ML20206E588
| ML20206E588 | |
| Person / Time | |
|---|---|
| Issue date: | 04/29/1985 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Jennifer Davis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 8606230446 | |
| Download: ML20206E588 (60) | |
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APR 2 91985 MEMORANDUM FOR: John G. Davis, Director Office of Nuclear Material Safety and Safeguards FROM: William J. Dircks Executive Director for Operations
SUBJECT:
CONTROL OF NRC RULEMAKING By memorandum of February 13, 1984, " Control of NRC Rulemaking by Offices Reporting to the EDO," Offices were directed that effective April 1, 1984, (1) all offices under EDO purview must obtain my approval to begin and/or continue a specific rulemaking, (2) resources were not to be expended on rule _
makings that have not been approved, and (3) RES would independently review rulemaking proposals fcrwarded for my approval and make recommendations to me concerning whether or not and how to proceed with the rulemakings.
In accordance with my directive, the following proposal concerning rulemaking has been forwarded for my approval.
Proposed revision of 10 CFR Part 73, " Physical Protection of Plants and Materials: to clarify policy concerning the designation and protection of nuclear power plant vital areas containing safety-related equipment.
(Sponsored by NMSS - memorandum, Minogue to ED0 dated April 9,1985.)
I approve continuation of this rulemaking. The NRC Regulatory Agenda (NUREG-0936) should be modified to reflect the status of this rulemaking.
Wgne6Wi!!!a:3l. Dirc';;
William J. Dircks Executive Director for Operations cc: V. Stello J. Roe H. R. Denton J. Taylor R. B. Minogue B606230446 850429 EDO RM P. G. Norry 73 PDR Distribution:
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MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM: Robert B. Minogue, Director Office of Nuclear Regulatory Research
SUBJECT:
CONTROL 0F NRC RULEMAKING: RES INDEPENDENT REVIEW 0F ONG0ING RULEMAKING SPONSORED BY NMSS Based on our independent review of ongoing rulemaking, " Miscellaneous Amendments Concerning Physical Protection of Nuclear Power Plants" (10 CFR Part 73),
sponsored by NMSS, RES recommends that this rulemaking effort should continue.
This proposed rule is a part of the Insider Rule Package, along with the Access Authorization Rule and the Search Requirements Rule. All 3 proposed Rules were published together on August 1, 1984 for public comment because of their marked interrelationship. The public coment period has ended as of March 7,1985 and the staff is currently analyzing the comments.
The basis for our recommendation to continue this segment of the rulemaking is as follows:
The proposed rule would clarify the policy for the designation and protection of vital areas in nuclear power plants containing safety-related equipment.
Particular concern has been focused on ensuring that security measures do not impede plant safety. Inspections have also indicated that certain physical security equipment is not now protected as vital, despite the fact that this equipment safeguards vital areas containing essential safety-related equipment.
In addition, experience with present requirements for key and lock controls indicates that 573.55 can be modified to provide more flexibility in this area while maintaining adequate plant protection. The staff believes that the clarification and refinement of requirements, as reflected in these amendments, is appropriate because they afford the increased assurance of plant safety.
Since requirements for protecting vital areas have been in effect for some time, and modifications to those requirements are needed, alternatives to this rulemaking such as revised guidance would be inappropriate in that they would not carry the force of a regulation.
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William J. Dircks 2 APR 9 1985 Costs for these improvements are estimated at $850K per site. The impact on NRC operations will occur in the area of licensing review of amended licensee security plans and Inspection and Enforcement staff support time. Initial cost to the NRC is estimated to be $299.5K and tstimated annual cost in subsequent years is $37.4K.
The benefit that would be derived from the Insider Rule package as a whole would be to improve the practicality and effectiveness of measures to protect against the insider threat at power reactor facilities while enhancing plant safety.
The Miscellaneous Amendments portion of the Insider Rule package specifically addresses enhancing safety through fewer access control points, and improved provisions for vital equipment access control during both routine and emergency conditions as well as facilitating response to emergency conditions.
The Director of NMSS recommended continuation of this rulemaking.
The complete RES independent review package has been sent to OED0 (Attention:
DEDROGR) and to the Director, NMSS. .
~b bL N Robert B. Minogue, D r ctor Office of Muclear Regulatory Research
Enclosure:
RES Staff Review Summary Sheet i
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APR9 1985 MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM: Robert B. Minogue, Director Office of Nuclear Regulatory Research
SUBJECT:
CONTROL 0F NRC RULEMAKING: RES INDEPENDENT REVIEW 0F ONGOING RULEMAKING SPONSORED BY INSS Based on our independent review of ongoing rulemaking, " Miscellaneous Amendments Concerning Physical Protection of Nuclear Power Plants" (10 CFR Part 73),
sponsored by NMSS, RES recommends that this rulemaking effort should continue.
This proposed rule is a Ntrt of the Insider Rule Package, along with the Access Authorization Rule and tte Search Requirements Rule. All 3 proposed Rules were published together on August 1, 1984 for public comment because of their marked interrelationship. The public comment period has ended as of March 7,1985 and the staff is currently analyzing the connents.
The basis for our recommendation to continue this segment of the rulemaking is as follows:
The proposed rule would clarify the policy for the designation and protection of vital areas in nuclear power plants containing safety-related equipment.
Particular concern has been focused on ensuring that security measures do not impede plant safety. Inspections have also indicated that certain physical security equipment is not now protected as vital, despite the fact that this equipment safeguards vital areas containing essential safety-related equipment.
In addition, experience with present requirements for key and lock controls indicates that 573.55 can be modified to provide more flexibility in this area ;
while maintaining adequate plant protection. The staff believes that the l clarification and refinement of requirements, as reflected in these amendments, !
is appropriate because they afford the increased assurance of plant safety. l 4
Since requirements for protecting vital areas have been in effect for some time, and modifications to those requirements are needed, alternatives to this rulemaking such as revised guidance would be inappropriate in that they would not carry the force of a regulation. I l
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Villiam J. Dircks 2 APR 9 3 85 Costs for these improvements are estimated at $850r. per site. The impact on NRC i operations will occur in. the area of licensing review of amended licensee ,
security plans and Inspection and Enforcement staff support time. Initial cost I to the NRC is estimated to be $299.5K and estimated annuel cost in subsequent l years is $37.4K. 1 The benefit that would be derived from'the Insider Rule package as a whole would be to improve the practicality and effectiveness of measures to protect against the insider threat at power reactor facilities while enhancing plant safety.
The Miscellaneous Amendments portion of the Insider Rule package specifically addresses enhancing safety through fewer access control points, and improved provisions for vital equipment access control during both routine and emergency conditions as well as facilitating response to emergency conditions.
The Director of N"SS recomended continuation of this rulemaking.
The complete RES independent review package has been sent to OEDO (Attention:
DEDROC,R) and to the Director, NMSS.
Originalsigned by: )
B9ERE bM J Robert B. Minogue, Director Office of Nuclear Regulatory Research
Enclosure:
RES Staff Review Sumary Sheet I , DISTRIBUTION:
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( NRC FORM 318 (10-80) NRCM O24 OFFICIAL RECORD COPY
RES STAFF REVIEW
SUMMARY
SHEET
- 1. Review of the completeness of the Rulemaking Review Package:
- a. The NRC Regulatory Agenda entry has been updated to reflect the most current status'of.the rule.
- b. The rulemaking package as it was pubiished in the Taderal Register as a proposed rule (49 FR 30735, 8/1/84) is complete.
- c. The sponsoring office Director's recomendation to the ED0 concerning continuation with the proposed rulemaking is included.
- d. The results of the sponsoring office review (Evaluation for Rulemaking) was not included in this package.
- e. A copy of the Comission paper, regulatory analysis (value/ impact statement), and a proposed draft regulatory guide were complete and included in the analysis. Not included was the CRGR package.
However, since the rule has already been published in proposed form, the CRGR had previously reviewed the package and their i
recomendations were addressed in the Commission paper.
- f. No sumary sheets, forms, or other documentation were requested by OEDO or "others" to assist in their review of the rulemaking.
Therefore, no such items were included in the review package.
- 2. Results of Review by the RES Task Leader:
- a. The proposed rule package clearly addresses the problems to be corrected. Years of operating experience had revealed a need for clarification and refinement of the proposed issues.
- b. The necessity and urgency of the proposed rulemaking are reasonable as presented in the package. This rule is a revision of the proposed rule entitled " Access Control to Nuclear Power Plant Vital Areas", (3/12/80 45FR 15937). Initial development of :
a final rule produced significant changes, resulting in the need '
to publish a revised proposed rule. ,
- c. The alternative to rulemaking stated in the rule package I appears to be reasonable.
- d. The issues addressed through the rulemaking, which are: (1) the designation of vital areas (to allow vital islands), (2) access controls to vital islands, (3) the protection of certain physical security equipment, (4) revised requirements for key and lock
- contro k (5) revised authority to suspend safeguards measures during emergencies, and (o) tne concurrent pubitcaticii cf a proposed regulatory guide, are sound. . j i ._ _ _- _ -_ __ __ _ . _ _ _ _
2
- e. The value/ impact analysis contained in the proposed rule package adequately addressed the impact to the public, industry, and NRC, including benefits and costs.
- f. The NRC resources and scheduling needed for this proposed rulemaking were analyzed and judged to be reasonable.
- 3. General Coments and Recomendations:
- a. The proposed subject actions are intended to clarify and/or modify certain existing physical protection requirements for nuclear power plants. These actions, when implemented, will reduce unnecessary burden on the industry while continuing to maintain adequate plant protection.
- b. It is recommended that this proposed rulemaking should proceed.
The staff is currently reviewing public comments, and any modifications to this rule would be a result of incorporating needed changes.
1
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'.....* 2, MAR 2 21985 MEMORANDUM FOR: J. A. Norberg, Chief Numan Factors and Safeguards Brcrch, DRA0 ;
FROM: Frank P. Gillespie, Chainnan RES Independent Review Board
SUBJECT:
CONTROL OF NRC RULEMAKING: RES INDEPENDENT REVIEW l 0F ONG0ING RULEMAKING Enclosed is a rulemaking RES independent review. (review1)package received from a sponsoring office for Enclosure In accordance with procedures approved by the EDO on May 30, 1984, the rule-making review package is assigned to your branch for action. (Enclosure 2).
The ED0-approved procedures allow a total of 20 working days for completing the RES independent review. To assist RES in completing its independent review in a timely manner, please submit the draft independent review package for this specific rulemaking to RAMRB by 7 working days from the date of this memorandum.
Frank P. Gillespie, Chairman RES Independent Review Board
Enclosures:
- 1. Miscellaneous Amendments Concerning Physical Protection of Nuclear Power Plants (PartofInsiderPackage)(10CFR73)
- 2. Procedures for Conducting RES Independent Review of Rulemakings l
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OFFICE REVIEW PACKAGE RECEIVED FROM NMSS
- y s teren 70 , UNITED STATES
,i NUCLEAR REGULATOR */ COMMISSION
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MEMORANDUM FOR: William J. Dircks l Executive Director for Operations FROM: John G. Davis, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
CONTROL OF NRC RULEMAKING - EDO QUARTERLY REVIEW In response to your memorandum of February 13, 1984, and in accordance with instructions provided in subsequent memoranda from the Office of Nuclear Regu-latory Research (NRR), the Office of Nuclear Material Safety and Safeguards (NMSS) has reviewed the ongoing or proposed rulemaking activities listed in Attachment 1 to this memorandum. On the basis of our review, we recommend approval of continued activity on these rules, with the exception of "Certifi-cation of Industrial Radiographers" and " Shallow Land Disposal of Radioactive Waste". Staff efforts on these are now directed toward terminating the two rulemaking activities. -
Also, as directed by your memorandum and the subsequent instructions from RES, we have prepared Review Packages for all of the listed rulemaking activities.
These are included as attachments to this memorandum, with copies forwarded to RES and the other reviewing offices.
1 r- ,'
J hn G. Davis, Director Office of Nuclear Material Safety and Safeguards Attachments:
l
k6 DIVISION OF SAFEGUARDS
" Miscellaneous Amendments Concerning Physical Protection of Nuclear Power Plants (Part of Insider Rule Package)"
Contact:
John Davidson 427-4708 I
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e NRC REGULATORY AGENDA ENTRY O
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Miscellaneous Amendments Concerning Physical Protection of Nuclear Power Plants (Part of Insider Rule Package)
, CFR CITATION: !
10 CFR 73 ABSTRACT:
The proposed rule would require in Nuclear Power Plants (1) the designation of vital areas (to allow vita 1' islands), (2) access controls to vital islands (3) requirements (4) revised the protectionfor of key certain and physical lock controls,security and(equipment,5) revised authority t'o suspend safeguards measures during emergencies. (Years of operating experience revealed a need for clarification and refinement.)
The requirements will clarify policy in these areas and reduce unnecessary burden on the industry while maintaining plant proteciton. This rule is ,
a revision of the proposed rule entitled, " Access Control to Nuclear Power Plant Vital Areas." Initial development of a final rule produced signi- r !
ficant changes, particularly the criteria for personnel access controls to vital areas, resulting in the need to publish a revised proposed rule.
This proposed rule and the other components of the insider rule package were reviewed by the NRC Safety / Safeguards Review Comittee which considered a number of alternative approaches to vital island configurations and provided recomendations that are reflected in the proposed rule.
Since requirements for protecting vital areas have been in effect for some time, and modifications to those requirements are needed, alternatives to this rulemaking such as revised guidance would be inappropriate in that they would not carry the force of a regulation.
1 Costs for these improvements are estimated at $850K per site. The impact on NRC operations will occur in the area of licensing review of amended
- licensee security plans and Inspection and Enforcement staff support time.
Initial cost to the NRC is estimated to be $299.5K and estimated annual cost in subsequent years is $37.4K.
TIMETABLE Previous NPRM 03/12/80 45 FR 15937 i
NPRM 08/15/84 49 FR 30735 NPRM Comment Period Begin 08/15/84 49 FR 30735 '
i NPRM Coment Period End 03/07/85 Final Action 09/85 LEGAL AUTHORITY 42 USC 2101; 42 USC 5841 EFFECTS ON SMALL BUSINESS AND OTHER ENTITIES: No
-- , , , - . .- , -- ,_- . . - - - - - - . , - , - - . , . ~ . - - - - - . - - - , - - - - - - , - , - - - . v,- ,
TITLE:
Miscellaneous Amendments Concerning Physical Protection of Nuclear Power Plants (Part of Insider Rule Package)
AGENCY CONTACT:
John J. Davidson Office of Nuclear Material Safety and Safeguards Washington, DC 20555 301 427-4708 e
- o e.
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TITLE: '
Miscellaneous Amendments Concerning Physical Protection of Nuclear Power Plants (Part of Insider Rule Package).
, CFR CITATION:
fi ABSTRACT:
- The proposed rule would require in . Nuclear Power Plants -(1) the
) designation of vital areas (to allow.vit'al islands), (2) access l controls to vital islands, (3) the protection of certain physical security equipment, (4) revised requirements for key and lock controls, and (5) revised searches of hand-carried items at protected area entry points. The requirements will clarify policy in these areas and reduce unnecessary burden on the industry while maintaining plant protection. This ruls is a revision of the proposed rule entitled " Access Controls to Nuclear Power l Plant Vital Areas." Initial development of a final rule produced a significant changes, particularly the criteria for personnel i access controls to vital areas, resulting.in the need to publish a revised proposed rule. This proposed rule and the other components of the insider rule package were reviewed by the NRC Safety / Safeguards Review Committee which considered a number of j alternative approaches to vital island configurations and j provided recommendations that are reflected in the proposed rule.
Since requirements for protecting vital areas have been in i
effect for some time,'and modifications to those-requirements are needed, alternatives to this rulemaking such as revised guidance would be inappropriate in that they would carry
- the force of a regulation.
-Costs for these improvements are estimated at $850,000 per site. The impact on NRC operations will occur in the area of licensing review of amended licensee security plans and
' ' Inspection and Enforcement staff support time. Initial cost to the NRC is estimated to be $299,500 and estimated annual cost _ in l . subsequent years is $37,400.
TINETABLE:
NPRM 08/01/84 49 FR 30726 .
NPRM Comment Period Begin 08/01/84 j Comment period extended 12/11/84 49 FR 48200 NPRM Comment Period End 03/07/85 Final Action 09/00/85 LEGAL AUTHORITY:
42 USC 2101; 42 USC 5841 EFFECTS ON SMALL BUSINESS AND OTHER INTI' TIES: No I"
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me RULEMAKING AS CURRENTLY PROPOSED e
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! 8edsomt nav a-r / vel es; nie, ses / wed a % August 1. 2006 / Pteposed Rdas 3535 1squisemanas furPhgehnlpmesotion af What Isised P=amdA== and Asamme IJoensed Aselvities b Nudear power Commel Sabotage, On Mendi 22. ages, the Mtc published ammim
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portaking to nuclear powerplant vital proesado.s
- of. vital areas contidning access emmeralles FR18557).public
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to CpR part ya d'in's~been loamsed om sosetng comument mee tuvised and seesired. The that security messores do not tuspede #'===i-i- has signiScantly mised tilacemeneous Amendments . plant . Inspections how also these requiremanes to assure adequete conoorning physical protection of indicetod t certain physicalsecurity *oco88 for purposes winie
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- Ph"88 alnipment is not now protected as vital. "'"""P""r **8'5"*'d*
despite the fact that this equipment -- - * *= to 10 GR asencv: Nuclear Regulatory ys.se(d)(7) are now proposed that Comunimion. =' . ;1 vital a eas containing
- ii*I : -"J, ..' ted equipment. In adstress %acesmergency and ACTiest proposed rule. emergency acones contmleto vital addedon, experience with present eunasany:h NuclearRegalatory - for key andlock somtrols islanda. ,
r-i-is proposing to eased its ku Revised ======g==7 ogstrols anciser power plant seisgaards licates that proeidemore i 7sA6 A=vihilityin isares can b.e =arilA=d (1) the to *h of up.to.
date =====g==7 acones lista. (2) a
- .- '-M to clarify and seene while maintaining adequate requireasota for the designation and preemetion.The Osumissism MMpdresemat that acosas centsel devices protection of vitallesetions --amining that the alariSostion and raamament of be retriend hem hvoluntarcy safety-related equipment.h mined
- -- . as re8ected in these tenminated individuals prior to or requirunents are being considered in
- h- em is appreesista, because simultaneously with their =ces A =*ian of light of a Comunission review of the they afford the lamessed assurance of tennination. and (3) a roquirunant that impact of safeguards seguirements on plant safety. A discussion of each of the encontroBed exterior doors leading to plant safety objectives.The propened ====i==='* foRows. vitalislands be locked and alanned.
requirunents ase desiyted to provide a VHalluland somos controls during nuore safety.m=='4a== ealeguards af Vlaal Ames Desipuden ennergemey conditions inchule(1) a systein while snaintahdag current leseta . potsyWInimede) nequirement tInst licamesse per s -a,.ny of protection. Seedon 73.55 apwrequkwauch mbwphysical pseteetherend saves:h cmsmanat period expires licensee to proesce mR vttet areas (aroes *Mtigamerplumees heurethat-they de
. ' Pnday, naa==har 7.1984. r---e= in widch vediological sabotogr can be not combat wRh endbty eblessen, and received aber tida date willha ===P 3t=l=d). "- = % ' widch (I) a requiremment that _,, _7 considered fra is precucat to de so.but dealsante these vfter niens were 'i- *=8='an ==am memmer assurance of ====id=stion cannot be originally accepted by the r*===i=ian l'Wimm end eyempts stamb iskuuhrtshmee -
given except for -==*= rocerood en on an interim basis pendtag site specific "8uisthmihdepmoelmisme for or before tida date reviews to vertfy these d==g==a-= huye Isreihti=&==de -d -
Aeonesses:r====ne, abouldbe sent Many she.epeciBc miews have been methode of W hinthe to the Secessary of the Comm'.asion. U.S. . '1i N results indicate that event of a casuputerimiharel.
- Nuclear R=g=Intary e--i==ia= present i 73.2 requirements may be Althougli the
- to wGR Washington, D.C. 3555. Attenden. -=
"Jy strict la mandating 73.5E(d)(7) was seh6mst to a ====l of Docketing and Sero 6ne Breach, protection of aR vital areas. Public a-===e due to the -i-*==>
cm===nt= namy ainohe delivered to Many vitalareas are configured so rewording now being proposed, the Rocan1121.1717 Hiltreet.NW., that a saboteur most entur two os more PW le asking Asi additional j Washington DC, between 3:15 a.sa.and areas in anier to carry ont successful mts.
Eso p.m. Copies of comunesta neceived radiological sabotage. In such cases. It is A nthesa y w sempend sofspuesde are available for a-==ining and copying act necessary to protect aH of the areas D8ensuses Doming Emerymacise at the Cor.unission's Publicn acum-n, in ceder to thwart sabotage.h Room at 1717 H Street.NW Connai== ion is therefore considering As aJusult of ther===i== ton's Washington.DC. Single d of draft - adoption of a clartfled vital area miew ofpos aH=Iconflicts between guidance material nas7 be obtained frosa designatism policy which wesid seguire " - . L and safety requirements, the U.S. Mclear Regulatory protection only to the autant ==r=== y consideration is given to r- w= w..hing,n= DC E555. to interrupt sabo r aa===== would improving Ma=a===*e IBty to Attention: Director. Division of be given coesi latitude to take respond to site emergemales or " unusual TerhaicalInformatico and Document advantage of existing barners and events."h rmami== ion is proposms to Control. access control points. Certain hems, mise to CPR 73.55(a) to provide post punTseen proamaavices costract*, however would be deemed vitalin all authority to lie ==== to suspend Tom R. AHen. Chid. Regulatory cases. se include casite diesel safeguards enessures if required to Activities Secnon, or Henry S. ,
generators and batteries (=weineng accoonnodate emergency response Blumenthal HI, Division of M electrical distribution systems), reactor containment, control rooms, central
%g gg Office of Nuclear Material Safety and Safeguards. U.S. Nuclear Regulato alarm station. and onsite water supplies Commianion. Washington. DC 20555' le " nf piping) required for safe shut. Safeguards inspections bave indicated teiephone (301) 427-4010. down.h Commission specificaUy that. la some cases, certain security invites public ca===nt on the equipment does not appear to qualify for aary mroam atiose assumptions that should be used to designation as vital equipment under 10 Commission experience duruq the support the vital island designation CFR 73.2(i).& sabotage of this implementation of i 73.55- approach. equipment could significantly impact the 4
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Federal Register / W1. ee. Ns i49 / Wedne'sday August'I.1984 '/ MhmN R'n'!N .
security of the plant.For example. Regulatory FlexEdRty Certinostion 1811.as stat.see, as amended [ct UAC although to CFR 73.55(e)(1) requires that . In accordance with the Regulatory
'"* "'
- EU ee outral alarm station be designated Flexibility Act of 1980. 5 U.S.C. 805(b).
as vital, there is no speci8c requirement fand )and(h ).
the r'a==i==iaa hereby cert 18es that 7s.so(s)(23. (8XtiiXs) and (h). n.ss(hX2). and that the emergency power and other 'bse proposed reguladons will not, if (4XiiiXBl. rs.7o. rtn. rs.rs are issued under support systems necessary forits promulgated,have a signime mat sec. ista. as stat. sea, as amended (a UAC.
operation be designated as vital -a-se impact on a substantial 281(oll- ,
equipment. number of eman entities.These 2. In 173.2. peregraph (un) is added to Accordingly, the Commission is proposed regulations afect electric read as follows:
considering requiring protection of utilities that are doadnate in their i speci8ed onsite physical security respective service areas and that own $712 Defenseena.
l equipment necessary for the proper aan operate nuclear power plants. nese
- functioning of b security system.nis utilities do not fall within the dannition (an)"vitalislands" an one or more equipment will include secondary power of small bnewa=== set forth in Section 3 vital areas (s),,.v.4 d as a single supplies forintrusion alarms and of the Sean Businese Act.15 U.S.C. 632 entity.
nonportable communications equipment. or within the SmaR Business Size 3. In i 73.55. the ; th-- i nis action by the rm==1==ian is Standards set forth in to CFR part 121. paragraph paragraph (a) paragraphs -
predicated on the belief that this neee proposed reguladoes win affect (cX1) ant c)(2). paragraphs (dX7) and l protection is necessary to achieve the aque nuclear powerindustry (dXo), paragraphs (eX1) and (e)(3), and -
generalperformance iyaats of to contractors and vendors all of.which are the i=:iA; iparagraph of (h)(4) and large- which service the )(A) are revised to read as CFR 73.55(a).
- ey ad uch c tr.ls . .
. i Analysis $ rs.ss meandresnenes ser physisimi In a matter associated with access N notincrease inidal cost to b pressenen er seensed esehenes in nusteer control, the Commission is ==M=hg
- NRC due to sothmated thne to be spent power ruesure essenet emesiastems
===a'l-' of I 7155(dXe) to redum gn reviewing proposed changes to **88- .
==aed='y costs assadated with k*y physionipreesados pleas and By (12D days ham the eSective date of and lock controls.ne present conduedag Beld <==p=ena== to assure this === ant ==nt or'120 days after receipt .
l
+ - ts call for key. lock, and compHanos is $2es.5K per year laidally of a r ==i==w provided site specinc
-Ma= tion changes when any and $37.4K peryear thereafter. vital area review, whichever islatar) l employee who had access to these ne netincrease cost per applicant each Hoensee ahan subunitproposed -
devices is i= -i==ted. and Baensee in +=pt- -Hn= these ==-=<l==='= to Ids securityylan which Experience, however. indicates that requirements is estimated to be $1.sM dennehow the --=d'===* sital saland adequate protection could be obtamed initiaHy and would result in sisK designadan and protectionx = ts by changing keya. locks, and envings peryear thereafter. of paragraphs (a),(cX1t~(cXIL-(d)(2).
~ -Na=tions (1) routinely on an annual (dX7). (dX9), (eXI) and (3) and (h)(4) w01 IJet of Sebjects b 18 CFR Part 73 be met.Each submittal shaBinclude a basis;(2) whenever a person's acum -
cathorisation is revoked for reasons of Hasardous materials <m+. nation, propmed implementation schedule fw lack of trustwwthinen,rehabinty or Nuclear materials, Nuclear power plants r-nmi-taa approvatne amended .
safeguards y inadequate performance; and (3) when andreactes penalty.Repenas ~
1 of b ee
"-'"u oflocks is - --- ^ . --
i%a ts. Security measures. pbs must be implemented by the For the reasons set out in the within100 days after Envir====='=1 Impact: Categorical preamble and under the authority of the r%==t==taa approval of the proposed hel==lan Atomic Energy Act of1954, as ===nalad. security planin accordance with the the Energy Reorganization Act of1974. approval ar&antata De NRC has determined that this. as amended, and 5 U.S.C. 553 notice is propmed rule is the type of action (a) General performance objective -
hereby given that adoption of the andswa ;;;;ts.%o Econsee shall described in categorical exclusion to foHowing ===ar1===*= to 10 CFR Part 73 whbush and maintain an maik CFR 51.22(cX3).herefore neither an is contemplated. physical protecdon system ud security environmental impact statemeist nor an organizadon which wlR han as hs enviramnantal ======= ant has been PART y3-PHYSICAL PROTECTION OF abjective to provide high assurance that -
prepared for this proposed rule. PLANTS AND IAATERIALS acovida involving specialnuclear Paperwork Reduction Seat ====e he authority citation for Part 73 la material are not laimie=1 to the aa==an revised to read as follows: defense and security and do not
%e proposed rule has been submitted constitute an unreasonable risk to the to the Of5ce of Management and Budget ,["thesay- sn pubuc health and' safety.ne physical
- for clearance of the information 4 , u sut.7soIuS 3073,2187.2201) sec.301.se Sut tau, as protection system shall be designed to collection i%uu ents that may be amended, sec. 304, as Siat.124s (42 USC. Protect aardnst the design basis threat of cppropriate under the Paperwork se41. as44). radiological sabotage as stated in Reduction Act (Pub.L.95-511).%e SF- Section n.37tf) is also issued under sec. I 73.1(a).To achieve this general
- 83. " Request for Clearance," Supporting 301. Pub.1.35-238, se Stat. Fue (42 USC- performance, objectiva, the onsite Statement. and related documentation seet nou). physical protection system and security submitted to OMB will be placed in the For the purposes of sec. 223. es Stat. esa, se organization shallinclude, but not
- d NRC Public Document Room at1717 H n'"[,, M$ g$*e*a* $ necessarily be limited to, the
_ Street, NW., Washington. D.C. 20555. sea, as amended (42 Usc. 220t(b)): li n.ao. capabilities to meet the specific
%e material will be availsble for n24, n2s. n.2s n.27. n.37. n.40. n.4s. requirements contained in paragraphs inspection or copying. n.4a. n.so, n.ss, n47 are inued under sec. (b) through (b) of this section.The 1
l
_ ._. _ _ _ __ ~ _ _ _ _ _ _ - - _ - - . - . _ - _ _ _ - - - - _ - . _ _ - . ~ . _ . _ - __ __
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Federal Regialer / Vol. 4a, No.148 / Weshnesday . Anguet 1.1984 / Pr-8 Rules alr737
} r'-=== may sothertse an applicant (d) Aosses requiressants. * *
- i or licensee to provide ======ses for Individual's access authorizationis
' (7) Delicensee shalk revoked daie to his or her isch of
. . protection against rednoisgical sabotage (i) Establish as acones authorisation trustworthiness, reliability, or 4
!! other than those required by this see lon system telimit anescorted access to inadequate work performance, keys,
' if the applicant or Beansee demonstrates vital talands duringnonemergency locks. combinations, and related that the measures have the same high conditions to indivhhaels who require equipment to which that person had aneurance ongestive as specified in this access in order to perform their duties. access must be changed.
paragraph and that the overalllevel of To achieve this the liosasse mast: (e) Detection aldr. 0) All slerms
) .
system perfonmence provides protection -
(A)Estabheh current authorisation 6 . requirement pursuant to this part must l against radiological sabotage equivalent access lists for each vitalisland. De =annnicate in a continuously manned to that which would be provided by - access lists most be updated and ,
central alarm station located within the <
paragraphs (b) through (h) of this section reapproved by the cognizant licenses protected area and in at least ene other and meets the general performance manager or supervisor at least every St continuously manned station'not 4wts of this section. days.no licensee shan include on the necessarily onsite, so that a sm' gle act i
- -*dy.in the special cases of access list only individuals whose *
- licensed operating reactors with cannot remove the capability of caHing l specific duties require access to vital for assistance or otherwise responding adjacent reactor power plants under talanda during naa='amenency ,
construction the Itema=== shan to an alarm.ne ensite central alarm .
conditions. station shan be located within a and maintain a level of physi (B) positively control. in accordance building such that the interior of the i .. protecnon of the operating roeciar with the access het establish pursuant to central alarm station is not visible from 4
against radiological sabotage equivalent paragraph (d)(r)(i) of tids section. aD the perimeter of the protected area.nis I to the w,,_ mts of this section.*Ihe points of sonnel and vehide access station shall not contain any operational site #h or otherindividual to vital activities that would interfere with the designated in the Econsee's physical (C) Revoke,in the case of an execution of the alarm response protection plan shall have the methority individuafs 6 ' /.wy termination for function.no walla, doore. Goor, and )
to suspend any safeguards measure cause,the individuare access i
. pursuant to this section !!the any wmdows in the waus and in the authorization and retrieve his/her doors of the central alarm statian abau I r_-_7--- is =======vy to fact!Itate identificationbadge and other entry response to emergency con htians, be bullet sesistas. On sita secondary devices, asapplicable, priorto or power supply systems for alann provided that aR sufsgaards measures simultaneouslywith 444this are restored se soon as practicable - ==a-aciator e
- '- individual or his/her termination.- portable -. . quipment and nom.as
.4 tions equipment foDowing sash an essagency. ~ v i
,(tiltack and protect by an aceve requhed in paragraph (f) of this section fatrusion alarm system hnoccupied vital must be located mathin vital islands.,
Tj tc) Physical &mriers. (1) the Bcensee , islands and an exterior doors leading to . .
i 3' . shad locata vital equipment within a. vitalislands which are not otherwise
... e
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- vital area, which in tur. shan be located controDed. (s)De hasnese shan alarm ea -
withia a protected area;One ormore (ii) Design the access ada*= tion amagener azits in and protscsed ares '
3 vital areas may constitute a vitallsland. system to accommodate the potential and each vitalial==rt - '
Vitalialands shah be m T .d to need for rapid ingress or agress of )
i ,
ensure that anindividual must gain individuals during emergency conditions [h)Responu reluirmnent. ... j l access to a vitallsland to accaraplish - (4) Upon detection of abnormal j i or situations that could land to sabotage resulting in a significant emergency conditions. To help assure presence of scHvity w poem w i
rediological release or reactor onre this, the hcensee anst vehicles within an isolation zone, a damage or both. Access to vitalis! ands (A) Ensure prompt aczess to vitil protected area, material access ares. or i
must require passage through at least egn4===n' .
a vitalislamt er upon widence i
' two physical barners of sufBeient. (B) periaac=Hy review physical inchcanon oflenmelon into a ymkckd strength to meet thec.",_. security plans and contingency plans ama, a material sacen ama, w a del requirements of paragraph (a) of this andia 4-. to evalusta their island the Beansee security organizadon section. More than one vitalisland may potentialimpact on plant andpar=a===1 must be located within a protected safaty.- ,
area.De boonses e proted,se * * * * *
(iii) * *
- g ladependent vitallelands, onsite. Is) A11 keys. locks. == J===*8=== and . (A) Requiring responding guards or .
- alternathis and direct current emergency related equipment used to enmarel otherarmed response personnel to power saareas {=,r 4=ang electrical somes to protected areas and vital laterpose themselves between vital
{ distribution systems) required to permit
- Islands unust be contround to reduce the islands and material access areas and functioning of structures, systans and probability of compronuse. All such any adversary attempting entry for the componants important to safety, pdmary keys. locks, and combinations must be purpose of radiological sabotage or theft reactor containment, the reactos control danged atleast evey12 months. of special nuclear material and to room, central alarm statha, and onsite Whenever there is evidence or suspidon intercept any person exiting with special water supplies (excluding piping) that any key. lock. combination or nuclear material, and required forachieving plant hot related equipment may have been * * * *
- i .
shutdown or hotstandby. compromised. it must be changed.The
, . (2) The physical barriers at the 4. In I 73.70, paragraph (d) is revised licensee shallissue keys. locks, to read as foDows:
perimeter of the protected area must be combinations, and other access control separated from any other barrier devices to protected areas and vital I I 73JD 8h**'88-designated as a physscal barrier for a islands only to persons who possess * * *
- vital island withtn the protected area.
access authorization in accordance with (d) A log indicating name, badge
$ 73.56 of this part.Whenever an number, time of entry, reason for entry.
v g 6 Federkl Residad / Tot. te.'No.*14e Y-WedMeBay ?Ambist 1 'thd f9ropdie'id* Rase and thne of anJt of alltedivklaats ted accese to a vitallaland except indivklaals entering or exiting the seector control roman.
Dated at Wealdeston, DC, this Irth day of Julysees. .
Phr the Nedear Regulatory Commmaission. ,
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I Wof& Costausamt PRDer en amusreadmmesa.]
mL&aus coes reme.ews o
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. Assee Aessiertendenpeogressu assessenesee %
Conserning Physisef Presenten of '
Nuesserpowerpeanas;seershes of .
keepvidusse et reuer Reester Feemise; kutensten etConument Pened acessev:Nedeer Regulatory l c_ --
actiest FIrepened sele: Extension of l
ee8mm888Peded. ;
SUIsseenv:On Angest1.194 les FR i sorse:es FR seras:a rm seras),the .
Nuclear Regoletary rhh (NRC) pubhehed der publicensament she insiderSofoguenle Rules '
la, Assoas Aethertmetion Program,h6sceDeneses Amesubsente 7-- 3 pg,ysical Freescelen of Neclear Power Plante, and seendies of hdMdeale et Power Reector FecDeties.
'line et.am=et poded for $de proposed
- - -- % pedese wee to empero en Deceanber y. sees. The Ediosa Electric leetitute.(EEI).and Rh8C. have i requested en extenoien of the assunent !
period. in view of die hepertance of the proposed reie.ihe emment of one thet -
eel. and Kh0C segysted le regelred in order to provide seenbigful ensemente .
en behalf of their member etRines. and the destrebthey of1. ' . -a a role as seen se practicable.the NItC hoe decided to extend the comment per6od
, for en additionalgo days.
eave:The camasat pened hea been extended and now empires em March 7.
lask Comunente reonised after est date will be eensidered if it le practical to de ;
so, but assurance of seasidersties cannot be given ancept as to enamente received en er befoes that date.
aeoneesse: Send wrensa comumente er suggestions to the Seceetary of the r==la=ian U.S. Nucieer Regulatory r--aaa'a= Weekington, D.C 51555. [.
Attention:Dodetang and Service Bronch. ha may else he i delivered to Roam 3123.1717 H Se=eet. i NW,W--M DLC.betws,K.25 l en and siecya copies e4ty enes ; i receivedareavstablefennvea g and espying for a 6 6 P '
Comuniesion's Pub'.c E mw. . een et 1717HSoest.NW,%aben dC single etdraft guidmace meesdal may be imod besithe UANuclear Regelstory r==a as- Weekington, i D.C 30585. Attentiour Director.Dtvisies of Technical hiermetion and Decomment Control.
poa pusmann espeassavnes coerract:
Mr. Henry S. Blueneathal Ill Drviolon of ;
Sefeguards. Office of Nuclear Meterial
' Sfety and Selegeerde.UA Nuclear ,!.
Regulatory Counmisalon. Weenington, t D.C 30655, telephone (301) 427-4754.
Desed at Wesluesiee. D.C.this et day of
. December 1984.
For the Nuener Raouletory 8'h sommalI. Gilk.
Secreeerrefthe Conunteeion ,'
BAC KERo0ND M ATE R / AL l
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July 29, 1983 ' '
SECT-83-311
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, i 0 C:.C.'. , C ~. 5 4
for: The Commissioners Fede: William J. Dircks *
~
- Executive Director for Operations "q .
Subject:
PROPOSED INSIDER SAFEGUARDS RULES Purcose: To present for Commission consideration, three related rulemaking i
- actions concerning revised requirements for safeguarding power reactors. One of the rulamaking actions, the Access '
, Authorization Rule, was prepared in response to Comeission direction in a memorandum to the Acting EDO from the Secretary dated-June 30, 1980.
3 Discussion: This paper covers proposed rules in three areas related to safe-ci guards requirements for power reactors. These are: .
9 ,
o Access Authorization Rule (Screening Requirements) o Search Requirements Rule (Pat-1)own Search Issue) o Miscellaneous Safeguards-Related Amendments (Access Controls, Vital Area Designation, etc.) .
This rule package was studied by a multi-office Safety / Safeguards Committee which was formed in response to the Chairman's request of August 16, 1982. The Committaa had the overall task of study- .
i ing power reactor safeguards requirements and practices to deter-mine whether actual or potential conflicts exist with plant safety objectives. The Committee's recommendations have been accommodated in this package.
Contacts:
T. R. Allen or -
H. 5. 81umenthc1, SGPR 42-74010 ,
K. Z. Jangochian or 1 W. C. Floyd, RES 44-35976 ..- - 9
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.. t The Cummissioners 2
- 4 '
1 i
.1 -
j Access Authorization Rule 2
This proposed rule would establish a personnel screening program 9
for licensee employees and contractor personnel. It is designed i to provide increased assurance of trustworthiness. Further details
.I are provided in Enclosure A. Key elements of the program are:
] o Background Investigations to look for past behavior that i
d would indicate that the individual is unreliable or untrustworthy.
j o A Continual Behavioral Observation Program designed to detect changes in an individual's behavior pattern which indicates a .
- potential for committing acts detrimental to the pubite health ,
and safety. (On June 24, 1982, the Commission approved .
> i publishing for public comment a complementary rule concern-j
- ing " fitness for duty." That program will also depend on .
behavioral observation.) -
- o Support measures such as review procedures, grandfathering,
- . protection of information, guidance, and treatment of temporary workers.
3 A Hearing Board established in 1978 to examine the issue of 1
access authorization later recommended that the Commiss' ion include i psychological programs. assessment as a component of personnel screeding In developing this rule,' however, the staff infgrmally sought the opinions of various authorities concerning the value of psychological assessment for predicting behavior inimical to
. the public health and safety. Because of the wide variety of opinions expressed, the staff proposes to solicit further public 1
comment on this issue in the Supplementary Information accompany -
ing the rule rather than preposing specific requirements at this time."
Search Raouirements Rule i
This amendment would clarify the role of pat-down searches as a safeguards measure to be used only for suspicion or malfunction of search equipment and would complete outstanding action on industry petitions which have been pending since 1977. Although .
this rule has been previously published as a proposed rule in 1980, it appears appropriate to republish it (along with the other related rules) for a second round of public comment in :
light of the Safety / Safeguards Committee's findings that most l "The Office of Policy Evaluation advises that the NRC contractor who provided the study on the behavioral observation program states a revised program would be ,
nscessary if psychological assessment is not required. The staff plans to consider this position along with public ce=ents when received.
. I'
._ _ h,
t a e, s
- The Commissioners 3
3 5
I' .
4 j licensees have successfully adjusted to 100". equipment searches, 3
and believe that changing to random searches would be disruptive.
I Miscellaneous Safecuards-Related Amendments 4
q These Key features proposed are:changes are discussed in detail in Enclosure C.
J ..
. o A revised concept of vital area designation and protection.'
j This would result in a reduction in the number of vital /
. . areas at most' sites by grouping and protecting selected j items of vital equipment in fewer vital areas. Safety
would be enhanced through fewer access control points.
- o .4
. Improved provisions for vital equipment access control .
- during both routine and emergency conditions.
- l i
- o
- j!
Provision for licensees to have the authority to suspend a l
l conditions. measures to facilitate response to emergency safeguards l' )l o !I
, Revised changes. critaria for dataraining the need for lock and key i' Locks and keys would be changed annually, upon
- ' suspicion ,of compromise, or wi)en an incividual terminates .' j i employment under unfavorable circumsta,nces.
. CAGR Recommendation -
The CRGR has recommended publication of the proposed rule; however,'. li it believes that public comment should be sought on the use of a government-operated clearance program similar to that prescribed .j in 10 CFR Part 11 for "Q" clearances as an alternative to the -
proposed industry-administered screening program. The CRGR suggested that government clearances would provide increased h
1 assurance of trustworthiness, thereby permitting a reduction in .
access controls and other security measures. C r
The issue of an industry operated program versus a government- $
2 operated program was previously consicerad by a Hearing .Soard convened at the Commission's airection and in detail by the Commission itself. The Hearing Board recommended a private '
sector program such as proposed in the attachment. The Ccamission recognized that controversy existed concerning its authority under section 161(i)(2) of the Atomic Energy Act to require government ,
clearances 12 NRC 528, for individuals working at power reactors (CLI-80-37),
536, l
footnote IS (1980). While the staff believed !
- that such authority existad, the Office of General Counsel advised that the better legal view was that section 161(1)(2) could not be read broadly enough to consider the sabotage of light water reactors as constituting a threat to the national security,
.w.,,,, . . ~ . . --
1
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-,j . .
3 1 Tho Commissioners ..
4
} !
i' thereby not permitting the use of a government-administered .
clearam.: program (OGC legal opinion, September 11,1979). It may be that the Commission will wish to' reconsider this issue at 4
this time.
Value/Isomet
- This rulemaking package is designed to improve the practicality and effectiveness of measures to protect against the insider threat at power reactor facilities while enhancing plant safety.
3 l 4 The staff believes that costs associated with these changes can
{
j be minimized because many reactor licensees are either presently j using similar safeguards programs (e.g., personnel background e screening under ANSI 18.17) or can accommodate the proposed ,
- amendments (e.g., re-configuration of the interior layout of ,
< : .their plants to protect vital safety equipment under the " vital {
i island" approach) without undue expense. '
- The enclosures indicate that costs to the licensee of these amend-i ments will be approximately $1.7M per site on an initial basis i with annual maintenance cost of $300K. It will initially cost I 1 new plants, which receive their operating license after the effec-tive date of this rule, approximately $603K to screen their l
! employees with the same annual maintenance cost as existing plants. These expenditures are partially offset by cost savings '
- associated with licensees establithit:g a reciprocity progran for personnel screening and reduced key and lock control requirements.
Such reductions are estimated to reduce the cost to each site by approximately $200K per year. Costs to the NRC are estimated at
! $760K in staff tier > initially with annual maintenance approximat-1 ing 5170K. It is anticipated that no occupational radiation j exposure rule package. will be associated with implementation of this proposed
- Interrelationshio As previously stated, these proposed rule changes are presented together because of their marked interrelationship. Any major changes to the principal components of the proposed access j authorization program could impact the proposal to relax require-ments for lock and key controls and other current requirements. -
- Recommendations
- That the Comission:
1.
Acorove the amendments as set forth in Enclosures A, B, and C for publication as proposed rules in the Federal Register, with a 90-day public comment period. .
I e
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The Commissioners , 5 1
+ *
- 2. in order to satisfy the requirements of the Regulatory '
Flexibility Act, 5 U.S.C. 605(b), certify that this rule will not have a significant economic impact on a substantial
! 'i number of small entities. This certification is included i in the enclosed Federal Register notices contained in Enclo-sures A, B, and C. -
' li .
- } -
, 3. Note: -
- a. That the staff will revise the supplemental informa, tion
.'! of the Access Authorization Rule as necessary and -
appropriata to reflect any of the Commission's instruc-j tions pertaining to the question of a government run clearance program for power reactors resulting from
] the Commission's review of this proposal. .
i] a
- b. That the value/ impact statements which appear as attach-ments to Enclosures A, B, and C will ba placed in the 4 NRC Public Document Room.
i
- c. That draft guidance materials for the enclosed rule-making actions will be made publicly available concur-l rently with publication of these amendments (Attach-ment'2 to Enclosures A and C). '
- d. That, in accordance with 10 CFR 51.5(d)(3), neither environmental impact statements nor negative declara-tions need'be prepared since the proposed amendments j are not significant from the standpoint of environ-
. mental impact.
e.
i That these amendments contain information collection-and reporting requirements that are subject to review .
.! by the Office of Management and Budget. Upon Commis-sion affirmation, formal request for OMB review and '
ii" clearance will be initiated. OMB review may take 60-90 days from the date of publication in the Federal
! , Register. If approval is denied by OMB, the Commis-sion will be notified. -
- f. That appropriate Congressional Committees will be
- advised of these actions (see drafts provided as attach-ments to Enclosures A, 8, and C).
' g. That public announcements will be issued (see drafts provided as attachments to Enclosures A, 8, and C.).
- h. That copies of the Federal Register notices will be distributed by ADM:TIOC to all affected licensees and other interested persons.
I e s 8
- -ee--*==,e=-.... . , , . ,,
. . l
. . l 4 The Commissioners -
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That the Chief Counsel for Advocacy of the $sall
) '.* Business Administration will be informed of the 4 certification and the reasons for it as required by the Regulatory Flexibility Act.
N Schedulino:
i The. staff requests scheduling at an early policy session.
,I . .
W1 J. Dire
- Executive Director for Operations j
Enclosures:
i A - Access Authorization Rule B - Search Requirements Rule C , Miscellaneous Related Amendments 3
i ,
Casumissioners' comments or consent should be provided directly e to the Office of the Secretary by c.c.b. Friday, August 26, 1983.
4 Commission Staff office comments, if any, should be submitted i to the Commissioners NZ,T Friday, August 19, 1983, with an infor-mation copy to the Office of the Secretary. If the paper is of such aand review nature comment, that it requires additional time for analytical be apprised of when comunents may be expected.the erwuniesioners and the S
. DISTRIBUTION:
t'emuni esioners -
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EEGIONAL OFFICES EDO ELD ,
ASLAP SECT '
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i ENCLOSURE C 1,
MISCELLANE005 RELATED AMEN 0MENTS 9
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[7590-01] -
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i' j l MC1. EAR REGULATORY ComISSION t i
10 CFR Part 73 i,.
Miscellaneous Amendments Concerning Physical Protection t .
of Nuclear Power Plants
.i 1 AGENCY: Nuclear Regulatory Commission. -
ACTION: Proposed rule. '
SLSOMRY: The Nuclear Regulatory Commission is proposfng to amend its nuclear power plant safeguards regulations to clarify and refine require-j eents for the designation and protection of vital locations containing j
safety-related equipment. The revised requirements are being considered '
in light of a Commission review of the impact of safeguards requirements on plant safety objectives. The proposed requirements are designed to provide a more safety-conscious safeguards system whfie maintaining current levels of protection.
OATES: The comment period expires . Coments received
.4
, ' afte'- will be considered if it is practical to do so, but l
asswance of consideration cannot be given except for comments recafved on or before this data.
?
A00RE55ES: Coments should be sent to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, OC 20555. Attention:
Docketing and Sonice Branch. Comments may also be delivered to .
Room 1121,1717 H 5treet, W. , Washington, DC, between 8:15 a.m. and
! . 5:00 p.m. Copies of comments recaived are available for examining and copying at the Commission's Pubite Document Room at 1717 H Street, NW.,
~
Washington, DC. Single copies of draft guidance material may be octained from the U.S. Nuclear Regulator / Commission, Washington, DC 20555, Atten-tion: Director, Division of Technical Information and Document Control.
06/21/83 1 Attachment 1 to Enclosure C p A --
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.[7590-015..
t j
FOR FURTHER INF0lMATION CONTACT: Tom R. Allen, Chief, Regulatory Activ-
- I ities Section, Division of Safeguards, Offica of Nuclear MateMal Safety
' and Safeguards, U.S. Nuclear Regulatory Commission, ideshington, DC 20555, telephone (301)427-4010.
l SUPPLS Wf7ARY INFORMATION: Commission experience during the implementa-j tion of 5 73.55, " Requirements for Physical Protection of Licensed Activ-I -
ities in Nuclear Power Reactors Against Radiological Sabotage," has indi-cated a need to clarify the policy for the designation and protection of
.i vital areas containing safety-related equipment. 'Particular concern has
!I been focused on ensuring that security measures do not impede plant safety.
{ Inspections have also indicated that certain physical security equipment l ;
- is not now protected as vital, despite the fact that this equipment safe-guards vital areas containing essential safety-related equipment. In "
3 addition, experience with present requirements for key and lock controls i
,; indicates that 5 73.55 can be modiffed to provide more flexibility in this area while maintaining adequate plant protection. The Commission believes j
I -
that the clarification and refinement of requirrents, as reflected in :
these amendments, is appropriata, because they afford the increased assur-
'i 9
ance of plant safety. A discussion of each of the amendments follows.
I Clarification ~of Vital Area Desionation Policy (Vital- Islands)_ . . - - - -
{i Section 73.55 now requires each ifcansee to protect all vital areas i
(areas in which radiological sabotage can be accomplished). Security f plans which designata these vital areas were originally accepted by the l; .
Commission on an interim basis pending sita specific reviews to verify
.# these designations. Many site-specific reviews have been completed. The I results indicata that present I 73.55 requirements may be unnecessarily l'
~ strict in mandating protection of all vital areas.
- i Many vital areas are configured so that a saboteur must enter two.or
! . more areas in order to carry out successful radiological sabotage. In j1 i i such cases, it is necessary to protect all of the areas in order to J thwart sabotage. The Commission is therefore considering adoption of a clarified vital area designation policy whfen would require protection
~
06/27/83 2 l ' Attachment 1 to Enclosure C i
l:
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- -,~
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(7590-01) enly to the extent necessary to interrupt sabotage. Licensees would be
- i, given considerable latitude to take advantage of existing barriers and s
access control points. Certain items, however, would be deemed vital 3 in all cases. These include onsite diesel generators and batteries S,
-. (excluding electrical distribution systems), reactor containment, control q
rooms, central alarm station, and onsite water supplies (excluding piping)
',j required for safe shut-down.
Vital Island Protection and Access Control On March 12,19g0, the letC published proposed ameneonts to 10 CFR Part 73 pertaining to nuclear power plant vital access control
]j
'j (45 FR 15937). Public comment was invited and received. The Casurission has significantly revised these requirements to assure adequate access j
for safety purposes while accomplishing the safeguards obectives. Amend-j eents to 10 CFR 73.55(d)(7) are now proposed that address both nonemer-y gency and emergency access controls to vital islands.
'l Revised nonemergency controis include (1) the establishment of up-to-A .
date nonemergency access lists, (2) a requirement that access control devices be retrieved from involuntarily terminated individuals prior to
.] ,
or simultaneously with their notification of termination, and (3) a I
requirement that uncontrolied exterior doors leading to vital islands be
! Tocked and alarmed.
i *
' Vital island access controls during emergency conditions include (1) a requirement that 1(consees periodically review physical protection and contigency plans to insure that they do not conflict with safety , ,
objectives, and (2) a requirement that ifcensees develop procedures to i
facilitate emergency ingress and egress to vital islands (these proca-
' ,{ ,
dures would include provisions for back-up keys to vital islands and
- i methods of opening locked doors in the event of a computer failure).
Although the amendment to 10 CFR 73.55(d)(7) was subject to a round of pubite comment, due to the significant rewording now being proposed, '
the Consission is asking for additional enaments.
l 06/16/83 3
. httachment1toEnclosureC
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1 13' g
4 AuthoMtv to 9_ end Safmrds Measures DuMno E=c. wies
! *- As a result of the Commission's review of potential conflicts betueen safeguards and safety requirements, consideration is being given to faproving licensee's flexibility to respond to site emergencies or
" unusual events." The Commission is proposing to revise 10 CFR 73.55(a)
! l
., to provide authority to Ifconsees to suspend safeguards measures if
.; required to accounodata emergency response. .
l lt
.! Protection of Soecified Physical Security Ecutoment -
- j Safeguards inspections have indicated that, in some cases, cer~ain t 1
security equipment does not appear to qualify for designation as vital l {~ j .
equipment under 10 CFR 73.2(1). The sabotage of this equipment,could j significantly impact the secuMty of the plant. For example, although J
10 CFR 73.55(e)(1) requires that the central alaru station be designated .
, .')
as vital, there is no specific requirement that the emergency power and
} other support systems necessary for its operation be designated as vital equipment.
~
. ~11 Accordingly, the Commission is considering reqvfring protection of
,] specified onsite physical security equipment necessary for the proper ..
4
.. functioning of the security system. This equipment will include second-t J ary power supplies for intrusion alanes and nonportable causunications
-equipment. -This action by the Commission is predicated on the belief
~ ~ '
j that this protection is necassary to achieve the general performance i ! requirements of 10 CFR 73.55(a).
1 Key and Lock Controls .
In a mattar associated with access control, the Commission is con-j sidering amendment of I 73.55(d)(9) to reduce unnecessary costs asso-
- cisted with key and lock controls. The present requirements cail for
. key, lock, and combination changes when any employee who had access to thesedevicesisterminated. ' -
+
.j Experience, however, indicates that adequata protection could be i j obtained by changing keys, locks, and combinations (1) routinely on an 1
annual basis; (2) whenever a person's access authorization is revoked for P.
4 .
r .
06/16/83 4 i Attacament 1 to Enclosure C i
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. . _ _ _ _ - . - ..-._-.,..__-~.._.__,.,_._,__,.,._.,.._,._...,....______-______._________._..m-_.__.._----._--_-,
, . ~. . _ . . - . _ . - - - - - . - - - - - - . .- ~- . - . - - .
l -
C7590-013 i
- reasons of lack of trustworthiness, reliability or inadequate performance;
$' and (3) when compromise of locks is suspected.
i.
1 PAPERWORK REDUCTION STATBtENT '
l The proposed rule has been submitted to the Office of Management and
' Budget for clearance of the information collection requirements that may be appropriata under the Paperwork Reduction Act (Pub. Law 96-511). The SF-83, " Request for Clearance," Supporting Statement, and related docip mentation submitted to We will be placed in the NRC Public Document Room j at 1717 H Street, lef., idashington, DC 20555. The material will be avail-able for inspection er copying.
REGULATORY FLEXIBILITY CERTIFICATICN
' l.
In accordance with the Regulatory Flexibility Act of 1980, 5 U.S.C.
605(b), the Comeission hereby cartifies that these proposed regulations will not, if promulgated, have a significant economic impact on a sestantial number of small entities. These proposed regulations affect i!
electric utilities that are dominant in their respective service areas ff jj .and that own and operate nuclear power plants. These utilities do not fall within the definition of small businesses set forth in Section 3 of l j the Small Business Act,15 U.S.C. 632, or within the Small Susiness Size ,
],
Standards set t' orth in 10 CFR Part 121. These proposed regulations will' affect some nuclear power industry contractors and vendors all of which *
.> ., are large concerns which service the industry. t
\
j, LIST OF SUBJECTS IN 10 CFR PART 73 i*
Hazardous materials-transportation, Nuclear materials, Nuclear
{,
? power plants and reactors, Penalty, Reporting requirements, Security ,
measures.
j For the reasons set out in the preamble and under the authority of the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act 5
of 1974, as smonded, and 5 U.S.C. 553, notica is herehy given that adog-
)f it tion of the following amendments to 10 CFR Part 73 is contemplated.
06/16/83 5 Attachment 1 to Enclosure C l
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_ - . , - - . . - , , - . , , - - - - - - - , . - - - - - _ - - - . , - , , , . . - ,,-,,,n___..,-.n, - ., -- - . v,- ,- - .-,
l
- (7590-01] ..
J
.j 1
- 4 PART 73 - PHYSICAL PADTECTION OF PLANTS AND MATERIALS J.
j 4 The authority citation for Part 73 is revised to read as follows:
AUTHORI7Y:
l Secs. 53, 181, 68 Stat. 930, 948, as amended, sec. 147,
- !! 94 Stat. 780 (42 U.S.C. 2073, 2157, 2201); sec. 201, 88 Stat. 1242, as i
amended, sec. 204, 48 Stat.1245 (42 U.S.C. 5841, 5444).
Section 73.37(f) is aise issued under sec. 301, Pub. L 96-295, ;
j
.]{ - 94 Stat. 789 (42 U.S.C. Seel este). .
j i
- .3 ~ For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C.
j 2273); 55 73.21, 73.37(8), 73.55 i, 9 are issued under sec.181b, 68 Stat. 948, q
3 as amended (42 U.S.C. 2201(b)); SS 73.20, 73.24, 73.25, 73.26, 73.27, i 73.37, 73.40, 73.45, 73.46, 73.50, 73.55, 73.57 1
- d. are issued under sec. l 1811, 88 Stat. 949, as amended (42 U.S.C. 2201(f)); and 55 73.20(c)(1),
(}
! ' 73.24(b)(1), 73.26(b)(3), (h)(6), and (k)(4), 73.27(a) and (b), 73.37(f),
i
!) 73.40(b) and (d), 73.46(g)(6) and (h)(2), 73.50(g)(2), (3)(111)(B) and (h), 73.55(h)(2), and (4)(111)(8), 73.70, 73.71, 73.72 are issued under 1
l ,,
,.. sec. 151o, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
- I -
-l l J :
,; 2. ,
In 5 73.2, paragraph (nn) is added to read as follows:
':{ 4
- I 73.2 Definitions. -~ ~ ?
i, a n
,j . =
- (nn) " vital islands" are sets of vital areas in whfen sabotace
= n
- j
,' resultino in a sionificant radiolocical release or reactor core danace .-
or both cannot be accamelished without entry into at least one vital ;
,i island. l l
- 3. t In 5 73.55, the introductory paragraph, paragrah (a), para-
' graphs (c)(1) and (c)(2), paragraphs (d)(7) and (d)(9), rtragraphs (e)(1) and (e)(3), and paragraphs (h)(4) and (h)(4)(if1)(A) are revised to read
'} ,
as follows:
4 i ~
" rule.
Comparative text shows changes between present and the newly proposed
- deletions. Underlined text shows additions and dashed through taxt shows 06/27/83 i 6
Attachment I to Enclosure C j ,
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(7590-01] ,
i j $
$ 73.55 Requirements for physical protection of licensed activities in i
nuclear power reactors against radiological sabotage.
~
By (120 days from the effective date of this ameth nt or 120 days
. after rectint of a Commission orovided site soecific vital area review.
whichever is later) ==-M licensee shall submit Fe esed amendments to his security olan which define how the amer ='-* vital island desionation and neotection reavicements of naraorenhs (a). (c)(1). (c)(2). (d)(2).
(d)(7). (d)C9). (e)(1) and (3), and th)(4) will be met. Each submittal shall include a nrecosed inlementation scMie for Commission .reval.
The amended safaaaemis reoufrements of these oars.. hs must be implemented by the licensee within 180 devs after Consission sonroval of the n...esed j
security nian in =-:-: .4.::ce with the amoroved schedule.
(a) General performanca objective and requirements. The licensee i shall establish and safntain an ensita physical protection system and l security organization which will have as its objective to provide high
- assurance that activities involving special nuclear material are not t
inimical to the commen defense and security and do not constitute an unreasonable risk to the public health and safety. The physical protec-
- tion system shall be designed to protect against the design ~ basis threat of radiological sabotage as stated in 5 73.1(a). To achieve this general performance objective, the or: site physical protection system and security t -
organization shall include, but not necessaeily be limited to, the capa .
bilities to meet the specific requirements contained in paragraphs (b) .
through (h) of this section. The Commisafon may authorize an applicant or ifcansee to provide measures for protection against radiological sabo-tage other than those required by this section if the applicant or licensee demonstrates that the measures have the same high assurance objective as specified in this paragraph and that the overall level of system performance provides protection against radiological sabotage l equivalent to that which would be provided by paragraphs (b) through (h) .
of this section and meets the general performance requirements of this 3
section. Specifically, in the special cases of Ifeensed operating reac-tors with adjacent reactor power plants under construction; the licensee 1
06/16/83 7 Attachment 1 to Enclosure C r !
f
-..-.~.-.
, , ~' ' '
C7590-013 a
.:l shall provide and enintain a level of physical protection of the operating
- .j ' reactor against radiological sabotage equivalent to the requirements of j this section. The site suoervisor or other individual desionated in the Ifeensee's ohvsical protection olan shall have the authority to eseend c' any safeauards esasure oursuant to this section if the susoension is !
i i
necessary to facilitata r=-amse to ame. u. v cer.41tions. s.revided that 1 all safecuerds esasures are restored as soon as i.r.cticable followino j such an --_. a.;v.
i m a a a 1 t = .
(c) Physical SarH ers. (1) (the-++ cons.. ;.L:: iseste-Htai j r ;, '. .:, r.;.. ; .ie ;
. -.:..:., ii. i...., ehe44-te-feested y wf0. r. e .. '
sech-that-seeses- L ?u; - -
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t pess ._ C.,_ ei ; M ;
,.:.,. w herrf... .T ..Ti?efent strength 2
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. 4. . .; ef ,.e.. ,. .'. fat-of-this-seetfon- **
3 " . . O . one .it.; -
, te loested-within a-singte . . c 4 aree-]
The licensee shall locate vital soufoment within a vital area, which in i - turn shall be located within a protected area. _One or more vital areas any constitute a vital island.
4
- Ae*==s to vital is1 =4e aust roovire ,
' l- cassaae throuah at least taso physical barriers of sufficient ut..r.stfi to seet the performance recuirements of param.eh (a) of this section. More
) .
1 than one vital island sov be located within a sincle orotected area.
The ifcensee shall orotect as indeoendent vital islands, onsite alternat-inc and direct current esercency cower sources (excludino electM cal dis- ;
tHbution systems) recuired to semit functionina of structures, systaes i ;
' and consonents important to safety. cH enry reactor containment, the reac- . !
tor control roce, central alare station. and onsite water sucolfes (exclud- !
. .! 1 is ' ino sfoino) recuired for achievina olent hot shut-down or hot standhv.
I (2) The physical harHers at the peMonter of the protected area ,
must be separated free any other barrier designated as a physical barMer l e
for a vital Ceres] island within the protected area.
m a a e a '
(d) Access requirements. **"
j.
' (7) CYhe-44eensee-sheif-positivefy-contre + ef4 points-of personnei and-vehfefe-ac=ess-into-v+ tai-eress---Access-to-v+tei-eress shefi-be.
~
Wit.; t individee+ -who are-setherfred-secess-to vftef egeipment-end i.
06/16/83 8 Attachment 1 to Enclosure C i
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J_,".. , -_e b ,.e.f.. ;; r-detf . .'et'.e. ;e.;4en-for-sech individemie ;.' ;l :
5 . .. "if ., the-fssaance .T . eete+4y-codecnemhered '
3 badges-i. : :., vite + .. . 6 ;. :.:. e....s-+s e ^t.e.- f e . Access-to i
v4 tai-trees fe. ^.; ,... .ee-ef i,e.... e ? ; 11. 1 G vii A Usm .... k t
4 reisted-setivities-she++-not-be-sether42 -. ;.-for geoc eesse shown-to
.:. 11 ..-. " . . _ - .4.:^ .. . .r 1 : 6-2: x: ..; ;ed-by
, an-actf.e !..;. . eiere-systeme] The licensee shall:
- j
' l -- - - - - - -
(1) Establish an mee=es authorization svstas to limit unescorted- - --
access to vital islands durino r.e.--- .e.r.s conditions to individuals .
b who reavire -s in order to nerfom their duties. To achieve this
.; the licensee must:
.,'1 (A) Establish c.. ..rt authorization mee=ss If sts for ==-:n vital island. The -s lists must be 'Mtad and r :__ roved by the cooni-I
,J tant licensee senacer er supervisor at least every 31 days. The
- i 1
1 licensee shall include on the access Ifst oniv individuals P.eee scocific duties require mee=es to vital islands durino nonene. .;;w conditions.
j (8) 'Postively control, in accordance with the access list estab-
, lished oursuant to n..-, h (d)(7)(1) of this section. all ooints of j oorsonnel and vehicle mee=as to vital islands.
i 'i (C) Revoke. in the case of an individual's involuntary tamination i
for cause. the individual's me* ass authorization and retrieve his/her e identification 5-*a= and other entry devices, as acclicable, orier to or i '
simultaneousiv with notifyino this individual of his/her termination.
I i .
(D) Lock and orotect by an active intrusion alare system unoccucied 1
vital islands and all exterior doors leadino to vital is17.r.ds which are .
! not otherwise controlled. .
(ii) Desion the mee==s authorization system to accesmodate the poten- !
i i tial need for resid incress or eeress of individuals durino eneroency
{
conditions or situations that could feed to eme e w conditions. To I helo assure this, the licensee must:
(A) Ensure oronet access to vital soufoment. '
f (8) Periodically review chysical security stans and continoency ii olans and crocedures to evaluate their ootential fanact on olant and '
1 corsonnet safety. i
, # 2 l
1, 2 2 2
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I 06/16/83 l 9 Attachment 1 to Enclosure C
! I
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.[7590-01] ..
.. t 4 (S) All keys, locks, cambinations, and related equipment used t'
a to control access to protected areas and vital Ceress] i,gi,gg, l must be 4
controlled to reduce the probability of compromise. All such keys. tocks.
i
!'4 .
and combinations aust be chanced at least everv 12 months. Whenever there is evidence or susoicion that any key, lock, combination, or related NJ. equipment egy have been compromised, it must be changed. [Sn.. L. ;ne-i
) $ . wI ,.'.. ,---..L e I . , , , , .' i., IockS M M iens, i.!eted
_; J. L .:.;. ;; ;
, leyse-tendressese , e.b 4-1. L- ._ _ ] h
?
Ifconsee shall issue keys. Tocks. dinations. and other Ec sr control
.;.j devices to protected areas and vital isfert only to corsons who nossess
- {
access authorization in :-Ecc-se-r.co with 8 73.56 of this cart. Whenever q] an individual's -se authorization is r. dad due to his or her lack s of 17h.i.iiiness, reliability or inadeousta work perfomence keys, locks. combinations and related eouineent to which that oorson had access -
j, sust be chanced.
s i
- (e) Detection aids. (1) All alams required pursuant to this part
' sust annunicata in a continuously manned central alare station located J within the protected area and in at least one other continously manned 4
4 station [not nesseseri4y] onsita, so that a single act canngt remove the capability of calling for assistance or othenvisa responding to an alare.
.ie [T.
4,
.e ;te-centref-efare-station-s.b 1 :.e consft . 4 s--vita 4+sres-and 4 its we+4e, t . ., ee;;;. , f+oor; end eny-windows-in-i'.e d- is and-in the-; .. ehe44-be-be+4et-resisting-] The onsite central alare station
- .j shall be located within a building such that the interior of the central
{j alare station is not visible from the perimeter of the protected area.
. . ;.i ,
! This station shall not contain any operational activities that would
.3 interfere with the execution of the alam response function. The walls.
i j
- I ~ doors, floor, and any wie in the walls and in the (.sei=5 of the central q alars station shall be bullet resistino. On sita secondarv ca-Er sucoly 4 .? systems for alare annunciator eauf -nt and non-oortable consunciations equionent as roovired in pareersch (f1 of this section sust be located ,
' I. a within vital islands.
j a a n a a R a
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r 06/16/83 10 Attachment 1 to Enclosure C i
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[7590-01] .
I
' t (3) The Ifeensee shall af am all amergency exits in each protected and each vital [evee] g .
= = =
- (h) Response requirement. """
{
(4) Upon detection of abnormal presenca of activity or persons
! or vehicles within an isolation zone, a protected area, material access ij'* area, or a vital [ ares] h; or upon evidence or indication of intru-
^
sion into a protected area, a materfat access area, or a vital [ ares]
h, the licensee security organization must:
- a = a = n (iii)
(A) Requiring responding guards or other amed response personnet to interpose themselves between vital (evess] islands and material access j ,
i areas and any adversa n attempting ent y for the purpose of radiological sabotage or theft of special nuclear material and to intercept any person l exiting with special nuclear material, and a =
li .
=
!. 4. In f 73.70, paragraph (d) is revised to read as follows:
,s .
I 5 73.70 Records. .
- a = =
}
~
(d) A log indicating name, badge number, time of entn , reason for
(
entry, and time of exit of all individuals granted access to a [nersef4y ,
- -. ied] vital [eres] island excect those individuals enterine or exitino the reactor contro1 room. '
=
Dated at Washington, DC, this day of
- ?
1983.
i h
For the Nuclear Regulaton Commission.
i i .
j t
Samuel J. Chilk, Secretan of the Comeission. .
06/16/83 11 Attachment I to Enclosure C
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8
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1 3
N
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e b
7 J
-s e
ATTAOMENT 2 TO THE MISCELLANE005 AMENDMENTS ENCLO5URE (ENCL. C) g .
ORAFT REGULATORY GUIDE t .
.t f.
t I
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i 06/16/83 Attachment 2 to Enclosure C y_.
.WamuD -
_ M M M M, , . - - , --
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g t .
f TA8LE OF CONTENTS
-, .PSS* !
I. I 0N................................................... 1 I i II. vrTat AnEA DESIGNATION......................................... 1 A. Introduction..............................................
Vital 1 .
- 8. Islands............................................. 2
- 1. Description........................................... 2 i
- 2. Independent vital Islands. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3... Openings in Vital Area Barriers (Excluding Doors)..... 5
- 4. Temporary Vitalization................................ 6
- 5. Time-Dependent Vital Islands (Spent Fuel Pools)....... 6 . .
III. VITAL ISLAND ACCESS Colml0L5. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 A. Non-Emergency Controls.................................... 7 1.
2.
Access Lists......................*....................
Logging Requirements..................................
7
- 7 3.
Revocation of Accas s Authori zation. . . . . . . . . . . . . . . . . . . . 7
. 4. Locks, Alarms, and Emergency Controis for uncontrolled Exterior Doors......................... 8 I
B. Physical Protection Plan and Contingency Plan Interface... 8
- 1. Periodic Review of Security and Contingency P]ans..... 10 i a. Cross Trai ni ng. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Fac111tata Emergency Access to Vital Islands..........
- 2. 10 .
g a. Access to Keys..................................... 11 Codes.......................................
- b. Access 11
- c. Loss of Electrical Power. . . . . . . . . . . . . . . . . . . . . . . . . . . .11
.I
, IV. AUTHORITY TO SUSPENO SECURITY MEASURE 5. . . . . . . . . . . . . . . . . . . . . . . . . 12
+
A. Site Supervi sor or Other Designated Of fici a l . . . . . . . . . . . . . . 12
- 8. Controls That can be Suspended During Emergencies......... 13
, C. Use of Escorts............................................ 13
\i V. PROTECTION OF SECURITY EQUIPMENT............................... 13 VI. KEYS AND LOCX5............................................ 4... 14 APPENDIX A.......................................................... 15 4 Attachment 2 to Enclosure C t
. ~ ~ ~ ~ *~~1
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. I. INT 1t000CTION
?
L The Miscellaneous Related Amendeents published in (FR ) are designed to clarify safeguards policy for power reactors on: (1) vital area i
designations (vital island approach); (2) wital island access control during emergency and nonemergency situations; (3) protection of cartain physical ;
security equipment; and (4) key and lock controls. These revised requirements ;
have been developed in order to clarify and/or modify certain existing physical protection requirements. The amendments have been designed to foster plant safety while maintaining adequata safeguards.
This guida presents approaches for implementing the amendments indicated above with an emphasis on minimizing the safeguards igact on safety. .
l II. VITAL AREA DESIGNATION ;
A. Introduction i
The NRC's principle requirements with respect to the protection of items of vital equipment at nuclear power reactors are found in 10 CFR Part 73, " Physical Protection of plants and Natarials." These requirements are aimed at safeguard-ing against sabotage that could cause a radiological release. Section 73.55 has undergone significant revision, particularly paragraph (d) which has been l~
amended to incorporate the new vital island concept. At most power reactor facilities, this revised concept should result in a reduction in the number of .
vital areas by grouping and protecting selected itans of vital equipment in j larger areas referred to as " vital islands." In the protection of vital -
islands, the licensee should remain alert to any substantial advarse impacts l on safety created by safeguards requirements and initiata corrective actions necessary to fostar the safety of the plant, its personnel and the public.
- i l
\
r 06/16/83 1
! Attachment 2 to Enclosure C euene N * -
- - , - . - - - , - , - . - . . - . . . - . . _ , . , . . . _ , -,.,.,-..,---,..._,~,-.-,.,.__--n._-...,_, ..
l 1
- 8. Vital Islands 1
s
]
4
- 1. Descriotion !
'l As provided in 5 73.2(h), a vital area is "any area which contains vital equip-1~ ment." Further, vital islands, according to 5 73.2(nn), "are sets of vital
-l; .
areas in which sabotage resulting in a significant radiological release or reactor core damage or both cannot be accomplished without entry into at least i one vital island." '
5 j Appifcation of the vital island concept allows safeguards measures to be
.i developed by:
i i a.
Identifying only selected vital areas (or f tans of vital equipment) *
.j that require protection, thus providing flexibility in vital island j configuration.
i
' t j b. P ing colocated items of this selected vital equipment using existing
{- physical barriers to the maxiom extant possible. ,,
.I '
The first point recognizes that in most instances a significant radiological j release (typically exceeding 10 CFR Part 100 criterial) is possible only
- 5-I through the concurrent, failure or sabotage of two or more items of vital equip- :
i3 ment.
' This permits the protection within vital islands of selected items of
} equipment which could result in a significant release or could interrupt the . .
' I sabotage chain. The following helps to illustrata this concept.
< ,i og e
- ~
i .
. 'i -
t i 'Part 100.U, critaria specify reference values to be used in the evaluation of .
. reactor sites with respect to potential reactar accidents of exceedingly low probability sf occurrence and low risk of public exposure to radiation. Those
- s reference values are a total radiation dose in excess of 25 rem whole-body j
i dose or a total radiation dose in excess of 300 rem to the thyroid from iodine exposure.
I (Based on a 2-hour exposure time commencing famediately followJng the onset of the postulated fission product release.) ,
4 1
l
, 06/27/83 2 Attachment 2 to Enclosure C i
- _ .. .. em. m.,. , - , . -r. m - ~
., .. r
~- -"'1
n.-. - . _
I j .
I
{, g VITAL CtMPONENTS i
i A Vt V: Vs i
j E Vs V4 f
j ,
C Vs Vs
- t 4 -.
O V7
] Ve ,Vs
-5 t
i In the illustration above, V represents vital components, the sabotage of
) j which would produce a significant radiological release or core damage. Each i
i set shows a chain of vital equipment a sabotaur must tamper with, damage, or
} destroy to produce such an effect. As the illustration shows, protection of equipment located in Vs faterrupts sabotage chains A, 8, and C. Steiliarly, the protection of equipment located in V. interrupts'sanotage path 0. The
.!i vital island concept provides the option of protecting only these two loca-
! tions and defining one vital island containing them both or incorporating each location within other separata vital islands, whichever is the most effective.
This contrasts with the philosophy of protecting V through Va as vital areas..
As noted in point 8 above, the vital island concept also permits the maximum .
t . use of existing barriers and access control points. -
Vital island designations should be directed toward minimizing the opportunity to commit sabotage.
1 The NRC will be conducting studies on each reactor facility to identify items '
t I of equipment considered vital. The rationale for this selection will be dis-
. cussed with Itcensees for their use in the configuration and designation of
] J 06/27/83 3 Attachment 2 to Enclosure C l
J, _ _ ,m,.., . . . . -
,----.- ~~ * * * ~ ~ * * *I * * * *
- 1 . ,
vital islands. The licensee should then be able to designata vital islands that:
j a.
Ensure that an adversary would encounter the vital island protection i system in attempting to cause a successful offsite release of radiation;
+
b.
Minimize unnecessary access to vital equipment and minimize the amount
- I of nonvital equipment located within vital islands;
- c. .
,8 Facilitate the accountability of personnel access to vital islands;
{
> 6 l i e d.
{ : Reduce obstacles to rapid emergency ingress and egress; and
- e. Utilize existing barriers to the extant practicable.
- 2.
', Indeoendent Vital Islands I
The Commiission requires that certain areas and equipment be maintained as
! ;. independent vital islands to provide protection against the insider threat.
j They are as follows:. !
!. a.
~ Diesel generators or other onsite AC power sources and principle safety-related DC power sourcas (excluding electrical distribution systems).2 This would require that all diesel generators and batteries connected to
.s l
. class IE loads should be protected as independant vital islands. !
, .4 ,
t
, !. b. Primary containment.
\j . ,
.t l c. Control room.
't i
e d. Central alarm station.
- d* ,
4 i
8
, i ' onsite Electrical systans need not be protected unless designated as such by an analysis. .
- l. .
i ! .
l .
! 06/16/83 4
- Attac.bnt2toEnclosureC l
J u rc,;. . v vi.' ,- m . c.f v - " ' W ** T 7 " # # ' ' " " " ' * * * * ~
_ _ _ _ _ _ _ _ - - _ - . _ . - - _ . _ . - - _ _ _ _ , . - _ . . _ _ - - - _ _ . - - _ - _ , _ _ _ . . . - _ _ _ _ . _ , - _ , ,-_--_._..,.__.___,_m,___. -___._,_ ,..-_.._ _.-.--_, _--___
f ,
1
- e. Onsite water source required to achieve and maintain hot shutdown or hot standby. This would entail the protection of the primary water source for i at least one of the systems necessary to mitigata an anticipated opera-tional occurrence as defined in la CFR Part 50, Appendix A. This would include those conditions of nemal operation which are expected to occur l ene or more times during the life of the nuclear power unit and include but are not limited to loss of power to all .wirculation peps, tripping I
of the tureine generator set, isolation of the main condenser, and loss of all offsite power. If this onsite water source is protected as part of' primary containment, then it need not be protected as an independent vital j islama. '
. 3. Coeninos in Vital Island Barriers (Excludino Doors)
I i .
I According to 5 73.55(c)(1), "The licensee shall locata vital equipment within l 4 vital area, which in turn shall be located within a protected area. One or l' sore vital areas any constitute a vital island. Access to vital islands must require passage through at least two physical barriers of sufficient strength to meet t>e perfomance requirements of paragraph (a) of thts section." g
~
Accordingly, all openings in the vital island barrier that exceed 96 square l inches 3 and are gn atar than 6 inches one way, such as ventilation fans, venti-l 1ation ducts, cableways, and pipe pass-throughs, that lead to an area acces-f sible fr e outside the vital island should be specially protected. In addf- '
l *1on, the barrier should be constructed of estarials that provida delay to 4r.ed envy. Sech materials should be resistant to cutting, drilling, and '
puncture by small hand tools or tool substitutes.
Aay such opening into a vital island should meet the minimum level of penetra-i
- t. ion resistanca of the vital island barrier itself, so as not to lessen the serall integrity of that barrier. .
- .aeles of hardening techniques are described in Appendix A. These techniques s,; e as guidelines for seversi cost-effective ways of increasing penetration
(
s "Extracteo from American National Standard, ANSI /ANS-3.3-1982, with permis-sion of the publisher, the American Nuclear Society.
a aw83 5 Attachment 2 to Enclosure C
, , , _ , , .e . en amme e * ***e.e < ..o* * * * **** * * * * * *
- , - - - - - , - , . , ,,c.,_--- ,..-n._,..,--,,.,. - , - - _ - - - - - - . - - . - . - - - , , - , .
s . ,
- l .I . --
':} resistance time without lepaiMag the function of an opening. Other, techniques 1-are acceptable, as long as the opening is at least hardened to the level of the ,
j weakast part of the barrier.
I j
The licensee should also ensure that safety systems are not compromised by such j karriers. '
. .I.
- 4. Temoorsty Vitalization
.I . *
-1 The protection of only one part of a redundant safety r/ stem poses an inherent '
- i ,
weakness when, due to maintenance, repair, or replacement, a Ifconsee no longer i 'l relies on the protected primary system, but instead relies on a secondary, '
unprotected'systas. The secondary system would autamatically become vital because it would then perform a given safety function exclusively. In some '-
il
, .n instancas, however, the redundant system may lack the necessary physical barriers t
i and access control equipment. Tte licensee should have the capability to pro-
, 3,
' tact secondary systans which automatically become vital in the event companion
- (primary) wital equipment canses operation.
~
.i j
5.
Time-Oeoendent Vital Tsiands (Soent Fuel Poots) ,
s . . ,
,) Spend fuel pools are currently provided vital protection in accordance with 5 73.55. However, it is recognized that the radiation levels of spent fuel .
decay rapidly after removal from the reactor core and eventually do not
.] require vital protection because the potential for a Part 100 release is ,
i remota.
a Accordingly, under an alternate safeguards approach, spent fuel pools could be included in vital islands during that period when the spent fuel pools
- , )
ii pose a threat to public health and safety. After this initial period, Ifcensees would have the option of relaxing the spent fuel pool safeguards. '
i
\ .
3 4
i .
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4'
.'. 06/21/83 6 Attachment 2 to Enclosure C i f 4 ,
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III. YITAL ISLAND ACCESS CONTRDL5 !
, A. Non- h gency Controls lI The following are access requirements for power reactor ifconsees operating i
under routine conditions.
- 1. Access Lists t
Paragraph (d)(7)(1)(A) of I 73.55 requires that the ifcensee establish current authorization access lists for each vital island. The access list should be . - ,
updated and reapproved by the cognizant Itcensee manager or s'upervisor at least every 31 days. The access list should only include those individuals .
7 whose duties require that they have access to the specific vital island during routine operations. Certain access controls may be suspended during emergency l or abnormal plant conditions, so that the Ifst would be unnecessary under these j circumstances. Therefore, the names of emergency response personnel need not be on the Ifst. ~
i l .
. 2. Locaine Reevirements '
8 Licensees are required to keep a log that indicates name, badge number, time
- of entry, reason for entry, and time of exit of all individuals granted access to a vital island. The intant is to maintain a record of personal access and egress for each specific vital island. This may be accomplished through the .
use of computer-controlled access devices. A separate log documenting -
personnel access / egress for the reactor control room is not required.
. \
- 3. Revocation of Access Authorization l l
~'
} In accordance with 5 73.55(d)(7)(1)(c), the licensee should revoke an indi-
' vidual's access authorization and retrieve that individual's identification badge and other entry devices, as applicable, prior to or simultaneously wi,th notifying this individual of his/her termination, when the termination is involuntary and for cause. The individual should also be provided with an l
06/16/83 7 Attac.*nnent 2 to Enclosure C
, 9 1
__ . . . .s --
e
?
, o .
l
. l
.ij ,
escort to ensure prompt exit from the site. This provision is intended to
~,' reduce opportunities for disgruntled individuals to have access to the reactor
. -] facility.
jjl 4. Lock. A1ams. and %.,.r.cv controis for Uncontrolled Exterior Doors l l 5
In the interest of controlling access to vital islands in the accomplishment of 1
[8 the safeguards oh,fective,10 CFR 73.55(d)(7)(1)(O) requires that the licensee
-: " Lock and protect by an active intrusion alam system unoccupied vital islands
,] ,
and all exterior doors leading to vital islands which are not otherwise con-f1
- q trolled." Exterior doors will be interpreted as doors on buildings which con-tain a vital island or islands (sunshine doors). See the illustration on
- page 9.
l .
The licansee should protact a vital island by maintaining locks and alams on all doors that are not attended access control points. Acceptable criteria for i
the use and selection of commercially available locks are found in Regulatory Guide 5.12 " General use of Locks in the Protection and Control of Facilities and Special Nuclear Meterials." Oescriptions of various surface protection alams in addition to guidance on testing and maintaining alarm systans can be j found in NUREGH3320, " Interior Intrusion Alarm Systass."
The licensee should install " panic" hardware and establish procedures that pemit rapid and orderly egress free vital islands in the event of an emergency,
]
- situation. Emergency exit doors that have " panic" hardware should be alarmed .
to the central alare station in order to monitor usage of such doors.
}- 8. Physical Protection Plan and Continoency Plan Interface -
Paragraph (d)(7)(ii) of 5 73.55 specifies that the Itcenses shall "de' sign the l
access authorization system to accommodata the potential need for rapid ingress '
.i .
or egress of individuals during emergency conditions or situations that could
.i 1
4 lead to emergency conditions." In order to faci 11tata ingress / egress during
.?
such conditions, the Itcensee should conduct periodic reviews of security And
} cant.ingency plans and ensure prompt access to vital equipment.
1
?
06/16/83 8 Attac.'seent 2 to Enclosure C l i I!
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- EXTERIOR 000R ILLUSTRATION
- HYPOTHETICAL CONFIGURATION MOTECTED AREA FENCE
\
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I
'e l
ExteMar Door i
.i b '
.[{
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- l, i
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l Vital Island I
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k:ador Ocor i
9 .
Vital 4 hterior Door - Island Vital Island
/ -
htariar Occr t
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. 9 4
.- .. a ..
~ . .
d i
1 1. Periodic Review of Security and Contir w Plans
.i
'1 a
Paragraph (d)(7)(ii)(B) of 5 73.55 requires that the Ifcensee " periodically review physical security plans and contingency plans and procedures to evaluate '
their potential tapact on plant and personnel safety." The licensee should i
conduct such review annually to ensurw that security procedures do not nega-tively fapact the procedures outlined for emergency or abnorssi conditions.
i Licensees should also review the plans any time changes are ande which could
} affect plant or personnel safety or when the ifcansee becomes aware of a proce-j dure which could tapact safety. Licensees may use the Plant Operations Review il j Committee (PORC), que11ty assurance audit programs, corrective action report-ing systems or other appropriata programs to monitor the pot.antial. for safety / ~
] security impacts.
.li
- a. Cross Training 4
l q Interface problems between security and operations are reduced when the respec-j tive staffs are made aware, through cross-training and fr.de t.rination, of the q ,
roles, responsibilities and general practices of both organizati'ons. The i
.] Itcansee should provida personnel with exposure to the other organizations.
.I
- 2. Facilitate Eseroency Access to vital Islands i
' si
, During emergency or abnormal conditions, it may be necessary for certain j licensee personnel to gain quick access to vital equipment in order to mitigata -
or terminata some adverse plant condition. Also, it is important to ensure l that personnel can quickly egress vital islands if the emergency condition
) results in high radiation or other dangerous conditions within the vital island. -
t i Thus, I 73.55(d)(7)(i1)(A) requires that licensees ensure prompt access to vital equipment during emergency or abnormal conditions. Licensees can provide
? ,
for rapid ingress / egress during such conditions by providing back-up keys to i,
vital islands and methods of opening locked doors in the case of computer or *
'j power failure.
i -
t 1 lI 06/16/83 10 Attac.'unent 2 to Enclosure C i i , -, , .--_,.p., ; % . -
y ...- i m- -
c.- * ' ~' '
~
- - - ----' , *~~'".~~
j '
.i
. , a. Access to Keys i
j In the event of an emergency or abnormal condition at a power reactor, it may i
be necessary for certain personnel, particularly an operator, be assured
-j prompt access to vital islands or equipment. To facilitata access, operating personnel should be provided with access keys necassary to open doors which are locked for security or other purposes.
- b. Access Codes '
It has been observed that the use of individual manually entered identifica-tion codes hamper ingress due to sistaken entries, poor memories, etc. In order to minimize the igact on safety by assuring prompt access, the use of individual manually entered codes in vital area access control systans is not i
]- required or recommended by the NRC.
t i
.1 c. Loss of Electrical Power In order to fac111tata safety, the licensee should provide for rapid ingress /
egress during a computer or power outage. Upon loss of electrical power, if l i
'ntarior vital island doors are not specifically required by the ifconsee's Physical, Protection Plan to fail in the closed position, procedures should be 5
established which provide for prompt compensatory measures in opening locked doors.
The following are acceptable procedures for providing for safe ingress /
lj ogress during a power or computer outage: "
l.
1.
Have locks fail open during an outage or emergency and have guards deployed to monitor ingress / egress.
2.
Utilize an uninterruptible power supply system for electrical locking ..
devices. *
- 3. Provide keyed bypass locks for vital islands and ensure t.%t all 5
necessary personnel have keys. '
06/16/83 11 Attachment 2 to Enclosure C
_ W QweM MMM&= O
, _ - -. . - - - , - - *~#* ' ' ' ' ' ~ ' ' ' ~ ~ ~ " '
l , , .
4.
Install crash (" panic") bars on doors which should then be alarmed for
.j ' energency ingress / egress.
j IV. AUTHORITY TO SU5pENO SECURITY MEASURES 1
i j paragraph (a) of 5 73.55 states, in part, that "the site supervisor or other individual designated in the licensee's physical protection plan shall have the authority to suspend any safeguards measures pursuant to this section if such i
- suspension is necessary to facilitata response to energency conditions, pro .
1 vided that all safeguards measures are restored as soon as practicable follow-
'j.
ing such emergency." Tnis flexibility will accommodata the potential need for j rapid response to emergency or alwurnal conditions.
,I l 7-} A. Site Supervisor or Other Desionated Official 3
}
The licensee should specify in its physical security or contingency plan, by f title, the individual responsible for relaxing security requirements during .
] emergency or abnormal conditions. This individual should typically be the i sita supervisor. The plan should also specify a chain of responsibility for
'} suspgnsion of safeguards requirements in the event that the first designated '
i individual is unevailable.
i The authority to suspend safeguards measures should only be exercised when i sita conditions are or may soon pose a danger to public health and safety i which would result unless the controls are suspended. Relaxation of security j .
measures should be only to the extant necessary to accomplished the emergency i'
situation. In instances where an internal emergency exists which would not result in harm to public health and safety, but has the potential of endanger-ing plant personnel, accass controls can also be suspended. Such conditions i
would include fire onsita, sudden employee health problems, e.g. , heart attack, etc.
Each instance in which safeguards requirements are suspended without
['j approved compensatory measures must be reported to the NRC under the provi-1 sions of 10 CFR 73.71(c), as an event that lessens the effectiveness of It safeguards.
- 06/27/83 12 Attachment 2 to Enclosure C e'
.]
.- . = . , .. .. -n -
- .= ~ - ,
1 e 1 . . .
. 8. Controls That Can be Susoended Durino Emeroencies
.i
- j The types of controls that would be suspended in an emergency might include,
? but are not limited to the following:
' .}
.g
- a. Search and identification of personnel as specified in 5 73.55(d)(1),
I.
~
) b. Search of handcarries itans as specified in 5 73.55(d)(2),
'a 1 c. Search of vehicles required by 5 73.55(d)(4),
- ) l
'j
- d. Use of a badge identification system as required by I 73.55(d)(5),
.j.
8 1 e. Registration of personnel as specified in f 73.55(d)(6), and
.-l I
f.
Access controls for vital islands as required by 5 73.55(d)(7).
1
- C. Use of Escorts -
1
.i In the event safeguards controls are suspended, the ifconsee should use escorts I
ta the extent possible. Offsite response personnel should be escorted by desig- ;
[ nated licensee personnel with operable two-way radio communications to the !
]*
central and secondary alars stations. At least one escort should accompany ;
each emergency vehicle, and all offsita emergency response personnel should be '
in view of the escort at all times unless so doing would constitute a danger to .
the escort. For the purpose of this document, an escort is defined as a member j
l.
of the security organization or other designated individual responsible for l i
accompanying those personnel not allowed unescorted access within a protected
' ~
l area. An escort is not required to possess a technical knowledge of the plant's !
processes or equipment. .
- V. PROTECTION OF SECURITY EQUIPMENT 1
Paragraph (e)(1) of 8 73.55 requires, in part, that the ifconsee locate ensita l secondary power supply systems for alarm annunciation soutpoent in vital 06/16/83 13 Attachment 2 to Enclosur= C l
l
)
.- l 4
- . . : \
.. . j
. 1 islands.
' Protection of these items of equipment is necessary to reduce vulner- !
abilities in the system because their sabotage could significantly impact the 1.
safeguards of a plant. Therefore, ifcensees should include these pieces of equipment in vital islands.
j.
-4
'l VI. KEYS AND LOCKS 31 1
,'l .
2 Paragraph (d)(9) of 5 73.55 requires, in part, that keys, locks, combinations, 2 and related equipment must be controlled to reduce the probability of compromise.
,1 To accomplish this objective, the ifcensee should change all keys, locks, and 5
combinations at least annually or whenever there is evidence or suspicion that I 3
any key, lock, combinations or related equipment have been compromised. Such
.i 4 suspicion may be interpreted as the reasonable belief that com' promise has
.}
occurred even though physical evidence has yet to be uncovered. Changes should
'l:
also be made whenever a person who had access to protected areas or vital islands is tarainated for cause.
4 h
k Keys, combinations and other access control devices should only be issued to d ,,
those individuals possessing an unescorted access authorization in accordance with 5 73.56.
- 1 .
i i -
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1 1-0
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4
- l 06/16/83 14 Attachment 2 to Enclosure C i
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e s
2 APPENDIX A" 1 . .
8 1
F l .
l R
' Techniques 1 and 4 excerpted from NUREG/CR-1378, " Hardening Existing Strategic Special Nuclear Material Storage Facilities," June 1980.
06/16/83 15 Attachment 2 to Enclosure C l'
= 4P***
-m e e . - .p e, .
- Technique No. 1 Hardenina Openino in Catline or Wall
',) D ISTING STRUCTURE - Opening in Ceiling or Wall
. a j
.i TOOLS REQUIRE FOR PSETRATION - Depends on existing opening 1 PSETRATION TIME - Depends on existing opecing >
.i ,
., HARD SING ACTION
.;!'~
1.
Add strong staal jamb to opening
' i.
- 2. Form 3 separata grates by welding M or #5 robar into 6" grids. -
j! ,
Wold grates to inside contar and outer lips or jamb. (Another .
method is to weld 6 separata layers of retar alternating vertical
.j' and horizontal and offset from each other.)
j INCRFASE PS ETRATION RESISTANCE TIME - Approximately 15 minutes ADDITIONAL P SETRATION TOOLS REQUIRE - Boltcutters f
- y ADVANTAGES OF TECHNIQUE -
.] 1. Multiple layers to penetrata
] 2. Delay time can be increased by either increasing size of rebar or 4 numbers of rebar. .
li' a
?
1 j .
i
'I
- 06/21/83 16 Attachment 2 to Enclosure C i
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l _ _ _ . . . . . . . . _ . _ . . . . . . . . . _ . . . - . . . . . _ _ . . _ _ . . _ . . ....s... _ , .. , . a. . a . . ..... 2. ., .... . ..a . m . .
1 -
'~
DI AGR AA41 - llandoning C;- ';in Ceiling or Wall -
i ,
~
EMISTING STRUCTURE . SIARDENED STRUCTURE
, , SIDE VIEW 860E VIEW END OR TOP VIEW .
WALL WALL --
inllE ll e fl m_ilNIIMI El I ' NALLi
--- I IW- ALL
=
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WALL OPEN WALL WALL 3 3 3 3 3
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STEEL * *
, OR JAMS
- 3 : 3 3 E 3 E i - -
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'sfALL WALL WALL 6-- a"--I l- s -.4 EMAMPLE REPRESENTS A 22" a 24" OPENING CLOSED
. IPWilli NO. 4 HER AR RESAR PENETRATION RESISTANCE TIME PENETRAllON RESISIANCE TIME i 8 U MINUTES 4
e
. 0
.e.
o
- .j s .
i '
.a (j
- ' Technique No. 2 Hardenino a Duet in Caf1tna or Wall Where Air Flow
- 1 is Re-:-uiree
~ 'j
- EXISTING STRUCTURE - Duct opening in ceiling or wall where air flow is required
'! TOOLS REQUIRED FOR PENETRATION - Depends on existing opening J!l PENETRATION TIME - Oepends on existing opening HARDENING ACTION w
I L Construct duct to desired size by welding together several ducts c;
- with 6 inchesopenone areas way.of less than 96 square inches and not exceeding q INCREASED PENETRATION RESISTANCE TIME - A substantially improved barrier
- j ADDITIONAL PENETRATION TOOLS REQUIRED .%ne that have proved effective
, ADVANTAGES OF TECHNIQUE 1 L Provides many variations in materials and dimensions.
1 2. Offers many possibilities for custos upgrades.
- 3. Provides substantially improved resistanca.
- 4. Does not affect air flow.
.]-
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06/21/83 la Attachment 2 to Enclosure C l
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I. Technique No. 3 Hardenino a Duct in a Ceilino or Wall where Air Flow
.' .is Reovired DISTING STRUCTURE - Duct opening in ceiling or wall where air flow is required A
TOOLS REQUIRED FOR PSETRATION - Gwends on existing opening 9 PENETRATION TIME - Approximately 1 minute for a 24" x 24" duct (horizontal)
. ;; HARDENING ACTION
?
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.l or concertina. If coils cannot be used, bands or ribbons of barbed 1 tape can be riveted to walls.
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- 2. Attach diffusers with 16 quarter-inch bolts.
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INCREASED PENETRATION RESISTANCE TIME - Approximately 10 minutes
! ADDITIONAL PENETRATION TOOLS REQUIRED - Depends on installation method of q .
barbed tape ADVANTAGES OF TECHNIQUE
), 1. Greatly heapers crawl.through.
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06/21/83 20 Attachment 2 to Enclosure C I
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~1 Herdenino Openino in' Ceilino or Wall Where Air Flow is Recuirec
'l EXISTING STRUCTURE - Opening any size
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-) PEMETRATION TIE - Depends on existing opening ,
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.j NARDENING ACTION
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- 1. Add strong steel jamb to opening.
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y Wald steel jamb. steel pipes of 3" diameter or less together and then weld to INCREASED PENETRATION RESISTMICE TIME - More.then 15 minutes ADDITIONAL PENETRATION TOOLS REQUIRED - Cutting torch j . .
ADVANTAGES OF TECHNIQUE
.; 1. Allows air flow.
i 3. Reduces bodily ' access.
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ATTAOMENT'3 TO THE
- - MISCELLAhEDUS AMEN 0MENTS ENCLOSURE (ENCL. C)
VALUE/ IMPACT STATEMENT j .
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VALUE/ IMPACT STATEMENT MISCELLANEDUS AMENONENTS CONCERNING s
PHYSICAL PROTECTION OF NUCLEAR POWER'Pt. ANTS
-e
- 1. THE PROPOSED ACTION i e
, 1.1 Description i
The Cassission proposes to amend 10 CFR Part 73 in order to: -
i (1)
S Clarify policy on vital area designations (vital island approach);
(ii)
Revise vital faland access control requirements;
} (1'11)
- Permit the suspension of safeguards measures during safety emergencies;
- (iv)
- Require protection of certain physical security equipment; and *
(v) Revise requirements for key and lock controls.
i l.
1.2 Need for Proposed Action The sub, ject actions are being pursued in order to clarify'and/or modify
- certain existing physical protection requirements for nuclear power plants.
The amendments have been designed to foster plant safety while maintainin adequate safeguards.
, A detailed discussion of the need for each amendment is provided in the accompanying Commission paper. .
m.
1.3 Value/ Impact of Proposed Actions
., 1.
Vital Area Desionation Poliev Industry and Pubite - 8enefits and Costs
- If industry protects vital islands by using existing barriers and access control points, the following benefits would be derived:
I o 1 Minimized sabotage possibilities by protecting at least one i area within each set of vital areas wherein radiological sabotage could be accomplished. -
06/16/83 1
Attachment 3 to Enclosure C em.,. e.
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',l o Increased plant safety by allowing fewer interior barriers
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.. and access control points which could hinder safety response
- personnel.
1 i
') o Licensee flexibility in designing a physical security program, j
i.e., provides a high degree of latitude in the protection of selected areas thereby permitting the Ifconsee to minimize costs without significantly reducing safeguards effectiveness.
j 2. Vital Island Access Control Amendment 4 _ Industry and Pe lic - 8enefits and Costs If industry controls vital island access in accordance with the q proposed amanhents to I 73.55(d)(7), the following benefits would
- be derived
- . *
! o
' Improved emergency ingress or egress thereby fostering plant 4
safety.
e
,' o
' Better assurance that approved up-to-date nonemergency access
, Ifsts are used. This reduces the number of persons with access to reactor areas vulnerable to sabo* age.
o Reduced risk of sabotage committed by a person who rece.ived a h
tamination notice.
. ;l
- o Improved physical security integrity of. vital islands by locking 2
i' and alarming exterior doors, not otherwise controlled, which lead to vital islands.
{
- Because the proposed requirements set forth in the amendments in i
.1, 5 73.55(d)(7) are largely modifications of existing procedures, the. costs to
- j the industry are considered negifgibia. -
i . i The proposed amendments on vital area designations will permit ifcensees to protect groups of such areas as vital islands. The cost to reconfigure
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06/16/83 2 Attac.'unent 3 to Enclosure C i
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' existing vital areas into vital islands is approximately equal to the cost of enclosing tuo typical vital islands.
8ased on a survey of nine licensees, the cost to do so would be $1.2M.
t
- Initial Cost i Isomet (Cost in SK or M)
.' Aeolicable to Power Reactor Licensees (1) Cost to reconfigure vital islands based on industry survey................... 1.2M -
i (a) 30K deduction (assimas licensees will use existing barriers and 1
equipment in reconfiguring vital islands).............................. 360K (b) sub-Total............................. 340K .
j (2) To relocate and/or purchase door t control and alare systems.................. 10K 4
., Total projected cost per unit. . . . . . . . . . . . . . 850K
- 3. Protection of Physical Security Ecutosent 1 Industry and Public - 8enefits and Costs i
If industry protects free sabotage certain security equipment 1 not now appearing to qualify for designation as vital equipment under 5 73.2(1) but which significantly fopa:ts upon the security of the plant, the following benefits wodid be derived: .
o Protection of security equipment which would better assure its i .
availability during a safeguards emergency, thereby reducing
. the chance of successful radiological sabotage.
o Increased assurance of compliance with the general perforiaance
_ requirements specified in 5 73.55(a).
'Such equipment would include secondary power supply systans for intrusion.
alares and nonportable cosaunications equipment.
06/16/83 3 Attachment 3 to Enclosure C
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In order to protect security-related equipment such as secondary power I supply systems for intrusion alams and non portable communications equipment, 1
the typical reactor site would incur the following estimated costs:
')
Initial Cost Imoact (Cost in SK) y] Applicable to Power Reactor Licensees 1
i (1) To enclose (coge or fence) secondary j
power supply rystems and nonportable communications equipment (assumes the *
] installation af 100 linear feet of cage
) or fence material s at 8. 030K per foot). . . . . . . . . .
.9 3. 0K 4
i (2) To alam secondary power supply and 4 norr portable caemunications equipment 4
locations alarms per(asstases location, hardware three locations, and l two area
- f.
al are $1. 2K) . . . . . . . . . . . . . . . . . . . . .............. . . abor per 7.2K 4
Total Projected Cost............................
b 10.2K
- 4. Revised Key and Lock Controls '
I Industry and Public - 8enefits and Costs
- If industry revises its procedures in accordance with the proposed amendments to 5 73.55(d)(9), the following benefit would be derived: .
1, . _ . __ _ _ . _ _ _ _ - -
o Reduction in the expense and administrative burden of j ;
implementing a key and lock control program without ,
significantly reducing the safeguards benefits of such a
- program. ~
1 .
8 -
S q the proposed revisions to 5 73.55(d)(9) represent reducing the '
requirements concerning implementation of an effective key and lock control j program, the following savings are projected:
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06/16/83 a Attacament 3 to Enclosure C 1
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.i Aeolicable to Power Reactor Licensees Annual Costs (or Savines) i
-- (1) The labor cost to change the key and l lock system under present requi rements. . . . . . . . . . . $21.0K {
(assumes a site average of 1500 persons. ,
24 people issued keys 305 annual l turnover reta or 7 persons with keys i terminata annually, or one person l leaves every 51 days thereby requiring l
kay/ lock changes 7 times per year 83K per change.)
' (2) The labor cost to change the key and .
l : lock system under proposed requirements.......... less $6.0K (assumes a site average of 1500 persons, l 24 people issued keys 305 annual 4 turnover reta or 7 per, sons with keys -
. terminata annually. As the proposed
- requirements cause lock / key changes annually and when persons are terminated .
' for lack of trustworthiness or inadequata
,{ work performance (projected 1 of 7 persons),
lock /kay changes would average once every )
l; .
.180 days or 2 times per year 53K per change E
Net savi nos . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 315. 0K -
, i 5. MRC Operations - Benefits and Costs
- If the decision is made to adopt the vital island protection
- approach, the impact of these amendments on MRC operations will fall 8 in the areas of licensing negotiation and the conduct of field inspec-
,1 tions to assure complianca.
i Additional NRC actions will be necessary to assure compliance with (1) proposed asendments to 10 CFR 73.55(d)(7) concerning vital
' 1sland access control, (2) protection requirements for certain l
physical security equipment,8 and (3) revised key and lock cor, trol 1 requirements. ,
l
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45uch equipment would include secondary power supply syst ems for intrusion alarus and non portable communication equipment.
t 06/16/83 5 Attachment 3 to Enclosure C
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., The initial costa to the NRC is estimated to be:
1 i
4 (1) Licensing negotiation and review of amended security plans (assiming 8 staff-days / plan x
., 48 pl ans* x 5480/ staff-day). . . . . . . . . . . . . . . . . . . . . . . $184.3K (2) Inspection and Enforcement Staff support time for the negotiation process on per site basis
.) (assuming 5 staff-days /sita x 48 sites x
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$480/ staff-day)................................... +M Tota 1............................................. $299.5'K
.i The estimated annual cost to the NRC is estimated to be: i t (1) Licensing review and approval of security plans l (assuming 8 staff-days / plan x 6 revised .
., per year x $480/ staff-day. . . . . . . . . . . . . . ..........
. plans
$23.0K a
.i (2) Inspection and Enforcement staff support time for ~
M the negotiation process on per site basis (assuming 5 staff-days /sita x 6 sitas 3480/ staff-day. . . . . . . . . . . . . . per year x
- ...................... $14.4K Tota 1............................................. 337.4K
.! 6. Other Governoont Aconcies li It is not expected that these rulemaking actions will have any fopact
.j on other government agencies.
- 7. The Public \
j' ~
The pub 11c's protection from radiological release will be maintained by assurance of adequata safeguards of vital areas and equipment j from sabotage.within nuclear facilities. -
A_
j- There would be negligible impact on the public or effect on customer
] 1 electric bills.
i ~
j *The aanpower resosrcas required to amend the licenses to reflect vital
- islands have been included in budget projections for the period involved.
fj No budgetary changes will be required as a result of this rulemaking.
4 4A11 presently licensed power reactor units (71) are located on 48 sites
.:..] represented by 48 security plans. ,
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! 06/21/83 6 Attachment 3 to Enclosure C I
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- 1. 4 Decision on the Prooosed Action The benefit to be iderived from these amendments would be lower cos j fully implement MRC regulations regarding reactor safeguards while continuing to provide adequate protection of the public health and safety.
- 2. STATUTORY CONSIDERATIONS i.
2.1 MRC Authority v
! The Atomic Energy Act of 1954, as mended, Section 151(3) provides I authority for the Commission to prescribe regulations designed to protect the '
public health and minimize danger to _ life or property. *
', 2. 2 i Need for National Environmental Protection Act Assessment i
- The proposed action is*not a safor action, as defined by 10 CFR 51.5(a)(10), and does not require an environmental impact statement.
2.3
- Relationshin to other Existino or Procosed Reculations or Policies There are no apparent potential conflicts or overlaps with other NRC proposed regulations or policies nor with other agencies' regulations or policies.
, s' 1 . :
06/16/83 7 Attachment 3 to Enclosure C
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.8 MISCELLANEOUS AMEN 0MENTS ENCLOSURE (ENCL. C) i ORAFT PUBLIC ANNOUNCEMENT I -
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u- ..-. m m a w-NRC PROPOSES TO CLARIFY PHYSICAL SECURITY REQUIREMENTS POR NUCLEAR POWER PLANTS j
The Nuclear Regulatory Comeission is proposing to amend its regulations to
' clarify some of its requirements governing the physical security of nuclear pow e plants.
' As proposed, the amenchants would:
1.
Require that vital areas (areas in which radiological sabotage can ;
he accomplished) be protected only to the extent necessary to prevent
{ sabotage.
',' At present, all vital ar'ees must be protected; however, in ~
many cases, a saboteur would have to enter two or more vital areas to
{ i j carry out a successful radiological sabotage, and it is not necessary
- to protect all vital areas to interrupt sabotage.
- 2. 1 Define requirements,for access to vital areas to assure adequate '
l access for safety purposes while providing necessary physical security
- protection. . ,
3.
Provide the protection of specified physical security equipmert which, if sabotaged, could impact significantly the security of the plant.
An example would be a requirement for secondary power suppifes for intrusion alams and non portable communications equipment.
4.
Change the present requirement for key, lock, and combination changes when any employee with access to them leaves to:
- (1) change routinely.
every year; (2) change whenever a person's access authorization is
~
revoked for cause; and (3) change when the compromise of locks is suspected.
l
) !
- Interested persons are invited to submit written comments on the proposed
)
amendeonts to Part 73 of the Commission's regulations to the Secretary, U.S. 1 Nuclear Regulatory Commission, Washington, DC 20555, Attention: Docketing -
and Services Branch, by (90 days after FR publii:ation).
06/16/83 1 Ai. tac.'unent 4 to Enclosure C
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The proposed vital island concapt involves locating each Type I vital area and j' one vital area of each complete group of Type II vital areas in one or more protected vital islands.
)j This pemits the licensee to use, where possible, existing barriers / access control points and to take advantage of recurring j appearances of certain vital areas in many completa groups of Type II vital s areas (as is the case with Va in this illustration). Under this approach, j adequata safeguards for this example facility could be accomplished by j protecting yt, Vs, Va, and Vs, as one or more vital islands. These four areas could be structured in one to four vital islands. In the example, two vitali
.'j islands are shown.
A 0'1 This approach also permits the licensee flexibility in selecting and grouping
~] the vital areas to be protected into vital istands. For akample, the licensee
,} could choose to' include V, or V 2 o instead of V, since they are all in the same * *
~j completa group of Type II vital areas, and still maintain adequate protection.
Thus, the proposed vital island designation approach permits the Ifcensee to 3 (1) reduce the number of areas to be protected by concentrating on vital areas
.I i
which appear in a large number of Type II vital area groups, (2) select from I
each completa group of Type II vital areas the vital area that is most cost- i
.I effective to protact, and (3),take advantage of existing barriers and access control points in grouping vital areas into vital islands. ~
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t i ATTAQ9 TENT 5 TO THE MISCEU.ANEOUS AMDeMENTS DC1.05URE (ENCC)1..
VITAL ISI.AND IU.USTRATION .
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j Hvoethetical Conficuration
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i The illustration demonstretas the proposed vital island concept. This
.' - hypothetical facility has 10 vital areas, Vi through Vso. V2 and V are Type I vital areas (single vital area wherein radiological sabotage can be accomplished). Va through Yzo are Type II vital areas (vital areas wherein radiological sabotage can be accomplished only in conjunction with additional- .
sabotage activity in at least one other separata vital area.) [V3, V., and Vs3
~j-constitute a complete group of Type II vital areas (sabotage can be accomplished only by carrying out acts in all three locations). Likewise [V i 3 and Ve], [V and Vy], and [Vse Vs, and V.o] represent complete groups of *
, Type II vital areas.
, 06/16/83 1 ttachment 5 to Enclosure C t
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- ATTAC MENT 6 TO THE NISCELLANEOUS AMENOMENTS I (ENCLOSURE C)
I SUPPORTING STATENENT FOR RECOR0 KEEPING Ale . [
REPORTING REQUIROMNTS FOR
. 10 CFR PART 73 .i k
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SUPPORTING STATBetT FOR REPORTING REQUfREMENTS FOR 10 CFR PART 73 i~
. 1. Justification '
'. (1) The Commission proposes to amend 10 CFR 73.55, " Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological sabotage," to clarify and refine the policy for *
(1) the designation and protection of vital areas containing safety-related equipment, (2) wital area accass controls. (3) authoMty to
' suspend safeguards measures during safety emergencies, (4) protec-tion of certain items of security equipment which significantly impact nuclear plant secuMty, and (5) key and lock controls.
,- The requirements have been designed to ae-data recommendations - -
of the Safety / Safeguards Review Committee established in response to the Chairman's request of August 16, 1982. This Committee had the overall task of studying power reactor safeguards requirements and practicas to datamine whether actual or potential conflicts exist
, with plant safety objectives.
i Section 73.55 now requires that all vital areas (areas in'which radio-logical sabotage can be accomplished) be protected. Security plans
, which designate these vital areas were originally accepted by the >
Commission on an interim basis pending site-specific reviews to veMfy such designations. Many site-specific reviews have been '
completed. The results indicate that present 5 73.55 requirements may be unnecas,sarily stMct in mandating protection of all vital areas.
.- The Commission is considering adoption of a clarified vital area designation policy which would require protection only to the ehtent
' necessarf to interrupt sabotage. Licensees would be given consider-able latitude to taka advantage of existing barMers and access '
control points. Cartain components, however, would be deemed vital in all cases. These include: onsite diesel generators and
- battaMes (excluding electrical distribution systems), reactor .
06/16/83 1 Attac.'veent 6 to Enclosure C
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containment, control rooms, central alare station, and onsite water
% supplies (excluding piping) required for safe shutdown.
'lj at
- j The staff is proposing amendments to 10 CR 73.55(d)(7) that address both nonemergency and emergency access controis to vital islands.
Although the initial proposed amendment to 5 73.55(d)(7) was subject i to a round of public comment in 1980 (see 45 R 15937), the staff believes that the revised proposed requirements should also be .
, J.}
- p pubitshed for pubife comment due to significant rewording based on s)? the new concept for vital area designation described above. These e
- revisions assura adequate eccess for safety purposes while maintain-c.
ing safeguards requirements. '
2 j The staff is also proposing a revision to 5 73.55(a) to provide
.e t
- authority for licensees to suspend safeguards measures if required to Nata emergency response. These changes are bassa upon recommendations made by the Safety / Safeguards Committee that power
.1
, , reactor licensees be given improved flexibility to facilitate '
3 response to site emergencies or " unusual events."
~~
' The Commission is considering requiring protection of 'specified i
.1 5
onsita physical security equipment (includes secondary power supplies for intrusion alarms and non-portable cossounications equipment) which 3,
is required for the proper functioning of the security systas.
j Usually this equipment does not qualify as vital equipment, but the sabotage of this equipment could seriously impair the security of
'j~ ~
the plant. Such protection is necessary to achieve the general
.4 performanca requirements of ID CFR 73.55(a).
In a metter associated with access control, the Comeission is con ' -
j sidering amendment 5 73.55(d)(9) to reduce unnecessary co'sts associated j' with key and lock controls. The present requirements call for key, 3
.: lock, and combination changes when any employee who had access to these devices is terminated.
.)
I i
l 06/16/83 2 Attachment 6 to Enclosure C a
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1 Staff -ri- ind1==s that amp-te Protection -uw be auined by changing keys, locks, and combinations: (1) routinely on an j annual basis (2) whenever a person's access authorization is revoked for reasons of lack of trustworthiness, reliability, or inadequate j performance, and (3) when compromise of locks is suspected.
.I (ii) The attached draft " Vital Island Designation and Protection Guide,"
'i
-)f provides guidance to the' licensee for determining site-specific vital island designation and protection. This guide will be "
- provided to each licensee as a guida for use in developing their
-l respective plans. I t
] The licensee is required to prepare and submit a revised security i plan to the Commission for review and approval. Par %. Ji (d)(1) l
'. of 5 73.55 requires that each licensee establish authorized access lists for each vital island which are to be updated and reapproved l at least every 31 days. The access lists need to be maintained by )
.j the licensee in order to assure licensee compliance with the require- .l sent of the rule. I l
(iii) There are no similar data available in the field which can be used l for these purposes.
i
, 2. Descriotion of Survey Plan i
l There are presently 48 nuclear power reactor sitas which will be subject j- to this rule. It,is assumed that the progree will be organized and
, seinistered on a site rather than a reactor unit basis. The sailing l !
address for these affected sitas may be obtained from the Director of i Safeguards, Office of Nuclear Material Safety and Safeguards, U.S. ,
~
{ Nuclear Regulatory Commission, Washington, DC 20555.
- 1 a
06/16/83 3 Attacament 6 to Enclosure C i
I
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3.
4 Tabulation and Publication Plans 4
'd 1
Revised security plans submitted to the Commission will be reviewed, i
,1 approved, and filed by the Commission. Specific licensee revised secu-4 rity plans will not be published for public review or ramment in accord-
.g.
(i, ance with 10 CFR 2.790(d). The NRC anticipatas full compliance with the regulations.
,k 4.
1 j Time Schedule for Oata Collection and Publication J
.i
.l The ifcensee will be required to submit to the Commission his Access Authorization plan for approval within 120 days of the effective data of -
') the rule.
.j Within 360 days after the rule becomes effective or 120 days after approval by the Commission, whichever is later, the licensee is
! required to implement the requirements of his approved plan.
j It is estimated that it will take about 18 Commission staff-days to
] '
review and approve each plan submitted and that initially all plans will I
be reviewed and approved within 360 days after receipt of the plans.
- 5. Consultations outside the Acency . _ _ _ _ _ - . -
- The Safety / Safeguards Review Committee, during their task of studying '
O power reactor safeguards requirements and practices in order to deter-sine whether actual or potential conflicts existed with plant safety -
objectives, visited several licensee sites and observed plant operating conditions.
The suggestions and recommendations of the Committee's ti findings have been taken into consideration in the proposed revision of the rule.
l 06/16/83 4 Attachment 6 to Enclosure C 7 --
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g o i
, 6.
Estiastion of Resoondent Reoortino Surden lhamber of Respondents !
' Regulatory After Effective Annual :
Annual Reports Total Time Staff s Section Date of Rule ,
t Filed /Resoondents Recuired/ Response Hours '
- i
- 1. 10 CFR 73.55(a) 48 initially 1 plan / licensee 24 man-hours / plan 1152
$ 2. 10 CFR 73.55(d)(7) 48 initially 1 plan / licensee i
32 ann-hours / plan 1536
<; 3. 10 CFR 73.55(d)(9) 48 initially 1 plan / licensee 8 man-hours / plan 384
.} 7. Estiente of Cost to Federal Governments
?\
l s
It is ' estimated that it will cost the NRC 3184.3K (8 staff-days / plan x
? _
48 plans x S480/ staff-days) to review and approve all submitted revised
! fj security plans.
j It is estimated that six new plants will submit plans for review and approval each year which will cost the NRC about $23.0K to process j
I (8 staff-days / plan x 6 plans x $480/ staff-day). '
i
,i i
f i'
! e.
. l l
l i
i i a
I 06/16/83 5 Attachment 6 to Enclosure C n n.. . . - - - .. .w- ~ ~ ---
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