ML20077E179

Comment Supporting Proposed GL-reconsideration of Nuclear Power Plant Security Requirements for Internal Threat

ML20077E179
Person / Time
Site:	Calvert Cliffs
Issue date:	12/02/1994
From:	BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-59FR54923 59FR54923-00005, 59FR54923-5, NUDOCS 9412120152
Download: ML20077E179 (2)

Text

$

-y. .

[ ' ~!

} , - " _..a

_e e

e HonEur E.DENToN '-e~.3 ,.,, Baltimore Gas and Electric Company Vice President -; - L h Calvert Cliffs Nuclear Power Plant Nuclear Energy

, 1650 Calvert Cliffs Parkway b_, ~6 RI 2: 56 '"*Y' "^'yiand 20657 410 586-2200 Ext.4455 Local

'7' y ,

-o-.- 410 260-4455 Baltimore UCLg

• ~ , ' dr.

I

' b Lh @ q December 2,1994 h h 9 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Chief, Rules Review and Directives Branch l

SUBJECT:

Calvert Cliffs Nuclear Power Plant l Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 i

Proposed Generic Letter - Reconsideration of Nuclear Power Plant Security i Requirements For an Internal Threat We welcome the opportunity to comment on the Nuclear Regulatory Commission's (NRCs) generic letter proposal to change certain security measures to protect against an internal threat at nuclear power plants.

We endorse the draft comments submitted by the Nuclear Energy Institute in their letter of November 21, 1994. In addition, we have several comments on (I), Vital Area Access Control Measures.

One of the conditions stated for NRC acceptance of changes to vital area access control measures is,

"(2) measures are in place to examine hand <arried packages for explosives using equipment specifically designed for that purpose." The Analysis of NUMARC's Alternative Protective Strategy and Staffs Alternative Approach (Enclosure 4 to SECY-93-326) states that portal monitors are less than effective in detecting explosives carried on a person. Given this analysis, we question whether the portal explosives detector would qualify as "specifically designed" for the purpose of examining hand-carried packages. Ifit is not, then plants would have to purchase new equipment to comply with this requirement. We are enecaraged that NRC is forward-looking in supporting the use of newly developed security technologies.

When we are confident that the equipment designed for this purpose is proven reliable, we plan to take advantage of the provisions of this generic letter.

Elimination of separate access authorization lists for each vital area (Item 1. B) appears to be dependent on installation of explosives detectors and measures to protect against an external adversary. We do not see the connection between consolidation oflists and the installation of unrelated equipment.

9412120152 941202 PDR I&E MISC PDR

e b

Chief, Rules Rniew and Din:ctives Branch December 2,1994 Page 2 Item 1. B also states that the single list replacing the individual access lists would be revised as the status of persons on the list changes. It is not clear whether this means that the current requirement of 10 CFR 73.55(d)(7)(i)(A) for a 31-day validation of the list is also climinated. This point should be clarified.

Two areas that we are interested in will be addressed in a rulemaking process.

. Allow personnel with unescorted access to drive certain specified vehicles into the protected area

. Eliminate the quarterly submission of the safeguards log We support the approval of both these efforts. Should you have any questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours,

[ -

C2 RED /EMT/ dim cc: Document Control Desk, NRC D. A. Brune, Esquire J. E. Silberg, Esquire L. B. Marsh, NRC D. G. Mcdonald, Jr., NRC T T. Martin, NRC P. R. Wilson, NRC R. I. McLean, DNR J. II. Walter, PSC