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

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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)

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SNM Categories II & III

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Current NPUF Approach

• Regulatory Framework for Security at currently licensed NPUFs:

- Regulations

• 10 CFR 73 Orders

- Supplemental Security Measures

• Physical security SSMs

- Detect & Assess

- Delay

- Respond

- Orders Regulations

• Access Authorization

• 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

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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)

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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.

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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

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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

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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 Mod Dilute Cat I Highly Dilute Cat II Cat III Protective Strategy Protect against DBT Immediately detect Promptly detect Timely detect of theft and diversion attempts to remove of attempts to remove of attempts to remove of and radiological SNM and provide SNM and notify local SNM and notify LLEA sabotage sufficient delay law enforcement to recovery SNM through the use of agencies to allow Prevent the removal barriers and/or armed recovery of SNM.

of SNM and other responders to allow unauthorized activities LLEA to promptly involving SNM recover SNM Diversion Path Analysis Security Plan Physical Security Plan Physical Security Plan Physical Security Plan Physical Security Plan Safeguards Cont. Safeguards Cont.

Plan Plan Training & Qual. Plan Training & Qual. Plan

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

Manage Fatigue Physical Barrier OCA Vehicle Barrier Vehicle Barrier System/blast System analysis Isolation Zone Isolation Zone Protected Area Protected Area Vital Area Material Access Controlled Access Controlled Access Controlled Access Area Area Area Area Locked Processes Locked Processes Locked Processes Vault Vault-type room Vault-type room Hardened CAS Hardened CAS *15

Cat I Cat I Mod Dilute Cat II Mod Dilute Cat I Highly Dilute Cat II Cat III Access Controls Protected & Material Protected Area & Controlled Access Controlled Access Access Area Access Controlled Access Area Access Portals Area Access Portals Portals Area Access Portals Limit unescorted Limit unescorted Limit unescorted Limit unescorted access access access access Part 11 73.57 73.57 73.57 Photo Badges Photo Badges Photo Badges Photo Badges Escort Requirements Escort Requirements Escort Requirements Escort Requirements Search Programs OCA - vehicles None Protected Area - Protected Area -

entry (contraband) & entry (contraband) &

exit (SNM - exit (SNM &

shielding) shielding)

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

Vault (weapons) shielding)

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Cat I Cat I Mod Dilute Cat II Mod Dilute Cat I Highly Dilute Cat II Cat III Detection and Protected Area & Protected Area & Vault type room Assessment Material Access Vault type room Intrusion Detection Area Intrusion Intrusion Detection System with UPS Detection System System with UPS with UPS Video Capture Video Capture Central Alarm Central Alarm Central Alarm Station Station Station Secondary Alarm Secondary Alarm Secondary Alarm Station (on-site or Station (on-site or Station off-site) off-site)

Surveillance Surveillance Surveillance Surveillance Program - Program Program Program Protected Area &

unoccupied Material Access Area Periodic Patrols of Periodic Patrols of Periodic Patrols of Periodic Patrols of outside areas outside areas outside areas outside areas Two person rule in MAA Three person rule in Vault Illumination Illumination *17

Cat I Cat I Mod Dilute Cat II Mod Dilute Cat I Highly Dilute Cat II Cat III Communication CAS/SAS two-way CAS/SAS two-way CAS/SAS two-way Two-way redundant redundant redundant redundant communication with communication with communication with communication with LLEA LLEA LLEA LLEA Continuous Continuous Continuous Continuous communication communication communication communication between CAS/SAS between CAS/SAS between CAS and among security force and on-site and off- and on-site and off- on-site and off-site site response force site response force response force Non-portable Non-portable Non-portable Non-portable equipment on UPS equipment on UPS equipment on UPS equipment on UPS Response 10 Tactical Response Team -

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

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Cat I Cat I Mod Dilute Cat II Mod Dilute Cat I Highly Dilute Cat II Cat III Security Program Annually Bi-annually Bi-annually Bi-annually Review Management Management Management Management Review Review Review Review CAP or event log CAP or event log CAP or event log CAP or event log Maintenance & Required Required Required None Testing Compensatory In PSP In PSP In PSP In PSP Measures Suspension of Allowed Allowed Allowed Allowed Security Measures Records Required Required Required Required Alternative Allowed Allowed Allowed Allowed Measures

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