ML20141F407
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. . MAY 0 51991 i
flEPOD.N!DU:1 FOR: Rayrond J. Brady, Director Division of Security Office of Administration i
FR0!!: flartin J. King, Chief Personnel Security Eranch l Division of Security Office of Administration
. ' SifRJECT: APPLICATI0f!S FOR !!ATEDIAL ACCESS AllTHOPIZATIO!! DY GETIERAL AT0!!IC C0'tPAflY UlI0EP 10 CFR PAPT 11 This will confim tha meeting held with Donald Fasun, of 4.'itSS, on April 23, 1981 to discuss that should be done with the applications for natorial access autherization under 10 CrP Part 11 and the accompanying checks for their pro-cessing subnitted by General Atomic Co1pany.
f Two significant coints develoccd fron this raceting. First, such naterial l - (. authorization applications 3hould not be processed until the related arrended security plan is approved by !!!'SS. dhe second point is that authorization by Congress to handic fees associated with such applications could also be necessary and that such authorization has been requested in the FY-02 appro-priation bill.' Based on these two points, it was indicated by Ponald Kasun and agreed by those present at the meeting to:
- 1. Rescind the option in 10 CFR Part 11 of pernitting ,
licensecs to submit applications for material access authorization within 60 davs of fiarch 21, 1931 (the effectivo date of the rule). Combire this change with the other rule chances being processed by the Office of fluclear Regulatory Pescarch.
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- 2. llave !!!!SS, SGPL, inforn licensecs of the presently conterplated rule chango indicated above. This notification will then enable the Division of Securf ty to contact the Goveral Atonic Conpany regarding their recently subnitted applications .
for "U" natcrial access authorization and related fee payrants.
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8601090319 951223 Y50N39076 PDR A6%a
.. s i -lk , 0 Raymond J. Brady -
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- 3. Have N!!SS, withhold, if necessary, the approval of
. licensees' anended security plans amtil the required .
authority is given by Congress to establish an account for the deposit and use of licensee fees ,
associated with the naterial access authorization applications.
!!c will follow-up with Hf'.SS and RES on this matter, if necessary.
Original Signed By Martin J. King l'artin J. l'ing, Chief Personnel Security Pranch Division of Security Office of Mninistration' cc: P, Donoghue, ADf:
bec: D. Dopp, SPB J. Dunleavy, PERSEC M '
R. Voegeli SEC CEN File 6.10 CFR Part 11 SEC CEN File 16.3 9
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'1 l)Ao: > 904 NOTES ON SECURITY MEMORANDUM TO GILLESPIE DATED DECEMBER 19, 1980
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o National agency check does itot develop information on indebtedness, drug or alcohol addiction, or emotional instability; nor does P.S.Q.
The requirements of Appendix B to Part 73 relative to drug / alcohol disqualification and emotional instability relate only to security personnel and are physical or mental criteria. They are not deroga-tory information to be developed through investigation. NAC is appropriate for Part 11 purposes.
o Interval between investigations could range from 5 to 10 years.
We agree that background investigations for clearances granted by NRC should probably follow standard practice and be conducted at no greater than 5 year intervals. However, we would point out that a DOE or D00 l'
employee certified to the NRC as cleared, could not be required meet such a 5 year interval, o Burden of proof regarding an individual's untrustworthiness or unreliability for SNM access is on NRC, unlike information access programs where burden of proof of trustworthiness / reliability is on the individual.
We do not find this to be a serious problem. Other factors (exit searches, 2-man concept, etc.) work in concert with the SNM access authorizations to prevent theft of SNM. On the other hand, once
,information has been possessed by someone who is untrustworthy, the I
information is compromised. j
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Relative to the issue of NRC making the determination that an individual
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should be granted an SNM Access Authorization, we believe that NRC should accept determination by other agencies, certification, if the criteria r
'and scope of investigations meet thase of the NRC regulation.
o Is "grandfathering" acceptable as to:
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- a. accepting certifications,
- b. use of minimum documentation.
- c. waiving 5 year interval for B.I.'s?
- a. Certification appears desirable, especially in reducing licensee r
administrative burdens. This is Davis' view in a nutshell,
- b. Documentation requirements should be minimal if certification g cannot be used, i.e., acceptance of copies.
- c. The 5 year interval for review should probably be preserved, however,
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there may be valid reasons for not doing so.
o Is an NAC to be used to renew U and R's, as implied by the fee schedule?
Probably so, initially.. However, if the NAC review indicates need for further investigation, such additional investigations may be necessary, o Part 11 was revised to clarify a number of security concerns relative to:
- a. OIE inspecting Part 11 for compliance, b, security packets from vendors, consultants,
- c. no visitor control program,
'/ d. Part 11 closing date, and m:n 9L e. Division of Security is to receive copies of amended security plans.
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- o Who grants exemp'tions to 10.CFR Part 11?
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NMSS has responsibility for reviewing security plan amendments which
, licensees submit in accordance with Part 11,11, NMSS would grant exemptions based on those requirements. Division of Security administers the actual granting of SNM access authorizations. They would handle exemptions from relevant administrative requirements.
o A flood of up to 5,000 SNM access authorization applications will have to be spread out.
The number of prospective applicants has declined as indicated by the
.smemo to OPM dated October 30, 1981, This has resulted partly from the feduction in the number of facilities subject to 10 CFR 73.20 (Upgrade q Physical Protection Rule) and p'artly from an increasing definition in
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our knowledge of which jobs require SNM access authorizations.
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