ML20024G465
| ML20024G465 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 08/12/1977 |
| From: | Desiree Davis Office of Nuclear Reactor Regulation |
| To: | Mayer L NORTHERN STATES POWER CO. |
| References | |
| NUDOCS 9102120509 | |
| Download: ML20024G465 (2) | |
Text
~
so l
1TTRIBUT40f0 NRC PDR p ])
nap at Q3 i
Local PDR (2 i
ORB-2 Reading i
Docket Nos.
AUG 121977 RPSnaider
-(90-282 MGrotenhuis and 60-306 RMDiggs TJCarter Northern States Power Company DEisenhut ATTN Mr. L. O. Mayer, Manager JRHiller Nuclear support services Attorney, OELD 414 Nicollet Mall - 8th Fleer IAE(3)
Minneapolis, Minneesta 66401 JRBuchanan TBAbernath ACRS(16)y Gentlemen:
i i
RE: HONTICELLO WUCLEAR GENERATING PLANT PRAIRIE ISLAND WUCLEAR GENERATING PLANT UNIT N05.1 AND 2 We are currently reviewing the amended security plan which you sutmitted in accordance with 10 CFR 73.55. To keep you informed of our positions on and interpretations of 10 CFR 13.55, we have enclosed the followingt 1.
Our position regarding plant access for NRC personnel.
i 2.
The interpretatica by the NRC General Counsel of 10 CFR 73.55, g
" Illumination and Physical Search Requirements."
1 This information should be incorporated into the Modified Amended l
Security Plan which is to be submitted af ter the site visits by our l
security review teams.
If you have any questions regarding the enclosed infomation or site visits, you should contact the Project Manager assigned to your facility.
Sincerely, K
40 Don K. Davis, Acting Chief a
4 Operating Reactors Branch f2 Division of Operating Reactors Enclosurest N
i 1.
stC Position Regarding Plant g/J l
Access for NRC Personnel p)-
l 2.
NRC Interpretation by General l
l
- "**' h]) *$ /h, l
l
.< 'c d*Mh9,... khB3.
Dbb D0 0 U
~
RPSnaider;. esp MGrqtenhuis.
Dfi
. hun.
15 8/ '//77 8////7L 8/4/77.
8/
7L -
o
- o..........,,......o,,.............
mc roggag.gpg.-g I
PDR ADOCK 05000263
g NRC POSITION REGARDING PLANT ACCESS l
FOR NRC PERSONNEL i
gi[
NRC PERSONNEL (U
j
's NRC personnel are visitors to the plant and will generally fall into O g% y g
one of two categories.
These categories and the access control procedures for each are described below:
',; y
<,m i
1.
NRC personnel who are identified by the Director of the NRC i
Regional Office as likely to inspect the plent.
Such individuals f
will be provided permanent non-employee, no-escort-required picture R.
j badges as authorized by 10 CFR 73.55(d)(5), and added to the
'I authorized personnel list.
These badges will be kept at the protected area access control point (gate house) and will be issued i
to NRC personnel in conjunction with nonnal identification ana
'[
search fu rctions.
2.
0_ther NRC personnel.,
Individuals who fall into category 2 will be treated as nonnal plant visitors.
Plant visits by other NRC personnel will be prearranged.
If other NRC personnel, not accompanied by an NRC inspector (category 1), request entry into j
the plant without prior arrangements, the NRC Regional Office 1
will be consulted imediately.
I The NRC Regional Office or other NRC Office, if appropriate, will identify each individual described above with the following information:
Name, NRC badge or credential identification number, Social Security Number, date of birth, and clearance (if appropriate).
It should be i
noted that such individuals could include NRC contractors or consultants s
d and in that case, a suitable substitute identification number will be provided.
q Individuals falling into category 1 are authorized to serve as escorts for individuals of category 2, consisten: with normal plant escort i
requi rements.
t
}
G l
\\
~ ~ - - ~ ~ ~ _
i O
O
+
Title 10 - Energy
.i 1
1 4
4, CHAPTER I - NUCLEAR REGULATORY COW.ISSION
} gy; PART 8 - INTERPPITATIONS 7
l Interpretation by the General Counsel
'[ '
of 10 CFR 73.55.
Illumination and 4
Physical Search Requirements e5 m.,
4 AGENCY:
Nuclear Regulatory Com:sission ACTION:
Final Rule g.
z
SUMMARY
The Nuclear Regulatory Corrission's regulation
" Interpretations" is amended by adding an interpre-tation by the General Counsel of the requirements for physical protection of licensed activities in nuclear power. reactors against industrial sabotage set out in the Coc: mission's regulation " Physical Protection of Plants and Materials." The interpretation clarifies the illuminati>n 23 physical search requirements of the regulation.
l.
EFFECTIVE DATE:
This rule becomes effective on JU.1 3 01977 FOR FURTHER INFORMATION CONTACT:
Mr. C. W. Reamer Office of the General Counsel Nuclear Regulatory Com=ission l'
Washington, D. C.
20555 i;
Tel. (301) 492-8155.
SUPPLEMENTARY INFORMATION:
Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and sections $52 and 553 of I:
y Title 5 of the United States Code, the following amend =ent of Title 10, Q
~f
~ ~ ~ - - - - ~ ~
~ ~ ' -~~~ ~ ~ ~ ~~~~~~~ ~~~~ ~~~
(
O O
.u Chapter I, Code of Federal Regulations, Part 8, is published as a
- I 1
document subject to codification.
' g..
A new section 8.5 is added to read as follows:
(
?v; f 8.5 Interpretation by the General Counsel of Sec. 73.55 of tidd ', '
O.
Chapter.
IlluminationandPhysicalSearchRequirements.Q (a) A request has been received to interpret 10 CFR 73.55(c)(5)I y
73.55 (d) (1).
i
.,s..*.:.y[,
O
'l 10 CFR 73.55(c)(5) provides:
- v. ;.
I Isolation zones and all exterior areas within the
'~
protected area shall be provided with illumination sufficient for the monitoring and observation require-I ments of paragraphs (c)(3), (c)(4), and (h)(4) of this ll section, but r,t less than 0.2 footcandle measured t-I f.
l horizontally at ground level.
q (b)
The requester contends that the regulation is satisfied if 0.2' k<
t y
d footcandle is provided only at the protected area boundary and the iso-lation zone.
The language of the regulation is clearly to the contrary.
i E
it requires not less than 0.2 footcandle for "all exterior areas within
)
,j.
the protected area."
This regulation helps effectuate the monitoring and
.} _
t l
observation requirements of 10 CFR 73.55.
For example,10 CFR 73.55(c)(4) j states that "[ajl1 exterior areas within the protected area shall be periodically checked to detect the presence of unauthorized persons, i
l l
vehicles, or materials."
In the absence of illumination, such checking.
i could not be fully effective.
u~
l l
s l
(c)
The requester also asks whether the illu:nination requirement I
1 1
e i
h W
M
o o
T. <
\\
extenda to the tops and sides of buildings within the protected area.
J N1 To effectuate the monitoring and observation requiremetits cited above, l i,..
i.
illumination must be maintained for the tops and sides of all accessible structures within the protected area. This interpretation is consistant, i
with that siven by the Commission's staff to affected licensees and '(
applicants at a series of regional meetings held in March uf 1977 and #1
.;d will be reflected in forthcoming ravisions to NUPIC 0220, Draf t Interini AcceptanceCriteriaforaPhysicalSecurityPlanforNuclearPowerPiInt y
(March 1977).
V (d) 10 CFR 73.55(d)(1) provides in pertinent part:
The search function for detection of firearms, explo-sives, and incendiary devices shall be conducted either by a physical search or by use of equipment 5
capable of detecting such devices.
. K6,
,.- sc (e)
The requestor contends that until " equipment capable of detect $ng -
2 such devices" is in place, a licensee need not comply with the search d.w.2 requirement, but can utilize instead previous security programs.
This";
i contention is based on the first sentence of 10 CFR 73.55 which provides1' in pertinent part that the requirements of paragraph (d) of that section' shall be met by May 25, 1977, "except for any requirement involving con- (,
struction and installation of equipment not already in place expressed in [ paragraph ] (d)(1)
Under this sentence only those requirements p
of paragraph (d) which involve " construction and installation of equip-. qy g.;
ment" de not take effect on May 25, 1977.
Because a " physical search"' %
+ n :)
l.c i-does not require " construction and inst'allation of equipment",
le n.-
l 3Q l
< jf
,w g
~ 2pq b -
O o
y
' ~ ' ' -
impl,emer.tation of such searches is requi. red on May 25, 1977.
The regula '
tion provides alternatives:
"the search function... shall be conducted either by a physical search or by use of equipment...." Thus when appro. ;4 -
priate equip =ent is in place, the search function need not involva a l
V
~
physical search.
(f)
The paragraphs above set forth interpretation of regulations;#
v f;
do not apply those regulations.to particular factual settings.
For examp 3
no effort is made to state what lighting system night be used for a given'u.e =
facility; all that is stated is that a system must provide not less than 0.2 footeandle for all exterior areas within the protected area.
Similarly,-
no effort is made to define what is. an adequate " physical search"; all that is stated is that, in the absence of appropriate equipment, such searches must begin on May 25, 1977.
Effective Date: 'This amendment becomes ef f ective on JUN 3 01977
$(
(Sec. 161, 68 Stat. 948; 42 U.S.C. 2201).
q.[
Dated at M */m a [ w 1.I
- this / 7 day of 9 W 1977.
j.
()
For the Nuclear Regu'~1atory Commissio'n.' -
s bm James L. Kellap w
Acting General unsel yf sf h 4, ' '
D
)
t L
.k s
- j 6 g
&lf#
,. n 16 Y n.r.
a 4
4
~4-
?
. _