ML20126B045
| ML20126B045 | |
| Person / Time | |
|---|---|
| Issue date: | 09/11/1992 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9212210358 | |
| Download: ML20126B045 (2) | |
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umito sTMES C 4p" NUCLEAR REGULATORY COMMISSION.
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eesesse M FICE OF THE COMMISSIONE R MEMORANDUM FOR:
Samuel J.
Chilk Secretary of the Commission FROM:
James R.
Curtiss 4%& h,
SUBJECT:
SECY-92-272, RE-EXAMINATION OF NUCLEAR POWER PLANT SECURITY REQUIREMENTS ASSOCIATED WITH THE INTERNAL THREAT I have reviewed the subject paper and have no objection to the staff's plan to initiate the rule changes described in recommendations 1 through 6 and to advise licensees of the positions presented in recommendations 7 and 8.
In the development of the proposed rule modifications, I would ask the staff to consider and specifically present its conclusions on the following matters:
First, an underlying assumption in the staff's rationale for two of its recommendations -- relaxation of compensatory measures for l
mechanical lock failures for vital area doors (recommendation 1)
L and relaxation of requirements for access lists for vital areas i
(recommendation 2) -- is that most persons granted access to the protected area also have access to the vital areas.
While this may be true during normal plant operations, it may not be the case during outages, when many contractor employees are brought onsite.
In the outage situation, where effective behavioral observation for contractor personnel may be more difficult, it may be appropriate for licensees to limit contractor access to vital areas to reduce any potential for sabotage.
I would, I
therefore, ask the staff to carefully evaluate the basis-for the l
recommendations it is making, to ensure that we account for the fact that the above assumption underlying its two recommendations in this area may not always be valid.
The proposed rulemaking package should address-this point.
Second. if we are to assume that the internal threat has been reduced through implementation of the fitness-for-duty and access authorization rules -- an assumption that I believe is reasonable
-- I believe it would be appropriate to consider permitting licensee employees to carry their security badges home at the end-of the work day,.much-as we do with.our badges here at the NRC.
This approach would eliminate the need for e7ployees to first check-in with security personnel solely for the purpose of obtaining a badge.
Such a procedure could reduce the time it takes for employees to process into the protected area when they-9212210358 920911
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It may additionally allow a reduction in the number of security personnel required at protected area access control points.
For these reasons, I would encourage the staff to evaluate this option, and present its conclusions when it submits the proposed rulemaking package.
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The Chairman Commissioner Rogerr, commissioner RemicK commissioner de Plangue
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