ML20037B426
| ML20037B426 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities  |
| Issue date: | 08/12/1977 |
| From: | Desiree Davis Office of Nuclear Reactor Regulation |
| To: | Bolger R COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8009260709 | |
| Download: ML20037B426 (6) | |
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ORB-2 Reading Dockct ios a-437/50-245 RBevan and ou-4d4/50-26d P0 Connor RMDiggs Comontrecith Ecison Company DNeighbors TJCarter ATTN:
Mr. R. L. Coloer DEisenhut Assistant Vice President JRMiller Post Office Box 767 kto y, OELD Chicago, Illinois 60690 JRBuchanan Gentl emen:
TBAbernathy ACRS (16)
RE: D'1ESDEN NUCLEAR 90i!ER STATION Ut!IT ROS.1, 2 A :D 3 OUAD-CITIES HUCLET.R POUER STATION UNIT NOS.1.YJD 2 lie are currently reviewir.c the ament ed security plan which you sub:-ittec in accordance with 10 CFR 73.55.
To keep you inforns:
of our positions on and interpretations of 10 CFR 73.55, we i; ave enclosed the following:
1.
Our position regarding plent access fcr MRC personnel.
2.
The interpretation by the NRC General Counsel of 10 CFP 72.65,
" Illumination ana Physical Search Requirments."
Inis infornation should be incorporated into the l'oof fieti /s: riced Security Plan which is to be submitted after the site visits by our security review teams.
If you have any questions regarding the enclosed infortation or site visits, you shoulc contact the Project Manager assignen to your f acili ty.
Sincerely, Original signed by dA l
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L, Access for Ed Personnel jV2'g 2.
tidC Interarctation by General Counsel cf 10 CFil 73.55 D
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NRC POSITION REGARDING PLANT ACCESS FOR NRC PERSONNEL NRC PERSONNEL NRC personnel are visitors to the plant and will generally fall into one of two categories.
These categories and the access control procedures for each are described below:
1.
NRC cersonnel who are identified by the Director of the' NRC Reoional Office as likely to insoect the olant.
Such individuals will be provided permanent non-employee, no-escort-required picture badges as authorized by 10 CFR 73.55(d)(5), and added to the authorized personnel list.
These badges will be kept at the protected area access control point (gate house) and will be issued to.NRC personnel in conjunction with norrel identification and search fu rctions.
2.
Other NRC personnel..
Individuals who fall into category 2 will be treated as normal 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 the plant without prior arrangements, the NRC Regional Office will be consulted immediately.
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 rurnber, Social Security Number, date of birth, and clearance (if appropriate).
It should be noted that such individuals could include NRC contractors or consultants and in that case, a suitable substitute identification number will be provided.
Individuals falling into category 1 are authorized to serve as escorts for individuals of category 2, consistent with normal plant escort requi rements.
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Title 10 - Energy C' DAFTER I - NUCLEAR REGULATORY CO'ZCSSION 3
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Interpretation by the General Counsel of 10 CFF. 73.55.
Illu=ination and Ph'/sical Search Require =ents AGENCY.
Nuclear Regulatory Cc=issien AC~ ION:
Final Rule SU'cDi4RY:
The Nuclear Regulatory Co=ission's regulation
" Interpretations" is anended by adding an interpre-tation by the General Counsel of the requirenents for physical protectica of licensed activities in nuclear power reactors against industrial' sabotage set cut in the CoHssien's regulation "Physicnl Frotection of Plants and Materials." The interpretation clarifies the illu tination and physical search requirements of the regulation.
fw!!a:e 30 c-//
EFFICTI7E DATE:
This rule becenes effective on FOR FUR'~2ER INFORMATION CONTACT:
Mr. C. 'i. Reaner Office of the General Counsel Nuclear Regulatory Cen=ission
'riashington, D. C.
20555 TeJ.. (301) 492-8155.
D OF rg rq(r SUPPLEMENTARY INFORMATION:
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Fursuant to the Atc=ic Energy Act of 1954, as anended, the Energy Re:rge ':ation Act of 1974, as amendec, and secticas 552 and 553 of Title 5 ef the United Secres Code, the follesdng anend ent of Title 10,
Chapter.I, Code of Federal Regulations Part 8, is published as a o
-docunent subject to codification.
1 1
A new section S.5 is added to read as f ollows:
i 5.5 Intercretation bv the General Counsel of Sec. 73.55 of this Chaeter.
Illenination and Physical Search Recuirements.
(a)
A request has been received. co interpret 10 CFR 73.53(c)(5) and 73.53 (d) (1).
10 CFR 73.55(c)(5) provides:
i Isolation zones and all exterior areas within the protected area shall be provided dith illumination sufficient for the =onitoring and observation require-ments of paragraphs (c)(3), - (c) (4), and (h)(4) of this section, but not less than 0.2 footcandle measured i
horizontally at ground level.
(b)
The requester contends that the regulation is satisfied if 0.2 footcandle is provided only at the protected area boundary and the iso-i lation :ene.
The language of the regulation is clearly to the contrary.
It requires not less than 0.2 footcandle for "all exterior areas within the protected area."
This regulation helps effectuate the =enitoring and ii observatibn require =ents of 10 CFR 73.55.
For example, 10 CFR 73.55(c)(4) states that "[ajll exterior areas within the protected area shall be periedically checked to detect the presence of unauthorized persons, t
vehicles, or =aterials."
In the absence of illumination, such checking j
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could r : be fully effective.
o The requester also asks whether the illumination requirement (c)
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ev.tends to_:he tops and sides of buildings within the protected area.
To effectuate the conitoring and observation require =ents cited above, illu=ination cust be =aintained for the tops and sides of all accessible ~
structures withi the protected area.
This interpretation is consistent with that given by the Co==ission's staff to affected licensees and applicants at a series of regional =eetings held in March.of 1977 and will be reflected in forthco=ing revisions to NUREG 0220, Draft Interi=
Acceptance Criteria for a Physica'l Security Plan for Nuclear Power Plants (March 1977).
(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 j
either by a physical search or by use of equip =ent capable of detecting such devices.
(e)
The requestor contends that until " equip =ent capable of detecting such devices" is in place, a licensee need not cc= ply with the search require =ent, but can utilize instead previous security progra=s.
This
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contention is' based on the first sentence of 10 CFR 73.55 which provides in pertinent part that the require =ents of paragraph (d) of that section i
shall be =et by May 25, 1977, "except for any require =ent involving con-i i
struction and installation of equipment not already in place expressed in' [ paragraph ) (d)(1)
." Under this sentence only those require =ents of paragraph (d) which involve " construction and installation of equip-
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=ent" do not take effect on May 25, 1977.
Because a " physical search" does not require " construction and inst'allation of equip =ent",
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B 1.placen:ation of such searches is requi ed on l'ay 25, 1977.
Tna regul:-
- icn prevides alte.1atives:
"the search functica... shall ha conducted either by a physical search or by use of equipnant...."
Thus ehan ap7:0-priate equierent is in place, the search function need no: in::lve a physical search.
(f)
The paragraphs above se: forth in:erpretatica of reguicticas; they do not apply those regulations.to particular factual settings.
For exa ple, no effort is cade to state :: hat lighting syste: might be used for a given facility; all that is stated is that a syste: =ust provide not less than 0.2 f:cicandle for all exterior areas teith'- -ke protected area.
Si=ilarly, no affor: is made to define :: hat is an adequate " physical search"; all that is stated is that, in the absence of appropriate equip =ent, such searches cust begin on 19: 25, 1977.
Effective Date:
This a=endrent becones effective on JLn.:, 30.- 7 m
(Sec.161, 68 S tat. 943; 42 U.S.C. 2201).
Dared at d.uc 1[-
this / 74 m
day of Gw_
1977.
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For the Nuclear Regdlat::y Cc nission S
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Janes L. Kelle*/
Acting General Cdunsel
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