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Latest revision as of 11:30, 12 December 2021
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g NUCLEAR REGULATORY COMMISSION l
" WASHINGTON, D. C. 20556
- NOV 2 31982 MEMORANDUM FOR: L. J. Evans, Jr., Chief Fuel Facility Safeguards Licensing Branch Division of Safeguards Office of Nuclear Material Safety and Safeguards FROM: Raymond J. Brady, Director Division of Security Office of Administration
SUBJECT:
DRAFT REVISIONS TO 10 CFR PART 11 Reference is made to your November 9, 1982 memorandum transmitting the proposed draft revisions to 10 CFR Part 11, and to subsequent detailed discussions
-between Messrs. Russell R. Rentschler, Odell F. Smith, and James J. Dunleavy of our staffs.
Enclosed are our initial specific comments on the various revised sections of-
.Part 11. As indicated to Mr. Rentschler by Mr. Dunleavy, we are currently discussing with ELD several issues related to the " renewal" provision (see
(- enclosure, 5 11.15 (c)) and to the application of the criteria for determining eligibility-.for access to or control over special nuclear material (see (b) below). We will keep you advised of the status of these discussions.
With respect to the INPM Subconnittee's unresolved concerns identified in your memorandum, we offer the following comments:
(a) By revising 5 11.15 (a)(2)'as we suggest in our specific comments,
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licensee employees in possession of an active NRC access authorization under 10 CFR Part 25 could request NRC to grant SNM access authorization at a comparable level without filing complete applications in accordance with511.15(b).
(b) We agree that the requirements of 55 11.11 (b) and 11.13 (a) could conceivably result in the removal of licensee employees from positions in which they have worked for considerable periods of time if found ineligible for NRC SNM access authorization. This is also true with respect to the provisionsofs11.15(c). However, it should be noted that under the criteria set forth in 10 CFR Part 10.11 and their application as specified in s 11.21 (a), (b), (c), and (d), a demonstrated record of favorable work
' CONTACT: J. J. Dunleavy, PERSEC 42-74001 L
B601090455 851223 7 PDR PR PDR 11 50FR39076 1
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L. J. Evans, Jr. NOV 2 31982
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performance in such positions for considerable periods of time is itself a mitigating factor in resolving eligibility questions for SNM access authoriza-tion. As indicated above, we will keep you advised of the status of discussions with ELD on this and related issues.
Finally, we note for your information one important difference that remains between the requirements of 10 CFR Part 11 and 10 CFR Part 25. Under 10 CFR Part 11, no age limitation is being placed on a comparably scoped background investigation that may serve as the basis for NRC "U" or "R" access authoriza-tion. Under 10 CFR Part 25, however, we are placing a five year age limitation on a comparably scoped background investigation that may serve as the basis for NRC "Q" or "L" access authorization. We believe that such a policy is entirely appropriate for the NRC classified information program and consistent with federally acceptable personnel security practices and procedures.
We appreciate the opportunity to comment on these revisions to 10 CFR Part 11 and we will continue to assist you in this effort.
l Rap o d J. Br , Dire o Mvi 'on of urity
( 0ff'eoff d nistri io l
Enclosure:
As stated cc: R. F. Burnett, NMSS, w/ encl
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'Vt_ NOV 2 31982 SEC Comments on Proposed Draft Revisions to 10 CFR Part 11 511.11(b) - This section should be revised to also allow an individual in possession of an NRC "L" or an equivalent active federal tccess authorization, but not yet in receips + F an "R," unescorted access to any protected area at any :ite subject to this Part provided that a complete application was submitted in accordance with 5 11.15 and the applica-tion has not been disapproved.
- In the second sentence, the words "...as reflected in
. Section 11.15(f) of this part..." should be deleted.
(Refer to our comments on 11.15 (f).)
511.13(a)(1)and 511.13(b)(i) - The word " approved" should be deleted and replaced with "NRC 'U.'"
511.15(a)(2). - The words "NRC or other" should be inserted between
" active" and " federal in the first sentence. The words "if other than NRC" should be inserted between " clearance" and "to" in the third sentence.
..( - The last sentence should be revised to add after the word
" individual" the phrase, "specifying the investigative basis and level of such."
511.15(b) - This section should be revised as shown and the required foms should be identified by the appropriate form number:
(1) Personnel Security Questionnaire (NRC-1, Parts I and II);
(2) National Agency Check-Data for Nonsensitive or Noncritical-Sensitive Position (SF-85A)-for' "R" cases only; (3) two completed standard fingerprint cards (FD-258);
(4) Material Access Authorization Acknowledgment (NRC- );
(5) Authority to Release Information (NRC-259);
(6) related forms where specified in accompanying
- instructions (NRC-254); and j (7) a statement by the employer, prospective employer, or
- (
contractor identifying the job to be assigned to or 9
i ,
NOV 2 31982
(
assumed by the individual and the level of authoriza-tion needed, justified by appropriate reference to the licensee's security plan.
511.15(c) - This provision is currently under review by ELD. We will provide comments to you upon completion of ELD's review.
5 11.15 (e) - The following changes should be made:
- delete the word "New" in (1), (2), and (3).
- place an asterisk after $15.00 in (3) and (4) and indi-cate by footnote: "If full field investigation is deemed necessary, a fee of $1,550.00 will be assessed."
- delete the phrase "When no investigation required" in (4).
511.~15(f) - As written, this section appears to waive the requirements for any individual (e.g., licensee employees, contractors,
( vendors, etc.) who already possesses an active DOE /NRC or equivalent federal access authorization to obtain an NRC "U" or "R" access authorization. This section should therefore be revised to authorize the use of the certifi-cation process described in 5 11.15 (a)(2) in meeting the requirements of 59 11.11 (b), 11.13 (a), etc., but not to eliminate.those requirements.
- Any revision of this section should include an exception to the requirements of 511.11 (b) for federal employees on official business, and, if you feel warranted, for visits by non-site personnel (e.g., contractor, vendor, national laboratory personnel, etc.) on official business I who possess NRC/D0E "L" or "Q" or equivalent access ;
authorization. '
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