ML20080H696
| ML20080H696 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/08/1995 |
| From: | George Thomas DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9502230271 | |
| Download: ML20080H696 (4) | |
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Beaver Va ley Power Station Shippingport. PA 15077-0004 (412) 393-5206 (412) 64F8069 FAX February 8, 1995 oconor s. tsou^s Dmsion Vice President Nuclear Services Nuclear Power Omsson U.
S.
Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555-0001
Subject:
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Request for Exemption from 10 CFR 73.55(d) (5);
Requirements for Physical Protection Against Radiological Sabotage In accordance with the provisions of 10 CFR 73.5, Duquesne Light Company (DLC) requests an exemption from certain requirements of 10 CFR 73.55, "Rectirements for Physical Protection of Licensed Activities in Nue)
Power Reactors Against Radiological Sabotage,"
for Beaver Valley ower Station Units 1 and 2.
Specifically, DLC requests an exempvicn from 10 CFR 73.55 (d) (5) which states that "An individual not employed by the licensee but who requires frequent and extended access to protected and vital areas may be authorized access to such areas without escort provided he receives a picture badge upon entrance into the protected area which must be returned upon exit from the protected area..."
As justified in Attachment 1, this exemption will allow individuals with unescorted access to keep their picture badges with them when departing the protected area, and shall be contingent upon implementation of an alternative (biometric) access control system.
Undat the proposed alternative
- system, individuals authorized uneocorted access to the protected area will have the physical characteristics of their hand (hand geometry) registered in the biometric access control system with their keycard.
An individual requesting access must present both their hand and their keycard.
Access will only be granted when their hand geometry matches that of the physical characteristics previously registered in the computer for that keycard.
Implementation of the biometric unescorted access control system will continue to meet the general performance requirements of 10 CFR 73.55(d) (5).
DLC has estimated that resources valued at approximately $285,000 annually can be made available for other purposes by eliminating the need to issue and retrieve picture badges.
The proposed alternative unescorted access control system provides for a
combination of identity verification processes that are at least equal to the existing process.
9502230271ADOCK O O O 34 PDR PDR 0
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Rsquant for Exonption from 10 CFR 73.55(d) (5)
Requirements for Physical Protection Against Radiological Sabotage Page,2 DLC requests that NRC grant this exemption by May 1, 1995, in order to facilitate implementation of the biometrics access control 3
system prior to the conclusion of the next refueling outage.
Additional information regarding changes to the physical security plan is being forwarded separately.
Upon exemption approval, the Beaver Valley Power Station Physical Security Plan will be updated pursuant to 10 CFR 50.54(p) to reflect this change.
Any questions concerning this topic may be directed to Mr. Mike Johnston, Manager, Nuclear Security, at (412) 393-7812.
Sincerely, e
i k
/M8 George S.
Thomas Attachment cc:
Mr.
L.
W.
Rossbach, Sr. Resident Inspector Mr. T. T. Martin, NRC Region I Administrator Mr.
G.
E.
Edison, Sr. Project Manager i
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ATTACHMENT NO. 1 Request for Exemption From 10 CFR 73.55(dif5) l e
i GEBENT SYSTEM Currently, unescorted access into the Beaver Valley Power Station is controlled by use of an individual's photograph attached to a keycard i
(badge).
Before granting
- entry, security officers at the access points verify that the photograph on the badge is that of the individual requesting access.
The badge is then issued and represents the holder's identification and authorization to be 1
onsite.
Badges are returned to the security area upon exit from the protected area.
PROPOSED SYSTEM The proposed system will use a hand geometry biometric access control system which will require each individual, who is authorized unescorted access, to have the physical characteristics of their hand registered with their badge number in an access control computer system.
When an individual requesting access places their badge into the card reader and their hand on a measuring surface, the computer compares the hand geometry characteristics to that registered for the badge number.
If the characteristics stored in the computer match the badge number, access is granted.
This provides a nontransferable means of identifying individuals and represents an enhancement over the current system by eliminating the possibility of human error.
It i
also provides a
positive means of assuring that a lost or stolen j
badge could not be used to gain access.
Therefore, individuals, including contractors, would be allowed to keep the badge in their i
possession when departing from the protected area.
Other access processes, including search function capability, access revocation, and processes for individuals requiring escorted access, will remain the same.
A security officer responsible for access control will continue to be positioned within a bullet-resisting structure.
}MSIS FOR EXEMPTION Under the proposed biometrics access control system, individuals would be allowed to take their badges offsite.
We believe the basis for 10 CFR
- 73. 55 (d) (5) was to ensure that badges could not be compromised or stolen by being taken offsite.
The DLC proposal will implement an alternative form of identification which will replace security officer verification of the picture badge for access control.
Access will be granted or denied based on verification of the hand geometry of the person registered to the badge.
The biometric system is at least as reliable as the picture badge identification process.
Loss or theft of the picture badge is, therefore, no longer relevant to the effectiveness of the access control program.
The proposed access control system would continue
. O Attachment No. 1 Page 2 to provide for identity verification processes equivalent to 10 CFR 73.55 (d) (5).
Pursuant to 10 CFR 73.55(a),
other measures for protection may be authorized by the Commission if the proposed alternative has the same high assurance objective and the overall level of system performance provides protection against radiological sabotage equivalent to the regulation, and meets the general performance requirements of 10 CFR 73.55.
Testing evaluated by Sandia National Laboratory (SANDIA REPORT entitled "A
Performance Evaluation of Biometric Identification Devices",
SAND 91-0276 UC-906 Unlimited
- Release, June, 1991) demonstrated that the hand geometry equipment possesses strong performance characteristics and is capable of meeting the proposed detection probability and confidence level.
Based on the results of the Sandia Report and on experience gained at Beaver Valley Power Station under the present photo-identification
- system, the false-accept rate for the hand geometry system is at least equal to the current system.
The performance requirement of 10 CFR 73.55(d) is to ensure that the licensee controls the points of personnel access into the protected area.
Under the proposed biometric access system, DLC will continue to control points of personnel access.
Required access processes, including search function capability and access revocation, will-remain unchanged; only the processes required to issue, retrieve, and store badges at the entrance / exit will be eliminated.
Picture badges will continue to be displayed by individuals while inside the protected area.
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