Is the proposed definition of “individuals with unescorted access” reasonable and sufficient?
If not, why? For example, should persons granted unescorted access to “areas of significance” be permitted access to the facility when no supervision or oversight is present (e.g., evenings or weekends)? Should the NRC require access controls such as maintaining records of the time and duration of persons accessing an “area of significance” without escorts? Comment: One commenter stated that unescorted access should permit individuals access to areas and equipment without supervision. Another commenter stated that the ANPR’s definition of “unescorted access” as “any individual who has the ability to access licensee-designated `areas of significance’ without continuous direct supervision or monitoring by an authorized individual,” is not workable. This commenter states that inherent in the current definition is the concept of an individual with capability and knowledge to exercise control over or remove SNM without detection and/or response by the protection system. According to this co
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