ML19319C459
| ML19319C459 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/03/1978 |
| From: | John Miller Office of Nuclear Reactor Regulation |
| To: | Mccormick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8002140839 | |
| Download: ML19319C459 (2) | |
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FEB 0 31978 i
l Docket No. 50-346 MElORAND*JM FOR:
R. G. McComick, Acting Assistant Director Division of Safeguards Inspection, IE FROM:
James R. Miller, Assistant Director for Reactor Safeguards, NRR
SUBJECT:
UNRESOLVED ITEMS - DAVIS-BESSE NUCLEAR POWER PLANT
REFERENCE:
1.
Pemorandum frem J. A. Hind to R. G. McComick, November 18, 1977,
Subject:
Unresolved Items -
Davis-Besse Nuclear Power Plant 2.
Femorandum from R. G. McCormick to J. R. Miller, Decec'ber 21, 1977,
Subject:
Davis-Besse Nuclear Power Plant (DN 50-346)
The referenced memoranda request resolution by NRR of three itens which were identified in an inspection of the Davis-Besse Nuclear Pcwer Plant.
While it is not clear to me exactly which issues need resolution, your concern appears to be related to the definition of a " specific vital area", particularly as it effects badge coding, badge validity, access authorizatica reporting and the nucber of non-employee badges that have been issued.
The objective of " access control" 1: to reduce the opportunity for radiological sabotage. The approac! being followed is to permit cnly those people whose work require acce.;s to vital equiment to have such access. The regulations prescribe a nunter of possible tools and eeans for accorplishing control, such as locating vital equircent only in vital areas, entry to controlled areas only through controlled access portals, identification badging, etc. None of the control tools or control means are likely to provide adequate control by themselves, therefore, the capability to meet the objective of the reculation must be determined by considering the integrated performance of all components of access control.
Consecuently the need to code the badge for a specific vital area or for all vital areas will depend upon site features, the access control system and the site security plan. The licensee, in authorizing unescorted access to vital areas, must base this authorizatien on a "need-to-enter" or the work related need for access to vital equipment.
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- 3 R. G. McCormick L111e no limit has been stated on the w. of persons that may be granted this authorization, it is obvicu sy desirable that the number be limited to those required for safe c seration of the facility.
The need to limit tt.a period of time that badges are valid must also be based on the integrated security system and access control systen!.
The objective to be met is again to maintain au'horizations for only those persons that have a "need-for-access" to vital equipment to perfom their work and thereby to assure safe operation of the facility.
Consequently no specific limit on the period of badge validity or access authorization has been established. Certainly, remcving badges and names from authorization lists of individuals that no longer require access, even temporarily, is essential in meeting the stated obj.tive.
The method of coding identification badges or the ceans by which the badges are to identify the area to which authorization has been granted and the visual badge ccding is also dependent on the integrated access control system and, therefore, the prescribed system can only M cvaluated in conjunction with the evaluation of the overall access control system.
As you know, the security plan review teams are currently involved in the review and evaluation of security plans. They will be considering the provisions in the plan not only to meet 3 73.5 (d) (5 and 7) but the general performance requirecents of g 73.55 (a) (1 and 2). We are aware that certain bacging requirements may not have been fully implemented by May 25, 1977 because procurement and installation of equipment is involved. In our judgerent all implecentation by August 24,1978 in this area is consistent with a graded implementa-tion philosophy of g 7f.55.
Our review team leade.s have been advised of the David-Besse inspection findings and will be alert to these concerns in reviewing these matters.
It is important that the IE review team nembers also provide help in the review of '.hese areas.
I hope this has been some help, but since I am not clear as to just what probleas you feel exist I also cannot be sure I have adequately addressed them.
If I have missed your point, give me or Jack Berggren a call. Maybe we can get together and better zero in on just what the problems are.
DISTRIBUTION:
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