ML19249A405

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Draft Interim Acceptance Criteria for Physical Security Plan for Nuclear Power Plants
ML19249A405
Person / Time
Issue date: 03/31/1977
From:
Office of Nuclear Reactor Regulation
To:
References
NUREG-0220, NUREG-220, NUDOCS 7908220598
Download: ML19249A405 (84)


Text

N U R EG-0220 INTERIM ACCEPTANCE CRITERIA FOR A PHYSICAL SECURITY PLAN FOR NUCLEAR POWER PLANTS D R AFT 8.'d l89

)l'0f0005'15 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission

NUREG 0220 INTERIM ACCEPTANCE CRITERIA FOR A PHYSICAL SECURITY PLAN FOR NUCLEAR POWER PLANTS DRAFT March 1977 4j Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

TABLE OF CONTENTS PART I 0F THE PHYSICAL SECURITY PLAN ACCEPTANCE CRITERIA PAGE CHAPTER 1 - SECURITY ORGANIZATION.................

3 1.1 Management Organi zation......

3 1.2 S ecu ri ty O rga ni za ti o n................................

3 1.3 F a c i l i ty P e r s o n n e l..............................

4 1.3.1 Personnel Reliabili ty.....

4 1.3.2 Personnel Training in Securi ty Practices......

f 6

1.4 P l a n t S ec u ri ty Pe r so nnel............................

1.4.1 Qualifications for Employment in Security.....

6 7

1.4.2 Screening..................

7 1.4.3 Training.....................................

7 1.4.4 Retraining....................

8 1.4.5 Security Equipment..................

9 1.4.6 Authority of Guards to Use Weapons............

9 1.4.7 Security Force Composition.

1.5 Local and Other Law Enforcement Agencies............

10 1.6 Access Au tho ri za tions...............................

11 CHAPTER 2 - FACILITY AND ENVIRONS.,...........................

13 2.1 General Site and Area Layout..............

13 2.2 Fixed and Mobile Security Posts in the Owner-Controlled Area..............

13 2.3 Early Wa rni ng Detec tion Sys tems.....................

13 CHAPTER 3 - PROTECTED AREA PERIMETERS.........................

14 3.1 Perimeter Barri er and Isola tion Zone.................

14 14 3.1.1 Layout..........

3.1.2 Physical Barriers.................

14 3.1.3 Ill umination and Surveillance................

16 3.1.4 Intrusion Detection Ha rdware..................

18 3.1.5 Securi ty Posts (Fi xed and Mobile).............

21 1O1 b> n<1 -4i /I i

TABLE OF CONTENTS (Continued)

PAGE 3.2 Pro tec ted A rea Por ta l s............................ 22 3.2.1 Personnel Access Portals and Posts............

22 3.2.1.1 Layout................................ 22 3.2.1.2 Physical Structures.................. 22 3.2.1.3 Locks, Keys, Combinations and Related Equipment............

22 3.2.1.4 Securi ty Pos ts...........

22 3.2.1.5 Search and Admittance Control Hardware...........................

24 3.2.1.6 Picture Badge System................... 26 3.2.1.7 Commu n i ca t i o n s.......................

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3. 7. 2 Vehicle and Cargo Access Portals and Posts....

28 3.2.2.1 Layout.................................

28 3.2.2.2 Physical Structures...................

28 3.2.2.3 Locks, Keys, Combinations and Related Equipment..........................

29 3.2.2.4 Security Posts.......

29 3.2.2.5 Vehicle and Cargo Search Hardware.....

30 3.2.2.6 Communi ca tions.......................

30 CHAPTER 4 - PROTECTED AREAS.......

31 4.1 Layout.

31 4.2 Physical Structures..........

31 4.3 Illumination and Surveillance.

32 4.4 Securi ty Pos ts (Fixed and Mobile).................

33 4.5 Escorts....................................

34 CHAPTER 5 - VITAL AREA BOUNDARIES.........................

35 5.1 Layout..........

36 5.2 Physical Barriers................................ 36 5.2.1 Barrier Descriptions......................

36 5.2.2 Intrus ion Detec tion Hardware.................. 37 1 O ^d 0A4

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TABLE OF CONTENTS (Continued)

PAGE 5.3 V i ta l A rea Po r ta l s..................................

40

5. 3.~ 1 Personnel Access Portals and Posts............

40

. 40 5.3.1.1 Layout.........

5.3.1.2 Physical Structures...................

41 5.3.1.3 Locks, Keys, Combination and Related Equipment..

41 5.3.1.4 S e c u r i ty Po s ts......................

41 5.3.1.5 Access Control Hardware....

41 5.3.1.6 Coded Badge System...

41 5.3.1.7 Communi ca tions....

42 5.3.2 Vehicle Access Portals and Posts...........

42 5.3.2.1 Physical Structures.....

42 5.3.2.2 Security Posts......

42 5.3.2.3 Communi ca ti on s............

43 44 CHAPTER 6 - VITAL AREAS.

6.1 Central Alarm Sta tion.......

. 44 6.1.1 Location and Layout.

44 45 6.1.2 Physical Structures..

6.1.3 Alarm and Surveillance Monitoring Hardware...

45 47 6.1. 4 Manning..

ap 6.1. 5 Commu n i ca ti o ns..................

48 6.2 Secondary Alarm Sta tion...

50 6.3 Other Vi tal Areas........

6.3.1 Surveillance Hardware..

52 6.3.2 Security Posts (Fixed and Mobile).....

53 6.3.3 Escorts......

54 CHAPTER 7 - CEt1 TRAL COMMUNICATIONS SYSTEMS.........

55 55 7.1 Telephone System..

7.2 Intercom and Public Address System..

55 7.3 Other Central Comnunication Systems......

56 CHAPTER 8 - RESPONSE TO SECURITY CONTINGENCIES...

57 8.1 Response Force Availability.

57 57 8.2 Assignment of Responsibilities.

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TBLE OF CONTENTS (Continued)

PAGE CFAPTER 9 - SPECIAL SECURITY MEASURES DURING REFUELING / MAJOR MAINTENANCE OPERATIONS..........................

60 CHAPTER 10 - SPECIAL SECURITY MEASURES DURING CONSTRUCTION 0 P E RA T I O N S......................................

6 2 CHAPTER 11 - CVERALL PHYSICAL SECURITY PROGRAM PERFORMANCE.....

63 PART II UF THE PHYSICAL SECURITY PLAN ACCEPTANCE CRITERIA......

68 CHAPTER 12 - TESTS, INSPECTIONS AND MAINTENANCE................

68 12.1 Physical Barriers and Access Poir.ts................

68 12.2 Ala rms a nd Annuncia tors............................

68 12.3 Special Purpose Detectors..........................

69 12.4 Commu n i ca t i o n s Eq u i pme n t............................. 70 12.5 Securi ty Personnel Equi pment........................

71 CHAPTER 13 - SECURITY RECORDS.................................

72 13.1 Securi ty Tours, Inspections, and Tests..............

73 13.2 Maintenance.......................................

73 13.3 A l a rn A r : u n t a t i o n s................................

74

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13.4 Securi ty desponse.......

...........................74 13.5 Autho ri zed I ndi vi dual s..............................

75 13.6 A cc e s s to V i ta l A r s o................................ 75 13.7 Nonemployee Accest...................................

76 CHAPTER 14 - SECURI). AUDITS...................................

73 14.1 Program Audits......................................

78 844 194~-

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INTRODUCTION This document has been prepared for use in conjunction with the

" Interim Format and Content for a Physical Security Plan -for Nuclear Power Plants", NUREG - 0207, U. S. Nuclear Regulatory Commission, February 1977 (Draft). The pr 2entation of acceptance criteria follows exactly the organization of the " Format and Content" document.

In 10 CFR 73.55 (a) a single criterion for the act tance of a nuclear reactor physical security system is established. This cri terion can,

be stated succinctly as nigh assurance protection against industrial sabotage by a well-armed, team of several outsiders assisted by a single insider or by a single insider acting alone."

Satisfaction c." this criterion can, of course, be achieved in an infinite variety of ways.

Based upon the requirement for high assurance protection against industrial sabotage and the inherent nature of the nuclear power plant and associated threat, a number of secondary criteria can be derived from the single criterion stated above.

These criteria have been derived from the single criterion stated above. These criteria have s

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I been derived ~to guide the licensee in designing an acceptable s

physical security system.

Additional guidance to the licensee is provided bf' hxemplary Design of a Physical Security System for a Nuclear Powee Plant" to be published by the USNRC.

This exemplary design will be prepared for a generic nuclear power plant using the L

acceptance criteria stated herein.

s The acceptance criterie have been developed in three steps:

1) The general characteristics of nuclear power plants

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t and their physical security systems were established.

2) This description was combined with a general characterization of the threat to produce a set of tactical objectives for the physical security system.
3) The threat uas analyzed and the physical security system acceptance criteria appropriate for achieving the tactical objectives for each threat component were obtained.

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PART I 0F THE PHYSICAL SECURITY PLAN ACCEPTANCE CRITERIA CHAPTER 1 - SECURITY ORGANIZATION 1.1 MANAGEMENT ORGANIZATION Ageptance Criterion 1.1. A Management of the physical security organization nust be independent of the management of the opera ting organization.

piscussion This criterion applies to the any-to-day management of physical security and plant operating activities.

These activities reluire coordination which should be provided by establishing indecendent chains of cocinand reporting to top management of the facility or top corporate management.

Acceptance Criterion 1.1.B Management of the conduct of physical security audits (See Chapter 14) should be independent of normal physical security managerrent Discussion There is a clear conflict of interest when ohysical security audit procedures are conducted by those whose system is being audited.

1.2 SECURITY ORGANIZATION bk Acceptance Criterion 1._2d At least one full time member of the security organization who has the authority to direct tra ohysical security activities of the security organization in meeting the threat shall be onsite at all times.

This individual should report directly to the individual 3

(plant manager, his designated alternate, shif t suoervisor, etc. )

with final responsibility for plant operation on a shif t.

D_iscussion As will be discussed further in later sections, the n<. ture the threat is such as to severely limit the amount of outside helo that can be provided.

Consistent with this philosophy, the criterion calls for the continuous presence of a licensee representative who has the authority to assume overall direction of physical security operations in the event of an incident.

This criterion is partially derived from 10 CFR 73.55 (b)(2).

Acceptance Criterion 1.2.8 A clear chain of succession of responsibility must be established for the transfer of authority in the event of disablement of a key member of the physical security organization during an incident.

Discussion This criterion simply calls for a plan of organization that will permit orderly pat sage of authority should tLa individual charged with directing the physica! security activities of the security organization be disabled in the course of responding to a security contingency.

1.3 FACILITY PERSONNEL 1.3.1 Personnel Reliabili ty 8kk k

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Acceptance Criterion 1.3.1. A The licensee must develop and conduct a screening orogram for all personnel who are authorized for unescorted access to the protected area.

As a minimum, this program should follow the employee screening guidance in American National Standard, ANSI 18.17, " Industrial Security for Nuclear Power Plants".

Certification of totally equivalent screening (such as "L" or D00 National Agency Check) by a government program will be acceptable.

Personnel routinely on the site should be trea ted as employees.

A contractor screening program is acceptable if it can be proved that tha Drogram provides coverage equivalent to or grea ter than ANSI 18.17.

Discussion Consistent with federal and state law regarding fair employment practices, a screening program must be developed and administered.

This program should exclude from employment those whose background would indicate an inconsistency with the required high level of industrial sabotage protection.

As stated in the statement of considerations in 10 CFR 73.55, the Commission is presently considering a screening program.

Acceptance. Criterion 1.3.1.B Assure that the procedures used in ootential employee screening are available for USNRC inspection.

Discussion 845 k

Records of the procedures of the pre-employment screening program must be maintained in a nanner permitting USNRC inspection to assure that the required information is being sought.

Private informa tion should be protected consistent with Federal and local " privacy" acts.

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1.3.2 Personnel Training in Security Practices Accepta nce Cri terion 1. 3.2.B_

Demonstrate that all authorized individuals (other than physical security force personnel) understand their role in physical security and their responsibility in the event of security contingencies.

_ Discussion A training program should be developed to establish and maintain cognizance of physical security procedures by all authorized personnel.

A refresher program should be conducted annually. A statement of attendance certified by the instructor shall be considered suitable demonstration.

1.4 PLANT SECURITY PERSONNEL 1.4.1 Qualifications for Employment in Security Acceptance Cri terion 1.4.1. A All physical security force personnel (guards, watchmen, armed response individuals) must possess physical and mental capabilities consistent with their role in the detection, assessment and neutralization of security contingencies.

These qualifications must be checked no less frequently than annually.

Discussion Refer to " Nuclear Security Personnel Interim Qualification and Training Requirements" for details as to required qualifications and 6

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certifications of compliance. Qualifications are addressed in 10 CFR 73.55 (b)(4).

1.4.2 Screening No criteria additional to 1.3.1. A and 1.3.1.B.

1.4.3 Training Acceptance Cri terion 1.4.3. A Provide assurance that all members of the physical security force receive training consistent with their roles.

Discussion Refer to " Nuclear Security Personnel Interim Qualification and Training Requirements" for details of the required curriculum, qualifications of instructors, and certifications of successful completion.

The need for a trained physical security force is established in 10 CFR 73.55 (b)(4).

1.4.4 Retraining Acceptance Cri terion 1.4.4. A Each guard, watchman, anc armed resoonse individual shall be requalified annually.

Such requalification shall be documented.

Id k t Discussion This criterion is established in 10 CFR 73.55 (b)(4).

Refer to

" Nuclear Security Personnel Interim Qualification and Training Require-ments" for details of the required curriculum and certifications of 7

successful completion.

1.4.5 Security Equipment Acceptance Criterion 1.4.5. A All guards must wear distinctive uniforms which clearly distinguish them from nonsecurity and local law enforcement personnel.

Discussion Uniforms provide identification when responding to security contingencies.

It is reconviended that uniforms be stored on site to lessen the chance of thef t.

The requirement for uniforms is established in 10 CFR 73.2.

Acceptance Criterion 1.4.5.8 The guards and armed response individuals must be pi vided with weapons and equipment consistent with the threat, the requirements of federal and local laws, and the facility's physical security plan.

Discussion The term weapons as used here includes incapacitating agents, such as Mace.

The USNRC recommended weapons and equipment for the guards and armed response inaividuals are listed in " Nuclear Security Personnel Interim Qualification and Training Requirements".

Secure weapons storage should be provided in the protected area. Weapons provided by the licensee or a contractor should not leave the owner-controlled area.

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Acceptance Criterian 1.4.5.C All on-duty physical security force personnel must be capable of continuous connunication with the central and secondary alarm stations and will all other members of the security force when within the owner-controlled area.

Discussion Portable conmunication equipment should be assigned which minimizes blackout areas.

At least two channel transmission and reception will provide an acceptable level of jamming resistance.

The communication requirement is derived from 10 CFR 73.55 (f)(1).

1.4.6 Authority of Guards to Use Weapons There are no specific acceptance criteria.

1.4.7 Security Force Composition Acceptance Criterion 1.4.7. A As stated in 10 CFR 73.55 (h)(2) a nominal response force of ten guards and armed response individuals is required.

This number must include at least five guards.

Discussion Any decreese in the number of armed response individuals must be stated here and later justified in Chapter 8.

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1.5 LOCAL AND OTHER LAW ENFORCEMENT AGENCIES Acceptance Criterion 1.5. A Demonstrate that a workable response plan has been developed and agreed to in writing by ali elements of local and other iat enforcement agencies that may be called upon for support.

Discussion This criterion calls for the establishment of agreements as to how support forces will respond to a call for help and how they will be employed upon arrival.

Acceptance Criterion 1.5.B Written agreements must be reached with all elements of local law enforcement and other agencies that may be called upon for support in the event of an incident to assure that the direction of physical security operations always rests with a single individual.

Discussion The instances of authority conflicts in crisis management are It is desirable, though not necessary, that this authority numerous.

always rest with a licensee employee.

It is necessary that any individual who might assume conmand be familiac with all aspects of the plant's response plan and the security considerations peculiar to nuclear power plants.

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Acceptance Cri terion 1.5.C Demonstrate that key members of appropriate local and other law enforcement agencias have been familiarized with response procedures, plant layout, and the peculiar constraints imposed in the protection of a nuclear reactor.

Discussion Supporting response personnel must be shown to be familiar with their role in responding to security contingencies.

1.6 ACCESS AUTHORIZATIONS Acceptance Criterion 1.6. A Establish definitive, written procedures for granting authorization for protected / vital area unescorted access.

These procedures shall satisfy the requirements of ANSI 18.17 and clearly establish the need for access.

Discussion The number of persons granted unescorted access will clecriy affect the possibility of sabotage actions involving authorized individuals.

This criterion calls for limiting unescorted access to only those personc requiring access for the safe and efficient operation of the plant. Where feasible, persons requiring access to only a specific vital area should be so authorized.

All persons ge nted unescorted acce',s authorization must have satisfied the requirements of the screenin program described in Acceptance Cri,terion 1.3.1. A.

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Acceptance Criterion 1.6.B Establish definitive, written procederes for granting authorization for protected / vital area escorted access.

Discussion This criterion calls for the establishment of written procedures to be followed in granting visitors access to protected / vital areas.

These procedures should er ablish that visitors are expected and that they are carrying proper identification.

Acceptance Cr'terion 1.6.C All packages and material for delivery into the protected area shall be checked for proper identification and authorization.

Discussion Procedures must be developed and applied which verify that packages which are mailed or shipped to the piant are expected by the addressee.

This criterion is derived from 10 CFR 73.55 (d)(3).

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CHAPTER 2 - FACILITY ENVIRONS 2.1 GENERAL SITE AND AREA LAYOUT There are no specific acceptance criteria.

2.2 FIXED AND MOBILE SECURITY POSTS IN THE OWNER-CONTROLLED AREA There are no specific acceptance criteria.

2.3 EARLY WARNING DETECTION SYSTEMS Acceptance Criterion 2.3. A If detection systems are used external to the barrier at the prctected area perimeter, they must annunciate in both the central and secondary alarm stations.

The systems must also be tamper-indicating and self-checking and satisfy any other requirements for intrusion detection systems located at the protected area perimeter.

Discussion The detection systems considered in this criterion might be used to provide early warning of activities beyond the perimeter of the protected area which might indicate a threat to the protected area.

Therefore, fence-monitoring systems or those systems immediately adjaceni to the barrier are not to be considered under this criterion.

It is required that early warning detection systems satisfy all the requirements established in Chapter 3 for intrusion detection systems located at the protected area perimeter.

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CHAPTER 3 - PROTECTED AREA PERIMETERS 3.1 PERIMETER BARRIER AND ISOLATION ZONE 3.1.1 Layout Acceptance Cri terion 3.1. A Isolation zones maintained in outdoor areas adjacent to the physical barrier at the perimeter of the protected area must extend at least twenty feet on each side of the perimeter and must be free of visual obstructions so as to permit accurate assessment of security contingencies detectcd at the protected area perimeter.

Discussion This criterion calls for an isolation zone at the protected area perimeter that permits the assessment system to provide accurate information for all intrusion contingencies.

3.1.2 Physical Barriers Acceptance Criterion 3.1.2. A Physical barriers at the protected area perimeter must at the minimum satisfy the requirements of 10 CFR 73.2 (f)(1), (2).

Discussion The requirement for a barrier at the perimeter of the protected area is established by 10 CFR 73.2 (g).

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Acceptance Criterion 3.1.2 Means must be established to prevent unauthorized penetration of the protecteo area by general and special purpose wheeled vehicles.

A system must be established in the isolation zone and within the protected area to derail unauthorized railroad equipment penetrating the protected area.

Discussion

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At all points en the protected area perimeter at which successful penetration of the protected area is not prevented by topography or other constraints, a barrier to successful penetration must be established.

Successful penetration occurs when the vehicle continues to provide transport af ter penetration. A tractor-trailer combination should be considered the largest wheeled vehicle seeking to penetrate. Aircraf t are excluded.

Acceptance Criterion 3.1.2.C All security locks should satisfy the criteria stated in 10 CFR 73.2 (m).

All security locks, keys, combinations and related equipment must satisfy the requirements of Regulatory Guide 5.12.

All security keys should be controlled and kept in a locked cabinet when not in use.

Whenever there is evidence that any key, Icek, combination or related equipment may have been compromised, it shall be changed.

Upon termina tion of employment of any employee, keys, locks, combinations, and related equipment to which that employee had access shall be changed.

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Discussion The physical security plan must present an effective system for managing all locks, keys, combinations, and other related equipment employed in securing the protected area perimeter.

The term

" employee" includes both licensee employees and anyone onsite who has had access. This criterion is largely derived from 10 CFR 73.55 (d)(9).

Acceptance Criterion 3.1.2.0 Measures must be taken to fully compensate for any reduction in the effectiveness of a physical barrier Discussion Compensatory measures may include steps taken at the protected area perimeter or at other points in the physical security system.

3.1.3 Illumination and Surveillance Acceptance Criterion 3.1.3. A Illumination mus+ be maintained at the protected area perimeter including the isolation zone.

The minimum level of illumination, as stated in 10 CFR 73.55 (c)(5), is.2 footcandle measured horizontally at ground level.

Discussion bkO Illuni. nation is sufficient when it permits detection as defined by Acceptance Criteria 3.1.3.B and 3.1.3.C.

Loss of illumination is permitted for a maximum of one minute before restoration of illumination.

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Initiation of emergency procedures to provide equivalent protection should be started inviediately.

Acceptance Criterion 3.1.3.B High assurance detection of the projection of unauthorized material over the protected area perimeter must be provided.

Discussion This criterion addresses attempts by the adversary to defedt searches by throwing unauthorized material over the protected area bat rier prior to attempted protected area entry through a portal.

The presence of unauthorized weapons and explosives within the protected area will provide the adversary an unacceptable tactical advanta ge.

Acceptance Criterion 3.1.3.C The capability shall be provided to:

1) Observe unauthorized activities in the isolation zone.
2) Accurately assess intrusion detections made at the protected area perimeter.

Discussion The first component in this criterion requires that at least one member of the physical security force has the capability of observing unauthorized activities in the isolation zone at all times.

This does not require continuous observation.

A CCTV system or a manned security post with a field of view in the isolation zone is sa tis fac tory.

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The second component requires the ability to clearly view the intrusion zone before the intruder has time to leave the area.

Acceptance Criterion 3.1.3.D Capability must be provided for transmission of equivalent surveillance data to the central and secondary alarm stations.

Discussion The requirement for communication of surveillance data obtained by members of the physical security force is satisfied by communications criteria ( Acceptance Cri teria 3.2.1.7. A and 3.2.2.6.B).

Totally equivalent systems for obtaining data from surveillance hardware are not required. What is required is the ability to receive all surveillance data.

For example, if there are a number of CCTV cameras at the facility, the central alarm station may have several moni tors.

At least one monitor is required at the secondary alarm station which has the capability of selecting and displaying the image transmitted by each camera.

3.1.4 Intrusion Detection liardware Acceptance Criterion 3.1.4. A All intrusion detection system hardware must satisfy the criteria of USNRC Regulatory Guide 5.44 The system must provide high assurance detection of all penetrations of the protected area perimeter, y a 2 1 2-18

Discussion This criterion is based upon the assumption that a high level of detection performance within the protected area (i.e., not near the protected area perimeter) will be inconsistent with efficient operation of the plant.

Further, undetected penetration of an armed adversary to a vital area perimeter may provide an unacceptWle tactical disadvantage to the physical security system.

Consistent with the requirement for proper detection sensitivity stated ir. Regulatory Guide 5.44, high assurance protection will be provided by the system when it detects an intruder in the secured zone ninety-five out of one-hundred times.

The modes of intruder penetration considered should be running, walking, crawling, rolling, and jumping.

Acceptance Criterion 3.1.hB All intrusion alarm systems must be provided with emergency electrical power as stated in USilRC Regulatory Guide 5.44.

Discussioa The loss of external power can reasonably be assumed at the start of a violent assault. Alarm systems must be provided by onsite emergency sources with sufficient power to operate.

Acceptance Criterion 3.1.4._C All intrusion alarm systems must satisfy the criterion for the frequency of false and nuisance alarms stated in Regc ory Guide 5.44.

Innocent alarms (detined below) must satisfy the same criterion.

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Discussion False alarms are defined as those alarms which have been generated without any apoarent cause.

Nuisance alarms are defined as those alarms generated by the alarm system detecting a change in the operating environment.

Innocent alarms are caused by animals, authorized personnel, windblown material, etc., entering the security zone.

Acceptance Criterion 3.1.4.D All intrusion detection systems must be tamper-indicating and self-checking, e.g., an automatic indication is provided when failure of the alarm system or a component occurs, or when the system is on standby power.

Discussion This criterion is established by 10 CFR 73.55 (e)(2).

The requirements for tamper-resistance and self-checking are established by Regulatory Guide 5.44 Acceptance Criterion 3.1.4.E All detection system hardware must annunciate at the central and secondary alarm stations.

(See also 4.6).

Discuss _ ion This criterion is derived from 10 CFR 73.55 (e)(1).

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Acceptance Criterion 3.1.4.F In the event of detection hardware outage, compensatory procedures must be developed to assure an equivalent level of protection.

Discussion Compensatory measures may be taken at any pr. int in the physical securi ty system.

3.1.5 Security Posts (Fixed and tiobile)

Acceptance Criterion 3.1.5. A If structures considered as defensive positions are established at the protected area perimeter, they must ae bullet-resisting.

All entrance points to these structures must be locked wher occupied.

Discussion This criterion refers to structures not at protected area portals.

Any structure at the perimeter must be constructed so as to provide the same degree of protection as the remainder of the perimeter barrier.

Bullet-resisting is defined in 10 CFR 73.2 (q).

The structure must resist an Underwriter's Laboratories Level IV round as defined in UL-752.

This is a soft-point round (not armor piercing).

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maximum nuzzle velocity to be considered is 2410 f t/sec.

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Acceptance Criterion 3.1.5.B The protected area perimeter barrier must be patrolled at the same frequency as the protected area.

(See Acceptance Criterion 4.4.B.)

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Discussion The purpose of this patrol is to detect any readily apparent disruptions of barrier integrity and any other unusual occurrences.

3.2 PROTECTED AREA PORTALS 3.2.1 Personnel Access Portals and Posts 3.2.1.1 Layout Acceptance Criterion 3.2.1.1. A

?.ccess must be through a locked door which is controlled by an individual protected by a structure which is bullet-resistant.

Discussion This criterion is derived from 10 CFR 73.55 (d)(1).

The require-ments for bullet resistance are established in Acceptance Criterion 3.1.5. A.

3.2.1.2 Physical Structures There are no criteria other then those noted in Acceptance Criteria 3.2.1.1.A and 3.1.2.A.

3.2.1.3 Locks, Keys, Combinations and Related Equipment All locks, keys, combinations and related equipment must comply with Acceptance Criterion 3.1.2.C.

3.2.1.4 Security Posts U*

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Acceptance Criterion 3.2.1.4.A Each portal must be manned by at least two members of the physical security force when open for personnel access.

Discussion All posts will require one person to conduct searches and a second person, in a hardened room (Acceptance Criterion 3.2.1.1. A),

to control access.

It is desirable, but not necessary, that a guard be within the hardened room.

Acceptance Criterion 3.2.1.4.B Unauthorized entries must be detected and communicated to the central and secondary alarm stations with a level of assurance consistent with Acceptance Criterion 3.1.4. A.

Discussion Acceptance Criterion 3.1.4. A established the required level of intrusion detection performance using Regulatory Guide 5.44 as a reference.

The same level of intrusion detection must be provided at personnel portals.

Forceful entry at a protected area personnel portal must be detected with high assurance to severely limit the possibility of undetected access to the vital area perimeter.

This detection may require the use of duress alarms.

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3.2.1.5 Search and Admittance Control Hardware Acceptance Criterion 3.2.1.5. A, All search and admittance control hardware must annunciate warnings at the portal.

Discussion All hardware used to detect unauthorized material or personnel seeking unauthorized admittance must annunciate so that members of the security force at the portal are warned.

No warning at the centr.il or secondary alarm station is required.

Notification of both security force members will reduce the possibility of insider assistance.

Acceptance Criterion 3.2.1.5.B All packages must be searched prior to protected area entry to detect firearms, explosives and incendiary devices or other items which could be used for industrial sabotage.

Discussion This search may be conducted using detectors, if these systems can be shown to operate with high assurance.

Where high assurance Cannot be shown, a physical search must be used including disassembly if necessary.

Cogs inay be used to search vehicles and packages for explosives if they are trained to Federal Aviation Administration Sta ndards.

This criterion is derived from 10 CFR 73.55 (d)(3).

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Acceptance Cri terion 3.2.1.5.C A search of all personnel entering protected area must be conducted to detect firearms, explosives, and incendiary devices.

Discussion All personnel must be searched prior to entry into the protected area.

This search may be conducted -ing detectors, if these systems can be shown to operate with high assurance. Where high assurance cannot be shown, a physical search must be employed.

This criterion is derived from 10 CFR 73.55 (d)(1).

.g44 2 19 -

s 25

Acceptance Criterion 3.2.1.5.D Verify the access authorization of personnel entering at protected area portals.

Discussion In order to assure that unauthorized personnel are not granted protected area access, an ef fective system for verifying the iaentity and authorization of each individual must be established at all protected area perimeter personnel portals.

This criterion is derived from 10 CFR 73.55 (d)(1).

3.2.1.6 Picture Badge System Acceptance Criterion 3.2.1.6. A A numbered picture badge identification system shall be used for all individuals who are authorized access to the protected areas without escort.

These badges should show the access authorization level of an individual while in a protected or vital area.

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 and which indicates (i) non-employee no escort required; (ii) areas to which access is authorized and (iii) the period for which access is authorized.

Individuals not authorized by the licensee to enter protected areas without escort shall be badged to indicate that 26 cf 4 l-, 2 l.

an escort is required ar.d the access authorizatian level.

Badges shall be displayed while inside the protected area perimeter Discussion As a means of personnel control within the protected and vital areas, a system for allowing physical classification of personnel as to their level of access (protected or vital) must be maintained.

This permits back-up control of access by all authorized personnel.

It is recognized that certain circumstances (e.g., radiation consider-ations) preclude wearinr badges. This criterion is derived from 10 CFR 73.55 (d)(5), (6).

3.2.1.7 Communica tions

__ Acceptance Criterion 3.2.1.7. A Each portal must have the capability of continuous communication with the central and secondary alarm station.

Discussion This requirement will usually be satisfied by satisfaction of Acceptance Criterion 1.4.5.C which calls for all on-duty physical security force personnel to have continuous communication capability with the primary and secondary alarm stations.

It is recommended that wire communications (e.g., telephone, intercom) be provided as a backup.

Okk C

27 s

3.2.2 Vehicle and Cargo Access Portals and Posts Acceptance Criterion 3.2.2. A e

All vehicles, except under emergency conditions, shall be searched fMr items which could be used for sabotage purposes prior to entt into the protected area.

Vehicle areas to be searched shall include the cab, engine compartment, undercarriage and cargo area.

Discussion This criterion is derived fron 10 CFR 73.55 (d)(4).

The requirement for the search of all packages and material transported by vehicles is established by Acceptance Criterion 3.2.1.5.B.

All vehicles, whether or not they are licensee-designated, must be searched.

3.2.2.1 Layout Acceptance Criterion 3.2.2.1. A Access to the protected area must be controlled by an indivi 'ual protected by a structure which is bullet-resisting.

Discussion The level of bullet-resistance required is established in Acceptance Criterion 3.1.5. A.

3.2.2.2 Physical Structures All structures which are part of the protected area perimeter barrier must satisfy Acceptance Criterion 3.1.2. A.

bkk 28

3.2.2.3 Locks, Keys, Combinations, and Related Equipment All locks, etc., must comply with Acceptance Criterion 3.1.2.C.

3.2.2.4 Security Posts geptance Criterion 3.2.2.4. A A

All portals must be manned by at least two members of the physical security force when open for vehicle access.

Dj_scussion All posts will require one person to conduct searches, a second person, ir, a bullet-resisting room (Acceptance Criterion 3.2.2.1. A),

to control access.

It is desirable, but not necessary, that a guard be with'. the hardened room.

Acceptance Criterion 3.2.2.4.B The number of visitor personnel accompanying a non-licensee-designated vehicle into the protected area should be minimized.

Disc,tsion The minimum number of personnel required to operate and off-load the vehicle should be pernj.tted protected area access. All those admitted must satisfy the standard criteria established for admittance of visitor (escorted acce'ss) personnel.

' 05\\

$. b f

29

3.2.2.5 Vehicle and Cargo Search Hardware There are no specific acceptante criteria.

3.2.2.6 Coninun cations Accep_tance Criterion 3.2.2.6. A Each portal must have the capability of continuous conununication with the central and secondary alarm stations.

Discussion The discussion of Acceptance Criterion 3.2.1.7. A is applicable and no further discussion is required.

80r1 30

CHAPTER 4 - PROTECTED AREAS 4.1 LAYOUT Acceptance Cri terion 4.1. A Exclude storage areas from proximity of vital areas.

Discussion When material must be transported within the protected area, placing storage areas away from vital area boundaries will reduce the dangers associated with vehicle presence. A further gain will be realized from this procedure through the maintenance of a full field a view of vital area boundaries by elimination of possible obstructions due to the presence of material.

Acceptance Criterion 4.2.B The physical barrier at the perimeter of the protected area should be separated from any other barrier designated as a physical barrier for a vital area within the protected area.

p.iscussion This criterion is contained in 10 CFR 73.55 (c)(2).

Sufficient separation (at least 2') feet) must be maintained to prevent bridging from barrier to barrier, thereby avoiding interaction with the perimeter barrier detection systems.

Lesser distances will be satisfactory if suitable compensatory measures are provided.

4.2 PHYSICAL STRUCTURES e

There are no specific acceptance criteria.

8 4 225 31

4.3 ILLUMINATION AND SURVEILLANCE Acceptance Criterion 4.3.A Illumination must be maintained throughout the protected area including the top and sides of all structures.

The minimum level of illumination, as stated in 10 CFR 73.55 (c)(5), n.2 footcandle measured horizontally at grouna level.

Discussion This criterion calls for an extension of the level of illumination required by Acceptance Criterion 3.1.3.A throughout the protrcted area.

Loss of illumination is permitted for a maximum of one minute before restoration of illumination.

Initiation of emergency procedures to provide equivalent protection should be started immediately.

Illumination measurements for the tops of bt.ildings should be taken there.

Acceptance Criterion 4.3.B If surveillance hardware systems are provided in the protected area, capability must be provided for transmission of equivalent surveillance data to central and secondary alarm stations.

Discussion The discussion of Acceptance Criterion 3.1.3.D applies.

No additional discussion is required.

844 226 32

4.4 SECURITY POSTS (FIXED AND MOBILE)

Acceptance Criterion 4.4. A All physical structures in the protected area credited as defensive positions for response forces must provide:

1)

Bullet-resistance 2)

Full field of view and fire in assigned response area.

3) Audible and visible indication of intrusion alarms in assigned response area.

Discussion Defensive positions may significantly increase the effectiveness of the response force.

It is recommended that these positions be equipped with wire communications to provide a backup to the portable comiilunication system carried by the armed response force.

s Acceptance Criterion 4.4.B s All exterior parts of the protected area must be patrolled at random intervals for the purpose of human, on-the-scene visual observa tion..Each part of the protected area must be observed at least once every two hours.

Patrolling personnel must be capable of continuous conriunication with the central ar.d secondary alarm stations.

Procedures must be established for frequent status reporting to the central alarm station.

M

'l 844 227' 33

Discussion Duress alarms may be used to verify the safety of patrolling personnel.

This patrol may be used to satisfy the required observation of vital area boundaries discussed in Acceptance Criterion 5.2.2.A.

4.5 ESCORTS Acceptance Criterion 4.5. A Within the protected area the following escort requirements exist:

1) All vehicles not licensee-designated must be escorted by a menber of the physical security force (guard, watchman, armed individuals).
2) All visiting personnel must be escorted by an individual who is authorized for nonescorted access to the protected area and designated for escort duty.

Discussion It is recommended that a guard or armed individual be used to escort vehicles since they might be used to conceal weapons or sabotage material.

It is assumed that all weapons and unauthorized material carried by visitors on their persons have been prevented from penetration at the protected area perimeter.

844 228 34

CHAPTER S - VITAL AREA BOUNDARIES Acceptance Criterion 5.A Each item on the list of vital equipment shall satisfy the criteria for being designated vital established by 10 CFR 73.2 (i).

Discussion None required.

Acceptance Criterion 5.B The licensee shall locate vital equipment only within a vital area which, in turn, shall be located within a protected area such that access to vital equipment requires passage through at least two physical barriers. More than one vital area may be located within a single protected area.

Discussion This criterion is a restatement of 10 CFR 73.55 (c)(1).

It establishes the relationship of vital to protected areas and the minimum essential barrier requirements for vital areas.

Acceptance Criterion 5.C The licensee shall positively control all points of personnel and vehicle access into the vital areas.

Access to vital areas shall be limited to individuals who are authorized access to vital equipment and who require such access to perform their duties.

Access to vital areas for the purpose of general familiarization and other non-work-related activities shall not be authorized except for good cause shown to the licensee.

35 844 i;2.9

4 Discussion This criterion is derived from 10 CFR 73.55 (d)(4).

It provides the fundamental guidance for controlling access to vital areas.

There are two elements of positive access control:

1) Assurance of an authorized need for vital area entry 2)

Identification that the person actually entering is the individual that has the authorized need for entry.

5.1 LAYOUT There are no specific acceptance criteria.

5.2 PHYSICAL BARRIERS 5.2.1 Barrier Descriptions Acceptance Criterion 5.2.1. A All vital area barriers should be resistant to penetration by explosives and breaching tools.

The amount of resistance to penetration must be consistent with the time required for armed force response. The penetration resistance of the barriers must not be diminished by doors, windows, and other openings in the barrier.

Discussion This criterion applies to all elements, both portal and nonportal, of the vital area barriers located at the vital area boundary.

\\

b4k 2

's Acceptance Criterion 5.2.1.B e

is., ij All emergency exits in vital area barriers should be locked and alarm 36

Discussion g

This criterion is derived from 10 CFR 75.5 e)(3).

Locks on y

emergency exits should in no way impede egress m the vital area.

Acceptance Criterion 5.2.1.C Locks, keys, combinations, and other related equipment should sa tisfy Acceptance Cri terion 3.1.2.C.

Discussion

' 9cks, keys, combination, and other related equipment used at the vital area boundary should satisfy the criteria for quality and control specified for such equipment used at the protected area perimeter.

5.2.2 Intrusion Detection Hardware Acceptance Criterion 5.2.2. A High assurance detection must be provided for all vital area entries.

Ac tiv alarm systens must be used to protect portals to unoccupied vital areas. Ala m systems must satisfy the requirements of the " Interim Federal Specification:

Alarm Systems, Interior, Security, Compcnents for", W-A-00450-B (GSA-FSS).

Discussion The physical security system must detect all penetrations of the vital area perimeter whether or not those entries are made at vital area portals.

This criterion applies to forceful entries as well 37 844 231

as those that are undertaken by stealth.or deceit.

This criterion is based upon the conviction that undetected vital area penetration will provide an unacceptable tactical advantage to the adversary.

Satisfaction of the criterion may be achieved by inspecting vital area boundary barriers at a frequency consistent with the minimum time 'or threat penetration using tools authorized for the protected a rea.

This inspection may be conducted by the individual patrolling the exterior locations in the protected area.

Detector and line supervisory units should satisfy specifications included in the Interim Federal Specification W-A-00450-B (GSA-FSS).

W. f',-00450-B has specifications for three other types of detector units and one type of line supervisory unit which the NRC does not recommend for use by the licensee because of the ease by which they can be bypassed.

These are Type II, " Conductive foil," Type VII,

" Vibration detector," Type XI, " Pressure mat detector," and the Class AB, " Digital and Tone-Wire Transmitted" line supervisory unit.

The requirement for active alarms is derived from 10 CFR 73.55 (d)(4).

Acceptance Criterion 5.2.2.B All alarm systems must be provided with standby electrical power.

Discussion The loss of external power can reasonably be assumed at the start of a violent assault.

The transfer of standby power must comply with Interim Federal Specification W-A-00450-B (GSA-FSS).

38

Acceptance Criterion 5.2.2.C All intrusion alarm systems must satisfy the criteria for the frequency of false and nuisance alarms stated in Regulatory Guide 5.44 and Interim Federal Specification W-A-00450-B (GSA-FSS).

Discussion The discussion of Acceptance Criterion 3.1.4.C applies, and no further discussion is required.

Acceptance Criterion 5.2.2.D All intrusion detection systems must be tamper-indicating and self-checking, e.g., an automatic indication is provided when failure of the alarm system or a component occurs, or when the system is on standby power.

Discussion This criterion is established by 10 CFR 73.55 (e)(2).

The requirements for tamper-indication and self-checking are established by Regula tory Guide 5.44 and W-A-00450-B.

Acceptance Criterion 5.2.2.E All detection system hardware must annunciate at the central and secondary alarm stations.

Discussio_n

}3 This criterion is derived from 10 CFR 73.50 (e)(1). 39

Acceptance Criterion 5.2.2.F In the event of detection hardware outage compensatory procedures must be developed to assure an equivalent level of protedion. Discussion Compensatory measures may be taken at any point in toe physical security system. 5.3 VITAL AREA PORTALS 5.3.1 Personnel Access Portals and Posts 5.3.1.1 Layout Acceptance Criterion 5.3.1.1.A Access to vital areas must be through a locked door. If an individual is controlling access, whether or not he is located at the portal or remote from it. he must be protected by a structure which is continuously locked, is bullet-resistant and permits detection and communication of forceful entry with high assurance. Discussion Ali access to vital areas must be governed by positive access control. There must be high assurance that warnings of attempts to enter vital areas by attacking manned security posts will be communicated to the central and secondary alarm stations. This detection may take the form of duress alarms. 844 234 40 k,

5.3.1.2 Physical Structures There are no specific acceptance criteria. 5.3.1.3 Locks, Keys, Combinations and Related Equipment All locks, keys, combinations and other related equipment must comply with Acceptance Criterion 3.1.2.C. 5.3.1.4 Security Posts There are no criteria additional to Acceptance Cr iterion 5.3.1.1. A. 5.3.1.5 Acces Control Hardware Acceptance Criterion 5.3.1.5. A All access control hardware must annunciate warnings of unauf norizec entry attempts at the central and secondary alarm stations. Discussion All access control hardware, such as key card systems, must pro-vide redundant warning of unauthorized entry attempts. 5.3.1.6 Coded Badge System Acceptance Criterion 5.3.1.6.A Specially coded numbered badges shall be issued indicating vital areas to which access is authorized. Discussion This criterion is derived from 10 CFR 73.55 (d)(4). This badge may be the same as the picture badge discussed in Acceptance Criterion 3.2.1.6.A. ,44 235 8 41

5.3.1.7 Communica tions Acceptance Criterion 5.3.1.7.A Each post at a vital area boundary portal must have continuous communication capability with the central and secondary alarm stations. Discussion This requirement will be met by satisfying the requirements of Acceptance Criterion 1.4.5.C. 5.3.2 Vehicle Access Portals and Posts 5.3.2.1 Physical Structu cs_ There are no requirements additional to those of Acceptance Criterion 5.2.1.A. 5.3.2.2 Security Posts Acceptance Criterion 5.3.2.2. A A portal must be manned by at least one armed member of the physical security force when open for vehicle access. Discussion Because of possible insider complicity, the armed member of the physical security fource escorting the vehicle does not count in the required manning of vehicle portals. The armed escort must remain with the vehicle while in the vital area. 8kk 42

5.3.2.3 Coninunica tions Acceptance Criterion 5.3.2.3.A Each fixed security post at a vehicle access portal must be capable of continuous communicatirn with the central and secondary alarm stations. Discussion This requirement will be met by satisfying the requirenents of Acceptance Cri terion 1.4.5.C. D 84Il 237 43 e

CHAFTJK 6 - VITAL AREAS 6.1 CEf1 TRAL ALARM STATI0fl Acceptance Criterion 6.1. A. The onsite central alarm station shall be considered a vital area. Discussion This criterion, taken from 10 CFR 73.55 (e)(1), establishes the central alarm station as a vital area. 6.1.1. Location and Layout Acceptance Criterion 6.1.1._A_ The onsite central alarm station shall be located within a building such that the interior of the central alann station is not visible from the perimeter of the protected area. This station shall not contain any operational activities that would interfere with the execution of the alarm response function. Discussior This criterion, taken from 10 CFR 73.55 (e)(1), establishes the basic location and layout requirements for the central alarm s ta tion. The interior must not be visible from the vantage point of an individual standing on the ground (topography should be considered) outside the protected area perimeter. 344 258 44

6.1.2 Physical Structures Acceptance Criterion 6.1.2. A The walls, doors, ceiling, floor, and any windows in the walls and doors of the onsite central alarm station shall be bullet-resisting. Discussion The term " bullet-resisting" is to be interpreted as defined in Acceptance Criterion 3.1.5. A. Any hardware associated with doors and windows must also > e bullet-resisting. Acceptance Criterion 6.1.2.B All portals (windows, doors) which would permit personnel entry (aperture area exceeding 96 sq. in. or one dimension exceeding 6 inches) must be kept locked at all times. Discussion Lock, keys, combinations, and other related equipment used must satisfy Acceptance Criterion 3.1.2.C. They shout'd be designed so as to impede only entry to the central alarm station. 6.1.3 Alarm and Surveillance Monitoring Hardware Acceptance Criterion 6.1.3.A All alarms should annunciate within one second in a continuously manned central alarm station located within the protected area. Alarm hardware should satisfy the requirements of W-A-00450-B. 45

Discussion This criterion is derived from 10 CFR 73.55 (c)(1) and defines the basic function of the central alarm station. Use of the processing capability of a computer to support nonsecurity functions should not interfere with the ability to support security functions. Acceptance Criterion 6.1.3.B The annunciation at the onsite central alarm station shall indicate the type of alarm (e.g., intrusion alarm, emergency exit alarm, etc.) and location. The central alarm station operator must not be able to change any alarm point status (SECURE, ACCESS, or INOPERATIVE) or actuate any locking or controlling device at a protected area or vital area portal without first getting an enabling action from the secondary alarm station ope ator. Discussion This criterion is derived from 10 CFR 73.55 (e)(2). The degree of alarm localization must be integrated with the planned capability to assess and respond to the alarm. Acceptance Criterion 6.1.3.C The central alarm station must be capable of performing all required operations on emergency power. 844 240 46

Discussion The loss of all external power at the start of a violent assault is a reasonable assumption. This criterion cells for full operational capability to exist within the central alarm station from the time primary power is lost with no interruption. This emergency power should be provided from onsite sources. Acceptance Cri terion 6.1.3.D All annunciator and other alarm or surveillance system hardware, including transmission lines, snall be tamper-indicating and self-checking. Discussion The criterion is based on standards established for all detection aids in 10 CFR 73.b5 (c)(1). Computerized systems should have measures to protect access to computer programs. 6.1.4 Manning Acceptance Criterion 6.1.4.A The central alarm station must be continuously manned by at least one member of the physical security force who is totally dedicated to the duties of security monitoring. Discussion The importance of the central alarm station in the physical security system prohibits distractions that will result if other gh 2k\\ 47

duties are required. The requirement fo,.mnning by a security force member, who is not necessarily armed, is based upon the need for monitoring by an individual who is thoroughly familiar with the operation of the physical security system. 6.1.5 Communications Acceptance Criterion 6.1.5. A The central alarm station must provide wire (e.g., telephone) and wireless (e.g., radio, microwave) systems which provide fully independent and redundant communication with local law enforcement and the plant control room (s) (if independent of the central alarm s ta tion ). Capability must also bt provided to remain in continuous contact with members of the physical security force while on patrol. Discussion This criterion is derived from 10 CFR 73.55 (f)(1), (2), (3). All intermediaries in a communication link must have standby power available. If a communication link is wireless, the entire link must be wireless. 6.2 SECONDARY ALARM STATION Acceptance Criterion 6.2.A All alarms shall annunciate in a continuously manned central alarm station located within the protected area and iti at least one [j k $, 2k2 48

other continuously manned station, not necessarily onsite, such that a single act cannot remove the capability of calling for assistance or othemise responding to an alarm. Discussion The above statement, derived from 10 CFR 73.55 (e)(1), establishes the requirement for a secondary alarm station. When located onsite this station is to be protected as a vital area. The station must be manned by a not necessarily armed member of the physical security force. Bullet-resistance is not mandatory. Acceptance Criterion 6.2.B The secondary alarm station operator must not be able to change any alarr. point station (SECURE, ACCESS, or INOPERATIVE) or actuate any locking or controlling device at a protected area or vital area portal without first getting an enabling action from the central alarm station opera tor. Discussion None required. Acceptance Criterion 6.2.C Whether or not the secondary alarm station is located onsite, it must satisfy the following requirements:

1) Contains no operational requirements which would interfere with the execution of the alarm response function.

49 844 243

2) Has each personnel entry portal locked at all times.

3) Has annunciators, and other alarm or surveillance hardware which are all tamper-indicating and self-checking.

4) Is capable of fully independent and redundant communications with local law enforcement and the plant control room (if independent of secondary alarm station) and is capable of continuous communication with the physical security force. 6.3 OTHER VITAL AREAS Acceptance Criterion 6.3.A (Alternate 1) All access to the very limited number of vital locations, such as containment, wherein acts conducted entirely within this location could result in industrial sabotage must include at least two personnel authorized for unescorted access to vital areas. Discussion A limited number of what might be termed " type 1" vital locations exist in a plant. This vital location is an entire vital area or some section of a vital area which can be reached only by passage through a barrier Extremely sensitive equipment is located in this location, such that an individual would have the ability to commit industrial sabotage actions using authorized equipment. In these few vital locations of the plant actions must be closely monitored. The nominal method of @ k k 2 k k. 50

monitoring will be the "two-man" rule. In those cases where it can be shown that remote television monitoring coupled with rapid response to unauthorized activities can produce an equivalent level of protection, the "two-man" rule is not required. Acceptance Criterion 6.3.A (Alternate 2) Compartments are used to eliminate all possibility of access to vital locations (as defined in Alternate 1). Discussion A possible alternative to the use of the "two-man" rule is the elimination of the possibility of a single authorization providing access to a plant location wherein action taken entirely in that location could result in industrial sabotage. This could be accomplished by placing vital equipment in compartments (using, for example, wire mesh cages). Positive access control would be applied to each compartment. Acceptance Criterion 6.3.B Develop and document procedures for controlling access while in vital areas to tools and materials which could be used to assist in acts of industrial sabotage. Discussion There are a large number of tools and materials used routinely in vital areas which could be used in their normal form or in modified Eik k 51

form tv assist in performing acts of industrial sabotage. While recognizing that the total control of all such tools and material is not consistent with the efficient operation of the plar.t, it is clear that the control or materials such as large machinery and potentially explosive chemicals are mandatory in an effective physical security program. This criterion requires that each licensee develop a r ogram fer controlling potentially destructive material in vital areas. The program will provide material control without significantly degrading efficient plant operation. The program should emphasize good housekeeping procedures and the utilization of limited access storage facilities. 6.3.1 Surveillance Hardware Acceptance Criterion 6.3.1.A If used, all surveillance system hardware must be self-checking and tamper-iniicating. Discussion None required. Acceptance Criterion 6.3.1.B If used, surveillance hardware must provide equivalent information to the central and secondary alarn stations. 8kk 2kb 52

Discussion The discussion of Acceptance Criterion 3.1.3.D is applicable. 6.3.2 Security Posts (Fixed and Mobile) Acceptance Criterion 6.3.2.A Consistent with operating constraints, all vital areas should be patrolled by a member of the plant staff such that they are visually inspected at least once each shift. Discussion Patrols provide a necessary part of any system of vital area noni toring. This requirement does not apply to areas within containment or other areas where inspection would cause exposure to unacceptable levels of radiation. It also does not apply to areas where inspection would significantly interfere with efficient operation of the plant. It is expected that this criterion can be satisfied by the normal rounds of plant operators. Convenient conmunication capability to the central and security alarm station (e.g., telephone, intercom) should be provided. Acceptance Criterion 6.3.2.B If used, all security posts in the vital area should provide continuous connunication capability with the central and secondary alarm stations. ~ g44 247 53

Discussion This criterion will be met by satisfying Acceptance Criterion 1.4.5.C which requires continuous communication capability to the central and secondary alarm stations for all members of the physical security force. 6.3.3 Escorts Acceptance Criterion 6.3.3.A Provide escort for visitor personnel in vital area. Discussion All visitor personnel (not authorized for unescorted access) must be escorted by an individual auti. rized for unescorted access to the protected area and designated for escort duty. The maximum permissible ratio of unauthorized personnel to escort personnel is five to one. Acceptance Criterion 6.3.3.B Provide armed escort for vehicles in vital areas. Discussion Vehicle access to vital areas is expected to be limited. When access is required, the threat associated with the presence of vehicles should be limited by the continuous presence of armed security force personnel. 844 248~ 54

CHAPTER 7 - CENTRAL COMMUNICATIONS SYSTEMS 7.1 TELEPHONE SYSTEM Acceptance Criterion 7.1.A Protect with locks and alarms any locations within the plant at which the ability to telephone internally and/or externally could be significantly disrupted. Discussion There may be several locations within the plant such as the main switchboard or communication closets or cabinets,where a saboteur could easily disrupt all or a large portion of the plant's telephone communication capability. These areas should be locked at all times, constructed to prevent personnel entry other than through a door and alarmed when not occupied. 7.2 INTERCOM AND PUBLIC ADDRESS SYSTEM Acceptance Criterion 7.2.A Protect with locks and alarms any locations within the plant at which the ability to use the intercom or public address systems could be largely or totally disrupted. Discussion This criterion applies only in those cases where intercoms and/or public address systems are used in the plant and taken credit for in the physical security plan for the plant. In those cases where 55 hk2

it does apply, protection similar to that provided for the telephone system (Acceptance Criterion 7.1.A) should be provided. Acceptance Criterion 7.2.B All intercom and public address systems should be provided with an onsite source of emergency power. Discussion As was the case with the previous criterion, this applies only to those systems which are credited as being part of the ohysical security system. 7.3 OTHER CENTRAL COMMUNICATION SYSTEMS The requirements stated in Acceptance Criteria 7.2. A and 7.2.B apply to all other central communication systems which are taken credit for in the physical security plan. 844 250 56

CHAPTER 8 - RESPONSE TO SECURITY CONTINGENCIES 8.1 RESPONSE FORCE AVAILABILITY Acceptance Criterion 8.1.A The operational duties of armed res?onse individuals r:ust not interfere with their ability to perform. rasoonse tasks. Discussion The physical security response force may be composed of guards and armed response individuals. Armed response individuals may be assigned operational as well 3: physical security responsibilities. A clear discussion of all. operatic 9al duties of armed response individuals and the location of these duties is required. These operational duties must be correlated with all physical security duties and the freedom of all armed respcase individuals to immediately perform all physical security duties at all times must be demonstrated. 8.2 ASSIGNMENT OF RESPONSIBILITIES Acceptance Criterion 8.3. A Demonstrate that cecurity pracedures exist which will be used in responding to each of the cont hgencies stated in Section 8.2 of the Interim Format and Conteni Document and in the discussion bei:w. The discussion of the procedures must explain when and Nw the ( ) security organization will taxe action to exc. cute thesd procedures in i g. response to the following contir.gencies: MA 25F

1) Guard Strike or Other Unavailability of the Security Force 2)

Disruptions of Internal Order Fires or Explosions Site Evacuation Personnel Disturbance

3) Stated or Perceived Threats to Sabotage
4) Civil Disturbance 5)

Suspected or Confirmed Intrusions or Sabotage Attempts Alarmed Annunciations Discovery of Breached Barriers

6) Discovery of Unidentified Persons in Protected or Vital Areas 7)

Discovery of Suspected Sabotage or Sabotage Devices 8} Multiple Loss of Onsite and Offsite Communications gscussi The criterion is largely derived from 10 CFR 73.55 (h)(2). It calls for the development of a plan which will effect efficiently the decisions and actions. The discussion must contain:

1) a predetermined set of decisions and actions to satisfy the stated tojective.
2) an identification of the data, criteria, procedures, and mechanisms necessary to accomplish the following:

(i) determine whether or not a threat exists (ii) assess the extent of a threat, if any opi ne din d) 58 ~~ ? 4

(iii) inform local law enforcement agencies and request assistance if necessary (iv) interpose members of the armed response force between vital areas and any adversary attempting entry for purposes of industrial sabotage, and (v) prevent or delay an act of industrial sabotage by applying a sufficient degree of force to counter that degree of force directed at them, including the use of deadly force when there is a reasonable t,elief that it is necessary in self-defense or in the defense of o thers.

3) A specification of the individual, group, or organizational entity responsible for each decision and action.

This discussion is not intended to include any actions under any Emergency Plars (Appendix E of 10 CFR 50) that deal with the hazards to public health and safety that are the consequences of the release of radioactive material, even though these releases mioht result from acts of sabotage. The Nuclear Regulatory Commission is considerit.g amendments to regulations governing nuclear reactors which wnuld call for the development of a formal contingency plan. The work done in responding to this criterion will be largely applicable to satisfying the neeu -) c f for a formal contingency plan. Okk LJJ 59

CHAPTER 9 - SPECIAL SECURITY MEASURES DURItiG REFUELIt1G/ MAJOR W4It4TEt4EllACE OPERATI0tlS Acceptance Criterion 9. A There will be no increase in the likelihood of successful industrial sabotage during refueling operations. Discussion Refueling and the maintenance and repair operations that normally accompany the refueling process may substantially increase the vulnerability of plants to sabotage. The licensee must demonstrate that he has developed procedures to maintain high assurance protection against industrial sabotage during refueling operations. Such procedures might include the following steps: 1) Keeping to a minimum the number of personnel permitted within containment and tid spent fuel pool building, if outside of containment. 2) Employing a system of work authorizations which permit only authorized work to be performed.

3) Using the system of work authorizations to assist in minimizing the number of " visitor" personnel allowed in vital areas at any one time by permitting convenient task sequencing.

All positive access control and escort procedures must be maintained in all vital areas during refueling operations. 60

Acceptance Criterion 9.B Implement procedures for inspecting all vital areas and equipment which may have been visited subsequent to the completion of refueling / major maintenance operations. Discussion The large number of personnel present and the large number of tasks being performed make difficult monitoring of all activities. In order to compensate for this problem, careful inspection and testing of all vital areas and equipment is required prior to return to normal procedures. Inspection is only required in those cases where access has been granted to the vital area during the refueling / major maintenance operations. 844 255 61

CHAPTER 10 - SPECIAL SECURITY MEASURES DURING CONSTRUCTION OPERATIONS Acceptance Criterion 10. A The level of physical protection afforded a plant site must not be diminished by construction operations at any adjacent site. Discussion The piesence of heavy equipment, tools, and possibly large numbers of persennel some of whom may be routinely performing tasks in the isolation zone creates an increased threat of industrial sabotage. Procedures for the application of hardware and personnel to provide a level of protection equivalent to that which would exist if construction were not present must be provided. .844 256 62

CHAPTER 11 - OVERALL PHYSICAL SECURITY PROGRAM PERFORMANCE Acceptance Criterion 11. A Demonstrate that the physical security system satisfies the general performance requirenent, that is, it provides high assurance protection against industrial sabotage. Discussion In addition to demonstrating compliance with the detailed requirements of paragraphs (b) through (h) of the rule; it is necessary to show that the integrated phvsical protection system in conjunction with the security organization will provide protection with high assurance against industrial sabotage. The general performance requirement stated in paragraph (a) of the rule has been provided as an aid in assessing the level of protection considered to be adequate and prudent at this time. The integrated physical protection systems and the security organization must be designed, however, to deal effectively and discriminately with an entire range of possible security contingencies. These could range from the normal situation of no '.ttempt to intrude, to the unknowing and accidental intrusion of a child or adult, to several activists moderately prepared and notivated to intrude in order ta vandalize or disrupt operation, to the threat level of 573.55 (a)(1). 844 257' 63

This criterion requires the demonstration that the previously described physical security elements, when integrated to constitute a system, provide high assurance protection against all threat scenarios. While it is not necessary to use the approach described in the following paragraphs in demonstrating high assurance protection, it is strongly recommended since it is conceptually straightforward and will simplify the process of assuring compliance with 10 CFR 73.55. The approach is based upon the supposition that there are four discrete opportunities to initially detect the threat: (1) beyond or at the protected area perimeter, (2) within the protected area, (3) at a vital area boundary and (4) within a vital area. Given this initial detection there is some likelihood that the threat will be subsequently neutralized. The state of the art in quantifying the performance of detection hardware and procedures has advanced to the point that it is possible in most cases to assign a reasonably precise quantitative value to an associated probability of successful detection. Therefore, the licensee is required to assign such a value and justify the choice. However, rigorous determination of the overall likelihood that the threat will be neutralized, given initial detection, is complex in that it is a function of the adversary tactics, e.g., targets, paths through the facility, etc., the delay afforded by plant barriers, the time of response by the security force and the .b 64

engagement between the adversary force and the security force. Some of the variables may be quantified, e.g., delay times afforded by specific barriers and time of response. Others, e.g., probabili ty of armed response force success in an engagement with an adversary involving the use of weapons, cannot be quantified with satisfactory precision using state-of-the-art computational techniques. Therefore, in general, it must be demonstrated that given initial de tec ti o n, the onsite response force must be able to intercept and engage an adversary force in less time than is available for the adversary force to successfully penetrate any single or multiple vital area barriers such that disablemer.t of equipment within those areas would lead to a significant release of radioactivity. This demons t ra tion must consider minimum distances (in time) which the adversary must travel, times of delay in penetrating barriers, and times of response by security force personnel. Delay and response time determinations begin with detection of the attempted intrusion. These calculations would include, for example, the determination of 1) Barrier penetrations times 2) Time for the intruder to traverse the shortest available path from the perimeter barrier to th'e vital area barrier. 3) Times for receiving alarm.

4) Time for threat assessment and response force initiation.

5) Time for the security force response to the intrusion. 844 259 g

In evaluating overall " success" it may be assumed that the abili ty to engage the adversary force with a superior number of guards and arned response individuals will provide the requisite hig!. assurance of success against the postulated threat. It has been assumed that the original response force will be rapidly reinforced. This assumption should be verified by the licensee's physical security plan. A simple approach for this demonstration when dealing with the external threa t is recommended by the fiRC. First high assurance detection (t.95, see Acceptance Criterion 3.1.4. A) at the protected area perimeter must be shown. fieutralization of the threat is then accomplished if there is successful armed security force response whe"e the criterion for " success" is as establishee in the previous paragraph. The contributions due to detections at points other than the perimeter can then be ignored. This is clearly a conservative approach. Credit will be given for the presence of other defenses such as additional barriers within vital area, presence of armed responne individuals in vital areas, and the physical separation of vital components. High assurance protection against the internal threat can be demonstrated by affi'rming compliance with the Acceptance Crite i' which control insider access to protected and vital areas and activities in vital areas. 844 260 66

Acceptance Criterion 11.B All credit taken for adversary delay (including penetration prevention), ;ntrusion detection system performance, surveillance system performance, search and admittance control hardware performance, and access control hardware performance must be justified. Justification must also be provided for credit taken for the detection performance of humans or animals and the response time performance of the armed response force and supporting law enforcement. Discussion The physical security plan must justify by stating. aferences used or tests performed in determining the level of system ef fec tiveness. This justification should consider in detail all environmental effects (weather, atmospheric transmission, electrical transmission,etc.). Where the intrusion detection system consists of more than one subsystem, the method used in amputing the overall level of effectiveness must be explained. '.844 261 67

PART II 0F THE PHYSICAL SECURITY PLAN ACCEPTANCE CRITERIA CHAPTER 12 - TESTS, INSPECTIONS AND MAINTENANCE 12.1 PHYSICAL BARRIERS AND ACCESS POINTS Acceptance Criterion 12.1. A All physical barriers must be maintained in operable conditior. Discussion This criterion is derived from 10 CFR 73.56 (g)(1). The term " access points" refers to all apertures in physical barriers that normally serve as personnel and vehicle portals and the means (e.g., locks, gates) that are used to control access at these points. Required is a list of each type of barrier and the inspections that are used to assure integrity. Also required is a list of access control mechanisms, the tests that are used to assure credited performance, the frequency of test conduct, and the condition (s) that would indicate each item out of service. It is recommended tha t each system be inspected no less than once every seven days. 12.2 ALARMS AND ANNUNCIATORS Acceptance Criterion 12.2.A Each intrusion alarm shall be tested for performance at the beginning and end of any period that it is used for security. If the period of continuous use is longer than seven days, the intrusion alarm shall be tested at least once every seven days. 844 262 ~ 68

Discussion This criterion is quoted directly from 10 CFR 73.55 (g)(2). The term " alarm" is defined to include all sensors, transmission lines, and annunciators that comprise de alarm system. Required is a list of each type of alarm system, the functional test that is used to assure credited performance, test frequency, and the conditions that would indicate each item out of service. Also i 3 quired for each type of alarm system is the calibration test fr?quency and a commitment to adjust the test frequency in accordance with the demonstrated equipment performance. 12.3 SPECIAL PURPOSE DETECTORS Acceptance Criterion 12.3.A All special purpose detectors used as security related devices or equipment shall be maintained in operable condition. piscasion This criterion is derived from 10 CFR 73.55 (g)(1). Included in the category special purpose detectors are all systems used to detect the presence of unauthorized material. Required is a list of each type of special purpose detector, the procedures employed for calibration and control, the test (s) used to assure credited performance, the frequency of test conduct, 'and the conditions that would indicate each item out of service. Also required for each type of 844 263-69

special purpose detector is the calibration test frequency and a commitment to adjust the test frequency in accordance with demonstrated equipment performance. We intend to study and evaluate weapon detector inspection and test procedun s similar to those used by the Federal Aviation Administration. We are also studying procedures for explosives or incendiary detectors. 12.4 COMMUNICATIONS EQUIPMENT Acceptance Criterion 12.4./_ Communications equipment required for communications onsite shall be tested for performance not less frequently than once at the beginning of each security personnel work shif t. Communications equipment required for communications offsite shall be tesRd for performance not less than once each day. Discussion This criterion is quoted directly from 10 CFR 73.55 (g)(3). It requires that all security-related portable and permanent onsite communication systems, whether or not they are intended for routine or emergency use, must be tested roughly every eight hours.

Likewise, all security-related offsite communications equipment must be tested daily. The test program described must include a list of all communi-cation systems tested, the test that is used to assure credited 7

performance, the frequency of test conduct, and the condition (s) that would indicate each item out of service. 8kk 2b 70

12.5 SECURITY PERSONNEL EQUIPMENT Acceptance Criterion 12.5.A All security personnel equipment shall be maintained in opera tional condition. Discussion This criterion is derived from 10 CFR 73.55 (g)(1). Included as security personnel equipment are weapons, protective clothing, vehicles and ai a other items that may be used by guards, armed response personnel, and watchmen which does not involve communications. Initial tests should be performed on all items to assure that they are functionally satisfactory. Recurrert tests are required to be performed only on weapons. Weapons sFould be inspected daily and tested consistent with the time of requalification of guards and armec response personnel. In no case should the period between testing be more than twelve months. 711 other equipment should be inspected at least every twelve months. The test and inspection program described should include conditions that would indicate a weapon or other piece of equipment unsatisfactory. .844 265 71

CHAPTER 13 - SECURITY RECORDS Acceptance Criterion 13. A All security records should be retained for a period of at least one year with the following exceptions: 1) Initial qualification tests shall be maintained for the life of the equipment..

2) Maintenance records shall be maintained for a period of five years.
3) Security training records shall be maintained for the period of employment of the individual.
4) Records of access to locks, keys, combinations and other related equipment shall be maintained for period of employment of the individual.

Discussion A minimum of one year is required for NRC inspection purposes. The first exception is required by the need for the information for continued reference for inspection purposes. The second exception permits review of the terformance history of security reioted equipment. Training records are required to assure compliance with Acceptance Criteria 1.4.3. A and 1.4.4. A. Records of access c.re required to permit conpliance with 3.1.2.C. '4 72

13.1 SECURITY TOURS, INSPECTIONS, AND TESTS Acceptance Criterion 13.1.A Establish and maintain a system for documenting all routine security tours and inspections, and all tests, inspections performed on physical barriers, intrusion alarms, communications equipment and other security related equipment. discussion This criterion is derived from 10 CFR 73.70 (e). Records should provide a description of the purpose of each tour, 'est, or inspection and the result. Codes may be used. The physical security plan should briefly describe the data to be recorded, the position (s) of the individual (s) responsible for maintaining the log, and the mechanism to be used in assuring that all data is transmitted and recorded. 13.2 MAINTENANCE Acceptance Criterion 13.2.A Establish and maintain a system for documenting all maintenance actions performed on physical barriers, intrusion alarms, communication equipment and other security related equipment. Discussion This criterion is derived from 10 CFR 73.70 (e). State i*differences, if any, in the maintenance recordkeeping program from that described in sa+isfying Acceptance Criterion 13.1. A. d44 2b 73

13.3 ALARM ANNUNCIATIONS Acceptance Criterion 13.3. A Establish and maintain a system for recording each alarm, false alarm, alarm check, and tamper indicatic n that identifies the type of alarm, location, alarm circuit, date, and time. Discussion This criterion is derive _. from 10 CFh 73.70 (f). The physical security plan should briefly describe the data to be recorded, the position (s) of the individual (s) responsible for maintaining the log, and the mechanism to be used in assuring that all data is transmitted and recorded. 13.4 SECURITY RESPONSE Acceptance Criterion 13.4.A Establish and maintain a system that records details of the response by facility guards, watchmen, and if applicable, armed response individuals to each alarm, intrusion or other security incident. Discussion This criterion is derived from 10 CFR 73.70 (f). State differences, if any, in this recordkeeping program from that described in satisfying Acceptance Criterion 13.3. A. 844 268 ~ 74

13.5 AUTHORIZED INDIVIDUALS Acceptance Criterion 13.5. A Establish and maintain a record of all persons who have been authorized access to protected areas. Discussion This criterion is derived from 10 CFR 73.70 (a). The name, address, badge number, inception and expiration date of the autiiorization, dreas to which authorized access is granted and the name of the approval authority should be recorded. The physical security plan should indicate the position (s) of the individual (s) responsible for maintaining these records. 13.6 AC;ESS TO VITAL AREAS Acceptance Criterion 13.6. A Establish and maintain a record of all persons authorized access to vital equipment and the vital areas to which access is authorized. Discussion This criterion is derived from 10 CFR 73.70 (b). State differences, if any, in the recordkeeping program from that described in satisfying Acceptance Criterion 13.5.A. A I

'844 26j,c 75

Acceptance Criterion 13.7.A Establish and maintain a log indicating name, badge rumber, time of entry, reason for entry and time of exit of all individuals granted access to a vital area. Discussion This criterion is derived from 10 CFR 73.70 (d). The recording of entries and exits of vital areas and reasons for entry is necessary to achieve positive access control. The physical security plan should indicate the position (. ) of the individual (s) responsible for mainta ning these records. 13.7 NONEMPLOYEE ACCESS Acceptance Cri terion 13.7. A Establish and maintain a register of visitors, vendors, and other individuals not employed by the licensee who are granted access to the protected area. Each such individual shall be requit d to register his na,T, date, time, purpose of visit and employment affiliation, citiaeaship, and name of individual to be visited. Discussion This criterion is derived from 10 CFR 73.70 (c), 73.50 (c)(5), and 73.55 (d)(6). Pursuant to 73.63 (c)(5) an individual providad a pic '.ure badge because of frequent or.d extended protected or vital 76 b4

area access need not be escorted. The position (s) of the individual (s) responsible for maintaining the register should be included in the physical security plan. 844 27I 77

CHAPTER 14 - SECURITY AUDITS 14.1 PROGRAM AUDITS Acceptance Criterion 14.1. A Establish and maintain a program for periodically providing management review of the physical security program. This program should include an onsite audit and should focus on agreement between the physical security effectiveness being achieved by personnel, hardware, and procedures and the level established by the approved physical security plan. Discussion This review should be conducted by management personnel who are not ordinarily responsible for participation in or direct management of the physical security program. The onsite audit may be conducted by appropriate quality assurance personnel or consultants. Required is an identification of the position (s) of review personnel and an affirmation that written audit reports will be prepared. This affirmation might take the form of an audit report outline which identifies the procedures used to audit the system. The audit should take place no less frequently than annually. This physical security plan should identify the annual publication date. of this review plan. 844 272 78}}