ML20052E813

Forwards Revision of Facility Industrial Security Manual Security Contingency Plan & Security Force Training & Qualification Manual.Revisions Withheld (Ref 10CFR2.790)

ML20052E813
Person / Time
Site:	Kewaunee
Issue date:	05/04/1982
From:	Mathews E WISCONSIN PUBLIC SERVICE CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
CON-NRC-82-74 NUDOCS 8205110449
Download: ML20052E813 (4)

Text

e NRC-82-74 WISCONSIN PUBLIC SERVICE CORPORATION P.O. Box 1200, Green Bay, Wisconsin 54305 (n y N  %

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/ 6 May 4, 1982

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D 4i 6 Dr. Haroid R. Det.Lon, Director Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Dr. Denton:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Revision of the Kewaunee Industrial Security Manual (ISM) and Format Changes to the Security Contingency Plan (SCP) and Security Force Training and Qualification Manual (1&QM)

During the periodic review required by Section 9.7 of the ISM, we identified several areas where charges are desirable.

The majority of the changes are typographical corrections, changes to reflect current titles of persons with security responsibilities or to more fully define the area of responsibilities of security personnel. A change not falling in these categories was made on page 3-12. Previous wording of that page stated that key cards would be captured by a mechanical device upon exit from the protected area. The present wording will allow exit from the protected area by using a non-capturing card reader. This change was prompted by the poor performance of the card capturing reader. A statement supporting our determina-tion that this is not a lessening of security ef fectiveness is attached. This attachment is considered safeguards information within the context of 10 CFR 73.21 and as such must be protected from disclosure.

Also enclosed is a copy of the SCP and a copy of the T&QM. There has been no change in the content of these two documents. However, they are now being produced in a manner which will allow a page-by-page revision and are being provided to you, in whole, for your convenience.

80 6i 'l L 6- l 8205110449 820504 PDR ADOCK 05000305 F PDR

a Dr. Harold R. Denton May 4, 1982 Page 2 1

The entire ISM and the entire SCP are considered Safeguards Information within -

the context of 10 CFR 73.21 and must be protected from disclosure. The portions of the T&QM which must be protected are marked " Security Safeguards Information."

This submittal is made under the provisions of 10 CFR 50.54(p) as changes which do not lessen the security effectiveness of the plan. In order to assist your review of the revised ISM, a list of affected pages has been included as Attachment 2 to this letter.

Very truly yours ,

E. R. Mathews Senior Vice President Power Supply & Engineering snf Enc.

cc - Mr. J. G. Keppler, US NRC Mr. Robert Nelson, US NRC - w/o enc.

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ATTACHMENT 1 ATTACHMENT SUPPORTING THE REMOVAL CF THE CARD CAPTURING READER AT THE KEWAUNEE PLANT -

The purpose of the. card capturing reader is to " provide positive control over _the access cards, thereby minimizing the probability of compromise of .

the system by copies _ of ~ cards."

WPS has contacted Rusco Electronics Systems, the equipment manufacturer, to ascertain the ease in which the cards may be duplicated. We were informed that .

the cards contain over 1039 different code permutations using 55 magnetic read areas.. Rusco has contracted several laboratories to duplicate the encoding on the card. Only Underwriters Labs (UL) has been successful in code ' duplication (and they had to destroy the original to do it) indicating that considerable expertise is needed to increase the probability of Access Control System compro-mise.

In addition to the inherent security of the card against duplication, several actions will be taken to minimize. the probability that the cards will be removed from the site. First, during high traffic times a security of ficer or watchman will be present at the protected area exit to observe proper deposition of the key cards. Second, the key cards will be inventoried at the end of each shif t -

to identify those cards , if any, which were removed from the site. Any cards removed from the site will be deactivated. These actions are the subject of a Security General Order recently issued (SCO-16).

We feel that the above measures offer equivalent protection of the key cards and, therefore, replacing the card capturing card reader with a read only card reader is properly made under the provisions of 10 CFR 50.54(P).

1 5/4/82 SECURITY SAFEGUARDS INFORMATION

ATTAGMENT 2 t

4 1

List of pages affected by Revision -3 to the Kewaunee ISM.

3 1- 34 a

1 1-1 1-35 1 1-2 Figure 1-1 1-3 Figure 1-2 (deleted) i 1 3-12 ,

1-8 3-17 1-9 3-23 1-11 4-2

+

1-12 4-3

. 1-15 5-1 1-18 5-2 1-22 5-3 l

4 1-26 5-4 1- 30 Figure 5-10 (added) 1-33 t

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, , _ _ _