ML20133J197

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Forwards Proposed Clarification of Examples Listed in Proposed Guidance for Events to Be Reported within 1 H & to Be Logged in Proposed Rev to 10CFR73.71.Related Chart & Survey Results Also Encl
ML20133J197
Person / Time
Issue date: 05/08/1985
From: Burnett R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20132B800 List:
References
FRN-50FR34708, RULE-PR-73 AB46-1-43, NUDOCS 8510180330
Download: ML20133J197 (16)


Text

{{#Wiki_filter:& f Mkl, UNITED STATES E s$ NUCLEAR REGULATORY COMMISSION namwoTom. o. c. 2 ossa Mh-l S., o....

                /               .

MAY 0 81985 MEMORANDUM FOR: Victor Stello, Jr., Deputy Executive Director Regional Operations and Generic Requirements d FROM: Robert F. Burnett, Director Division of Safeguards, NMSS

SUBJECT:

CATEGORIZATION AND REPORTING OF EVENTS (10 CFR 73.71) i Please recall that a number of points were raised by the CRGR during the April 17,1985 meeting' which considered our proposed revision to 10 CFR 73.71. We have considered your suggestions and believe they will result in eliminating ambiguities and providing more meaningful guidance for implementing the provisions of the rule. Enclosure 1 proposes clarifi-cation to the examples listed in the proposed guidance for events to be - reported within one hour and events to be logged. ' We have also developed a chart (Enclosure 2) which provides a comparison of requirements for. reporting of events under the present and proposed rules. This may answer some of the questions you raised concerning just what is and what isn't reportable. Concern was also expressed that our proposed requirements for the reporting of lost or stolen badges would place an undue burden on licensees. We have ' surveyed the regions and find- that only a negligible number of access badges which are not properly compensated (reportable) have occurred. See Enclosure 3 for the results of this survey. Please let me know if any further information is needed prior to your further action on the proposed rule.

                                                                             .L ,_. .

j Robert. F. Burnett, Director Division of Safeguards, NMSS

Enclosures:

(3), as stated -'

i cc: W. Schwink, DEDROGR Staff I w/encls. (15 copies) 1* 8510180330 851009 . 50 34708 PDR l

_ _ - . .- . - - _ - .- - . . - _ . - ~ - _ - _ - - .- . _- - - .. - . COMPARISON WITH CURRENT.ONE HOC REPORT - 04E HOUR REPORTS 04E HauR REPORTS LOG ONLY - (CuaRENT) (PROPOSED} (PROPOSED)

4. Attempted or confirmed intrusions at (1) Purposefully attempted or confinned intrusions into vital, material access, protected, 'or protected areas, material access areas, controlled (1) Tallgating by licensee employee /contracter ti, controlled access areas. access areas or vital areas. This includes tail- gain access to an area that he or she is-94 ting by employees / contractors to gain access to authorized to be in.
b. Attempted intrusions' into protected an area to which they are not authorized. (Note:

area by protesting groups. Any unauthorized entry through a required barrier must always be reported within one hour whether or not the breach has been properly compensated.) ,

c. Discovery of or attempted introduction (2) Discovery of the, actual or attempted introductiun i
!                                        of unauthorized weapons, emplosives,                               or possession of unauthorized weapons, emplosives. ( -                                                           ,

1 or incendiary devices inside the or incendiary devices into or within the protected

  • t I
  '                                      protected or controlled iccess areas./l                            area, controlled access areas, material eccess                                                                        *I
                                                                                                                                                                                                                                    -l areas, or vital areas.                                                                                   #
                                                                                                                     -                                                                                                                          )'
d. (3) Substantlated bomb or entorion threats. In addition (12) Unsubstantiated base or extortion threa$s ' ; '

Bone threats or entortion threats./l a telephonic follow-up report of the results of a bomb search should be made within one hour of com-received from individuals. W

                                                                                                                                                                                                                                  '/

pletion. Unsubstantiated bomb threats need not be d %y lamediately reported unless a specific organization 6,4 c. . or group claims responsibility; in this case the ~/ 1 _ .(hreat must be reported within one hour. $.

  • I .
e. M.tss demonstrations, picketing, or ott+r (19) Mass demonstration at plant site that may pose a job actions at the plant site./l threat to the facility. ,1 {~ *
                                                                                                                                                                                                                                 ;th,
  • Q,i f.

Civil disturbances near the plant site./l (20) Civil disturbance within one mile of plant site that *

  • may pose a threat to the facility. IJ*
g. Loss of both central and secondary (13) Uncompensated loss of both central and sec'ondary alarm stations./2 (3) Loss of a single alam station ability 4 alam station ability to monitor or remotely * , .

assess alarms, or communicate with off site monitor or remotely assess alarms, but $4) .p i sources . offsite communication capability reaalgsi,, ,

                                                                                                                                                                                                                             -m                      j
h. Loss of all capability for offsite (16) Complete loss of offsite communications. The (8) Loss of intra-convoy communications ablHt  ;

com.unication to the local law enforce- licensee should report the complete loss of , ment agency./2 offsite communications within one hour if ' possible or immediately af ter restoration of communica tions. If communications to of f-site , g are lost and cannot be restored within an hour. then the licensee should use communications g located offsite to notify the NRC. ,

                                                                                                                                                                                                                                            ->p E                                                                                                                                                                                                 ,             ,

o 1 g . 4 I 1 These events should be evaluated and reported in accoroance with contingency plans. If the threat is more potential in character than explicit, it can be reported within 24 hours from the time it has been estimated to be in existance. 7 i h 2 These events do not have to be reported within one hour if properly compensated for in a timely manner; however, theyu have to . t /t l m- a wi.e _ _ ~ _ _ . _ _ ___ .. _ _ _ . . __ _ ._ _ . , _ __ - . - - __ _ . - _ . - -

ONE HOUR Rf PORis (coC L) ONE HOUR REPOR15 (con't) LOG ONLY (con't) (CURRENT) __ _ _ _ _ _ _JPPOP0st D)_ _ _ _ _ _,,_ _ (PROPOSID)_ ,,, E' # ' # #"'# * * *

i. Loss or degradation ut power f.v the (IS) Uns umpensated loss of all electrical power #

physical s?curity system (t,rlow that level supply to seturity systems that would allow '" ""'" # U' ""~ sequired to keep tte security systeen unauthorized or undetected access. # ' operating at rated capacity)./2 7

j. Failure or loss of operability of any (6) Discovery of intentionally f alsifical filentification (1) Properly compensated security computer failures alarm or intrusion detection system or badges or key cards or security computer failures that do not assis .

portion thereof that: could be directly g g in allowing unescor gd or undetected access.  ? emploited to allow undetected access t or stolen key cards. ID card blanks. keys, or any i. vital or mateelal access areas such as (2) Properly ccanpensated card reader failures. (1) card reader access co'ntrol system a sM t M 4% underizd or ' undetected access to protected areas, material - malfunction *.o that unauthorized personnel

                                                         ,                       g     ,,             ,qg could gain access to vital areas or                                                                      (4) CCTV camera failure in a single zone if a     U       M NRC apped f acility pmNures                 intrusion detection system remains operaC, (2) simultaneous failure of vital or              cannot acc unt for the loss.                                ggon,y, material access area intrusion detection                                                                                                                          !

aoJ threat assessment equipment./2 (11) Uncompensated loss of a sinijle intrusion detection system zone. ($) Failure of a single perimeter lighting zone if intrusion detection system remains opera-(18) Meneer of security force found asleep at post. tional. , (6)Properlycompensatedlossofasingleintrusionh. detection system zone. . _ _ .,

k. Unavailability of minimum nuncer of (14) Unavailability of minimum number of security l l T ,[

security personnel./2 personnel or en actual or iminent strike by the  : security force. .

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J l These events should be evaluated and reported in accordance with contingency plans. If the threat is more potential in chJraCter than explicit, it can be reported within 24 hours from the time it has been estimated to be in existance. 2 These events do not have to be reported within one hour if properly , compensated for in a timely manner; however, they have to be reported within 24 hours. M d5 k T __L I M _ _

COMPARISON WlIH CURRENT 24 G UR REPORT 24 HOUH REPORT Oh[ HOUR REPONT # LOG ONLY i (CURRENT) (PROPOSE 0) (PROPOSED)

a. Thef t of security weapon at the site. (I4TTEf t of security weapon at the site.

3

                                                                     ~~                  ~

b. {22) Conflr E security equipa st tampering of ^(ifConfirmedsecurityequipmenttemperingof Confirmed tampering with security equipment. suipjcious orlain. non tutnicinus nrinia_

c. Discovery of spurtous identification badges. (6) See #6 under or.e hour report. (10) Properly compensated accidental removal offsite key cards, or security locks and keys, or loss of badge by employee, i.e.. badge is promptly cancelled. or use:of
                              ,,                           (7) See #1 under one bour report                              cedurc5 account for.Lbc loss. PRC-approved pro-
d. Thef t of documents containing proprietary or classified security information. . _

(9) Theft or loss of classified documents pertaining ' to facility or transport safeguards. (hote: Also reportable undes 10 CIR 95.57.) (21) Compromise of safeguards information (including , , , loss or theft) which would significantly assist an individual in an act of radiological sabotager . . ~ or thef t of special nuclear material. ,  ; , .

e. Unemplained fire or emplosion within the (10) fire or explosion of suspicious or unknown origin 2' e 11 i
 .      isolation zone, protected area, or controlled          witnen the isolation zone, protected area.                                                        "~ ' ' '

access area that could af fect plant security. material access area, controlled access area, or m vital area.  ?

                                                                                                                                                                               ?
f. Sudden retirement, discharge, or resignation of key security personnel if the event results in a moderate loss of physical security effectiveness./3 '

4 i

g. Security-related injury to a member of the a security organization such as that caused by f malfunctioning security equipment. 3
h. Sicaouts or other labor problems affecting (14) See #14 under one hour report. l the readiness of the security forces.

3 These events do not have to be reported if properly compensated for in a timely manner; however, they do have to be - recorded in the licensee's records. ' r I

I 24 HOUR REPORT (con't) ONE HOUR REPORT (con't) (CURRf fti) LOG ONLY (con't) (P6t0 POSED) (PROPOSED)

4. Any event that reduces the capability for See #13 under one hour report (3) toss of a single alarm station ability to 1

offsite communication to the local law enforce- monitor or remotely assess alarms, but dual ment agencies. (This would not include loss of service of any one regular telephone, even offsite communication capability remains; from an alarm 5%ttion. However, it would i include loss or malfunction of an alarm See #16 under one w.. .vga.4 See #8 under log only station radio or hogline equipment./3 l , I

                                                                                                                                               .                e j, Failure or loss of operability of any alarm or          See #6 under one hour report                            See #1 under log only                    * ~

intrusion detection system or portion thereof i that could be directly emploited to allow See #7 under one hour report See #2 under log only undetected access to the protected area su(h as (I) simultaneous failure of any one perimeter intrusion alarm segment and threat See #17 under one hour report See #4 under log only assessment equipment or (2) undetected failure of any one perimeter intrusion alarin segment./l See #18 under one hour report MM r M Wy See #6 under log only 6 P i 6 i

k. Failure of perimeter lighting to an extent that would impair threat assessment./3 See #5 under log only
1. toss of either the central or second4ry alarm See #13 under one hour report See #3 under log only statton-/3
m. Museer of guards at transfer points of a ship- See #14 under oree hour report ment fewer than that required by the regulation or security plan./3 N

3 These events do not have to be reported if properly compensated for in a timely manner; however, they do have to be rewrded in the licensee *s records.

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                                                                                                                                                           -              m

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4 . i 24 HOUR REPORT (con't) ONL HOUR RIPORT (con't)

  -                   (CUR ENI)                           _      _

[ PROP DJ l

n. Unemplainable security situations tweding ($) Discovery of a criminal act involvis g licensee personnel ,

the effectiveness of security to the limit or contractors with the potential to impact facility defined in the physical security plan. operation or en individual's trustworthiness or rella-bility in the nuclear setting (i.e.. discovery of a conspiracy to bomb the fecility or disturb its vital components, falsification of background screening

                            .,                              certificates, etc.)                                            .

(II) Discovery of a suspicious vehicle following a licensed

                                -                           carrier transportina SSM.

(12) Mechanical breakdown of transport vehicle carrying $$NM. (4) Uncompensated suspension of safeguards controls during emergency conditions which could allow undetected and unauthorized access. I k i h~

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                                                                                                                         !            h= s m

O l I 1 3 These events do not have to be reported if properly compensated for in a timely manner; however, they do have to be recorded in the licensee's records.

                                                                                                                                    .W '

. h, . I _

(Exerpt from R.G. 5.62, (attachment 2 of rule package). hk PROPOSED REVISIONS TO GUIDANCE II. g. Examples of S'afeguards Events That Should be Reported Within One Hour (1) Attempted or confirmed intrusions into protected areas, material access areas, controlled access areas or vital areas. This includes tailgating by amphyees/ contractors to gain access to an area to which they are not authorized. (Note: Any unauthorized entry through a required barrier must always be reported within one hour whether or not the breach has been properly compensated.) Clarification: (1) Purposefully attempted or confirmed intrusions into protected areas, caterial access areas, controlled access areas or vital areas. This int udes tailgating by employees / contractors to gain access to an area 1 to which they are not authorized. (Note: Any unauthorized entry through a required barrier must always be reported within one hour whether or not the breach has been properly compensated.) (2) Discovery of an introduction or attempted introduction of unauthorized weapons, explosives, or incendiary devices into the protected area, controlled access areas, material access areas, or vital areas. Clarification: (2) Discovery of the actual or attempted introduction or possession of unauthorized weapons, explosives, or incendiary devices into or within the protected area, controlled access areas, material access areas, or vital areas. (3) Credible bomb threats or extortion threats. In addition, a telephonic follow-up report of the results of a bomb search should be made within one hour of completion. If a bomb threat is made where evidence suggests that it is not credible, it need not be reported. C1arification: (3) Substantiated bomb or extortion threats. In addition a telephonic follow-up report of the results of a bomb search should be made within one hour of compl etion. Unsubstantiated bomb threats nee 1 not be immediately reported unless a specific organization or group claims-responsioility; in this case the threat must be reported within one hoir. (4) Uncompensated suspension of safeguards controln during emergency conditions which could allow undetected or unauthorized access. Clarification: (4) Uncompensated suspension of safeguards contro's during emergency conditions which could allow undatected or unauthorized access. (Note: Events re-portable u'nder 10 -CFR 50.72 do not require duplicate reports under 10 CFR 73.71.).. (5) Discovery of a criminal act involving licensee personnel or contractors (e.g. discovery of a conspiracy to bomb the facility or disturb its vital components, f alsification of background screening certificates, etc.) Clarification: (5) Discovery of a criminal act involving licensee personnel or contractors with the potential to impact facility operation or an individual's trust-worthiness or reliability in the nuclear setting (i.e., discovery of a conspiracy to bomb the facility or disturb its vital componer.ts, falsi-fication of background screening certificates, etc.) ENCLOSURE 1

(6) Discovery of falsified identification badges, key cards and keys. Clar!fication: (6) Discovery of intentionally falsified identification badges or key cards, t l (7) Discovery of unaccounted for or unassigned key cards, and 10 card blanks, keys and lock sets, or any access device that could allow unauthorized and undetected access to protected areas, material access areas, controlled access areas, or vital areas if not properly compensated. Clarification: (7) Discovery of uncompensated and unaccountcd for, lost, or stolen key cards, 10 card blanks, keys, or any access device 'that could allow unauthorized or-undetected access to protected areas, material access areas, controlled access areas, or vital area if use )f NRC approved facility procedures i .cannot account for the loss. i (8) Theft or loss of documents containing Safeguards Information. Clarification: Delete, see item (21)

(9) Theft or loss of classified documents pertaining to facility or trans-J port safeguards. (Note
Also reportable under 10 CFR 95.97.)

1 Clarification: None (10) Fire or explosion of suspicious or unknown origin within the isolation 4 zone, protected area, material access area, controlled access area, or vital area. Clarification: (10) Fire or explosion of suspicious or unknown origin within the isolation zone, protected area, material access area, controlled access area, or vital area. (Note: Events reportable under 10 CFR 50.72 do not require ] duplicate reports under 10 CFR 73.71.) 7 (11) Discovery of a suspicious vehicle following a licensed carrier.

;                           Clarification:                                                                                                          ;

(11) Discovery of a suspicious vehicle following a licensed carrier transporting i SSM1. l 1 l (12) Mechanical breakdown of transport vehicle carrying SSNM. Clarification: None 1 (13) Uncompensated loss of both central and secondary alarm station ability to monitor or remotely assess alarms, or communicate with offsite sources. Clarification: None ] I (14) Unavailability of. minimum number of security personnel or an actual or

imminent strike by the security force.

j C1 arificat1'o'n: None F (15) Uncompensated loss of all electrical power supply to security systems  : that would allow unauthorized or undetected access. . . Clarification: None i t r i I I l r,_ _ ,. , . . . _ _ _ . . . _ _ _ . _ _ _ _ _ _. _ . . _ . , . . . _ _ _ , _ _ _._ __.___.__.__,___,:.__,

3- l\ b "L , l (16) Complete loss of offsite communications. The licensee should report the complete loss of offsite communications within one hour if possible or i immediately after restoration of cnmmunications. If communications to

offsite are lost ard cannot be restored within an hour, then the licensee j should use communications located offsite to notify the 'NRC.

Clarification: None - (17) Uncompensated loss of a single intrusion detection system zone. , i Clarification: None ^ (18) Member of security force found asleep at post, uncompensated. . Clarification-(18) Member of security force found asleep at post. 1 (19) Mass demonstration at plant site. ) Clarification: (19) Mass demonstration at. plant ' site that may pose a threat to the facility. s (20) Civil disturbance within one mile of plant site if it is a threat to the facility. ! Clarification: l (20) Civil disturbance within one mile of plant site that may pose a threat to q the facility. j (21) Compromise of safeguards infonnation which would significantly assist an individual in an act of radiological sabotage or theft of special nuclear material. Clarification: ! (21) Compromise of safeguards infonnation (including loss or theft) which would - l significantly assist an individual in an act of radiological sabotage or, ! theft of special nuclear material. ' Add: ! (22) Confirmed security equipment tampering of suspicious origin, i

III, c. Examples of Events Required to be Recorded in the Licensee's Log (p.10) i j (1) Security computer failures that do not assist in allowing unauthorized or undetected access, or are properly compensated i

Clarification: . (1) Properly compensated security computer failures or security computer I j failures that do not assist in allowing unetcorted or undetected access. , (2) Card reader failures that have been properly compensated. I Clarification: (2) Properly compensated card reader failures. ! (3) Loss of a single alarm station capability to monitor or remotely asess i alarms but dual offsite communication capability remains. i Clarification: None l

(4) CCTV camera failure .in a single zone if intrusion detection systen remains l l operational .  ;

! Clarification: None i i r-e-.- , - - - g+,r,+e e--+--yu-ew y g--y3 -ert* nr+,----m, ,----,,w .,-c-,we,-e,----, e .-vy--_, ,wm-,-ee-.----e.. - ,~--.------%-,,---,-me, -y< = - - - - a-re. -- - - - ,m- m -

1 ' i (5) Failure of a single perimeter lighting zone if intrusion detection l system renains operational. Clarification: None i (6) Loss of a single intrusion detection system zone that has been properly compensated. Clarification: (6) Properly compensatad loss of a single intrusion detection system zone. (7) Tailgating by a licensee enployee/ contractor to gain access to an area , that he or she is authorized to be in. ~ Clarification: Non'e (8) Loss of inter-convoy communications ability. Clarification: (8) Loss of intra-convoy communications ability.

(9) Compromise of safeguards information which would not significantly assist an individual in an act of radiological sabotage or theft of special nuclear material.

Clarification: Del ete (10) Accidental removal offsite or loss of badge by employee, if badge is pranptly cancelled. Clarification: (10) Properly compensated accidental renoval offsite or loss of badge by - t employee, i.e., badge is pranptly cancelled, or use of NRC-approved procedures account for the loss.  ; Add:  : (11) Properly compensated loss of all electrical power supply to security systems that if uncompensated would allow unauthorized or undetected access. i Add: (12) Unsubstantiated bomb or extortion threats received from individuals. t

Add:
(13) Confirmed security equipmen*. tampering of non-suspicious origin.

l Add: (14) Theft of security weppon at the site. 1

                                              'ee         e i

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        -_ __ . - - _ _ _ . . _ _             .. _. __. _ _ _ _ _ . _ _ . _ , .           . . _ _ _ _ _    _ ,c _ _ . .___ _ . _ _ _ .. _   _ . - , _ _ _ _ _ . _ , _ _ . _ _ _ _ _ _ . __ _ _
   -            . - . . -. ..                     . .   - . - . _ .    - . . .   - =   _ _    . . - _ - .             - - . - . -
 ,                              s l

AB % -i 1 { . Summary of Regional Comment Re: Lost / Stolen Access Badges 1 l The vast majority of access badges do not leave the facility. In all the l Regions, only one facility was noted as allowing access badges to be taken

off site.

i 1

The number of badges granting access to the PA or VA lost or stolen annually i with"'t proper compensation is extremely low.

i l i The consensus of Regional comment indicates that if an access badge is lost j or stolen and not properly compensated then it should be reported to the NRC i

!                                 within one hour.

5 j Other than the regulation, few regional guidelines exist on the reporting of j an uncompensated lost or stolen badge because of the infrequency of the event. i Lost or stolen access badges that are properly compensated are logged. l l { I 4 i f I ENCLOSURE 3

hfAv REGION SURVEY RE: LOST / STOLEN ACCESS BADGES CONTACT: Region I DATE: April 19, 1985

1. Do any utilities that use picture ID badges for access to the PA or VA allow the badges to leave the site?

Badges for PA or VA access do not leave the site. In some cases an owner controlled access card is allowed to leave the site. This card is surrendered prior to entering the PA and replaced with PA or PA/VA access cards and/or key cards.

2. On average, how many badges granting access to the PA are lost or stolen annually without being properly compensated?

Uncompensated loss extremely infrequent, cannot reca'l an instance of this.

3. On average, how many badges granting access to a VA are lost or stolen annually without being properly compensated?

See #2.

4. What is your view on the cresent requirement for a licensee to report an uncompensated lost or stolen badge that could allow unauthorized or undetected access to the PA or VA?

Situation where employee with PA access only picks up lost VA badge within a facility is troublesome. Some utilities use cipher codes in addition to access cards; this would counter unauthorized use of VA access card. Missing badge would be reported at end of shift when individual who lost card attempted to leave facility. At this time the badge could be properly compensated.

5. What guidelines .are used by the Regions to counsel licensees on whether or or not to report an uncompensated for lost or stolen badge?

Situation does not occur where a lost or stolen badge is not properly compensated. Noted one event at Beaver Valle details whether it had been stolen or lost.) y where a badge The licensee was foundcom-implemented (no pensatory measures, logged the event and reported event to Regional Office. t

kkh-'( l REGION SURVEY RE: LOST / STOLEN ACCESS BADGES i - CONTACT: Region II~ DATE: April 19, 1985 ! 1. Do any utilities that use picture ID badges for access to the PA or VA allow

;           the badges to leave the site?

Yes, one - B&W Navy allows access badges to go home with employees. 1 2. On average, how many badges granting access to the PA are lost or stolen j annually without being properly compensated? l Some utilities do not lose any because people are posted at exit points with l the purpose of collecting badges. Some, like TVA, have problems. Estimate i <12 per day " misplaced" in RII. Amount lost or stolen infinitesimal. For site with worst access controls, May-six badges taken offsite, June-one, July-3.

3. On average, how many badges granting access to a VA are lost or stolen 4 annually without being properly compensated?

l See #2, one badge is used for PA/VA entrance.. i

.      4. What is your view on the present requirement for a licensee to report an
;           uncompensated lost or stolen badge that could allow unauthorized or undetected

+ access to the PA or VA? com-j Cannot pensated.think If it of didany example occur where would worry more thisabout wouldwhy occur the and not be licensee c',uproperl;ld not i properly compensate than the lost badge. Thinks this should be reported within

one hour.

l 5. What guidelines.are used by the Regions to counsel licensees on whether or { 4 not to repor,t an uncompensated for lost or_ stolen badge? Log in daily journal if properly compensated. 4

AB% 4 REGION' SURVEY RE: LOST / STOLEN ACCESS BADGES CONTACT: Region III DATE: April 19, 1985 l

1. . 00 any utilities that use picture ID badges for access to the PA or VA allow the badges to leave the site?

No

2. On average, how many badges granting access to the PA are lost or stolen j annually without being properly compensated?

Maybe 10's, not 100's. 4

3. On average, how many badges granting access to a VA are lost or stolen annually without being properly compensated?

See #2, number above includes PA's/VA's.

4. What is your view on the present requirement for a licensee to report an uncompensated lost or stolen badge that could allow unauthorized or undetected access to the PA or VA?

Would be concerned if individual w/PA access only picked up a lost VA badge and attempted to enter VA, this should be immediately reported. Also, agrees ) w/ Region II, that if ! cit / stolen badge cannot be properly compensated, this is an indication of a problem that should be reported immediately. i, l

5. What guidelines are used by the Reg'ons to counsel licensees on whether or not to report an uncompensated for lost or stolen badge?

i Most cases involve a dropped or misplaced badge within the PA which is returned I to security immediately when found. Bdages lost / stolen that are not found i are properly"c~ompensated for through computerized access controls. If a lost / stolen badge cannot be properly compensated it should be reported immediately. Knows of no examples of this situation, but feels example

should be in guidance if situation does occur.

i

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REGION SURVEY RE: LOST / STOLEN ACCESS BADGES CONTACT: Region IV DATE: April 19, 1985

1. Do any utilities that use picture ID badges for access to the PA or VA allow the badges to leave the site?

No, all have recall system where badge is recalled at end of shift. If card is not surrendered at end of shift, individual is paged. If no response is received, indivdual is called at home. If individual refuses to cooperate, he or she is visited by member of security.

2. On average, how many badges granting access to the PA are lost or stolen annually without being properly compensated?

Minimal number

3. On average, how many badges granting access to a VA are lost or stolen i annually without being properly compensated? -

i See #2 above l

4. What is your view on tne present requirement for a licensee to report an i uncompensated lost or stolen badge that could allow unauthorized or undetected j access to the PA or VA?  ;

Lost or stolen ,(dges b are not a problem because of infrequency of event. If  : a badge is acciedntally removed from site it has not been logged out on the  ; computer system. Attempted use of the badge to gain PA entrance will cause  ! an alarm. If a badge is lost or stolen and proper compensatory measures are  ! not affected, then the event should be imediately reported to NRC.

5. What guidelines 'are used by the Regions to counsel licensees on whether or not I to report an. uncompensated for" lost or stolen badge? l Cannot remember situation ever occurring where lost / stolen access badge f was not properly compensated for. Feels bigger problem is lost NRC badges 'i that could be used to gain licensee facility access.
        ....                                                                                        "k REGION SURVEY RE: LOST /ST0LEN ACCESS BADGES j            CONTACT:     Region V                                               DATE: April 19, 1985 1
1. Do any utilities that use picture I.D. badges for 'ccess a to the PA or VAallowtheb{dgestoleavethesite?

No i 2. On average, how many badges granting access to the PA are lost or stolen j annually without being properly compensated? l Could not provide a number because it is not a problem. i

3. On average, how many badges granting access to a VA are lost or stolen annually without being properly compensated?

l

                'See above.

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4. What is your view on the present requirement for a licensee to report an uncompensated lost or stolen badge that could allow unauthorized or undetected access to the PA or VA?

i' Cannot think of example of situation over past'eight years. Facilities have computerized access controls that allow for immediate compensation of lost or stolen badge. i 5. t!nat guidelines are used by the Regions to counsel licensees on whether or not to report an uncompensated for lost or stolen badge? Knows of no guidelines because situation does not exist. Lost / stolen badges are immediately compensated for hen noted in 109 4 t p . :. . ..

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  • J ftEMORANDUM FOR: John G. Davis, Director Office of Nuclear Material Safety and Safeguards FROM: Victor Stello, Jr., Chainnan Comittee to Review Generic Requirements

SUBJECT:

CRGR REVIEW 0F NMSS PROPOSAL TO REVISE SAFEGUAPDS EVENT REPORTING At CRGR Meeting No. 74, R. Burnett (NMSS) presented for CRGR review, a proposal to revise NRC reporting and recordkeeping requirements and guidance concerning safeguards events. In sumarv, the CRGR recomended that the proposal be modi-fied to incorporate clarifications and reviewed by the staff to assure that both immediate and other reporting of safeguards events are necessary and timely. Furthermore, Mr. Burnett stated that he would promptly examine the matter con-cerning badge loss and report his findings to the CRGR. After consideration of the findings of such a review and examination, the Comittee was to decide whether further CRGR consideration of the proposal is necessary. , In a May 8,1985 memorandum to me, Mr. Burnett enclosed his review and examin-ation findings along with proposed modifications to the Regulatory Guide Revision which was reviewed at CRGR Meeting No. 74. The CRGR has considered Mr. Burnett's findings and proposed modifications and decided that further CRGR consideration of this matter at this time is not necessary. 4  ; ._.- , (, \' , * -l Victor Stello, Jr., Chaiman Comittee to Review Generic Requirements cc: SECY Commission (5) W. J. Dircks. Office Directors Regional? Administrators CRGR Members G. Cunningham R. Burnett

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