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
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ML18324A839, ML19029A107	List:
References
CN 19-004
Download: ML18324A842 (5)

Text

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 1 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 2 2200, Appendix A

2201-07 GUIDANCE Inspection Direct Procedure Security Construction and Operational Program1 Inspection Number Effort (DIE)2 Inspection of ITAAC-Related Security Structures, Systems, and 65001.17 160 Components 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 Security Organization, Management Effectiveness, Program 81000.10 26 Reviews and Audits 81000.11 Material Control and Accounting (MC&A) 6 81000.14 Review of New Reactor Target Sets 48 Fixed Site Physical Protection of Special Nuclear Material of Low 81431 11 Strategic Significance 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 3 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 4 2200, Appendix A

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

Number Change Notice and Completion Date (Pre-Decisional, Non-Public Information)

Researched commitments back four years Training to be covered ML120860224 and found none. Appendix developed to at the July 2013 Annual N/A 09/07/2012 N/A support security construction inspections Security Counterpart CN 12-020 under IMC 2200. Meeting.

Administrative edits made to include:

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

ML18324A842 Upon completion of a SUNSI review, the N/A 01/29/19 N/A ML18324A841 staff concluded that this IMC should be CN 19-004 decontrolled. Consistent with the staffs SUNSI determination, this IMC is now publicly available.

Issue Date: 01/29/19 Att1-1 2200, Appendix A