ML20062A813
| ML20062A813 | |
| Person / Time | |
|---|---|
| Issue date: | 09/05/1990 |
| From: | Cline W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Mckee P Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9010230152 | |
| Download: ML20062A813 (3) | |
Text
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SEP 5 1980 i
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MEMORANDUM FOR:
Phillip F. McKee, Chief i
Safeguards Branch Division of Reactor' Inspection and Safeguards' Office of. Nuclear Reactor Regulation I
s FROM:
William E. Cline, Chief:
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Nuclear Materials Safety and Safeguards Branch l
Division of Radiation Safety and Safeguards-
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SUBJECT:
RECOMMENDATIONS TO REDUCE UNNECESSARY RESOURCES-SPENT-HANDLING POWER REACTOR SAFEGUARDS INFORMATION_
j Reference is made to Mr. Robert Martin's July 2, 1990,= memorandum to l
Dr. Murley, subject referenced above~, which was also provided to Region II..
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We concur generally with the proposed reduction in the amount ~ of safeguards i
material possessed and maintained by both the NRC and licensees, and we agree that a considerable amount of overclassification of Safeguards Information However, many of i.he proposed concepts for. reducing the volu'me of occurs.
safeguaro-does not appear feasible in. light of the necessity.for the availa-
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bility of plans and procedures -for use by; the security force and other..
l functional areas.
While a considerable amount of the material contained in plans and prccedures-is not Safeguards = Information, other linformation that is
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pertinent is ufeguards and, in manyninstances, must be included -in reports, plans, and procedures..
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It further appears that a major initiative to declassify portions of existing plans, procedures, and reports as' proposed would require considerable effort l
and would not be cost-effective.
It would appear to be more feasible to 4
encourage restraint in overclassification of material through emphasis applied
- 4 during inspections and possibly.. an Information Notice, with self-restraint practiced by the Agency in-house.
Inspectors should be reminded'to document inspections and related correspondence to the extent possible without divulging Safeguards Information with adherence monitored during document review and coordination.
r COMMENTS ON INDIVIDUAL CONCEPTS PROPOSED ARE AS'FOLLOWS:
Concept 1:
Prepare physical security notices of violation 1(NOVs). without -
including SGI.
i Agree where possible.
However, in most instances the inclusion'of Safeguards Information-is necessary to clearly demonstrate - the extent or degree of violation of regulatory requirements.-
Concept 2:
Reduce the distribution lists for documents containing.SGI.
Agree to the extent feasible, y
Concept 3:
Recommend licensees decontrol portions of.their Physical Shcurity Plans that are not SGI.
9ot'oiso152 900905 lg REG 2 SUBJ
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SEP 5 1990 Phillip F. McKee 2
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-l If the intent is to mark or identify portions of plans that do not contain
't Safeguards Information accordingly, that would appear advantageous in some j
respects.
However,'the overall benefit does not appear to be beneficial since the plan or document must be-identified and protected in the manner appropriate for the highest category (safeguards) of material contained therein.
Concept 4:
Refrain from marking documents SGI that only provide information l
available from FSARs.
i Agree with the proposal providing specific locations, equipment contained j
therein, and method of gaining access is not -discussed.
Concept 5:
. Prepare physical security information reports without including SGI.
Disagree as a matter of routine. Any routine inspection report should document security force capabilities, relative compliance with regulatory requirements,
'I and Physical Security Plan commitments.
Specific deficiencies.as well as the i
circumstances and contributing factors involved in security violations must be documented to support the violation issuance and subsequent followup and j
- closecut, a
Concept 6:
Routinely review-and decontrol old documents that were originally.
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marked SGI and that are no longer viewed as containing SGI.-
i Agree, providing review can be accomplished without unduly burdening available
'i administrative and inspector resources.
Should appropriately be accomplished in conjunction with record retirement actions.
Concept 7:
For a physical. security inspection that does not identify-a violation or an unresolved item, issue a non-SGI generic form letter that does not specify details of the inspection..
Disagree.
Inspection findings, observations, and-results are-the basis.for SALP inputs and -document inspector conclusions ' relative to security effec-tiveness, assessment of equipment adequacy, and personnel ability to defend the facility against the. postulated threat.
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William E. Cline', Chief I
Nuclear Materials Safety and Safeguards Branch -
1 Division of Radiation Safety I
and Safeguards cc:
(See page 2)
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LSEP' 6' 1990~1 Phillip F. McKee
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L. Bentenhausen. RI B. Mallett, RIII A. Beach, RIV R. Pate, RV bec: Document Control Desk J. Stohr I
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