ML19296D017
| ML19296D017 | |
| Person / Time | |
|---|---|
| Issue date: | 12/21/1979 |
| From: | NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML19296C882 | List:
|
| References | |
| REF-10CFR9.7 SECY-79-682, NUDOCS 8002290230 | |
| Download: ML19296D017 (8) | |
Text
9 Value/ Impact Assessment on Access Controls to Nuclear Power Plant Vital Areas I. The Proposed Action A.
Description It is proposed to amend 10 CFR Part 73 to more explicitly define the type of access controls required at entrances to nuclear power plant vital areas.
8.
Need for the Proposed Action A recent audit at a nuclear reactor facility, initiated because of an attempt to damage fuel at the facility, determined that several hundred licensee and contractor personnel had access to the area where the fuel was stored (a vital area) during the time the attempt was made.
Many of the personnel did not require access to this vital area during the time the incident occurred and many did not need access to this vital area at all.
Audits at other nuclear power reactors revealed that similar conditions existed.
That is, access to vital areas was authorized on a basis which generally was tied to an individual's title i.e., nuclear engineer, without establishment of the need for an individual to be in an area at all nor to be in an area during a particular time frame.
Also, " tailgating" (more than one person passing through a portal on only one person's authorized access) was taking place at the facility.
8 002 290y 1
Enclosure "D"
The regulations and other guidance documents containing criteria deal-ing with access controls to vital areas are listed in Appendix "A" In approving the physical security plan, submitted in accordance with the provisions of section 73.55, NRR delegated to the licensee the responsibility for determining those individuals who should have access to vital areas within the context of the regulations and guide-lines listed in Appendix "A".
The recent surveys and audits of all operating nuclear power reactors revealed that some of the licensees have broadly interpreted the guidelines and have used lax criteria for authorizing individuals unescorted access to vital areas.
That is, access lists to particular vital areas included anyone who might need access to that area regardless of the frequency or duration of the need.
This was not in consonance with the intent of the regula-tions or guidelines.
A need exists to more explicitly define the type of access controls required at vital areas in order to eliminate this loose interpreta-tion by the licensees.
It is proposed that this need be fulfilled by amending the regulations.
C.
Value/ Impact of the Proposed Action 1.
NRC Operation Definitive access control criteria will 2:u-e that a proper and uniform level of protection is applied to all vital areas at Nuclear Power Plants.
Also, because the criteria will limit the number of individuals having access and the period these individuals can enter a vital area, the investigative process 2
Enclosure "0"
of determining the cause of an act of sabotage will be enhanced.
The fact that an act can be traced more easily to a potential perpetrator will serve as an added deterrent against insider sabotage.
Further, the enforcement of these criteria will be enhanced by the fact that they will be regulatory requirements.
The impact on the NRC staff will be the need to review licensee plans to assure that the requirements are adequately considered.
It is estimated that it will take 1.5 person-days of staff time per facility for this purpose.
These estimates are con-servative, and represent outside bounds for the cost of review, because changes will be handled in accordance with 10 CFR 50.54(p).
That is, changes will be reviewed as changes that "do not decrease the safeguards effectiveness of the plan" and in accordance with 10 CFR 50.54(p) will be submitted to the NRC within 2 months after the change is made.
Imoact (cost in $K)
- 1) Review licensee plan 1.5 person days / plan x 48 licensee plans
= 72 person days @ $100/ person-day 7.2 Total NRC Licensing Program Implementation Cost 7.2 No additional resources or manpower will be required to imple-ment this because it will be integrated with present licensing tasks.
The Office of Inspection and Enforcement impact is negligible and criteria will be factored into the normal inspection process.
3 Enclosure "D"
2.
Other Government Acencies - It is expected that other government agencies will not be perceptibly affected by these regulatory changes.
Value may accrue to the FBI in that it may be able to investigate an incident more effectively and rapidly because of the more definitive data base available.
B.
Industry i
The fact that the proposed criteria w ll serve as a deterrent to sabotage will provide some value to the Industry in that the likelihood of sabotage damage to plant and services will be reduced.
The impact to industry will amount largely to the cost of developing procedures to assure that the access control criteria are properly implemented.
The estimated cost for this is as follows:
Initial Cost Impact (cost in $K)
- 1) Prepare access lists and procedures -
10 person-days / facility x 48 licensee facilities = 480 person days @
$100/ person-day 48.0 2)
Revise access list computer programs 5.0 53.0 Annual Costs
- 1) Revise and maintain access lists 2 person-days / facility x 48 licensee facilities = 96 person-days @ $100/
person-day 9.6
- 2) Revise and maintain access list computer programs 5.0 14.6 4
Enclosure "0"
4.
Public - The public will benefit because the criteria will pro-vide an increased deterrent against insider sabotage.
The public would be impacted by higher consumer electric bills resulting from the utilities passing their costs for implementing the access control criteria.
These costs would be as follows:
a.
Implementation Cost Increase in Electric Utility Bills.
Given the net electrical generation Of 22,082,423 megawatt hours for March 19781 at 2
1.6 cents per kilowatt-hour, the cost of generation for one month would be $353,318,768.00.
Dividing the total industry initial cost for the vital area access procedures by 12 to obtain the monthly cost over a one year period gives a cost of $4.42K.
Dividing the monthly implementation cost by the current monthly generation results in a cost of.000020 cents per kilowatt-hour or about a.00125%
increase in the total cost per kwh.
54,420 MWH 100 cents _.000020 cents x
22,082,423MWH 1000 kwh kwh b.
Maintenance Co st:
The annual maintenance cost results in an annual increase to electrical costs of.00034% per kwh.
INUREG 0020, Vol. 2 No. 4, April 1978.
2 Monthly Energy Review, Part 6 - Nuclear Power, Page 42 April 1978.
5 Enclosure "D"
D.
Decision on the Action The benefits to be derived will provide additional security to vital area control and will provide a deterrent to insider sabotage.
The costs to implement these ;ontrols are minor.
II. Technical Aoproach A.
Technical Alternatives The vital area access controls to be applied are mostly procedural in scope and therefore a discussion of technical alternatives is not applicable.
III. Procedural Approach A.
Procedural Alternatives Procedures that could be used to promulgate the proposed action include the following:
1.
Regulation 2.
Regulatory Guide 3.
ANSI Standard, endorsed by a Regulatory Guide 4.
Branch Position 5.
NUREG 8.
Value/ Impact of Procedural Alternatives the present regulatory framework specifying vital area access controls is summarized in Appandix A.
It consists of a general statement in the regulations and several branch positions.
This has proven to be less than satisfactory in many cases.
It has become apparent through operating experience that a more definitive statement of requirements 6
Enclosure "D"
are needed which are enforceable.
The preferred alternative under these conditions is to state the requirements in a regulation.
All other alternatives would be essentially the same as presently exists.
C.
Decision on Procedural Approach Alternative 1 is the preferred approach, that is to amend section 73.55(d)(7) of 10 CFR Part 73 to more explicitly define the type of access controls needed at vital areas of nuclear power plants.
IV. Statutory Considerations A.
NRC Authority The Atomic Energy Act of 1954, an amended, Section 16.i and 1610 pro-vide authority for the Commission to require access controls to nuclear power plant vital areas.
B.
Need for NEPA Assessment The proposed action is not a major action, as defined by 10 CFR 51.5(a)(10) and does not require an environmental impact statement.
V. Relationshio to Other Existing or Proposed Regulations or Policies There are no apparent potential conflicts or overlaps with other NRC oroposed regulations or policies nor with other agencies regulations or policies.
7 Enclosure "D"
VI. Summary and Conclusion Recent events have proven that the present regulatory framework is neither sufficiently explicit nor enforcable to generate the kinds of access con-trols that are needed for vital areas of nuclear power plants.
The pro-posed amendmen..i to 10 CFR Part 73 will correct this condition.
8 Enclosure "D"