ML20247N823
| ML20247N823 | |
| Person / Time | |
|---|---|
| Issue date: | 12/16/1988 |
| From: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| To: | Davis A, Ernst M, Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20247N685 | List: |
| References | |
| FOIA-89-108 EGM-88-11, NUDOCS 8904060334 | |
| Download: ML20247N823 (3) | |
Text
Sh RfC 8,f UNITED STATES NUCLEAR REGULATORY COMMISSION r
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WASHINGTON, D, C. 20555
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DEC 161998 EGM-88-11 MEMORANDUM FOR:
William T. Russell, Regional Administrator, Region I Malcolm L. Ernst, Acting Regional Administrator, Region II A. Bert Davis, Regional Administrator, Region III Robert D. Martin, Regional % administrator, Region IV John B. Martin, Regional Administrator, Region V James G. Partlow, Director, Office of Special Projects i
FROM:
James Lieberman, Director Office of Enforcement
SUBJECT:
DETERMINING SEVERITY LEVEL 0F VIOLATIONS INVOLVING ACCESS CONTROL AT VITAL AREAS LOCATED WITHIN OTHER VITAL AREAS After reviewing several cases from the Regions concerning access control at vital areas contained wholly within other vital areas, the Office of Enforcement (0E) discussed the significance of these types of violations with the NRR Safe-guards staff.
NRR advised OE that violations of licensee commitments in physical security plans that exceed the performance objectives of 10 CFR Part 73 are not in themselves significant and that, although the event or condition may still be considered a violation, the Severity Level should be adjusted to reflect the lower significance.
In view of this policy, it is significant only)when a licensee fails to provide j
the two barriers required in 10 CFR 73.55(c)(1.
In the case of an unlocked, unalarmed vital area portal or an opening in a vital area barrier, if the vital area in question is contained within another vital area and the barrier l
for this other vital area satisfies the structural commitments, the requirement for two barriers is met (See Enclosure 1, figure A). Although this is still considered a violation, the Severity Level should be lower than that specified by the examples in Supplement III of the Enforcement Policy.
SfHlarly, when the barrier or portal in question is part of a vital area l
barrier that surrounds another vital area barrier, the significance of the violation will be determined by what equipment is present in each area.
If the only vital equipment is located within the inner vital area and no vital
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equipment is present outside this inner vital area while within the outer vital gi area barrier, the violation should be classified at a seve ty level below that Q-specified in Supplement III (See Enclosure 1, figure B).
rwever, if there is vital equipment present inside the outer vital area but not protected within the inside inner barrier, the protection would lack the two required barriers and the severity level would be the same as that specified in Supplement III (See Enclosure 1, figure C).
An exception to this guidance is when the failures represent a breakdown in control of safeguards activities following example C.7 of Supplement III.
1 8904060334 890403 PDR FOIA t
UNNERST89-108 PDR A
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Mul iple Addressees 1 This lower significance due to duplicate barriers does not apply at the protected area perimeter because of the unique activities (e.g., authorization check, search, and badging) conducted at that barrier.
i If there are any questions on this matter, contact Dick Rosano (492-0740).
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James Lieberman, Director
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Office of Enforcem nt
Enclosure:
As stated j
cc:
J. M. Taylor, DED0 j
R. Erickson, NRR i
R. Burnett, NMSS L.. Chandler, OGC D. Crutchfield, NRR I
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Portal / Barrier Violations for Vital Areas Contained Within Other Vital Areas 1.
L Protected Area Barrier Protected Area Barrier h
Vital Area Barrier Vital Area Barrier i
Vital Area Barrier _
Vital Area Barrier I
p Vital Vital Equiprent Equipment i
Inadequate Barrier / Portal Inadequate Barrier / Portal Figure A Fiqure B l
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Protected Area Barrier Vital Area Barrier i
l Vital Vital Equip-Area ment Barrier i
Inadequate Barrier / Portal 1
Figure C 1
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