ML20040G859
| ML20040G859 | |
| Person / Time | |
|---|---|
| Issue date: | 02/10/1982 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | NRC |
| References | |
| RULE-PRM-73-7 NUDOCS 8202160545 | |
| Download: ML20040G859 (6) | |
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-I OU M NUCLEAR REGULATORY COMMI22IOG 10 P2 M9
[ Docket No. PRM-73-7]_..y gM p
Elimination of Required Log Out o'f'Pe'rsonnel 3
from Vital Areas of Nuclear Power Reactors i;<
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@_6 AGENCY:
Nuclear Regulatory Commission.
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ACTION:
Notice of receipt of petition for rulemaking from Wisdo'q' sin Ay (NMj Electric Power Company, et al.
SUMMARY
- The Nuclear Regulatory Commission is publishing for comment a petition for rulemaking dated December 2,1981 filed on. behalf of the Wisconsin Electric Power Company, et al.
The petition requests changes in 10 CFR Part 73, " Physical Protection of Plants and Materiais," which would eliminate "... the log out requirement at nuclear power reactors for individuals given access to normally unoccupied vital areas." The petitioners contend that the "... requirement not only is unnecessary from a safety standpoint, but may be detrimental to safe plant shutdown and effective plant response to other emergencies. Moreover, other more
'he petition includes sensitive facilities have no similar requirement."
T proposed amendatory text which would achieve this requested change.
DATES:
Comments must be received on or before APR 191982 Comments re'ceived after APR 1 S 1982 will be considered if practical to do so but assurance of consideration cannot be given except as to comments received on or before this date.
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B202160545 820210 PDR PRM 73-7 PDR
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ADDRESS:
Comments should be sent to the Secretary of the Commission, U.S. Nulcear Regulatory Commission, Washington, D.C. 20555, Attention:
Docketing and Service Branch.
Comments may also be hand-delivered to Room 1121, 1717 H Street, NW., Washington, D.C. between 8:15 a.m. and
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5:00 p.m.
A copy of the petition and the memorandum in support of the petition may be obtained by writing to the Division of Rules and Records, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.
Coments on the petition may be inspected and copied at the NRC's Public Document Room, 1717 H Street, NW., Washington, D.C.
FOR FURTHER INFORMATION CONTACT:
John D. Philips, Chief, Rules and Procedures Branch, Division of Rules and Records, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, D.C., 20555.
Telephone:
(301) 492-7086.
Toll-free:
(800) 368-5642.
SUPPLEMENTARY INFORMATION: The Nuclear Reglatory Commission has received a petition for rulemaking filed on behalf of the Wisconsin Electric
-Power Comoany, the Public Service Electric and Gas Company, the Commonwealth Edison Company, the Yankee Atomic Electric Company, the Northern States Power Company, and the Sacramento Municipal Utility District which requests elimination of "... the log out requirement at nuclear power reactors for individuals given access to normally unoccupied vital areas."
The petitioners, in an accompanying memorandum in support of the petition, state that "... the logging out of individuals from vital areas at' nuclear power plants is unnecessary in view of the other protect ve
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In support of this statement, the petitioners review the requirements for nuclear power plant physical security plans set forth at 1573.55(d) and 73.70 and list 30 requirements, other than the log out requirement, which the petitioner contends "... provide more than adequate control over access to protected areas of the plant." The petitioners also note that most nuclear power plant licensees have implemented personnel screening programs involving a background investigation and psychological screening of employees.
Thus, "... a log out requirement for regular t
plant personnel who have been screened, badged, searched and logged
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into vital areas is totally unnecessary for plant safety."
Also in support of the petition, the petitioners review other Federal agencies which have responsibilities over facilities they say are more sensitive than commercial nuclear power reactors and which do not have log out requirements for the vital areas of these facilities.
These facilities include " nuclear weapons storage areas, military nuclear research facilities and many military bases... ", which do have actass control requirements but which do not include a log out-requirement.
The petition concludes that "if logging out is deemed unnecessary for three types of facilities, then logging out surely is unnecessary at less sensitive nuclear power reactors."
Thirdly, in support of the petition, the petitioners contend
... the log out requirement may be detrimental to safe plant shutdown o
and effective plant responses to emergencies." The petitioners state that:
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There are a number of log out systems presently in use at vital areas of nuclear power reactors; some, for examole, require an employee to insert a computer card into a carc rsader on the inside of the door to the area before exiting; other systems have only a button on the inside of the area to release the door, but require an employee to insert the card into a reader on the outside of the door before leaving the area.
Under either system, if an employee fails to log out of an area, he or she will be restricted from gaining access to Other vital equipment or areas until security personnel have manually instructed the computer.
A number of practical problems are caused by this logging out requirement.
During an emergency or when bringing the plant to safe shutdown, plant personnel may easily forget to log out o,f a vital area, thereby delaying their entry into other vital areas and seriously hampering effective plant responses.
During heavy traffic periods when the computer is busy, the logging out process may be greatly slowed, causing frustration and preventing employees from moving quickly from one vital area to another.
Under certain log out systems, when an individual forgets to log out of one vital area and tries to enter a second vital area, an alarm is sounded and a CAS (Central Alarm Station) or SAS (Secondary Alarm Station) operator must respond. The operators are thus diverted to handling unimportant matters when they should be performing surveillance.
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" U.i The log out requirement causes an additional problem in essentially doubling the use of the plant computer. During heavy traffic. periods, the computers are so greatly burdened
' that their speed is reduced, causing inconvenience and frustration and increasing the likelihood of computer failure. Moreover, the increased wear ano tear on the computer's hardware increases the incidence of_ component failure and required maintenance.
It has been suggested that log out information is helpful in the event of a material theft or tampering with equipment in a vital area.
In such cases, it is argued, logging out identifies the. exact time during which all individuals were present in a-vital area and facilitates any subsequent investigation. The petitioners point out, however, that because it is often difficult
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to isolate the exact time when such an event may have taken place, it is necessary to investigate all persons who logged into a vital area during a period of several hours, or a day. Thus, the critical information is not when a person logged out of a vital area, but when the person logged into the area.
While it is true that log out information may be somewhat useful, it will never obviate the need for a complete check of all personnel who logged into an area.
More importantly, any marginal benef.it from log out infctmation is far outweighed by the danger of delay to plant emergency response time which may be caused by logging out.
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The petitioners included a proposed amendment to 173.70(d) by adding the text in the enclosed arrows as provided below.
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PART '73 - PHYSICAL PROTECTION'0F PLANTS AND MATERIALS
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Paragraph (d) of 573.70 is revised to read as follows:
173.70 Records.
(d) A log indicating name, badge number, time of atry, reason for entry, and time of exit of all individuals granted access to.
a normally unoccupied vital area, --) except that a log kept by each licensee subject to the provisions of 173.55 need not indicate the time of exit of the above-mentioned individuals. 4-
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Dated at Washington, D.C., this
/C day of Frucey,1982.
For the Nuclear Regulatory Conmission.
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fSamuelJ.Chilk,'
Secretary of the Co:nnission.
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