ML20209B210
| ML20209B210 | |
| Person / Time | |
|---|---|
| Issue date: | 06/09/1999 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20209B181 | List: |
| References | |
| SECY-99-024-C, SECY-99-24-C, NUDOCS 9907060301 | |
| Download: ML20209B210 (3) | |
Text
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NOTATION VOTE RESPONSE SHEET TO:
Annette Vietti-Cook, Secretary FROM:
COMMISSIONER MCGAFFIGAN l
SUBJECT:
SECY-99-024 - RECOMMENDATIONS OF THE SAFEGUARDS PERFORMANCE ASSESSMENT TASK FORCE (WITS 199800188)
Approved k
Disapproved Abstain Not Participating COMMENTS:
See attached comments l
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DATEC I
l Entered on "AS" Yes 6 No l T !8E i Ta !2' CORRESPONDENCE PDR 3
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l Commissioner McGaffiaan's Comments on SECY 99 024 l
I approve the staff's four recommendations outlined in SECY-99-024. as supplemented by the staff's remarks at the May St" Commission briefing.
I also join Commissioner Merrifield in commending the staff that outlined their concerns in the two differing professional views (DPV) and the one differing professional' opinion (DPO) on the OSRE program.
In the final analysis. I agree that the new safeguards assessment program is a better product because of the interactions arising from.the concerns raised in the DPVs and DPO.
I note that at the May 5t" briefing. Mr. Orrick informed the Commission that he considered his concerns outlined in the February 3, 1999. DP0 resolved. 'I am encouraged by this constructive use of the DPV/DP0 process.
The proposed new rule and associated guidance offer the opportunity to clarify our security requirements and reduce unnecessary regulatory burden.
It will be a significant step f0" ward to recognize operator actions and engineered J
safety. systems as integral components of a licensee's overall response to sabotage scenarios.
As the staff develops the rule and associated guidance and uses the remaining OSREs to pilot concepts for the revised safeguards inspection and assessment program. I would encourage staff to interact with stakeholders in an open process, akin to that used for the Part 70 proposed rule and the revised source term proposed rule. The' Commission has received remarkably positive comments on the open process we have used in each of these j
rulemakings.
I recognize that in this case. protection of safeguards information may. impinge on openness. but that should be kept to a minimum.
I also agree that our design basis threat needs to be periodically updated.
As I indicated at the May St" briefing, I have doubts about the notion of no warning.
That may be appropriate for some parts of the threat spectrum. but as the threat becomes more elaborate. the probability of detection and warning goes up.'
At the current time power reactor licensees must maintain a const. ant high-level-vigilance to defeat a design basis threat that could do far more damage with far less likelihood of adverse consequences for the attackers by attacking other soft targets in say the chemical industry.
Our European colleagues, presumably, have a very different design basis threat for their power. reactors, because one does not see.anything like the large U.S. guard forces and other security measures at European plants..The Commission needs to better understand this disparity.
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SECY-99-024 I am also concerned about the tradeoffs between security and safety at our power reactor facilities.
I certainly want adequate security and to maintain these facilities in their current status as among the hardest, if not the hardest. industrial facilities in the United States.
But at times security measures (such as welding doors shut) can detract from reactor safety (for example, by impeding access not only by intruders but by plant personnel).
Chairman Jackson pointed out at the May 5"' Commission briefing that by recognizing operator actions and engineered safety systems, we will better understand the tradeoffs between security and safety.
I agree.
I will be interested in any insights gained by staff and licensees about existing security measures as this new approach is utilized in the remaining 0$REs.
E/L4
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