1776 I STREET, NW SUITE 400 WASHINGTON, DC 20006-3708 PHONE 202.739.8094 FAX 202.785.1898 aph@nei.org

NUCLEAR ENERGY INSTITUTE 

Adrian P. Heymer 

SENIOR DIRECTOR, NEW PLANT DEPLOYMENT 

NUCLEAR GENERATION DIVISION

August 18, 2006 

Mr. Roy P. Zimmerman 

Director 

Office of Nuclear Security and Incident Response 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

SUBJECT: Technical Reports on Template for FSAR Section 13.6, Physical 

Security; and the Generic Security Inspections, Tests, Analyses and 

Acceptance Criteria for New Plants 

PROJECT NUMBER: 689 

Dear Mr. Zimmerman: 

In support of combined license application preparations, the Nuclear Energy 

Institute (NEI) is submitting two technical reports for NRC review and 

endorsement: 

• A template for Section 13.6 of a Final Safety Analyses Report (FSAR) for a 

combined license application (Enclosure 1), and 

• Generic Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) for 

Physical Security (Enclosure 2). 

The FSAR section for Physical Security and the Generic Security ITAAC are 

important documents for the design, licensing and construction of new plants. The 

industry has discussed these two new plant topics with the NRC staff. The Section 

13.6 template and the Generic Security ITAAC have been developed based on insights 

from these meetings. 

These generic documents are being used by combined license applicants as guidance 

in preparing combined license applications and technical reports that will be 

submitted in 2007. As a result, we request NRC endorsement by the end of 

November 2006. We understand that, following the NRC review, the NRC will 

either issue a Safety Evaluation Report (SER) or a letter documenting the NRC’s 

conclusions. This will enable the template and ITAAC report to be incorporated by 

reference into a new plant combined license application. 
Mr. Roy P. Zimmerman 

August 18, 2006 

Page 2 

If you have any questions, please contact Jim Fisicaro at (202) 739-8018; jjf@nei.org

or me. 

Sincerely, 

Adrian P. Heymer 

Enclosures 

c: Mr. Glenn M. Tracy, NRC 

Mr. Scott Morris, NRC 

Mr. Douglas Huyck, NRC 

 Document Control Desk 
Enclosure 1 

FSAR 13.6 

13.6 PHYSICAL SECURITY 

The physical security program consists of the Security Plan, Training and 

Qualification Plan and Safeguards Contingency Plan and will be implemented prior 

to initial fuel arriving on-site. The program satisfies the regulatory requirements 

for fixed commercial nuclear power plants set forth in 10 CFR 50.34 (c) and (d), 10 

CFR 52.79, 10 CFR 26 and 10 CFR 73. Details of the program are included in the 

plans and are classified as Safeguards Information in accordance with 10 CFR 

73.21. The program includes descriptions of and provisions for the following: 

• Security organization 

• Physical barriers for vehicles and personnel 

• Bullet resisting barriers 

• Access control for vehicles and personnel 

• Fitness for Duty Program 

• Searches of personnel, vehicles and packages 

• Intrusion alarm systems and detecting unauthorized intrusions 

• Security power supply system 

• Provisions for monitoring the access to vital equipment 

• Selection of security personnel 

• Security communications systems 

• Testing and maintenance 

• Law enforcement assistance 

• Training of security personnel 

• Response to contingencies 

• Security assessment 

13.6.1 Security Organization 

The security organization provides a management infrastructure to protect the 

facility against radiological sabotage. The organization includes a management 

system to support the development and maintenance of security plans and 

procedures for the effective implementation of the physical security program. The 

organization is based on a command structure with implementing procedures and is 

staffed by appropriately trained and equipped security personnel for the protection 

against threats as described in the Design Basis Threat (DBT). 

13.6.2 Physical Barriers for Vehicles and Personnel 

Physical barriers are installed and designed to protect and control access to the 

facility. Vehicle barrier systems are installed to prevent the entry of vehicles 

carrying explosives as defined in the DBT beyond the safe standoff. A protected area 

barrier is installed to prevent access of unauthorized personnel into the protected 

area. Personnel access of authorized individuals to the protected area is permitted 

through designated personnel access portals through the barrier after positive 

identification is verified. Vital area access is controlled by allowing only authorized 

personnel and by requiring passage through at least two physical barriers. Access 
2 

points to vital areas are locked and alarmed with activated intrusion detection 

systems. 

13.6.3 Bullet Resisting Barriers 

The doors, walls, floor and ceiling of the main control room and the continuously 

manned central alarm station are designed to be bullet resisting in accordance with 

applicable design criteria. 

13.6.4 Access Control for Vehicles and Personnel 

An access authorization program provides high assurance that individuals who are 

permitted unescorted access to the protected area are trustworthy and reliable. All 

individuals allowed unescorted access to the protected area are issued a photo 

identification badge, which is displayed while inside the protected area. Access to 

the protected area is controlled through designated portals to ensure only 

authorized vehicles, personnel and packages are allowed entry. Vital area access is 

controlled to permit access to authorized personnel. Vehicle passage through the 

vehicle barrier system is controlled through designated access points to ensure only 

authorized vehicles are allowed entry. 

13.6.5 Fitness for Duty Program 

A fitness for duty program in accordance with 10 CFR 26 provides reasonable 

assurance that personnel permitted unescorted access to protected and vital areas 

are not mentally or physically impaired to perform their assigned duties. 

13.6.6 Searches of Personnel, Vehicles and Packages 

Prior to entry into the protected area personnel, vehicles, packages and materials 

are searched for firearms, explosives and incendiary devices. This may be 

accomplished by physical searches and/or the use of detection devices such as metal 

detectors, explosive detectors and x-ray machines. A secondary physical search is 

conducted if there is reason to believe an individual is attempting to introduce 

firearms, explosives or incendiary devices into the protected area or whenever 

search equipment is out of service. 

13.6.7 Intrusion Alarm Systems and Detecting Unauthorized Intrusions 

Isolation zones and exterior areas of the protected area are provided with sufficient 

illumination to permit the observation of these areas during hours of darkness. 

Surveillance is accomplished by security personnel or surveillance technology. 

Intrusion alarm equipment detects penetration or attempted penetration of the 

protected area and vital area barriers. Intrusion detection alarms annunciate in a 

continuously manned central alarm station and in another continuously manned 

station so that a single act can not remove the capability of calling for assistance or 

responding to an intrusion alarm. 
3 

13.6.8 Security Power Supply System 

Site security systems are powered from a reliable power supply meeting the 

requirements of IEEE-692, “Standard Criteria for Security Systems for Nuclear 

Power Generating Stations.” Security equipment that supports critical monitoring 

functions, such as intrusion detection, alarm assessment and the security 

communication system, receives power from the security power supply system. The 

security power supply system is capable of sustaining operation for a minimum of 

24 hours. 

13.6.9 Provisions for Monitoring the Access to Vital Equipment 

An access authorization system is established to limit access to vital areas to only 

those individuals who require access to perform their duties. The access list is 

validated at least once every thirty-one days to confirm a continued need for access 

to vital areas. 

13.6.10 Selection of Security Personnel 

Prior to employment or assignment to the security organization, personnel must 

meet minimum requirements with regard to age and education and have no felony 

convictions that involve the use of a weapon or that would reflect adversely on the 

individual’s reliability. Personnel assigned to the security organization are screened 

to ensure they have no physical weaknesses or abnormalities that would adversely 

affect their performance of security duties. 

13.6.11 Security Communications Systems 

Communications systems are established within the security organization to ensure 

the ability of security personnel to communicate with an individual in each 

continuously manned alarm station. The alarm stations have the ability to 

communicate with law enforcement agencies to summon assistance. Non-portable 

communications equipment can be powered from the security power supply system 

so that it remains operable in the event of the loss of normal power. 

13.6.12 Testing and Maintenance 

Security systems are maintained by trained personnel to ensure proper 

functionality and operability. Intrusion detection alarms and communications 

equipment are tested at an appropriate frequency to verify continued operability 

and performance effectiveness. 

13.6.13 Law Enforcement Assistance 

Liaison is established and maintained with local law enforcement agencies to 

provide assistance to the station when required during a security incident. 

13.6.14 Training of Security Personnel 

Prior to initial fuel arriving on-site and assignment to security duties, security 

personnel are trained and qualified in accordance with the Training and 

Qualification Plan. The Training and Qualification Plan identifies critical tasks 

applicable to each security position. Through qualification in the applicable critical 

tasks, security personnel demonstrate the required knowledge, skills and abilities 
4 

to perform their assigned position. There is also an annual requalification on 

selected critical skills. 

13.6.15 Response to Contingencies 

The Safeguards Contingency Plan provides guidance on responding to contingencies 

and threats as defined in the DBT. The plan provides a framework of predetermined 

responses to various safeguards contingencies with the objective of organizing 

resources to facilitate a coordinated response. A protective strategy that integrates 

responses of the security force, plant operations personnel and law enforcement 

agencies is established to prevent radiological sabotage. 

13.6.16 Security Assessment 

A Security Assessment Report covers target set analysis, the plant protective 

measures and strategy to address the elements of the DBT and evaluation of the 

safety/security interface. This report is categorized as Safeguards Information in 

accordance with 10 CFR 73.21. 
Enclosure 2 

Generic Security ITAAC 

Non-System Based Design Description & ITAAC 

Table 3 . 6 (cont. Inspections, Tests, Analyses and Acceptance Criteria

Design Commitment Inspections, Tests, 

Analyses

Acceptance Criteria

The walls, doors, ceiling and 

floors in the main control 

room and Central Alarm 

Station are bullet-resistant to 

a UL level 4 round.

Type test, analysis or a 

combination of type test and 

analysis will be performed for 

the walls, doors, ceilings and 

floors in the main control room 

and Central Alarm Station. 

A report exists and concludes that 

the walls, doors, ceilings and 

floors in the main control room 

and Central Alarm Station are 

bullet-resistant to a UL level 4 

round.

Central Alarm Station and 

main control room are defined 

as vital areas.

An inspection of the as-built 

central alarm station and 

main control room will be 

performed.

Access to the Central Alarm 

Station and main control room is 

through at least two security 

hardened barriers and an 

intrusion alarm system. 

Secondary security power 

supply system for alarm 

annunciator equipment and 

non-portable communications 

equipment is located within a 

vital area.

An inspection of the as-built 

location of the secondary 

security power supply for alarm 

annunciator equipment and 

non-portable communications 

equipment will be performed.

Access to the secondary security 

power supply for alarm 

annunciator equipment and nonportable communications 

equipment is through an 

intrusion detection system and at 

least two security hardened 

barriers. 

Unoccupied vital areas are 

locked and alarmed with 

activated intrusion detection 

systems that annunciate in the 

Central and Secondary Alarm 

Stations upon intrusion into a 

vital area.

A test of the as-built 

unoccupied vital area door 

alarms to the Central and 

Secondary Alarm Stations will 

be performed.

The unoccupied vital area doors 

are locked. The intrusion 

detection systems annunciate in 

the Central and Secondary Alarm 

Stations upon intrusion into each 

unoccupied vital area. 

The locks used for the 

protection of the vital areas 

are manipulative-resistant.

Type test, analysis or a 

combination of type test and 

analysis will be performed for 

the locks used in the protection 

of the vital areas. 

A report exists and concludes that 

the locks used for the protection 

of the vital areas are 

manipulative-resistant.

The Vehicle Barrier System 

is installed and located at 

the necessary stand-off 

distance to protect against 

the DBT vehicle bombs. 

Type test, analysis or a 

combination of type test and 

analysis will be performed for 

the vehicle barrier system used 

to protect against the DBT 

vehicle bombs. 

A report exists and concludes that 

the vehicle barrier system will 

protect against the DBT vehicle 

bombs based upon the as-built 

stand-off distance of the system. 

An intrusion detection 

system is installed to detect 

penetration or attempted 

penetration of the Protected 

Area Barrier and Vital Area 

Barriers. 

Tests will be performed for the 

as-built intrusion detection 

system used to detect 

penetration or attempted 

penetration of the Protected 

Area barrier and the Vital 

Area Barriers. 

The intrusion detection system 

annunciates in the Central and 

Secondary Alarm Stations upon 

penetration or attempted 

penetration into the protected 

area or vital area.