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--Establish criteria for judging the acceptability
of alternative protective devices and systems.

--Implement a procedure whereby security plans
cannot be approved until a site has been visited
by the reviewer and the comments of the regional
inspection office have been obtained.

--Establish specific and stringent require-
ments for upgrading guard forces.

--Authorize and encourage inspectors to go
beyond approved security plans when appraising
security systems and implement a timely
procedure for correcting deficiencies.

--Develop and implement additional procedures
to provide greater assurance that inspections
are consistently thorough and make unannounced

inspections.

--Take immediate action to increase interim
protection at all operating nuclear powerplants.
Such action should include (1) promptly alerting
plant management of the serious deficiencies in
security systems at existing powerplants,
(2) specifying interim measures that powerplant
management can take to strengthen security in
line with the proposed regulations, (3) improving
local law enforcement coordination, and (4) in-
creasing the number of guards.

AGENCY COMMENTS AND

RECENT ACTIONS

On February 16, 1977, we briefed NKC, at its request, on our concerns regarding powerplant security. NRC solicited our views because it was planning to issue revised security regulations. In fact, an internal memorandum dated February 11, 1977, made the NRC Commissioners' approval of the proposed regulations contingent upon our briefing. Subsequently, the proposed regulations were published in the Federal Register on February 24, 1977, and became effective on March 28, 1977.

NRC agreed with the thrust of the report, but disagreed with our recommendation concerning the need to take immediate action to increase interim protection at all operating nuclear powerplants. NRC stated in its letter to us that it considered the publication of the new security regulation which requires the licensees to take certain security actions by May 25, 1977,

to be an appropriate interim action. The actions taken to date to improve powerplant security are a step in the right direction.

Nevertheless, the licensees are permitted by the regulations almost 1-1/2 years to comply with several significant provisions involving construction or installation of equipment, such as

--detection of penetration or attempts to penetrate
the protected area;

--bullet-resistant control room and guardhouses;

--equipment for detecting firearms, explosives,
and incendiary devices;

--positive control of all points of personnel and
vehicle access into vital areas;

--establishment of microwave or radio communi-
cations, in addition to conventional telephone,
with local law enforcement authorities; and

--closed circuit television or other means of
observing the protected area barriers.

Because of the inadequacies in security systems at nuclear powerplants and because powerplants may have until August 1978 to implement the above provisions, as well as others, we believe that NRC should take immediate steps, as outlined in the report, to increase the interim protection at all operating nuclear powerplants.

CHAPTER 5

SCOPE OF REVIEW

We obtained the information contained in this report by reviewing documents, studies, reports, correspondence, and other records, and by interviewing officials at

--NRC Headquarters, Bethesda, Maryland;

--NRC Region I, Office of Inspection and
Enforcement, King of Prussia, Pennsylvania;

--NRC Region II, Office of Inspection and
Enforcement, Atlanta, Georgia;

--NRC Region III, Office of Inspection and
Enforcement, Glen Ellyn, Illinois; and

--Six nuclear commercial powerplant sites at
various locations.

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Your February 24, 1977, memorandum forwarded for staff review
and comment the subject document.

It was stated in the subject report that inconsistencies in the
level of protection presently exist among individual security plans.
It was also implied that no remedial action was being taken to
eliminate these inconsistencies. We were aware of the inconsistencies
and, with the publication of the new physical security rule (73.55),
have taken significant action not only to eliminate the inconsistencies.
but also to provide a high level of protection against industrial
sabotage at all nuclear power reactors.

This new rule establishes a performance criterion for the physical
protection of nuclear power reactors. This criterion can be stated
succinctly as requiring "high assurance protection against industrial
sabotage by (1) a determined, well-armed, well-trained team of several
outsiders assisted by a single insider or (2) a single insider acting
alone." In meeting this general requirement the rule states that the
onsite physical protection system and security organization shall
include, but not necessarily be limited to, the following capabilities:

1) A physical security organization including armed
guards to protect the facility against industrial
sabotage.

2) At least two barriers to protect vital equipment,
illumination of all outdoor areas, isolation zones
extending on both sides of the protected area
perimeter to permit observation of activities on
both sides of that barrier, and a bullet-resistant
reactor control room.

APPENDIX I

Thomas J. McTiernan

APPENDIX I

3) Search of all individuals, packages, and vehicles
prior to entry into the protected area; escort of
all but licensee-designated vehicles while in the
protected area; a badge system for identification
of the level of plant access authorization; escort
of visitors while in the protected area; positive
access control of all points of personnel and
vehicle vital area access.

4) Intrusion alarms that annunciate in a continuously
manned central alarm station and at least one other
continuously manned station.

5) Continuous communication capability for on-duty
guards with each alarm station; telephone and wireless
communication between alarm stations and local law
enforcement authorities.

6) A nominal force of ten guards and armed, trained
personnel immediately available at the plant to
fulfill security contingency response requirements,
with a minimum of five guards in this response force.

Revised security plans submitted in response to 73.55 are due on
May 25, 1977. These will be reviewed onsite by several teams,
each led by an individual from Nuclear Reactor Regulation and
including personnel from Inspection and Enforcement (IE). During
the review, each plan will be evaluated against standard acceptance
criteria, thereby increasing uniformity in the levels of protection
required.

To supplement this new rule, the Commission has published for comment
a clearance rule for screening individuals permitted unescorted access
to protected areas. This clearance rule, if adopted, would provide
additional assurance against industrial sabotage involving an insider.
There remain three areas in the report about which we believe specific
comments are in order.

The first area contains the GAO staff recommendation that "immediate interim action" should be taken and that plants be placed on "alert". We disagree. By publication of 73.55, with its provisions that call for implementation by May 25, 1977 of the above described capabilities except for any requirement involving construction and installation of

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