ML20087K485
| ML20087K485 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/10/1995 |
| From: | Quinn S CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9508230326 | |
| Download: ML20087K485 (6) | |
Text
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Stephen E. Oulnn Yice President Consolidated Edison Company of New York, Inc.
Nian Point Station August 10,1995 Broadway & Bleakley Avenue Buchanan, NY 10511 Re:
Indian Point Unit No. 2 Telephone (914)73&s340 Docket No. 50-247 Document Control Desk US Nuclear Regulatory Commission Mail Station F1-137 Washington,DC 20555
SUBJECT:
Request for Exemption from 10 CFR 73.55(d)(5),
Requirements for Physical Protection Against Radiological Sabotage, Access Requirements Pursuant to title 10 CFR 73.5, " Specific Exemptions", Consolidated Edison Company of New York, Inc. (Con Edison) requests an exemption from the requirements of 10 CFR 73.55(d)(5), " Requirements for Physical Protection Against Radiological Sabotage, Access Requirements", for Indian Point Station, Units 1 and 2. The exemption will permit the implementation of an alternate unescorted access control system which would eliminate the need to issue and retrieve badges at the protected area entrance / exit locations and would allow all individuals, including licensee employees and contractors, with unescorted access to keep their badges with them when departing the site. An exemption from 10 CFR 7355(d)(5) is required to permit contractors to take their badges off-site instead of returning them when exiting the protected area.
Con Edison believes that this exemption request satisfies the criteria of 10 CFR 73.5 as described in Attachment 2 and meets the preliminary attributes of a cost beneficial licensing action. Con Edison has based their exemption request on similar requests granted throughout the industry. If approved, Con Edison plans to implement the biometric access control system by December 31,1995. Therefore,in order to facilitate implementation of the system Con Edison requests that the NRC prioritize this submittal accordingly. Upon approval of the exemption, the Indian Point Station, Units 1 and 2, Physical Security Plan will be updated in accordance with 10 CFR 50.54(p).
Upon exemption approval, Con Edison commits to complete the items listed in attachment 1.
9,y a e o.
N *w b U (, i 9508230326 950810
{DR ADOCK 05000247 I l PDR i
i, Should you have any questions regarding this matter, please contact Mr.
Gharles W. Jackson, Manager, Nuclear Safety and Licensing.
Very truly yours, L
cc:
Mr. William T. Russell Director, Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 Mr. Thomas T. Martin Regional Administrator-Region I US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Francis J. Williams, Jr., Project Manager Project Directorate I-1 Division of Reactor Projects IDI US Nuclear Regulatory Commission Mail Stop 14B-2 Washington,DC 20555 Senior Resident Inspector US Nuclear Regula.-ory Commission PO Box 38 Buchanan,NY 10511
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Docket Nos. 50-03 & 50-247 Pagel of t List of Commitments l
1.
Revise the Physical Security plan to allow licensee and contractor employees to take their card key badges off-site.
2.
Implement a process for testing the proposed system to ensure j
continued overall level of performance.
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c ATTACHMENT 2 REOUEST FOR EXEMPTION - BIOMETRICS ACCESS CONTROL INTRODUCTION:
Con'o11 dated Edison Company of New York, Inc.
(Con Edison) s
- requests, in accordance with the provisions of 10 CFR 73.5,
" Specific exemptions," an exemption from certain requirements of 10 CFR 73.55,
" Requirements for physical protection of licensed 1
activities in nuclear power reactors against radiological sabotage" for Indian Point Station, Unit 1 and 2.
Specifically, Con Edison requests an exemption f rom 10 CFR 73.55(d)(5).
This section, in part, states that an individual not employed by the licensee but who requires f requent and extended access to protected and vital areas may be authorized access to such areas without escort provided that he receives a picture badge upon entrance into the protected area which must be returned upon exit f rom the protected area.
Title 10 CFR 73.55 states that the licensee shall establish and mainta in an on-site physical protection system and security organization which will have as its objective to provide high accurance that activities involving special nuclear material are not contrary to the common defense and security and do not constitute an unreasonable risk to the public health and safety.
Title 10 CFR 73.55 specifies that the Commission may authorize an applicant or licensee to provide measures for protection against radiological sabotage other than those required by 10 CFR 73.55.
This can be accomplished if the applicant or licensee demonstrates that the measures have the same high assurance objective as specified in the regulation, and that the overall level of system performance provides protection against radiological sabotage equivalent to the regulation.
Exempt ion f rom 10 CFR 73. 55(d) ( 5 ) is requested to allow individuals with unescorted access to take their photograph identification card key badges of f-site in conjunction with the use of a hand geomet ry biometrics system to control unescorted access into the Protected Area of Indian Point Station.
CURRENT OPERATION:
1 Currently, unescort ed access into Indian Point Station is controlled through the use of a photograph badge / card key (during the remaining discussion the term " badge" will be used to mean the combination of a picture badge and card key).
The security force members at the protected area entrance through the Command Guard House use the photograph on the badge to identify the irdividual requesting access.
Under the current system, badges are not taken off-site and are issued, stored, and retrieved at the entrance / exit Command Guard House.
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PROPOSED SYSTEM:
Under the, proposed system, each individual who is authorized unescorted access will have the physical characteristics of their hand (hand geometry) registered with their badge number in the access control system.
Since no one can use a badge to gain access except the individual whose hand geometry has been registered to that
- badge, individuals (this also includes individuals not employed by the licensee, e.g. contractors) will be allowed to keep their tedge with them when they depart the site.
All other access l
processes, including search function capability, will remain the same except for elimination of the process to issue, retrieve and store badges at the Protected Area ent rance/ exit Command Guard House.
At least one security force member will continue to be positioned at the Command Guard House.
'Ibe hand geometry system is superior to the current process because it provides a non-transferable means of identifying people, unlike Itotographs and the use of a personal identification number with a badge.
During the registration process, hand measurements are taken three times on each hand with the results being averaged.
'Ihis forms a template of the user's hand which is stored for later use in the actual verification process.
A registered user enters his/her badge into the card reader and places the hand on the measuring surface.
The system detects when the hand is properly positioned and then takes a picture.
The unique characteristics are extracted from this picture and then compared with the previously stored template.
The performance of the hand geometry biometrics system has been evaluat'ed by Sandia National Laboratories (see Sandia Report entitled " A Performances Evaluation of Biometrics Identification Devices," Sand 91--0276 UC--906 Unlimited Release, printed June 1991).
Based on the results of this report regarding biometrics systems, the false-accept rate for the hand geometry system is at least equal to the current system.
Upon exemption approval, Con Edison shall update the Indian Point Station, Units 1 and 2, vnysical Security Plan accordingly, and will institute a process for testing the system to ensure that the sensitivity or the system is maintained at an appropriate level.
As stated, all other access processes will remain the same except for elimination of the process to issue, retrieve and store badges at the protected area entrance / exit of the Command Guard House.
The system being proposed for Indian Point Station will use the same hand geometry biometrics equipment and is configured in the same manner as the biometrics systems currently in operation at Calvert Cliffs Nuclear Power Plant and Limerick Nuclear Power Station.
These plants have been granted similar exemptions.
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.,; g BASIS FOR EXEMPTION:
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Exempt ion,f rom 10 CFR 73. 55 (d) ( 5 ) is authorized by law, will not present an undue risk to the public health and safety and is y
consistent with providing common defense and security.
The change Will not_ decrease the overall IcVel of the security _ system.
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'Ihe underlying purpose of 10 CPR 73.55(d) is to control all points i
of personnel access into a protected area.
Under the proposed system, Con Edison will continue to control all points of personnel access into the protected area.
All required access processes, including search function capability and access revocation, will remain the same.
The basis for 10 CFR 73.55(d)(5) was to ensure that the badges could not be compromised or stolen by being taken off-site.
Under the proposed system, badges would be taken off-site, however,. both the badge and a hand geometry match would be necessary for access into the protected Area.
Even if a badge could be compromised or stolen, access would not be possible without the hand geometry of the person registered to the badge.
Thus, the proposed system would continue to provide a combination of identity verification processes and, in fact, would increase the level of access control at the Indian point Station.
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