L-93-178, Requests Exemption from Certain Requirements of 10CFR73.55, Requirements for Physical Protection of Licensed Activities ...Against Radiological Sabotage, for Units 1 & 2
| ML20056F600 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point, Saint Lucie  |
| Issue date: | 08/18/1993 |
| From: | Bohlke W FLORIDA POWER & LIGHT CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| L-93-178, NUDOCS 9308300139 | |
| Download: ML20056F600 (4) | |
Text
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Horida Power & Light Company, P.O. Box 14000, Juno Beach, FL 33408-0420 AUG I 81993 kPL L-93-178 10 CFR 73.5 Thomas E. Murley Director, Office of Nuclear Reactor Regulation U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Reauest for Exemotion - Biometrics Access Control.
Dear Dr. Murley:
The purpose of this letter is to request, in accordance with the provisions of 10 CFR 73.5, " Specific exemptions," an exemption from certain requirements of 10 CFR 73.55, " Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage" for St. Lucie Units 1 and 2 and Turkey Point Units 3 and 4 (attached).
As discussed with members of your staff at a public meeting on June 2,
1993, Florida Power & Light Company (FPL) expects to implement biometrics m.ccess control at Turkey Point Units 3 and 4 by December 1993, and at St. Lucie Units 1 and 2 by March 1994.
Based on this, FPL requests that the subject exemption be issued by November 15, 1993.
If you have any questions regarding this request, please contact us.
Very truly yours bk fl&
W.
H. Bohlke Vice President Nuclear Engineering and Licensing Attachment WHB/msd cc: Document Control Desk USNRC Stewart D.
Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Senior Resident Inspector, LSNRC,-St. Lucie Plant 930830013g93081805000gO g@g g
DR' ADOC
,p an FPL Group company
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1 L-93-178 Page 2 of 4 j
ATTACHMENT INTRODUCTION l
Florida Power & Light Company (FPL) requests, in accordance with the provisions of 10 CFR 73.5, " Specific exemptions," an exemption j
from certain requirements of 10 CFR 73.55,
" Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage" for St. Lucie Units 1 and 2 and Turkey Point Units 3 and 4.
Specifically, FPL requests an exemption from 10 CFR 73.55 (d) (5). This section, in part, states that an individual not employed by the licensee but who requires frequent and extended access to protected and vital areas may be authorized access to such areas without escort provided that he receives a picture badge upon entrance into the protected area which must be returned upon exit from the protected area.
Title 10 CFR 73.55 states that the licensee shall establish and maintain an onsite physical protection system and security organization which will have as its objective to provide high assurance that activities involving special nuclear material are not inimical to the common defense and cacurity and do not j
constitute an unreasonable risk to the public health and safety.
Title 10 CFR 73.55 specifies that the Commission may authorize an applicant or licensee to provide measures for protection for radiological sabotage other than those required by 10 CFR 73.55.
i This can be accomplished if the applicant or licensee demonstrates that the measures have the same high assurance objective as specified in the regulation, and that the overall level of system performance provides protection against radiological sabotage equivalent to the regulation.
This exemption is requested to allow the use of a hand geometry biometric system to control unescorted access into the protected areas of the St.
Lucie and Turkey Point nuclear plants, in conjunction with taking the photograph identification badges l
offsite.
CURRENT SITUATION Currently, unescorted access into St. Lucie and Turkey Point is controlled through the use of a photograph on a badge /keycard (during the remaining discussion, the term " badge" will be used to mean the combination of a picture badge and keycard).
The security officers at each entrance station use the photograph on the badge to identify the individual requesting access.
Under the current system, badges are not taken offsite and are issued, stored and retrieved at each entrance / exit location.
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L-93-178 Page 3 of 4 r
PROPOSED SYSTEM Under the proposed system, each individual who is authorized unescorted access will have the physical characteristics of their hand (hand geometry) registered with their badge number in the access control computer.
Since no one can use a badge to gain access except the individual whose hand geometry has been registered to that
- badge, individuals (this also includes individuals not employed by the licensee e.g., contractors) will be allowed to keep their badge with them when they depart the site.
All other access processes, including search function capability, will remain the same except for elimination of the process to issue, retrieve and store badges at the entrance stations to the plants. At least one security guard will continue to be positioned within a bullet-resisting structure to be responsible for the last act of access control.
i The hand geometry system is superior to the current process because it provides a nontransferable means of identifying people, unlike photographs on a badge.
During the registration process, hand measurements can be made on both hands with the results being i
averaged.
This forms a template of the user's hands which is J
l stored for later use in the actual verification process.
A registered user enters his/her badge into the card reader and places the hand on the measuring surface.
The system detects when the hand is properly positioned and then takes a picture.
The unique characteristics are extracted from this picture and then compared with the previously stored template.
1 On June 2, 1993, FPL met with members of the NRC staff to discuss the use of a hand geometry system at its sites and'provided at that meeting a copy of the SANDIA REPORT entitled, "A
PERFORMANCE EVALUATION OF BIOMETRIC IDENTIFICATION DEVICES" (SAND 91--027 6 UC--
I 906 Unlimited Release, Printed June 1991).
Based on the results of this report regarding biometrics systems and on experience gained at our sites under the current photo-identification system, the false-accept rate for the hand geometry system is at least equal to the current system.
Also at the meeting, FPL responded to various questions regarding the implementation of a hand geometry system.
FPL will develop a process for testing the system ensuring that the sensitivity of the system is maintained at an appropriate level.
As stated above, all other access processes will remain the same except for elimination of the process to issue, retrieve and store badges at the entrance / exit stations to the plants. Upon exemption approval, FPL would update its physical security plans accordingly.
l e
t L-93-178 I
Page 4 of 4 BASIS FOR EXEMPTION The requested exemption to the regulations is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security.
The requested exemption presents a special circumstance, in that application of the regulation in this particular circumstance would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.
The underlying purpose of 10 CFR 73.55 (d) is to control all points of personnel access into a protected area.
FPL believes that the basis for the wording in 10 CFR 73.55(d) (5) was to ensure that the badges could not be compromised or stolen by being taken offsite.
Under the proposed system, badges would be taken offsite. However, both the badge and hand geometry would be necessary for access into the protected area.
FPL points out that even if a badge could be compromised or stolen, access would not be provided without the i
hand geometry of the person registere.d to the badge.
FPL maintains that the proposed system would continue to provide for a combination of identity verification processes and, in fact, would increase the level of access control at its plants.
Based on the
- above, application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule and the overall level of system performance i
will provide protection against radiological sabotage equivalent to the regulation.
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