Index | Site       Map | FAQ | Facility       Info | Reading       Rm | New | Help | Glossary | Contact UsProtecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION -   About NRC    - The     Commission 
  - Statutory Authority 
  - Strategic Plan 
  - Budget &      Performance 
  - Organization & Functions 
  - Locations 
  - History 
  - Values 
  - Policymaking 
  - Radiation Protection 
  - Fire Protection 
  - How We Regulate 
  - Grants 
  - Civil Rights 
  - 
- NuclearReactors    - Operating Reactor Locations 
  - Reactor Quick Links 
  - Power Reactors 
  - Research and Test     Reactors 
  - Operating Reactors 
  - Operator Licensing 
  - New Reactors 
  - Operator     Licensing for New Reactors 
  - Reactor Safety Research 
  - Advisory Comm (ACRS) 
  - Decommissioning     of Nuclear Facilities 
  - 
- NuclearMaterials    - Fuel Cycle Facility Locations 
  - Uranium     Recovery Locations 
  - Materials Quick Links 
  - Special Nuclear Material 
  - Source Material 
  - Byproduct Material 
  - Med, Academic & Ind Uses 
  - Source Materials Facilities 
  - Uranium Recovery 
  - Fuel Cycle Facilities 
  - Materials     Transportation 
  - Materials Research 
  - Advisory Comm (ACMUI) 
  - Decommissioning     of Nuclear Facilities 
  - Materials     Environmental Reviews 
  - 
- RadioactiveWaste    - Waste Quick Links 
  - Low-Level Waste 
  - Waste Incidental to     Reprocessing 
  - Incidental Waste Criteria 
  - High-Level Waste 
  - Uranium Mill Tailings 
  - LLW Disposal 
  - HLW Disposal 
  - Spent Fuel Storage 
  - Spent Fuel Transport 
  - Waste Research 
  - 
- NuclearSecurity    - Security     Spotlight 
  - NRC     Responsibilities 
  - Domestic Safeguards 
  - Radioactive Material Security 
  - Facility Protection 
  - Nuclear Material Control 
  - International Safeguards 
  - Information Security 
  - Emergency     Preparedness 
  - &; 
- Public Meetings&   Involvement    - Public Meeting Schedule 
  - Commission     Schedule 
  - Conferences & Symposia 
  - Documents for Comment 
  - Brochures & Fact Sheets 
  - Involving Stakeholders 
  - Info Quality Guidelines 
  - Rulemaking Process 
  - Licensing 
  - Enforcement 
  - Hearing Process 
  - Hearing Applications 
  - 

Home       > Electronic Reading       Room       > Document       Collections       > Generic       Communications >       Generic       Letters >       1996       > Gl96002 
				UNITED STATES                         NUCLEAR REGULATORY COMMISSION                    OFFICE OF NUCLEAR REACTOR REGULATION                           WASHINGTON, D.C.  20555-0001                               February 13, 1996NRC GENERIC LETTER 96-02:  RECONSIDERATION OF NUCLEAR POWER PLANT SECURITY                               REQUIREMENTS ASSOCIATED WITH AN INTERNAL THREAT Addressees  All holders of operating licenses or construction permits for nuclear powerreactors.PurposeThe U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter tonotify addressees that the NRC has reconsidered its positions on certainsecurity measures associated with protecting nuclear power plants against aninternal threat.  It is expected that addressees will review the informationfor applicability to their facilities and consider actions, as appropriate. However, suggestions contained in this generic letter are not NRCrequirements; therefore, no specific action or written response is required.Background  The fitness-for-duty (FFD) rule (10 CFR Part 26) published on June 7, 1989,required power reactor licensees to implement FFD programs.  The accessauthorization rule (10 CFR 73.56) published on April 25, 1991, required powerreactor licensees to implement access authorization programs.  One objectiveof these regulations was to ensure the reliability and trustworthiness ofpersons granted unescorted access to protected areas at nuclear powerfacilities.  In light of these regulations, the NRC initiated an evaluation ofsecurity requirements associated with protection against the insider threat atnuclear power plants.  One purpose of the evaluation was to determine if othersecurity requirements pertaining to protection against an insider remainappropriate.  The staff reported the results of its initial review in SECY-92-272, "Re-Examination of Nuclear Power Plant Security RequirementsAssociated With the Internal Threat," dated August 4, 1992.  After performingthis initial review, the staff recommended a reduction or elimination ofcertain security requirements that gave only marginal protection against theinsider threat.  After reviewing SECY-92-272, the Commission asked the staff to reexamine thesubject and explore alternatives for allowing reductions in unnecessary ormarginally effective security measures.  The results of this reevaluation arereported in SECY-93-326, "Reconsideration of Nuclear Power Plant SecurityRequirements Associated With an Internal Threat," dated December 2, 1993.  9601230206.                                                            GL 96-02                                                            February 13, 1996                                                            Page 2 of 5Description of CircumstancesIn a staff requirements memorandum dated February 18, 1994, which is availablein the NRC public document room, the Commission endorsed staff recommendationsto (1) issue generic correspondence informing licensees of the opportunity torevise certain commitments in their security plan and (2) proceed withrulemaking regarding specific changes to reduce or eliminate certain securityrequirements.  This generic letter identifies those areas in which licenseesmay choose to revise their plans without having to wait for the issuance ofthe rule changes that are in progress.  Section 10 CFR 73.55(a) specifies thatthe Commission may authorize a licensee to provide measures for protectionagainst radiological sabotage other than those required by 10 CFR 73.55paragraphs (b) through (h) if the licensee demonstrates that the measures havethe same high assurance objectives as specified in 10 CFR 73.55(a) and thatthe overall level of system performance provides protection againstradiological sabotage equivalent to that which would be provided by paragraphs (b) through (h) and meets the general performance requirements of10 CFR 73.55(a).  The Commission has determined that although the alternatemeasures addressed herein could result in a small decrease in a licensee'smeasures to protect against an internal threat, the additional licenseecommitments described reflect appropriately the same high assurance objectivesas specified in 73.55(a), and if properly implemented, the overall level ofsystem performance will provide protection equivalent to that provided byparagraphs (b) through (h) and meet the general performance requirements of 10 CFR 73.55(a).This generic letter was originally published in the Federal Register (November 2, 1994) for public comment and has been modified on the basis ofthose comments. DiscussionSome of the changes identified will require licensees to submit security planchanges in accordance with the provisions of 10 CFR 50.90, while other changesmay be processed in accordance with the provisions of 10 CFR 50.54(p) and canbe implemented without NRC approval.  Staff positions reflected in A and D donot apply to structures which are required to be bullet-resisting becauseleaving these doors unlocked or failing to compensate for lock failures wouldoffset the bullet-resisting protection features. As discussed below, licensee security plans may be revised in the followingfour areas:  (I)   Vital Area Access Control Measures      Changes to vital area (VA) access control measures identified below are      subject to confirmation that (1) certain other site-specific measures      are in place or will be implemented to demonstrate (e.g., through      contingency drills) that a capability, including a protective strategy,      exists to protect against an external adversary after making any of the .                                                   GL 96-02, February 13, 1996                                                   Page 3 of 5      changes and (2) measures are in place to examine hand-carried packages      for explosives (at the protected area barrier) using equipment      specifically designed for that purpose.        Plan changes requesting any of the following VA measures must contain      commitments to hold contingency drills at a frequency sufficient to      maintain response capability for response personnel.  The use of      "organic"-type X-ray equipment would satisfy the criteria for inspecting      hand-carried packages for explosives.  Other acceptable methods would      include portable "sniffers" and visual inspection.      Subject to confirmation of these measures, the following changes to a      security plan may be acceptable:      A.  Compensatory Measures - No compensatory measures need be taken for          either a lock or VA alarm failure for up to 72 hours after the          failure is discovered.  After 72 hours, the equipment must either be          operable or compensatory actions taken by posting a guard or          watchman.  During the first 72 hours of a lock or alarm failure,          that portal will be added to the existing patrol schedule to          periodically confirm functioning of the operable feature (lock or          alarm).  If both lock and alarm fail at a portal, that portal must          be posted immediately (within the time specified in the current          plan).                  B.  Maintenance of Discrete Vital Area Access Lists - Separate access          authorization lists for each vital area of the facility may be          eliminated.  As an alternative to those separate lists, it would be          acceptable to maintain a single listing of persons who have access          to any vital area.  To maintain its accuracy, this listing would          have to be revised as the access status of a person changes,          especially as the status relates to removal or loss of vital area          access authorization, but a 31 day validation of the list is not          required.      C.  Alarm Response - Modification to the response to vital area access          control alarms (doors) may be acceptable.  Response is only needed          to a VA door intrusion or tamper alarm but not to other alarms.  All          other alarms are to be resolved by existing procedures (e.g., assess          cause and fix problem).        D.  Locked Condition of Door - Although locking mechanisms and access          control systems, including door alarms, would be retained, doors to          vital areas could be left unlocked.  Licensees choosing this option          would be expected to have the capability to remotely lock the          door(s) from both the central and secondary alarm stations, as          necessary, in response to an external threat.  Licensees choosing          this option would be expected to demonstrate their ability to          remotely lock doors in time to delay an adversary where delay was          essential in the protective strategy.  Contingency drills should          test the use of the system locking function.  The contingency plan .                                                   GL 96-02, February 13, 1996                                                   Page 4 of 5          and procedures may have to be modified to indicate the immediate          "locking" of all VA doors during a safeguards emergency.  Access          control systems would be retained on VA doors and would be expected          to continue to maintain a record of personnel access and generate          alarms if the door were opened by someone without a proper access.           Existing plan commitments for compensatory measures for failed door          alarms and access hardware must remain in effect, unless changes are          approved by the NRC.  If the system function to lock the doors has          failed (unable to control locks from alarm stations), the VA doors          will have to be returned to a locked status.      The process for licensees to revise their security plans to implement      the changes to security measures in vital areas will depend on what is      presently contained in their security plans.  Since acceptance of these      changes is conditional on confirmation of two offsetting conditions,      most changes would need to be processed in accordance with the      provisions of 10 CFR 50.90.  Changes in security plans should include      commitments to the two measures described in the first paragraph of      Section I above.  (II)  Access Search of On-Duty Armed Security Guards      Changes that would allow armed security officers who (1) are on duty and      carry a weapon in accordance with assigned duties, (2) have already been      searched during their current shift, and (3) have left the protected      area on official business, to reenter the protected area without being      subjected to the metal detector searches (but still be subjected to      explosive searches) would be acceptable.  If search equipment is a      single unit containing both metal-detection and explosive-detection      equipment, alarms from the metal detector may be disregarded.  The staff      considers that this change could be made to security plans in accordance      with the provisions of 10 CFR 50.54(p).   (III) Containment Access Control Measures      Changes were proposed, when this generic letter was published for public      comment, that would allow persons other than security personnel,      provided they are appropriately trained with respect to access control      procedures in accordance with the security plan, to perform the access      control function for personnel and materials entry into the containment      at any time frequent access is permitted to the containment.  However,      this position is now unnecessary because the NRC amended its regulations      to eliminate 10 CFR 73.55(d)(8) effective October 10, 1995.  Special      access controls for entry into the containment during periods of      frequent access are no longer required.(IV)  Alternative Measures for Control of Security Badges        Changes that would allow for alternative approaches for accountability      of picture badges used for unescorted access so that certain types of      badges may be taken outside the protected area.  Alternative approaches .                                                            GL 96-02                                                            February 13, 1996                                                            Page 5 of 5      need to include the ability to ensure positive identification of      individuals upon entry to the protected area.  For employees, such      changes can be made under 50.54(p).  The staff considers that changes to      security plans to allow contractors to take security picture badges off      site would first require a request for exemption from the provisions of      10 CFR 73.55(d)(5).  An exemption is not required for licensee employees      because the regulations currently allow licensee employees to take      badges off site.  Upon approval of the exemption request for contractor      personnel, licensees would be allowed to implement the change in      accordance with the provisions of 10 CFR 50.54(p).  For assurance of unrestricted emergency access, the NRC staff notes theadvantages of (1) having the ability to remotely unlock doors to vital areasfrom each alarm station, (2) ensuring that malfunctions result in doorsfailing unlocked rather than locked, and (3) allowing all operators andauxiliary operators to carry metal keys that can override keycard-operatedlock mechanisms.  However, these conditions are not required for licensees toimplement any of the positions presented in this generic letter.This generic letter requires no specific action or written response.  If youhave any questions about this matter, please contact one of the technicalcontacts listed below.                                          signed by                                     Dennis M. Crutchfield, Director                                    Division of Reactor Program Management                                    Office of Nuclear Reactor Regulation                                    Technical contacts:   Loren L. Bush, NRR                      (301) 415-2944                      Internet:llb@nrc.gov                      Robert F. Skelton, NRR                       (301) 415-3208                      Internet:rfs1@nrc.gov