ML20203L552

Forwards Comments on Draft Reg Guide DG-5008, Reporting of Safeguards Events

ML20203L552
Person / Time
Site:	Palo Verde
Issue date:	02/25/1998
From:	AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-63FR275, RTR-REGGD-05.062, RTR-REGGD-5.062, TASK-*****, TASK-RE 63FR275-00009, 63FR275-9, NUDOCS 9803060116
Download: ML20203L552 (14)

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- - , _ , , /). g- 0;m, h 5 /pg Psio Verde Nuclear Jamee M. Levine Lenkt Vee Pretkient T EL (002)393-5300 FAX (002)393-0077 Mall $tation 7602 P.O Box $2034 f

Generating Ltatran Nuclear Phoentx. AZ 05072 2034 102 04082 -JMUDGM/KR February 25,1998 Rules and Directives Branch

• Office of Administration U. S. Nuclear Regulatory Commission _ rs, Washington, D.C. 20555-0001 = 3

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Subject:

Palo Verde Nuclear Generating Station (PVNGS) cg>f; q " 7 9h UrJts 1,2, and 3 b y, ;E  %

Docket Nos. STN 50 528/529/530 Comments on Draft Regulatory Guide DG 5008,

" Reporting of Safeguards Events" yy y,

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Dear Sirs:

In the January 5,1998 Federal Register (63FR21275), the NRC solicited

, comments to Draft Regulatory Guide DG 5008," Reporting of Safeguards Events,' dated December 1997. APS has reviewed DG 5008 and is providing comments in the erselosure.

Please contact Mr. D. G. Marks at (602) 3934492 if you have any questions or would like additional information regarding this matter.

Sincerely,

.L JMUDGM/KR/mah

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Enclosure:

Comments on Draft Regulatory Guide DG 5008 Cc: E. W. Merschoff I i

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Comments on Draft Regulatory Culde DG 5008 2.2 Examples of Safeauards Events To Be Reported Within One tigg

1. Events invoMng adual or attempted theft or diversion of SNM, attempts to steal or divert a shlpment of spent fuel, significant physical damage to a power reactor, or tempering that causes or has the potential to cause an interruption of the rmrmal operation of a licensed nuclear power reactor. (Paragraphs f(a)(1), l(a)(2), and l(a)p) of Appendix G) Thore are no compensatory measures that would preclude reporting this event within one hour.

Paraphrasing of Appendix G (I)(a)(1) through (3) in th's manner is confusing.

APS suggests deleting this example or using a more direct quotation of Appendix G. There is no requirement in Appendix G related to an attempt to steal or divert a shipment of spent fuel. The requirement has since been removed from Appendix G, therefore, it should not be retained as an example,

2. Bomb threat or extortion threats. (Paragraphs l(a)(2) and 1(a)(3) of Appendix G) There are no compensatory measures that would preclude reporting this evern within one hour.

Deleting the reference to " credible" threat is inconsistent with Appendix G (1)(a). In addition, APS believes that the guidance provided in Regulatory Guide (RG) 5.6.2, Revision 1, examples 2.2.1 and 2.4.13 concerning credible threats and unsubstantiated threats is pertinent and should be retained.

3. Discovery of Ulminal ads that have a connection to plant operations or discovery of a conspiracy to bomb the facility or sabotage its vital components. (Paragraphs 1(a)(2), l(a)(3),

1(c), and 1(d) of Appendix G) There are no compensatory measures that would preclude reporting this event within one hour.

This example is too vague when compared to examples 2.2.2 and 2.2.3 provided in RG 5.6.2, Rev.1 which it was intended to replace. APS suggests retaining the original text, excluding examples of events related to 10 CFR Part 26.

4. Discovery of theft or loss of dassified documents or significant unclassified safeguards information outside the proteded area pertaining to facility or transport safeguards for which compensatory measures have not been implemented. (Paragraph l(c) of Appendix G)(Note:

This is also reportable under 10 CFR 95.57 for dassified information.) The licensee should also report results of a search for the dassified documents or safeguards information. See Example 12 of Regulatory Position 2.4 for similar examples involving loss, not theft, of such Information. There are no compensatory measures that would preclude reporting this event within one hour.

The event that is of concern is a "significant degradation of the safeguards system designed to protect classified documents or significant unclassified safeguards information' and as such, no measures can adequately compensate for such an event that would preclude reporting this event within one hour. The event is significant whether or not it occurred inside or outside the protected area. APS recommends that the wording he changed to include the deleted exa_mple 2.2._17 from RG 5.6.2, Rev.1 concerning a compromise-of safeguards information that would significantly assist a person in an act of radiological sabotage or theft of SNM. In addition, example 2.4.12 does

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, Comments cn Draft Regulat:ry Culde DG 5008 discuss loss of significant unclassified safeguards inforrriation, as well as theft of insignificant unclassified safeguards information.

5. Fire or explosion of suspicious or unknown origin within the isolation zone, protocied area, controlled access area, material access area, or vital area. (Note: Events reportable under 10 CFR 50.72 or 50.73 do not require Suplicate reports under 10 CFR 73.71.)(Paragraphs 1(a)(2),1(a)(3), and 1(c) of Appendix G) See Example 4 of Regulatory Position 2.5 for similar examples that need not be reported or logged. There are no compensatory measures that would preclude reporting this event within one hour.

APS suggests that a qualifier be appended to the last sentence related to compensatory measures that states *unless the origin can De determined to be nonsuspicious within one hour and the facility sustained no significant damage."

6. Discovery of a suspicious vehicle following a licensed carrier transporting formula quantitles of SSNM. (Paragraph l(a)(1) of Appendix G) See Example 5 of Regulatory Position 2.5 for similar examples that need not be reported or hSged. There are no compensatory measures that would preclude reporting this event within ona hour.

APS suggests that a qualifier be appended to the last ser.tence related to compensatory measures tnat states "if there is confirmation that a threat exists." In addition, APS concurs with the deletion of example 2.2.7 in RG 5.6.2, Rev.1, f elated to mechanical breakdown of a transport.

7. Complete loss of offsite communications. (Paragraph l(a)(2) or (3) of Appendix G) If offsite commt.nications are restored within one hour of the loss, the licensee r,hould report this event immediately after restoration of communications, if communications cannot be restored within one hour of the loss, the licensee should use attemative means to no'!'y the NRC. There are no compensatory measures that would preclude reporting this event within one hour.

APS believes that this event would only be reportable as a safeguards event if the loss has been confirmed to be of malevolent or suspicious origin. APS suggests adding this qualifier to the example. Otherwise, the event is reportable in one hour under 10 CFR 50.72 (b)(1)(v).

8. Mass demonstration or other civil disturbance at or near the plant site that could pose a threat to the facility. (Paragraphs l(a)(2), l(a)(3), l(b), or 1(d) of Appendix G) There are no compensatory measures that would preclude reporting this event within one hour.

No comment.

9. Tampering with safety or ohvsical orotection equipment that is cohfirmed to be of malevolsnt or suspicious origin. (Paragraphs l(a)(1), l(a)(2), l(a)(3), l(b), l(c), or 1(d) of Appendix G) r ce Example 6 of Regulatory Position 2.5 for similar examples that need not be reported or logged. There are no compensatory measures that would preclude reporting this event within one hour.

The draft RG has developed a new undefined term " physical protectic.i equipment or system and used it intermittently to replace " safeguards" system or " security" equipment or system. APS suggests eliminating the new term.

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10. An assault on a power reactor, facility, or transport possessing or transporting SSNM regardless of whether perimeter penetration is achieved. (Paragraphs 1(a)(2), l(a)(3),1(b), or 1(d) of Appendix G) There are no compensatory measures that would preclude reporting this event within one hour.

No comment specific to the above example. However, APS would question the elimination of two very useful examples listed in RG 5.6.2, Rev.1 as 2.2.13 concerning a confirmed intrusion by unauthorized individuals, and 2.2.14 concerning the uncompensated suspension of safeguard controls during radiological or nonradiological emergencies that could allow undetected or unauthorized access,

11. Discovery of falsified identification b.)ges or key cards. (Paragraph l(a) of Appendix G).

There are no compensatory measures that would preclude reporting this event within one hour; however, steps should be taken immediately to cancel the badges or key cards from the access system and to determine to what extent the badges or key cards have been used.

, This example appears to duplicate example 2.2.12. APS suggests combining examples 2.2.11,2.2.12,2.2.16, and 2.2.21 dlnce they all are related to badges, key cards, or access devlees.

12. Discovery of uncompensated and unaccounted for, lost, or stolen key cards, identification card blanks, keys, or any access device that could allow unauthorized or undetected access to protected areas, controlled access areas, or vital areas. (Paragraph l(c) of Appendix G)

See Example 6 of Regulatory Position 2.4 for similar examples that need only be logged See Appendix C for a discussion of acceptable compensatory measures.

APS suggests combining examples 2.2.11,2.2.12,2.2.16, and 2.2.21 since they all are related to badges, key cards, or access devices. Appendix C does not contain any discussion related to acceptable compensatory measures for this event. APS has suggested an addition to the appendix and adding a sentence to see Appendix C for a dicussion of acceptable compensatory measures.

APS agrees with the deletion of example 2.2.17 of RG 5.6.2, Rev.1 concerning the compromise of safeguards information since it is covered by example 2.2.4 of this document.

13. (;i, compensated loss of all ac power supply to security systems that could allow unauthorized or undetected access to a protected area, material access area, controlled access area, or vital area. (Paragraph l(c) of Appendix G)

APS suggests adding a sentence to see Appendix C for a discussion of acceptable compensatory measures. In addition, add the phrase "(i.e., no standby power available)" to'!owing "ac power supply" for quick clarification.

14. Uncompensated loss of the ability to r,etect intmslon (a) at the protected area perimeter when the loss involves severalintrusion detection system zones or (b) within a single intrusion detection system zone when the condition could become known to a person not authorized unescorted access, eitl er because it lasts for a considerable time or is visually conspicuous 3

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Comments en Draft Regulat:ry Guide DG 5008 to the casual observer. (Paragraph l(c) of Appendix G) See Examples 3 and 4 of Regulatory Position 2.4 for similar exarnples that need only to be logged.

APS suggests adding a sentence to see Appendix C for a discussion of acceptabla compensatory measures.

15. Uncompensated loss of alarm capability orlocking mechanism on a vital area portal. 1 (Paragraph l(c) of Appendix G) See Example 9 in Regulatory Position 2.4 for similar l examples that need only to be logged.

The reference to material access area has been deleted in this example, and a new e%mple 2.2.20 has been created. APS suggest recombining example 2.2.20 with example 2.2.15. Example 7 in Regulatory Position 2.4 is the correct cross-reference. APS suggest1 adding a sentence to see Appendix C for a discussion of acceptable compensatory measures.

16. Improper control (to include loss or offsite removal) of access control media, including picture badges, keys, key cards, or access control computer codes, that results in someone using the medium during the time that it is not controlled. (" Improper control" as used here, does not include approved systems allowing employees to take badges offsite.) See Example 18.7

( f Regulatory Position 2.4 for similar examples that need only to be logged. See Example 9 cf Regulatory Position 2.5 for similar examples that need not be reported or logged.

Th's example appears to duplicate example 2.2.12. APS suggests combining dxamples 2.2.11,2.2.12,2.2.16, and 2.2.21 since they all are related to badges, key cards, or access devices.

17. Incomplete or inaccurate preemployment screening records (to include falsification of background information or inadequate administration, control, or evaluation of psychological tests) if the licensee would have denied unescorted access based on knowledge of the complete or accurate information, had a complete preemployment screening been done. See Example 18,9 of Regulatory Position 2.4 for similar examples that need only to be logged.

No comment.

18. Unavailability of a minimum number of security personnel or an actual or imminent strike by the guard force. (Paragraph l(c) of Appendix G)

APS suggests adding an acceptable compensatory measure to Appendix C and adding a sentence to see Appendix C for a discussion of acceptable compensatory measures.

19. Loss of a security weapon onsite that is not tetrieved within one hour of the discovery ofits loss. See Example 13 of Regulatory Position 2.4 for similar examples that need only to be logged.

No comment -

20. Loss of alarm capaoility orlocking mechanism on a material access area portal.

APS suggest recombining example 2.2.20 with example 2.2.15.

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Comments on Draft Regulatory Culde DGi5008

21. Discovery of unaccounted for, lost, or stolen keycards, identification card blanks keys, or any access device that could allow unauthorized or undetected access to material access areas.

This example appears to duplicate example 2.2.12. APS suggests combining examples 2.2.11,2.2.12,2.2.16, and 2.2.21 since they all are related to badges, key cards, or access devices.

22. At a fuel facility, loss of the capability at a ungle alarm station to monitor or remotely assess alarms.

APS suggests explicitly exetuding a power reactor since example 2.4.10, a loggable event, would appear to conflict with this example.

APS suggests reinstating an example similar to example 2.2.23 from RG 5.6.2, Rev.1.

, 23. Discovery of the actual or attempted introduction of contraband into or l

possession of contraband within the protected area, material access area, or vital area. (Paragraph l(d) of Appendix G) See Example 16 of Regulatory Position 2.4 for similar examples that need only to be logged.

APS suggests adding an example that addresses intentional tailgating by an unauthorized person.

24. An intentional entry of cn unauthorized person into a protected area, mater;al access area, controlled access area, vital area, or transport and malevolent intent has been established. See Example 18.4 of Regulatory Position 2.4 for similar examples that need only to be logged.

2.4 Examples of Sefeauards Events To Be Loaaed

1. Properly compensated security computer failures. (Paragraph Il(a) of Appendix G)

APS suggests adding a sentenes to see Appendix C for a discuss!on of acceptable compensatory measures.

2. Properly compensated vital area card reader failures. (Paragraph II(a) of Appendix G)

APS suggests adding a sentence to see Appendix C for a discussion of

, acceptable compensatory measures.

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3. Loss of ability to detect within a single intrusion detection system zone for a short period of time. See Example 14 of Regulatory Position 2.2 for similar examples that must be reported within one h)ur.

No comment.

4. Properly compensated loss cltha ability to detect intrusion (a) at the protected area perimeter when the loss involves several intrusion detection system zones or (b) within a single 5

, Comments on Draft Regulat':ry Culdo DG 5008 Intrusion detection system zone when the condition could become known to a person not authorized unescorted access, either because it lasts for a considerable time or is visually conspicuous to the casual observer. (Paragraph l(c) of Appendix G) See Example 14 of Regulatory Position 2.2 for similar examples that must be reported within one hour.

APS suggests adding a sentence to see Appendix 0 for a discussion of I acceptable compensatory measures.

5. Properly compensated failure or degradation of a single perimeter lighting zone below the acceptable standard described in the physical security plan, if the intrusion detection system remains operational. (Paragraph ll(a) of Appendix G)

APS suggests adding an acceptable compensatory measure to Appendix C and adding a sentence to see Appendix C for a discussion of acceptable compensatory measures.

6. Accidental removal offsite or loss of access badge or other access medium,if measures have l been taken within 10 minutes of the discovery of the loss to preclude the use of the badge to I gala access to a controlled area and to ensure that the badge has not been used in an unauthorized man. er, if an access control system also uses biometrics, the loss of an access badge or keycard does not need to be logged. (Paragraph Il(a) of Appendix G) See Example 12 of Regulatory Position 2.2 for similar examples that must be reported within one hour.

APS suggests combining examples 2.4.6,2.4.18.5, and 2.4.18.7 since they all are related to badges, key cards, or access devices. Appendix C does not contain any discussion related to acceptablu compensatory measures for this event. APS has suggested an addition to the appendix and adding a sentence to see Appendix C for a discussion of acceptable compensatory measures.

7. Properly compensated loss of either alarm or locking mechanism on a vital area portal.

(Paragraph ll(a) of Appendix G) See Example 15 of Regulatory Position 2.2 for similar examples that must be reported within one hour, The reference to material access area has been deleted in this example. The corresponding compensatory measure in Appendix C still retains the reference to material access area. APS suggests retaining the reference to material access areas and adding a sentence to see Appendix C for a '

discussion of acceptable compensatory measures.

8. Security computer failures that have the potential to reduce the effectiveness of the physical protection system. (Paragraph ll(b) of Appendix G)

APS suggests replacing the text following "failm G:th *that may not enable unauthorized or undetected access' and/or comb,;mg this example with example 2.4.1

9. Property compensated loss of alarms, closed circuit television, or security computers. The loss of backup capability may also be only logged if immediate restoration of system 6

, Comments cn Draft Regulat:ry Culde DG 5008 capability is provided by activating secondary computers. See Examples 15 and 16 in Regulatory Position 2.2 for similar examples that must be reported within one hour.

Examples 2.2.15 and 2.2.16 are not related to this example. APS suggests adding a sentence to see Apperdix C for a discussion of acceptable compensatory measures.

Footnote 2:

Posting personnel as a compensatory measure implies that the personnel are capable of performing the lost or degraded function. When they cannot perform that function, such as when they are asleep, there is an uncompensated loss that must be reported within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery, Preplanned compensatory measures are normally described in NRC approved safeguards plans.

A Generic Letter (GL) 91-03 example states that "A failed compensatory measure such as inattentive or sleeping acurity personnel, or equipment that fails after being successfully Jstablished as an effective compensatory measure for a degrcded security system" ... is an example of a safeguards event that does not need to be reported to the NRC withln 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery. APS requests that the GL wording be retained.

10. At a power reactor, loss of the capability of a single alarm station to monitor or remotely assess alarms, but monitortng or assessment capability remains in other stations. (Paragraph ll(b) of Appendix G)

APS suggests adding a sentence to see Appendix C for a discussion of acceptable compensatory measures.

11. For shipments of formula quantities of SSNM, intra-convoy communications ability is lost but at'itity to communicate with movement control center remains. (Paragraph ll(b) of Appendlx G)

No comment.

12. Loss of unciassified safeguards information when there does not appear to be evidence of theft and, within the first hour after the discovery, the information is retrieved and determined not to have been in the possession of an unauthorized person, or theft of such information when (i) the information would not have allowed unauthorized or undetected access to a protected area, material access area, controlled access area, vital area, or transport, or (ii) the vulnerability caused by the loss of the information is fully compensated upon discovery.

See Example 4 of Regulatory Position 2.2 for similar examples that must be reported within one hour.

APS suggests that the following wording currently in GL 91-03 be included in this example: " Compromise (including loss or theft) of safeguards information that would not significantly assist on individualin an act of radiological sabotage or theft of SNM." This would be equivalent to combining example 2.4.17 with this example.

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. Comments on Drt.it Regulat:ry Culde DG 5008

13. Loss of a security weapon onsite that is retrieved within one hour of the discovery of its loss.

See Example 19 of Regulatory Position 2.2 for similar examples that must be reported within one hour.

No comment.

14, Properly compensated closed circuit television failure in a single zone while the intrusion detection system remains operational. (Paragraph Il(a) of Appendix G)2 APS suggests adding an acceptable compensatory measure to Appendix C and adding a sentence to see Appendix C for a discussion of acceptable compensatory measures.

16. A design flaw or vulnerability in the physical barrier of a proteded brea, controlled access area, or vital area that could have allowed unauthorized access. (Paragraph ll(s) of Appendix G)

No comment.

18. Disce very of contraband inside the protected drea that is not a significant threat. (Paragraph ll(b) of Appendix G)

APS suggests including the guidance provided in GL 91-03: 'For example, such a condition could be the discovery of a few bullets. If contraband is found in a vehicle located in a parking lot outside the protected area, normally no report or log entry is required." In addition APS suggests including the guidance provided in RG 5.62, Rev.1: "The discovery of vehicular emergency equipment such as safety flares during entrance searches need not be reported or logqed." APS also suggests adding the cross-reference to example 2.2.23 : 'See iExample 23 of Regulatory Position 2.2 for similar examples that must be reported within one hour."

17, Compromise of safeguards information that would not significantly assist an Individualin gaining unauthorized or undetected access to a facility or would not signiricantly assist an individualin an nct of radiological sabotage or theft of SNM. (Paragraph Il(a) of Appendix G) i APS suggests combining this example with example 2.4.12.

i 18. Partial failure of an otherwise satisfactory access authorization or access control program.

The following are examples of partial failure.

l l 18.1 An employee or vendor who has br .i cleared and authorized to receive a badge l permitting unescorted access to pra',.ted and vital areas inadvertently enters the protected area improperly, e g.. through a unilcle gate, without being searched and issued a badge.

The licensee discovers the event, searches the Individual, issues a badge, and taker corrective action to prevent recurrence.

No comment.

18.2 Search equipment does not perform properly, which could allow unsearched individuals to enter the protected area, and the licensee does not detect the failure for a short period.

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Comments on Draft Regulatory cuide DG 6008

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See Example 8 in Regulatory Position 2.5 for similar examples that do not need to be reported or logged.

No comment.

18.3 An individual who is required to have an escort for a particular area inadvertently becomes separated from his or her escort but the escort or another person authorized for unescorted access recognizes the situation within several minutes and corrects it.

APS suggests including the additional guidance found in GL 91-03 for this event: *Further, if an individual separates from his or her escort to use a rest room which has limited mecos of egress and the escort remains nearby and has full view of the egress area, no report or log entry is required."

18.4 An employee of a licensee or cocctor who is authorized entry to a vital area enters that vital area improperiy without realizing s at the card reader is processing a preceding employee's card, or the employee walks in behind another employee without using a key card.

APS suggests including the additional guidance found in GL 91-03 for this event: "This event can be logged even if the employee was not authorized access to any VA, if the improper entry was inadvertent or without malevolent intent."

18.5 An individud enters a vital area to which he or she is authorized unescorted access by mistakenly r an access control medium (key card or badge) Intended for another individual w,t also authorized unescorted access to the area.

This example appears to duplicate example 2.4.6. APS suggests combining examples 2,4,6, 2.4.18.5, and 2.4.18.7 since they all are related to badges, key cards, or access devices.

l 18.6 An individual is incorrectly issued a badge granting access to vital areas to which he or she is not authorized, but does not enter any vital areas or does not enter any vital areas with malevolent intent. Another example is an individual who is incorrectly issued a badge but cannot reasonablNe it because he or she does not know the personal identification number needed to enter Ine area, and the event is promptly discovered and corrected by the licensee.

APS suggests that the guidance issued in GL 91-03 stating "Further, if an Individual is incorrectly issued a badge, but cannot reasonably use it because he or she does not know a personal identification number (PIN) needed to enter the PA, the event need not be reported or loooed if it is promptly discovered and corrected" be retained.

18.7 Improper control (to include loss or offsite removal) of access control media, including picture badges, keys, key cards, or access control computer codes, that could be used to gain unauthorized or undetected access, when the event is discovered and corrected by the licensee. See Example 16 in Regulatory Position 2.2 for similar examples that must be 9

Comments cn Draft Regulat*ry Cuide DG.5008 reported within one hour. See Example 9 in Regulatory Position 2.5 for similar examples that need no'. be reported orlogged.

This example appears to duplicate example 2.4.6. APS suggests combining examples 2.4.6,2.4.18.5, end 2.4.18.7 since they all are related to badges, key cards, or access devices.

18.8 Card reader fa. lure that causes vital area doors to unlock in the open position or to lock in the closed position but with no functional door alarm. See Example 10 of Regulatory Position 2.5 for similar examples that need not be reported or logged.

No comment.

18.9 incomplete or inaccurate preemployment screening records or inadequate administration, control, or evaluation of psychological tests that would not necessarily have resulted in a denial of access. See Example 17 of Regulatory Pesition 2.2 for similar examples that must be reported within one hour.

No comment.

2.5 Events Not Reauired To Be Loaaed or Reported

1. Cuts made by authorized maintenance personnel through a material access area or vital area barrier for a legitimate reason (e.g., to install a pipe) with prior approval, coordination w'th security, and proper compensatory measures.

No comment.

2. A child attempting to climb a protected area fence.

No comment.

3. Infrequent nuisance alarms caused by mechanical or environmental problems and false alarms that do not exceed the rates committed to in the licensee's approved ohysical protection plan or do not degrade system effectiveness.

No comment.

4. A fire or explosion if the origin can be determ'ned within one hour, to be nonsuspicious and the facility sustains no significant damage. See Example 5 of Regulatory Position 2.2 for similar examples that must be reported within one hour.

No comment.

5. A suspicious vehicle following a transport that is determined within one hou=, not to be a threat. See Example 6 of Regulatory Position 2.2 for similar examples that must be reported within one hour.

No comment.

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Comments on Draft Regulatory Culde DG 5008

6. Suspected tarnpering with safety equipment that is determined, within one hour, not to be tampering. See Example 9 of Regulatory Position 2.2 for similar examples that must be reported within one hour.

APS suggests including the qualifier that malevolent intent has not established nor is it of suspicious origin.

7, Olscovery of vehicular emergency equipment such as safety flares during entrance searches, unless the introduction was done for malevolent purposes.

No comment.

8. Failure of search equipment if the failure is discovered by the licensee before anyone goes through unsearched and the licensee uses other equipment with the same capabilities (such as hand held or walk through search devices). See Example 18.2 of Regulatory Position 2.4 for similar examples that need to be logged.

No comment.

9. Improper control (to include loss or offsite removal) of access control media, including picture badges, keys, key cards, or access control computer codes, that the licensee determines could not be used to gain unauthorized or undetected access. See Example 16 of Regulatory Position 2.2 for similar examples that must be reported within one hour. See Example 18.7 of Regulatory Position 2.4 for similar examples that need only to be logged.

No comment.

10. Card reader failure that causes vital area doors to lock in the closed position but the door alarm functions property, provided that access control measures are implemented before allowing individuals into the vital areas. See Example 18.8 of Regulatory Position 2.4 for similar examples that need only to be logged.

No comment.

APPENDIX A - GLOSSARY Safeguards system. The equipment, personnel, and procedures that make up the physical protection program necessary to meet Part 73 requirements.

The dr 4" b G has intermittently replaced " safeguards" system or " security" equipm n or system with a new undefined term

• physical protection" equipment or system. APS recommends the term usage remain consistent with glossary.

APS also suggests expanding the definition to include the following guidance:

Safeguards systems include equipment, procedures, and personnel practices; therefore, failures include not only mechanical and electrical system failures but also improper security procedures and inadequate or inadequately implemented personnel practices.

APS recommends adding " Discovered vulnerabilities" to the glossary.

Discovered vulnerabilities include significant flaws in the safeguards system I that could result in a reduction in overall nrotection at the site.

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Comments en Drc.ft R:gulattry Guid) DG 5008

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AEEENDlLC _COMEENDAIDMEEASWEB Vital area card readers. An e otable compensatory measure for this failure would be posting a secudty force member witt spriate access lists and communications capability at each door.

APS suggests adding ti ' requirement 'within 10 minutes of Mcovery of the

- fsilure."-

APS suggests adding the following compensatory measures to Appendix C:

Lost, or stolen key cards, identification card blanks, keys, or any access.

Such events need not be reported within i hour if measures are taken within 10 minutes of the discovery of the loss to preclude the use of the lost or stolen device for gaining access to a controlled area and to ensure that the lost or stolen device has not been used in an unauthorized manner prior to completion of actions to prevent unauthorized use of the device, i 1

Unavailability of minimum number of security personnel or an actual or

!. Imminent strike by the security force. If an unexpected unavailability of a minimum number of security personnel occurs, procedures pre-approved by the NRC may be used; or "on call" guards or trained management, supervisory, or operations personnel available within 10 minutes may be used to supplement the on-duty security force.

Degradation of single perimeterlighting zone. Measures to properly compensate for failure or degradation of a lighting zone must be implemented within 10 minutes of discovery and may include (1) using standby power, (2)

= using low light level surveillance devices, (3) using portable lighting systems, or (4) posting dedicated observers with appropriate communications equipment to provide an equivalent le vel of protection.

Closed circuit television feilure. Provide other assessment capability, such as a dedicated observer with appropriate communications onpability be posted within 10 minutes of discovery of the failure.

12 m.