ML19261B736
| ML19261B736 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/06/1979 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | Fred Miller OREGON, STATE OF |
| References | |
| NUDOCS 7903010459 | |
| Download: ML19261B736 (3) | |
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UNITED STATES f " ),7 NUCLEAR REGULATORY COMMISSION
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WASHING TON. D. C. 20555 V w /.g
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FEB 06 C Mr. Fred D. Miller Director, Department of Energy Labor and Industries Building, Room 111 Salem, Oregon 97310
Dear Mr. Miller:
I am responding to your letter of December 29, 1978 in which you discussed three subjects related to the physical security plan of "e Trojan Nuclear Power Plant.
In regard to the proposal of the Oregon Energy Facility Siting Council to adopt a rule related to acquisition of criminal records I offer the following info,rmation for your consideration. During its review of security slans submitted in implementation of 10 CFR 73.55 (specifically s73.55[d];7]), the NRC staff assessed the level of protection provided against unauthorized acts that is achieved through the reliability of the employees (Criteria 13.1 in NUREG-0416) plus the control of these people afforded by ac'ministrative means (Criteria 5.3.1.6) and physical barriers (Sections 5.2 and 5.3).
A copy of NUREG-0416 is enclosed as.
The degree of personnel reliability that is needed for unescorted access to Type II vital areas can be achieved with a screening program equivalent to that recommended in ANSI Standard N18.17-1973 "American National Standard -
Industrial Security for Nuclear Power Plants." Because of the increased sensitivity of Type I vital areas, additional levels of protection are required before unescorted access is pemitted.
The concept of " reliability" in all its aspects has been under review by the Commission and its staff for several years in an attempt to produce safeguard regulations that provide adequate protection against "the insider threat". The Commission is currently considering the degree to which an adequate evaluation of reliability can be acquired from back-ground investigations that are equivalent to those provided for national security clearances.
In a parallel action the staff has icentified all measures (both administrative and physical) that could lead to permitting unescorted access into Type I vital areas. These measures have been published in the staff's Review Guideline No. 23 that is enclosed as.
Until the Commission decides to make the proposed
" Clearance Rule" (10 CFR Part 11) effective, a licensee can implement Option #3 on Review Guideline No. 23 only by perfoming the equivalent of a National Agency Check (cf, Option 3[c]).
790301099
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FEB 0 61979 Mr. Fred D. Miller The elements that constitute a National Agency Check are enclosed in.
Two of the elements involve a search of the FBI's fingerprint and investigative files. Although the staff will consider any proposal that the licensee may offer as being equivalent to a NAC, part of the check should provide information on the criminal record of the applicant during the previous five year period.
It is obvious that access to the FBI files would provide this information. Our legal department has advised me that (under the provisions of 28CFR20.20(b),
20.20(c), 20.21(b)(2), 20.21(c)(3), and the explanatory notes in the lppendix to 28CFR20) a local agency with criminal history information should be able to release it for the purposes in question.
It is more diffi-cult to state whether 28CFR Part 20 Subpart C pennits access to FBI infor-mation in the National Crime Information Center, particularly the Computerized Cr....inal History File. We assume that you have concluded that your rule will permit such access. The staff would not object to the State of Oregon acting as intermediary for Portland General Electric Company to gain this access and we do net have any objection to the proposed rule if it can be implemented legally.
In regard to your second item related to security reporting require-ments, the staff has taken your suggestions undar consideration and will keep you informed of any action taken.
Your third item was a discussion of the compensatory measures to be taken at the Trojan Nuclear Plant upon loss of off-site electrical power.
The staff has approved the procedures proposed by the licensee in Section 4.3 and Table 8-14 of its security plan. While reaching this position the staff has been aware of the vulnerability of the emergency source of power and the time required to activate this emergency source.
The staff takes the position that compensatory measures may consist of or.e or more of the measures provided in the staff's Review Guideline No.10 that is enclosed as Attachment 4.
By considering the loss of power as an event that initiates immediate response, PGE has committed to. implement elements of several of these measures. One of the most acceptable compensatory measures for loss of off-site power would be to provide an emergency generator that is dedi-cated to this purpose; however, this measure is not mandated by the Commission's rules or guidance. The licensee's emergency source of elec-trical power has the capability of providing full illumination once it has been activated.
We have appreciated the opportunity to work with members of your staff in our review of the physical security of the Trojan Nuclear
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Mr. Fred D. Miller FEB 0 61979 Plant and to provide this information for your nJ1e making hearing.
Please let me know if we may be of further assistance.
Sincerely, f%
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rt A. Clark, Chief Reactor Safeguards Licensing Branch Division of Operating Reactors Office of Nuclear Reactor Regulation
Enclosures:
4,,as stated cc:
C. Goodwin, Jr., PGE F. Young, NRC/SP C. Trammell, NRC
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