**NRC INSPECTION MANUAL**	NSIR/DSO

INSPECTION MANUAL CHAPTER 0308 ATTACHMENT 6

BASIS DOCUMENT FOR SECURITY CORNERSTONE OF

THE REACTOR OVERSIGHT PROCESS

  Effective Date:  01/01/2020

0308-06-01    INTRODUCTION 

The security cornerstone of the Reactor Oversight Process (ROP) was originally called the “physical protection” cornerstone and was developed in the same manner as the other ROP cornerstones.  The security cornerstone is intended to meet the same guiding principles and program objectives as the rest of the ROP.  Those principles and objectives are described in Inspection Manual Chapters (IMCs) 0305and 0308 and the source documents listed in Section 8.

0308-06-02    CORNERSTONE STRUCTURE AND OBJECTIVE 

To understand how the cornerstone of safety is defined for safeguards and how it supports the ROP’s objectives and the agency’s mission and goals as stated in the NRC’s Strategic Plan, refer to the security section in the cornerstones of safety in IMC 0308, “Reactor Oversight Process Basis Document”.  

Key Attributes and Critical Elements

Through expert panels, key attributes were described for each cornerstone.  The key attributes were those areas within a cornerstone that needed to function for the associated licensee program or activity to meet the cornerstone’s objective.  Within each key attribute, the staff then determined those specific elements (called critical elements) that needed to be verified to determine if the licensee’s performance and programs adequately met the key attribute and, therefore, met the cornerstone’s objective.  The security cornerstone originally had four key attributes:

· Access authorization

· Access control

· Physical protection

· Contingency response

0308-06-03    INSPECTION

The technical basis for the development of the inspection

program for commercial power reactors for the security cornerstone is described in IMC

0308 Attachment 2, “Technical Basis for Inspection Program”.

Inspectable Areas

The original physical protection cornerstone had four cornerstone-specific inspectable areas: access control, access authorization, response to contingency events, and security plan changes.  The scope of several of the inspectable areas was limited because performance indicators were being used to measure aspects of the area and, therefore, those aspects were not directly inspected under the baseline inspection program.

Following the events of September 11, 2001, the U. S. Nuclear Regulatory Commission (NRC) issued additional security requirements on its licensees and created the Office of Nuclear Security and Incident Response (NSIR) to increase oversight of security at its licensees.  The NRC also initiated several analyses, evaluations, and studies to determine the vulnerabilities of its licensees to various scenarios and to develop strategies to reduce the vulnerabilities and mitigate the consequences of such scenarios.  In addition, the agency revised its list of capabilities for the design basis threat (DBT) against which power reactor licensees must be able to protect their plants. The agency also removed from public access any security-related information that could potentially be of benefit to adversaries wishing to do harm to NRC licensees.

When the agency created NSIR, the NRC included in NSIR’s responsibilities the oversight of material control and accounting (MC&A).  An additional key attribute, MC&A, and associated critical elements were added to the security cornerstone in 2007.  In 2013, the Office of Nuclear Material Safety and Safeguards (NMSS), via memorandum (ML13309A697), assumed the responsibility for oversight of MC&A however, the key attributes and the critical elements continue to remain in the security cornerstone.

0308-06-04    PERFORMANCE INDICATORS

When the ROP was developed, the staff attempted to relate Performance Indicators (PI) thresholds to probabilistic risk data.  This was achieved for most/or some of the reactor safety cornerstones.  Other PI thresholds could not be specifically tied to probabilistic risk data.  In such cases, the PI thresholds were tied to regulatory requirements or were based on the professional judgment of the NRC staff.  In the security cornerstone, the PI provides a useful measure of the status of systems, but its thresholds were chosen based on the professional judgment of the NRC staff.

The PIs in the security cornerstone do not have thresholds identified for the Yellow or Red Bands because there is no risk basis for a determination that a certain degraded level of performance reflected by these indicators can be correlated into mandatory plant shutdown.  It is expected that declining performance in the area monitored by the indicators would be interrupted by increased licensee corrective actions and by increased NRC attention.

0308-06-05    SIGNIFICANCE DETERMINATION PROCESS

The purpose of the Baseline Security Significance Determination Process (BSSDP) is to provide an objective means of evaluating findings related to common defense and security for activities licensed by the NRC as defined in IMC 2201, “Security Inspection Program for Operating Commercial Nuclear Power Reactors.”  The process also is used to provide reasonable assurance that licensees’ safeguards systems can provide adequate protection against the DBT based on defense-in-depth layers of protection as part of licensees’ commitments to NRC requirements.  The BSSDP incorporates areas of MC&A, protection of Safeguards Information, and physical protection.  The BSSDP is utilized once a performance deficiency has been evaluated as more than minor using IMC 0612, Appendix B, “Issue Screening,” and determined to be in the security area in accordance with IMC 0609, Attachment 4, “Initial Characterization of Findings.”

0308-06-06   PUBLIC ACCESS TO INFORMATION

In November 2003, the Commission asked the staff to present it with options for addressing the security cornerstone of the ROP.  The staff sent the Commission several options (see SECY-04-0020) with no change to the then current process and ending with a completely different process for assessing security.  The Commission chose an option that kept the security cornerstone in the ROP, but assessed security separate from the other ROP cornerstones.  The

Commission specifically directed the staff to “make no information publicly available”

(see SRM-SECY-04-0020).

The staff implemented the Commission’s direction in August 2004, by removing from the NRC’s public web pages the ROP assessment information related to the security cornerstone and making non-safeguards, security-related inspection documents official use only.  At the time, no security-related inspection reports or their cover letters were public because of an earlier response to the events of September 11, 2001.  However, in July 2011, the Commission approved staff’s proposal to “reintegrate security inspection findings and PIs into the Action Matrix of the ROP for commercial nuclear power licensees.”  The Commission also approved the staff’s recommendation “that the proposal be considered, where applicable and appropriate, for other NRC security inspection and oversight programs, such as reactors under construction” (see SRM-SECY-11-0073).

Also, by Commission direction (see SRM-04-191), the staff later provided new options to make certain information about security inspections publicly available.  The Commission chose an

option that would identify that a security inspection had been performed and that findings had been identified.  However, the Commission directed the staff to make public only certain, limited information regarding the inspections and associated findings.   Details regarding the nature of any findings as well as the number findings that were greater-than-green in significance were withheld from public disclosure.

0308-06-07    REFERENCES

7.1  Commission Papers and Staff Requirements Memoranda

SECY 99-007, “Recommendations for Reactor Oversight Process Improvements” (ML992740074) (non-public)

SECY 99-007A, “Recommendations for Reactor Oversight Process Improvements Follow up to Secy-99-007)” (ML992740073) (non-public)

SECY-04-0002, “Revisions to the Power Reactor Physical Protection Baseline Inspection Program” (ML033390092) (non-public)

SECY-04-0020, “Treatment of Physical Protection Under the Reactor Oversight Process” (ML033570084) (non-public)

SRM-SECY-04-0020, "Treatment of Physical Protection Under the Reactor Oversight Process" (ML040900126) (non-public)

SECY-04-0091, “Provisional Physical Protection Determination Process to evaluate Findings from the Security Baseline Inspection and Force-on-Force Inspection Programs” (ML040130797) (non-public)

SRM-SECY-04-0191, “Withholding Sensitive Unclassified Information Concerning Nuclear Power Reactors from Public Disclosure” (non-public)

SECY-05-0082, “Revised Assessment Process for the Security Cornerstone of the Reactor Oversight Process” (ML051090579) (non-public)

SRM-SECY-05-0082, “Revised Assessment Process for the Security Cornerstone of the Reactor Oversight Process” (ML052280031) (non-public)

SECY-05-0107, “Status of Activities and Improvements to the Physical Protection Significance Determination Process” (ML051640574) (non-public)

SECY-06-0036, “Public Disclosure Options within the Security Cornerstone of the Reactor Oversight Process” (non-public)

SECY-07-0015, “Results of Trial Assessment of the Industry's Optional Physical Protection Significance Determination Process” (ML070080171) (non-public)

SECY-07-0136, “Recommendation to Discontinue Two of Three Performance Indicators Associated with The Security Reactor Oversight Process,” (ML062760640) (non-public)

SRM-SECY-07-0136, “Recommendation to Discontinue Two of Three Performance Indicators Associated with The Security Reactor Oversight Process,” (ML072560811) (non-public)

SECY-11-0073, “Staff Proposal to Reintegrate Security into the Action Matrix of the Reactor Oversight Process Assessment Program” (ML112020038) (non-public)

SECY-16-0073 (ML17223A335), “Options and Recommendations for the Force-on-Force Inspection Program in Response to SRM-SEC-14-0088 (ML16279A345).” (non-public)

7.2  Program Documents

(Note:  a full list of ROP-related program documents can be found at http://www.nrc.gov/reactors/operating/oversight/program-documents.html)

Inspection Manual Chapter (IMC) 0305, “Operating Reactor Assessment Program”

IMC 0308, “Reactor Oversight Process Basis Document”

IMC 0609, “Significance Determination Process”

IMC 0609, Appendix E, “Physical Protection Significance Determination Process for Power Reactors”

IMC 2201, “Security and Safeguards Inspection Program for Commercial Power Reactors”

7.3  Non-NRC Documents

Nuclear Energy Institute NEI-99-02, “Regulatory Assessment Performance Indicator Guideline,” Revision 7, 31 August 2013

Issue Date:  11/09/20	2	0308 Att 6

Figure 1:  Access Authorization Basis Summary Sheet

Issue Date:  11/09/20	5	0308 Att 6

Figure 2:  Access Control Basis Summary Sheet

Issue Date:  11/09/20	5	0308 Att 6

Figure 3:  Contingency Response Force-on-Force Testing Basis Summary Sheet

Issue Date:  11/09/20	5	0308 Att 6

Figure 4:  Equipment Performance, Testing and Maintenance Basis Summary Sheet

Issue Date:  11/09/20	5	0308 Att 6

Figure 5:  Protective Strategy Evaluation and Performance Evaluation Basis Summary Sheet

Issue Date:  11/09/20	5	0308 Att 6

Figure 6:  Security Training Basis Summary Sheet

Issue Date:  11/09/20	5	0308 Att 6

Figure 7:  Fitness-for-Duty Program Basis Summary Sheet

Issue Date:  11/09/20	5	0308 Att 6

Figure 8:  Information Technology Security Basis Summary Sheet

Issue Date:  11/09/20	5	0308 Att 6

Figure 9:  Material Control and Accounting Basis Summary Sheet

Issue Date:  11/09/20	5	0308 Att 6

Figure10:  Security Aspects Performance Indicator Basis Summary Sheet

Issue Date:  11/09/20	5	0308 Att 6

Figure 11:  Review of Power Reactor Target Sets Basis Summary Sheet

Issue Date:  11/09/20	5	0308 Att 6

REVISION HISTORY FOR IMC 0308 ATTACHMENT 6

Issue Date:  11/09/20	Att 1-1	0308 Att 6