensee event reports relating. to responses or response capabilities for follow-up at the site.

e. Review performance indicators relating to response and alarm equipment

)erformance to determine if problems with a section(s) of the system are Secoming predictable and exploitable by an adversary,

f. Determine day and time to conduct a tour of the protected area intrusion detection system to identify areas of potential exploitable vulnerabilities in the system. If some are identified, the inspector should request the licensee conduct a test of the areas identified.

Establish and coordinate a plan to conduct a tour of the vital area e.

defensive positions, the conduct of at least two table top exercises with security shift supervisors, and the conduct of at least two force-on-force exercises,

f. Coordinate a plan to have at least three individuals, selected by the' inspectors, demonstrate tactical firing at the range with handguns and contingency weapons.

g. Determine the day and time to evaluate the training of the CAS and SAS operators.

h. Review response training requirements and weapons' firearms

• proficiency training requirements for regulatory and tactical content.

As determined by performance, events and regional staff. this baseline inspection effort may be completed anytime during the inspection period.

02.02 Conductina the Insoection NOTE: When conducting the inspection the inspectors should take the approach that an adversary must first penetrate the protected area intrusion detection system by a covert or overt action. If the inspectors determine that it is possible to enter the protected area through a covert action then the inspectors should consider the defensive positions that the adversaries would have to Jass to reach'a target. If the adversaries can reach a specific target set wit 1out alerting the security force, the licensee has a significant vulnerability that requires immediate compensatory actions. If the adversaries would encounter some level of force en route to a specific target then how much force and additional capabilities will need to be evaluated. If the inspectors determine that the 71130.03 DRAFT Issue Date: August 13, 1999 DRAFT

a e protected area intrusion detection system cannot be covertly penetrated then the inspectors should conduct a force on force exercise based on an alarm being generated and the security force responding appropriately to their designed protective strategies,

a. Intrusion Detection System Performance tests of intrusion detection aids should be conducted by one inspector stationed in the. primary or secondary alarm station to verify that alarms annunciate audibly and visually. and that there is an )

indication of the type and location of the alarm and a second inspector to observe licensee personnel or NRC contractor personnel performing the intrusion tests.

The second inspector should accompany a licensee supervisor and individuals who normally conduct testing of the perimeter intrusion detection aids on a ' tour of the perimeter to establish potential vulnerabilities that could be penetrated by individual (s) undetected and used as potential routes of travel to target sets. Only those areas specifically identified will be performance tested by the licensee at the request of the inspector. The inspector should select no less than three locations for crawl testing, three for simulated jump testing, and three for walk testing. The licensee should be able to demonstrate that if an area seems susceptible to jumping that the zone in question cannot be jumped. The licensee can accomplish this by demonstrating a simulated jump using a device such as an aluminum ball 12 inches in diameter, being passed over the zone at a height of six to seven feet.

The inspector in the alarm station should be able to recognize and identify the individuals in the detection zones on the assessment monitors. If the assessment aids or. monitors are not clear, verify the licensee has compensatory measure in place for degraded equipment.

The inspectors should verify that the fields of view provided by the assessment aids are according to the licensee *s physical security plan and procedures.

b. Defensive Strateav Review the licensee's documented response )lan, defensive strategy and relevant implementing procedures. Time 'ines should be examined to evaluate their bases and use in the overall response strategy. The number of responders, their locations. armament, capabilities and tactics should be examined individually to verify effectiveness to counter the DBT.

Established target sets should be reviewed to determine whether any changes have been made since the last evaluation (OSRE or inspection).

Changes to target sets should be forwarded to NRR's Safeguards . Staff for timely evaluation to determine whether the licensee *s protective strategy is affected. The licensee's analysis for the targets and protective strategy should also be discussed with a regional Senior Reactor Analysis. Determine plant operations staff participation in defining and validating the protective strategy.

Issue'Date: August 13. 1999 DRAFT 71130.03 DRAFT l

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c. Resoonse Performance Review the records of response drills performance to verify licensee's continuing capabilities and to identify issues that may represent uncorrected performance weaknesses or program vulnerabilities. This review shouk concentrate on tabletop records, audits, past drills, past exercises and actual responses. Issues identified during this review will be evaluated during on-site performance observation as necessary.

Require the licensee to demonstrate its capabilities to respond and to effectively implement the defensive strategy and response procedures. The number, type, complexity and focus of the demonstrations will be determined based on site-specific considerations such as topographical layouts, nature of target sets and previously identified performance. The NRC inspectors will choose target sets to be defended. provide a profile of the adversary (within context of the DBT). provide a description of adversary equipment to be simulated and specify points of adversary entry to the protected area. The licensee's response should include only those capabilities outlined in the licensee's security plan, protective strategy and implementing procedures.

Inspectors may request performance demonstration through drills (physical performance demonstrations of individuals or discrete portions of the response plan) tabletop discussion of actions, based on NRC-provided and exercises (integrated scenarios, done in an office environment physical demonstration of critical response functions). Nominally, at least two integrated response exercises will be observed and evaluated during one inspection each two years. Only licensee staff and resources will be used in the demonstrations, inspectors will not participate in nor direct response activities. Inspectors will not use or operate licensees' equipment.

Inspectors will evaluate the licensee's drill or exercise safety precautions to ensure that due care is taken to prevent unsafe acts and foster reasonable control. If drill or exercise critiques are conducted

. by the licensee, inspectors may observe to evaluate the licensee's self-a'ssessment activities.

At a minimum, the inspectors should observe (visually or audibly) the following program bases: responder's (selected) assignments; response routes. response timeliness, communications, command and control, tactical movement, effective use of cover and concealment, armament.

alarm assessment, barrier integrity, delay devices and operations interfaces. Nominally, inspectors should observe at least one responder, an alarm station and the adversary during each exercise.

d. Resoonse Trainina Inspectors will evaluate the effectiveness of training in response procedures through observation of activities and discussions with the licensee's staff who have response duties. Inspectors may evaluate firearms proficiency by either observing training or requesting that at least three selected individuals demonstrate their capabilities by means of the licensee's course of fire. The course of fire and weapons training should be evaluated to determine whether actual response conditions are simulated. The adequacy of weapons handling and manipulation should be observed. Responders should be able to effectively

'71130.03 DRAFT Issue Date: August 13. 1999 DRAFT

perform needed weapons' functions, demonstrate fire discipline and shoot accurately.

Determine, through a review of a selected but limited number of training records. that the weapons training observed has been consistently provided to all armed responders.

e. Exercise Conduct Inspectors will evaluate the licensee's conduct of drills, tabletop discussions, and exercises.

Inspectors will verify that exercises, conducted or planned. do not affect safety. The licensee must demonstrate due care for personal and equipment safety. The scheduling and conduct of exercises or drills should always be coordinated with operating staff to ensure that the performance demonstration will not adversely affect nor be adversely affected by plant safety activities.

The roles and performance of planners, controllers and adversaries should be evaluated to determine whether goals are met and that the performance activity reasonably challenges participants and reflects actual capabilities.

Inspectors will determine whether exercise findings, weaknesses.

violations or identified vulnerabilities are entered into a tracking system that takes due care to protect Safeguards Information and ensure timely and effective corrective action.

f. Performance Evaluation Inspectors will compare observed or recorded licensee performance to required plans. 3rocedures and applicable regulatory requirements. When performance fails to meet those requirements, a violation should be considered and dispositioned according to enforcement guidance. When no clear evaluation is possible, perhaps due to conflicting or disparate information, an unresolved item may be appropriate. NRR Safeguards Staff may need to be involved for evaluation and resolution. Weaknesses or vulnerabilities that are observed or identified should be brought to the licensee's attention and documented as necessary. The 3rogrammatic significance of specific findings may be evaluated using NUREG 1016.

Generally, the licensee's criteria for determining specific exercise related success or failure should be used. For example, the criteria used by licensee controllers or referees to determine the effectiveness of simulated weapons' fire and the effectiveness of cover and concealment should be established before the conduct of the exercise. Findings identified should be put in context of " Exercise Conduct" rather than

" Response Performance.,,

A licensee's response to a scenario should be considered adequate when they interdict the adversaries: (1) in a timely manner: (2) with sufficient numbers of responders who are appropriately armed and in protected positions.

Issue Date: August 13. 1999 DRAFT 71130.03 DRAFT

Inspectors should focus evaluations of licensee performance on public safety. The required ability to demonstrate high assurance of protection against the DBT is the focus of this performance evaluation.

Should a licensee demonstrate that they are not able to provide the minimum response required. it should be requested to take compensatory measures which will insure that the minimum response needed to provide protection against the DBT is effectively implemented. Inspectors will verify the implementation of that compensatory action before they leave the site.

02.03 Identification and Resolution of Problems I The inspector (s) should verify that:

a. The licensee *s assessments of problems and issues were of sufficient scope to address the key attributes of the Response to Contingency Events inspectable area. 1

b. The risk significance of the findings was properly addressed.

c. Root cause analyses ( if required depending on risk significance) and corrective actions were timely and adequate to prevent recurrence.

d. Industry and NRC generic issues were considered,

e. Required reports were made to the commission or inputs to the correct PIs were made.

f. The performance trend indicated by the sample set was consistent with the performance levels reported by the licensee for the applicable PIs.

71130.03-03 RESOURCE ESTIMATE The resource estimate for this section is approximately 104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br /> of direct inspection effort onsite every two years.

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I 71130.03 DRAFT Issue Date: August 13. 1999 DRAFT i

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