ML20038C584
| ML20038C584 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1981 |
| From: | Burnett R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20038C581 | List: |
| References | |
| NUDOCS 8112110249 | |
| Download: ML20038C584 (4) | |
Text
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NUCLEAR REGULATORY COMMisslON
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g WASHINGTON, D. C. 20555 DEC.7 1981
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MEMORANDUM FOR:
Darrell G. Eisenhut, Director Division of Licensing, NRR FROM:
Robert F. Burnett, Director Division of Safeguards, NMSS
SUBJECT:
SECURITY ACCESS REQUIREMENTS FOR OFFSITE EMERGENCY DESPONSE PERSONNEL
~
Your memorandum of October 22, 1981 expresses concern about security access procedures for emergency response teams during emergency exercises and drills and actual emergencies at power reactors.
i In general,10 CFR 73.55(d) requires that all personnel, packages and vehicles be seaNhed, except for vehicles under emergency conditions, and that persons requiring escort b? 'dentified, registered, badged and escorted prior to admis-sion.
Except for the waiver of vehi.cle search, the rule is not explicit as to whether day-to-day access requirements should apply during an emergency, nor does it give any indication as to how emergency access should be handled during practice drills and exercises.
Further, to our knowledge, there currently is no written guidance clearly addressing the subject, and our infomal discus-sions with IE's emergency planning and safQuards staff indicate that they agree such guidance'is needed.
With regard to present practices in the absence of specific guidance, we have called safeguards staff in' Region I, II', III, and Y to detemine how their respective power reactor licensees have handled emergency access, both during actual emergencies and during the emergency exercises and drills that are required by NRC.
For time critical or life threatening situations (e.g., heart attack victim on site) the licensees in general waive normal access procedures, provide security force escort with the offsite emergency team and vehicle while on site, and may issue visitor badges and dosimeters depending upon the nature of the emergency and the specific site procedures.
In the case of emergency exercises and drills, the licensees of Region I, III, and V in general maintain realism in the exercise by using the same access procedures as in an actual emergency. The licensees in Region II differ, however, in that they halt the exercise or drill and use normal non-emergency procedures to process offsite emergency teams and vehicles that are to enter the protected area.
After nomal i
processing is completed, the exercise restarts and the offsite emergency teams i
and vehicles are escorted on site by site security.
In our view, the application of normal day-to-day access procedures for admis-sfon of emergency response assistance that may be needed to accomplish time sensitive or life saving emergency services on site (e.g., fire fighting, ambulance, rescue, medical, police) is unrealistic and detrimental to the
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8112110249 0112 l
PDR REVGP NROCR
e' Darrell G. Eisenhut 2
basic intent an,d purpose of emergency, plans and preparedness. Under actual emergency conditions, the general approach clearly should be to waive the day-to-day procedures which excessively delay such teams and execute special-preplanned procedures that provide adequate security under Ine circumstances and also serve to guide and speed the response.
In the case of emergency exercises or drills, the approach should be the same as in an emergency in order to practice and improve on the execution and to avoid the chance of using incorrect procedures during an actual emergency.
The emergency access procedures followed in the four Regions in case of actual emergencies and in Regions I, III, and Y during emergency exercises and drills are along the lines of the general approach noted above. We believe that security escort on site will provide adequate security relative to the emer-gency teams and that delaying their access on to the site to issue security This belief badges and perform other 'ormal processing is counter-productive.
stems from the fact that in most instances the emergency conditions would involve a specific location on site and would require the emergency team's presence only temporarily; thus escorting such a team for security should not be especially difficult or costly, As a result of the preplanning and emergency response training,. drills, and axercises required of l'icensees with their associated of fsite emergency teams, the security force should be quite familiar with the teams that are involved.
Furthermore, the offsite teams in general are uniformed and easily recognized relative to the emergency condition on site that they have been called to deal with.
Finally, wi.th existence of the Emergency Operations Facility as required offsite, the emergency access procedures are necessary only for the time sen-sitive or life saving emergency services that may be needed on site.
Essen-tially all other federal, state, and local response orjanizations would operate from the Emergency Operations Facility off site during an emergency or exercise.
We believe this matter should be clarified and have attsched a proposed letter to all power reactor licensees for that purpose.
If there are any questions concerning the proposed letter, please contact Charles Gaskin at 427-4010.
l I*
Robert F. Burnett, Director Division of Safeguards, NMSS
]
Enclosure:
As stated I
cc:
H. Denton l
R. DeYoung,
V. Stello s
J. Davis B. Grimes D. Mausshardt
.H. Thornburg
. v' LETTER TO:
Power Reactor Licensees FROM:
D. G. Eisenhut, Director Division of Licensing 0,ffice of Nuclear Reactor Regulation
SUBJECT:
SECURITY ACCESS REQUIREMENTS F0'R OFFSITE EMERGENCY RESPONSE PERSONNEL
Dear Sirs:
Recently we received an inquiry concerning what security access controls are required for offsite emergency response personnel who are responding to actua'l emergencies or are participating.in emergency exercises and drills.
10 CFR 73.55(d) does not fully address the question and we were asked for a clarifi-cation of the issue.
The application of nonnal day-to-day access procedures for the admission of emergency response assistance that may be needed to accomplish time sensitive or life saving emergency services on site (e.g., fire fighting, ambulance, rescue, medical, police) is unrealistic and detrimental to the basic intent and purpose of emergency plans and preparedner.s. Under emergency conditions, the general approach should be to waive the day-to-day procedures which excessively delay such teams and execute special preplanned procedures that provide adequate i
security and also serve to monitor, guide, and speed the response. We believe that escirt of the teams will provide adequate security under the circumstances.
In the case of emergency exercises or drills, access requirements should be l
the same as in an actual emergency in order to practice and improve on the et.ecrtion and to avoid the cr.ance of using incorrect procedures during an 4
actual emergent.y.
m
2 Should you have any questions concerping this subject, please contact Sincerely, Director D. G. Eisenhuti Division of Licensing Office of Nuclear Reactor Regulation 9
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