ML19323D787
| ML19323D787 | |
| Person / Time | |
|---|---|
| Issue date: | 11/25/2019 |
| From: | Marissa Bailey Division of Security Operations |
| To: | Gross W Nuclear Energy Institute |
| Richardson A | |
| References | |
| NEI 09-05 | |
| Download: ML19323D787 (3) | |
Text
November 25, 2019 Mr. William R. Gross, Director Incident Preparedness Facility Security Officer Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004
SUBJECT:
REVIEW OF NEI 09-05, GUIDANCE ON THE PROTECTION OF UNATTENDED OPENINGS THAT INTERSECT A SECURITY BOUNDARY, REVISION 1, DATED OCTOBER 2, 2019
Dear Mr. Gross:
I am responding to your letter dated October 2, 2019, (Agencywide Documents Access and Management System Accession Number ML19275F859), in which you requested the U.S.
Nuclear Regulatory Commission (NRC) staffs review and endorsement of NEI 09-05, Guidance on the Protection of Unattended Openings that Intersect a Security Boundary, October 2019, Revision 1. Revision 1 provides definitions for two-dimensional and three-dimensional unattended openings.
In your letter, you requested approval for a larger three-dimensional opening that penetrates a security barrier. The NRC reviewed Sandia Labs, Technology Transfer Manual-Access Delay Volume I and II and determined that the referenced documents do not provide a valid basis for the dimensions requested. For example, the recommended size for a three-dimensional opening included a test that demonstrated that a 190-pound, 5-foot 6-inch male was unable to penetrate an opening; however, the report stated a smaller person could penetrate the opening.
While the NRC staff did find valid analytical data in the Sandia documents to consider a larger size opening, the staff is unable to endorse Revision 1 of NEI 09-05 as provided. Should you wish to resubmit the document with amended dimensions and a supportable technical basis, please consider the following factors:
Sandia Labs, Technology Transfer Manual Access Delay Volume I, Chapter 6, Page 6-20, Table 6-8, dated November 17, 2011, identifies testing conducted on different size openings.
The definition of a three-dimensional opening should include information such as the number of pathways, bends or turns; size of the smallest dimensions; and the depth and size of the cross section.
W. Gross 2 If you have any questions, please contact Mr. Alonzo Richardson, of my staff at (770) 500-9675 or via e-mail at Alonzo.Richardson@nrc.gov.
Sincerely,
/RA/
Marissa Bailey, Director Division of Security Operations Office of Nuclear Security and Incident Response
W. Gross 3
SUBJECT:
REVIEW OF NEI 09-05, GUIDANCE ON THE PROTECTION OF UNATTENDED OPENINGS THAT INTERSECT A SECURITY BOUNDARY, REVISION 1, DATED OCTOBER 2, 2019 DATED: November 25, 2019 ADAMS ACCESSION No. ML19323D787 OFFICE NSIR/DSO NSIR/DSO/SOSB NSIR/DSO NSIR/DPCP NAME A. Richardson D. Huyck S. Atack S. Helton DATE 11/20/19 11/22/19 11/22/19 11/22/19 OFFICE NSIR/DSO NAME M. Bailey DATE 11/25/19 OFFICIAL RECORD COPY