Comment on FR Doc # 2026-12989, NRC-2025-1303-0001, from Anonymous
Anonymous AnonymousOpposeIndividual
Summary: A retired industry worker expresses concern that moving prescriptive access control requirements to voluntary guidance could lead to inconsistent security and a compromise in physical protection programs. The commenter recommends maintaining enforceable standards, specifically suggesting regular access-level validations.
Introduction:
I previously worked in the industry and retired near the plant where I worked.
Background:
Access control measures in current § 73.55(g) would be revised to remove the prescriptive requirements regarding access to different areas of a facility. These specifics would be retained in guidance as voluntary considerations for licensee physical protection programs. Licensees would still be required by proposed § 73.55(g)(1) to ensure that their access control measures meet the performance criteria (e.g., restricts unauthorized access and implements verification measures) and performance objective.
Analysis:
While shifting prescriptive access control requirements to guidance may offer greater flexibility for licensees, it could also introduce inconsistencies in the implementation of security measures across facilities. Without clearly defined, enforceable standards, there is a risk that some licensees might interpret the guidance too loosely, potentially compromising the overall effectiveness of physical protection programs.
Recommendation:
My understanding of the requirement as a supervisor is to restrict people who don't need access to vital equipment, which reduces the risk. This seems like a small requirement with larger protection implications. Why not make access-level validations quarterly or semiannually versus none at all?