ML25168A087

09-06-83 ACRS Report on the Proposed Insider Safeguards Rules

ML25168A087
Person / Time
Issue date:	09/06/1983
From:	Ray J Advisory Committee on Reactor Safeguards
To:	Palladino N NRC/Chairman
References
Download: ML25168A087 (1)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, D. C. 20555 Honorable Nunzio J. Paliadino Chairman September 6, 1983

u. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

ACRS REPORT ON THE PROPOSED INSIDER SAFEGUARDS RULES During its 281st meeting, August 31-September 1, 1983, the Committee was briefed by the NRC Staff on the contents of SECY-83-311:

Proposed Insider Safeguards Rules.

This matter was also discussed with the NRC Staff on August 30, 1983 during a meeting of the ACRS Subcommittee on Safeguards and Security.

The general subject of the proposed rules -- the safeguarding of nuclear power plants against sabotage by insiders and assurance of the good in-tentions and trustworthiness of persons allowed access to vital equipment in these pl ants - - has 1 ong been a matter of interest and concern to the Committee.

We are pleased that rules bearing on these matters are nearing completion.

In general, we approve of the approach being taken.

In the course of our discussions, however, the following points were raised by the Committee.

We believe that these warrant further considera-tion by the Commission, or further attention on the part of the Staff.

1. Preemployment psychologi.cal screening This requirement was originally recommended by an NRC Hearing Board convened to consider access to special nuclear material in 1979 and was considered for inclusion in the Access Authorization Rule initially.

It has not been included in the current proposal.

Al though none of us supposes that such a provision could, of itself, be effective in a high degree -- any more than behavioral observation is likely to be -- it ought to be considered as providing an additional tool for dealing with an extremely difficult matter, and it ought to be included in order to strengthen the selection process.

2.

Background check In general, a five-year hi story is required for a background check.

Nothing very specific appears to be said concerning cases when it may 3370

Honorable Nunzio September 6, 1983 Additional comments by ACRS Members William Kerr and J. Carson Mark are presented below.

Sincerely,

~~

Chairman Additional Comments by ACRS Members William Kerr and J. Carson Mark We have seen no convincing evidence that a method of psychological screen-ing exists which is capable of identifying saboteurs.

Under the circum-stances, the use of some psychological test is likely to provide a false sense of security with no positive benefit.

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Honorable Nunzio September 6, 1983 be impossible for the employer to develop such information -- as might apply, for example, to a new immigrant.

We think there should be a more definitive statement on this point which could, for example, require that a person for whom a full five-year history is not avail-able should not be granted unescorted access.

3.

Grandfathering As proposed, those persons now having access authorization would retain it and such authorizations would appear to be transferable to other employers.

However, such authorizations are granted on different bases by different employers and, in some cases, on bases not equivalent to those proposed in the Access Authorization Rule.

For this reason, we believe that grandfathering and transferability should be 1 imi ted to those personnel whose initial employment was subject to a screening program substantially equivalent to that required by the Access Authorization Rule or whose reliability has been established by be-havioral observation or other reasonable means over a period of at 1 east five years.

Criteria for grandfathering within this context should be developed by the NRC Staff and a suitable grace period should be allowed to permit continued operation with existing personnel.

4.

Temporary devitalization In the case of nuclear power pl ants in cold shutdown, the Access Auth-orization Rule would permit workers for whom no access authorizations or checks may have been made to enter a temporarily devitalized area.

Though shut down, such plants are capable of suffering serious acci-dents and may be particularly vulnerable to mischief.

We understand that a study of the vulnerability of plants in cold shutdown is in progress and the results of this study may assist in defining areas to be devitalized.

5.

Vital area concept The present application of this concept does not appear to provide for the protection of the vital interties between the vital areas.

This could be a serious deficiency.

Sabotage or access protection appropri~

ate to the importance and vulnerability of these coupling systems should be provided.

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