Information Notice 2005-33, Safety/Security Interface - Managing Risk
| ML053470469 | |
| Person / Time | |
|---|---|
| Issue date: | 12/30/2005 |
| From: | Charemagne Grimes NRC/NRR/ADRA/DPR |
| To: | Office of Nuclear Reactor Regulation |
| Marc A. Brooks, NSIR, 301-415-8171 | |
| References | |
| IN-05-033 | |
| Download: ML053470469 (4) | |
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
December 30, 2005
NRC INFORMATION NOTICE 2005-33:
MANAGING THE SAFETY/SECURITY
INTERFACE
ADDRESSEES
All holders of operating licenses for nuclear power reactors, except those who have
permanently ceased operations and have certified that fuel has been permanently removed
from the reactor vessel.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to remind
licensees of the need to prevent unintended degradation of plant security by routine plant
operations, design changes, or maintenance, and conversely to prevent unintended
degradation of plant safety by analogous security activities. It is expected that recipients will
review this information for applicability to their facilities and consider actions, as appropriate.
However, suggestions contained in this information notice do not constitute NRC requirements
and, therefore, no specific action or written response is required.
BACKGROUND
In addition to the security enhancements instituted by order at nuclear reactor sites subsequent
to September 11, 2001, the NRC has considered whether specific measures are needed to
manage the potential for adverse interactions to occur between operational safety and site
security when changes are made to plant configurations, facility conditions, or security
postures. The current regulations require nuclear power plant licensees to establish and
maintain NRC-approved physical security plans which provide for high assurance that activities
involving special nuclear material are not inimical to the common defense and security and do
not pose an unreasonable risk to public health and safety (Section 73.55a of Title 10 of the
Code of Federal Regulations (10 CFR 73.55(a)), and to make no changes to these plans that
could decrease their effectiveness without prior NRC approval (10 CFR 50.54(p)(1)). Similarly,
10 CFR 50.59 allows licensees to make changes to their facility or procedures as described in
their final safety analysis reports without prior NRC approval provided that certain criteria are
met. Additionally, 10 CFR 50.65(a)(4) requires that licensees assess and manage the increase
in risk that may result from proposed maintenance activities.
These regulations do not explicitly address the need to prevent unintended degradation of plant
security and/or safety as a result of routine plant operations, design changes, or maintenance.
The NRC staff is currently considering new rulemaking to address this issue.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
DESCRIPTION OF CIRCUMSTANCES
The NRC staff has become aware of several cases in which actions taken by operations, maintenance, or security personnel were not promptly and effectively communicated to other
potentially affected organizations and had the potential to result in adverse effects on plant
safety or security.
Examples of security activities that had the potential to adversely impact safe plant operations
include: security force staffing changes on backshifts, weekends, and holidays that could
adversely impact operations during plant events or emergencies (e.g., opening and securing
vital area access doors to allow operations personnel timely access to safety-related
equipment) and the installation of security equipment that interferes with plant operations
(e.g., placement of a security fence that blocks the pressure relief blowout panel for the turbine
driven auxiliary feed water system, installation of security delay fencing with razor wire
preventing access to plant fire hydrants).
Examples of operational activities that had the potential to adversely impact security include:
physical barrier breaches during maintenance activities (e.g., removed ventilation fans or other
equipment from vital area boundary walls without taking compensatory measures to prevent
unauthorized access), blockage of fields of fire from bullet-resisting enclosures (or other
defensive firing positions), placement of scaffolding and other temporary equipment without due
consideration of the impact on security response pathways and the potential for unauthorized
access, and the staging of temporary equipment within security isolation zones.
DISCUSSION
The goal of maintaining effective oversight of the safety/security interface is to ensure that the
risk of adverse effects on safety and security are effectively managed before changes are
made to plant configurations, facility conditions, or security.
When licensees identify circumstances that may involve an adverse safety/security interface, they should consider whether compensatory and/or mitigative actions are needed to maintain
safety and security consistent with applicable NRC regulations, requirements, and license
conditions. Licensees evaluations of such changes must ensure the protection of public health
and safety, and the promotion of the common defense and security. OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
CONTACT
This information notice requires no specific action or written response. Please direct any
questions about this matter to the technical contact listed below or the appropriate Office of
Nuclear Reactor Regulation project manager.
/RA by HNieh for/
Christopher I. Grimes, Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Technical Contact:
William D. Reckley, NRR/ADRA/DPR/PSPB
301-415-1323 E-mail: WDR@nrc.gov
Marc A. Brooks, NSIR/DNS/RSS
301-415-8171 E-mail: mab9@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
- see previous concurrence
OFFICE
NSIR:DNS:RSS
TECH EDITOR
BC:NSIR:DNS:RSS
D:NSIR:DNS:NSP
D:NSIR:DNS
NAME
MABrooks*
PKleene*
SAMorris*
VOrdaz*
GTracy*
DATE
12 /15 /2005
12/15 /2005
12 /21 /2005
12 /21 /2005
12 /22 /2005 OFFICE
D:NSIR
IOEB:DIRS
TL:IOEB:DIRS
LA:PGCG:DPR
BC:PGCB:DPR
RZimmerman*
CRoquecruz*
ICJung*
CMHawes
CJackson
DATE
12 /29 /2005
12 /29 /2005
12 /29 /2005
12 /30/2005
12/30/2005 OFFICE D:DPR
NAME
CIGrimes
DATE
12/30/2005