ML20126B012
| ML20126B012 | |
| Person / Time | |
|---|---|
| Issue date: | 10/07/1992 |
| From: | Remick F NRC COMMISSION (OCM) |
| To: | Rogers, Selin, The Chairman NRC COMMISSION (OCM) |
| References | |
| COMFR-92-004, COMFR-92-4, NUDOCS 9212210339 | |
| Download: ML20126B012 (2) | |
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%wy COMFR-92-004 OFFICE OF THE COMMISSIONE R October 7, 1992 MEMORANDUM FOR:
The Chairman Commissioner Rogers Commissioner Curt'.ss Commissione de lanq e FROM:
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SUBJECT:
SEC 272, Re-examination of Nuclear Power Plant Security Requirements Associated With the Internal Threat After reading the staff's response to my request for additional information, I remain unconvinced that n11 opportunities for reducing security requirements have been explored in view of i
recent regulatory requirements that affect the insider threat.
I believe there are actions the Commission can and should take that go beyond what the staff has described in SECY-92-272 to improve the likelihood of continued safe operation at nuclear power facilities.
I say this for two reasons.
First, I continue to frequently hear people express concerns about the complexity of their plant security programs, the potential for hindered safe plant operation, the effect on pecsonnel morale, and the impact on plant operational efficiercy.
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i Second, although the staff concluded that none of our current requirements has a significant impact on plant safety, and none could be totally eliminated without some loss of confidence in our ability to meet our goal of hign assurance of protection against an insider, the staff has recognized in its response to me dated September 9, 1992, that certain applications of the combination of vital area barriers, vital area access controls, and compartmented vital areas could potentially have a negative impact on safety.
The potential for a negative impact on safety, the continuing criticisms about inordinate expenditure of effort on items of little true safety significance, the staff's conclusion in SECY-92-272 that a number of regulatory requirements associated with the insider threat appear to be only marginally ef fective, and the additional confidence in plant personnel provided by the fitness-for-duty and access authorization rules indicate to me that our current regulations in 73.55 are ripe for reassessment and possible refinement.
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- e 4 Tiic changes proposed by the staff provide very little in the way of an expected incrossa in operational safety or increase in operational efficiency the Commi sion return SECY-92-272 to the staff and I suggest that c
urge the staff to reconve.'e with NUMARC in order to develop a set
'of recommendations that will ha more consistent with today's insider threat.
I would also urge the staff to reconsider the apptcach suggested by NUMARC in its Alternative Protection Strategy as a stepping-off point for exploring alternatives.
I believe that we have an opportunity and justification to explore a less prescriptive approach to tho.
-"isting security requirements which were driven by concern tin: employee trustworthiness.
SECY please track.
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