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' CERTIFIED BY: MME E DATE ISSUED: 2/17/94* $arold W. Lewis - 2/25/94 I #~

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SUMMARY / MINUTES OF THE ACRS SUBCOMMITTEE MEETINGON SAFEGUARDS AND SECURITY

NOVEMBER 3, 199 MBETHESDA, MARYLAND

I. INTRODUCTION~

The Safeguards and Security Subcommittee of the AdvisoryCommittee on Reactor Safeguards met on November 3, 1993 in RoomP-110 at 7920 Norfolk Avenue, Bethesda, Maryland. The purpose ofthis meeting was to discuss protection against the malevolent useof vehicles at nuclear power plants; reconsideration of nuclearplant security requirements in terms of internal securityMneats; and safegttards issues associated with the advanced

! oviling water reactor (ABWR) design.I

The entire meeting was open to the public with the exception of aportion that was closed to discuss safeguards and securityinformation associated with the ABWR design. Mr. Herman Aldermanwas the cognizant ACRS staff engineer for the meeting. Themeeting was convened at 8:30 a.m., and adjourned at 3:30 p.m.

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II. ATTENDEES

The following individuals participated in the meeting.

|ACRS HER |

H. Lewis, Chairman P. McKee, NRC/NRR lJ. Carroll, Member R. Skelton, NRC/NRR '

P. Davis, Member E. Ten Eyck, NRC/NMSSW. Lindblad, Member F. Young, NRC/NRRC. Michelson, MemberJ. Wilkins, Jr., Member NUMARCC. Wylie, Member

R. EnkebollB. Whitesel

III. CHAIRMAN'S OPENING REMARKS

Dr. Harold W. Lewis, Subcommittee Chairman, convened the meetingat 8:30 a.m. and reviewed briefly the schedule for the meeting.He said that no written comments on requests for time to makeoral statements were received from members of the public.

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Jecurity and Safeguards Sub. 2Nov' ember 3, 1993 I

|IV. PROTECTION AGAINST MALEVOLENT USE OF VEHICLES AT NUCLEAR

POWER PLANTS Mr. P. McKee, NRC/NRR

Mr. McKee discussed briefly the bases for the development of theproposed rule on Protection Against Malevolent Use of Vehicles at

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Nuclear Power Plants.

The bombing of the Beirut Marine Barracks in 1983 promptedCongressional Hearings, studies by the NRC staff, and issuance ofNRC Generic Letter 89-07 on April 28, 1989. The generic letter

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|required licensees to develop contingency plans that could be i

implemented in less than 12 hours and that could provide vehicleaccess controls.

Following the intrusion event at Three Mile Island Unit 1 on,

February 7, 1993, and the World Trade Center bombing on February i

27, 1993, the Commission directed the NRC staff to review thei

design-basis threat for nuclear power plants and to consider what i

measures could minimize land vehicle threats. The staffq';alitatively determined that the margin of prudence between thehypothetical design-basis accident and the " actual threat" haddecreased based on the two events.

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Following a Senate hearing on March 19, 1993, the NRC staffgathered additional information on threats of radiologicalsabotage, and issued a commission paper (SECY-93-102, April 16,1993) with four proposed options. Option one would maintain thepresent contingency plans. Option two would require placing

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barriers on the major roadways and access points to the facility. 1

Option three would require a hardened barrier around theperimeter of the protected area boundary. Option four wouldrequire a sufficient standoff distances to protect against a bombexploding at the hardened barrier.

Following a public meeting on May 10, 1993, the NRC staff )developed a fifth option (SECY-93-16, June 14, 1993) that would '

establish Commission design goals and criteria. The licenseewould confirm conformance with the goals and criteria, or proposealternative measures.

The NRC staff proposed an amendment to 10 CFR Part 73 (SECY-93-270, September 29, 1993) to protect against malevolent use of |vehicles at nuclear power plants. The design-basis threat would |be changed in 10 CFR 73.1 to include a four-wheel-drive land )vehicle used to transport personnel, hand carried equipment |

and/or explosives. The vehicle control measures in 10 CFR 73.55 I

would be changed to define acceptable vehicle barrier systems.

Mr. Lindblad and Mr. Carroll noted that the NRC staff should haveinvolved the ACRS sooner in the rulemaking process. Mr. Lindblad

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questioned whether the staff had quantified the change in the

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Security and Safeguards Sub. 3November 3, 1993

margin of prudence and whether the change was substantial enoughto warrant rulemaking. Ms. Ten Eyck, Office of Nuclear MaterialSafety and Safeguards (NMSS), responded that the margin of safetyreferred to as margin of prudence in safeguards protection andthat judgment was used in evaluating the " actual threat."

Mr. Lindblad and Mr. Davis questioned what changes had occurredfor the FBI to reassess their ability to predict bomb threats.Ms. Ten Eyck stated that the Wold Trade Center bombing developedwithout any early warning. She noted that similar events coulddevelop very quickly and without forewarning.

Dr. Lewis asked what type of intelligence information wasavailable to the staff. Ms. Ten Eyck replied that the staff hasaccess to raw intelligence data and analysis reports throughcomputer links with the FBI and the intelligence community.Mr. Davis noted that, in the past, probabilistic risk assessmentswere unable to quantify the threat of sabotage due to changingconditions and lack of data. Dr. Lewis opined that quantifyingrisk was not nasy; however, the NRC could do a reasonable job ofestimating the threat.

Mr. Lindblad and Mr. Carroll questioned whether the TMI intrusionwas malevolent and whether public health and safety could have |been threatened if the vehicle carried a bomb. Mr. McKee replied i

that the entry was not malevolent and that the specific scenario|of a bomb-laden vehicle at TMI had not been studied.

Mr. Lindblad raised the issue of the use of deadly force to stopsuspected malevolent vehicles. Ms. Ten Eyck's response

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highlighted ambiguities between state and federal jurisdiction on |the requirements associated with guards carrying loaded weapons.

Mr. Davis and Mr. Carroll questioned the effects that improvedsecurity measures might have on complicating access to vitalareas during plant events. Mr. McKee responded that access tovital areas was considered during review of the internal threat

|and that licensees had not identified any impediments to event '

response.

Subcommittee Action

After further discussion, the subcommittee decided to refer thismatter to the full Committee for discussion and action during theNovember 1993, ACRS meeting.

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Security and Safeguards Sub. 4November 3, 1993

V. INTERNAL SECURITY THREAT - Mr. P. McKee, NRR

Mr. McKee discussed briefly the bases for the internal securitythreat concern. An internal sabotage event at Surry and industryproblems with security doors between 1977 and 1986, prompted thestaff to develop additional security requirements. Regulatorychanges required licensees to establish criminal history checksin 1987, fitness-for-duty programs in 1990, and unescorted accessprograms in 1992.

In September 1991, the commission directed the NRC staff toformally review the rules for protection against insider threats.The results of the staff review (SECY 92-272, August 1992)identified several security measures that provided only amarginal increase in security. The staff made recommendationsfor:

relaxing access control measureo

revising requirements for searching on-duty guards re-e

entering the protected area and for escorting licensee-ownedvehicles

informing licensees of the acceptability of reducing thee

number of vital areas and of minimizing the type ofinformation that needs to be treated a< r,afeguards material

The staff wanted to further evaluate the adequacy o. accessauthorization programs.

NUMARC proposed that many of the staff recommendations could beimplemented without rulemaking based on alternate protectivestrategies as allowed by the existing regu' # ions. NUMARC arguedthat plant fitness-for-duty, access authorization, and qualityassurance programs provided equivalent measures to some explicitrequirements. NUMARC also proposed alternatives to vital areacontrols during operation and control of protected area accessbadges.

The NRC staff reviewed NUMARC's proposal and concluded that theuse of one regulatory requirement as an equivalent measure tomeet another regulatory requirement was not appropriate. Thestaff determined that NUMARC's proposal for relaxing vital areaaccess control did not include consideration of external threats.

The staff developed three options for relaxing vital area controlrequirements without new rulemaking. The first option wouldallow relaxation of requirements if licensees review the securitychanges in regards to the external threat and install accessmonitors that would identify organic explosives. The secondopti.?n would allow compensatory time to repair failed security

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Security and Safeguards Sub. 5November 3, 1993

doors and would reduce requirements for responding to vital areadoor alarms. The third option would allow security doors, not Isubject to an external threat, to be left unlocked. The staffhad not decided which option to recommend.

The staff recommended proceeding with rulemaking for relaxingaccess controls for containment entry, escorting licenseevehicles, and search requirements for on-duty guards re-entering i

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the protected area. ll

In response to questions by Mr. Lindblad, Mr. McKee made the iIfollowing statements. Licensecs would have to develop a scheme

to ensure that all on-duty guards were monitored on their firstentry into the protected area. The new security regulations werenot intended to change radiological monitoring requirements and a I

review is necessary to ensure that the security relaxations do,

not preempt radiological regulations. |1

Mr. Lindblad asked whether security regulations differentiatedbetween plant operating modes. Mr. McKee answered that theregulations did not explicitly discuss modes, but did imply moderestrictions such as when the containment was opened. Mr.Carroll noted that the initial reason for not writing modedependent regulations was the possibility of planting a time bombin an unsecured vital area. Mr. Young, NRR, explained that theregulations allow vital areas to be devitalized during shutdownconditions, but require subsequent walkdowns before re-establishing the vital area.

Mr. Lindblad questioned why off-site law enforcement officerswere allowed to bypass site access control fire arms searchprocedures. Mr. McKee explained that the officers would becontinually escorted and that licensees had no jurisdiction torequire removal of the fire arms. Mr. Lindblad noted thatfederal laws could be used to over ride state laws.

In response to a question by Mr. Davis, Mr. McKee stated that thestaff did not calculate the cost savings expected from relaxationof the security requirements.

Mr. Enkeboll expressed NUMARC's opinion that all the newrulemaking issues should be addressed in single amendment. Mr. i

McKee explained that the NRC staff was evaluating the effects thedifferent rules have on each othor, and that the rules have acertain level of independence.

In response to a question from Dr. Lewis, Mr. Enkeboll statedthat NUMARC did not suggest a complete fresh look at the newrules, but did caution that two or three rules would need to beintegrated into the licensees' security organizations instead ofone. In response to a question form Mr. Carroll, Mr. Enkeboll,

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Security and Safeguards Sub. 6November 3, 1993

stated that relaxing vital area control measures within thepresent regulations should not be delayed in the interest of-having a more coordinated approach to the rule changes.

VI. SAFEGUARDS REVIEW OF ADVANCED BOILING WATER REACTOR DESIGNP. McKee, NRC (Closed),

This meeting was closed to public attendance due to thediscussion of safeguards material. No transcript was kept.Meeting minutes for this meeting are provided in a supplement andare available on request.

VII. SUBCOMMITTEE ACTION / FUTURE PLANS

The subcommittee deferred discussion of the proposed amendment onthe malevolent use of vehicles at nuclear power plants to thefull ACRS meeting on November 4, 1993. The subcommitteepostponed further discussion of the internal security threatuntil the NRC staff issues a proposed amendment. Thesubcommittee planned no further action on the ABWR safeguardsissues.

No additional assignments or follow-up matters resulted from thismeeting.

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NOTE: Additional meeting details can be obtained from atranscript of this meeting available in the NRC Public

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Document Room, 2120 L Street, N.W., Washington, D.C.20006, (202) 634-3273, or can be purchased from AnnRiley & Associates, 1612 K Street, N.W., Suite 300,Washington, D.C. 2006, (202) 293-3950.

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DOCUMENTS PROVIDED TO THE SUBC000(ITTEE

1. SECY 33-270, " Proposed Amendment to 10 CFR Part 73 toProtect Against Malevolent Use of Vehicles at Nuclear PowerPlants," September 29, 1993

2. Draft Regulatory Guide DG-5006, " Protection AgainstMalevolent Use of Vehicles at Nuclear Power Plants,"November 1993

3. SECY 93-166' " Staff Recommendations for Protection AgainstMalevolent Use of vehicles at Nuclear Power Plants," June14, 1993

4. SECY 92-272, "Re-examination of Nuclear Power Plant SecurityRequirements Associated with the Internal Threat," August4, 1992

5. Letter from Mr. F. Congel to J. Larkins, " ProposedReconsideration of the Nuclear Power Plant SecurityRequirements Associated with the Internal Threat," July 2,1993 (enclosed July 1, 1993 draft of proposed rulemaking)

6. Chapters 13 and 19 of General Electric Nuclear EnergyStandard Safety Analysis Report for the Advance BoilingWater Reactor

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SAFEGUARDS AND SECURITY SUBCOMMITTEEROOM P-110, 7920 NORFOLK AVENUE

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BETHESDA, MARYLANDNOVEMBER 3, 1993

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- TENTATIVE AGENDA -

APPROXIMATE TIME

Introductory Remarks, H. Lewis, Chairman, 8:30-8:40 a.m.,

Safeguards and Security Subcommittee (10 Min]

OPEN SESSION

NRC Staf f oresentation on the cronomed amendments to 10 CFR Part 73to orotect aaainst malevolent use of vehicles at nuclear coverclants

Background for rulemaking (20 Min) 8:40-9:00 a.m.Protection against vehicle intrusion (30 Min] 9:00-9:30 a.m.

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Protection against a vehicle bomb (30 Min] 9:30-[dY[9a.m.Proposed rule and implementation schedule 10: .5 -//;'20lorv

(30 Min) . ..t30 a.m.

* * * * * BREAK * ****~ [15 Min) 10: 30-10: 45 a.m.

NRC Staff oresentation on the reconsideration of nuclear olantag,curity recuirements associated with the internal security threattI: 2 0 - II' A?Background on evolution of insider threat 10: 45-11: 00 a.m.requirements (15 Min]n:30-niczStaff recommendations for reductions 11: 00-1+FF9 a . m.in requirements (30 Min)1:00 -- I'?O f nStaff assessment of a NUMARC proposed 1-1:30-12:00p. .0alternative protection strategy for pro-

tection against the insider threat (30 Min)n:C L* * * * * LUNCN * * * * * (1 HOUR] 12:0?-1:00 p.m.

I: 20 - r10 f, mFindings of staff's reassessment of options E.GG-li20:; r.for changes to insider requirements (30 Min]I!+o / * SS

Subcommittee Discussion (15 Min] p.m.

** BREAK TO CLEAR ROON FOR CLO8ED SESSION ** 1:45-2:00 p.m.

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RECONVEMB IM CLOSED SEs3 ION2:00 p.m.

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NRC Staff oresentation on the safecuards review of advanced boilingwater reactor desian

'3abotage vulnerability Analysis [30 Min) 2:00-2:30 p.m.

iSafeguards perspective of vital equipment 2:30-2:50 p.m.(20 Min)

operations / safeguards interfaces (20 Min] 2:50-3:10 p.m. I

Subcommittee discussion (20 Min) 3:10-3:30 p.m.Adjournment

3:30 p.m.

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