IE Circular No. 77-04 - Inadequate Lock Assemblies

CR77004 

                              March 17, 1977 

MEMORANDUM FOR:     J. P. O'Reilly, Director, Region I 
                    N. C. Moseley, Director, Region II 
                    J. G. Keppler, Director, Region III 
                    E. M. Howard, Director, Region IV 
                    R. H. Engelken, Director, Region V 

FROM:               N. H. Haller, Assistant Director for Safeguards 

SUBJECT:            IE CIRCULAR NO. 77-04- INADEQUATE LOCK ASSEMBLIES 

REFERENCES:         IE Circular No. 76-08 of December 22, 1976, Inadequate 
                    Vital Area and Material Access Area Lock Assemblies 

The reference cited above, less its Appendix A which was forwarded by 
separate means, is hereby cancelled and superseded. All copies of the 
reference are to be destroyed. 

The superseding Circular, No. 77-04, Inadequate Lock Assemblies, of March 
17, 1977, is enclosed for your distribution with the Appendix A to all Group
I, II, IV and V licensees within your Region. 

A sample transmittal letter to each licensee is provided. 


                                        Norman Haller, Assistant Director 
                                          for Safeguards 
                                        Office of Inspection and Enforcement

Enclosures:
1.   Trans. ltr to Licensees
2.   IE Circular 77-04
       Inadequate Lock Assemblies
.

(Transmittal Letter For IE Circular 77-04 To Each Safeguards Group I, II, IV
and V Licensee) 

Addressee: 

The enclosed IE Circular, 77-04 is forwarded for your information and use. 
The subjects covered by this Circular should be helpful to you in properly 
implementing the physical security systems needed for your facility to meet 
the requirements of 10 CFR Part 73. The illustrated Appendix is provided for
the sake of clarity and does not constitute an endorsement of any 
manufacturer's specific product. 

No written report to the NRC is required by this Circular. If you have any 
questions concerning this matter, contact the Director of this NRC Regional 
Office. 


                                        Regional Director 

Enclosure:
IE Circular 77-04
  Inadequate Lock Assemblies
  with Appendix A
.

                      Nuclear Regulatory Commission 
                   Office of Inspection and Enforcement 
                          Washington, D. C. 20555 

IE Circular No. 77-04                                  Date: MAR 17 1977
Page 1 of 3 

INADEQUATE LOCK ASSEMBLIES 

DESCRIPTION OF CIRCUMSTANCES: 

During recent physical security inspections at nuclear fuel cycle and 
reactor facilities, it was discovered that the lock assemblies securing some 
material access areas and vital areas were inadequate, improperly installed, 
or inoperable for a lack of maintenance. In a number of instances, the 
deficiencies were cited as items of non-compliance. The specific findings 
included: 

     (a)  Doors secured only with locks having simple spring latches which 
          could be readily depressed with a piece of plastic, a card, knife,
          or other thin instrument. 

     (b)  Doors secured with locks having dead latches which were 
          ineffective due to poor installation or lack of maintenance. The 
          installation tolerances for a dead latch are very critical and 
          their anticipated service life quite limited. 
          
     (c)  Outswinging doors and inswinging double-doors without mullions, 
          which were not equipped with astragals or guard plates to deter 
          forcible attacks upon the latch or bolt. 

     (d)  Exterior or exposed lock cylinders which were not equipped with 
          effective collars or cylinder guards to deter forcible attacks 
          upon the cylinders. 

     (e)  Doors secured only by lock sets with cylinders mounted within the 
          door knobs, making the doors very vulnerable to forcible attack. 

     (f)  Lock sets which did not engage their associated strike plates due 
          to incorrect installation, adjustment, maintenance, or damage. 

     (g)  Doors without locks. 
.

IE Circular No. 77-04                                 Date: MAR 17 1977 
Page 2 of 3 

DISCUSSION: 

10 CFR 73.2 (f) (2) requires that openings in building walls be of 
construction and fastening of sufficient strength so that the integrity of 
the wall is not lessened by the opening. This requirement extends to vital 
areas (10 CFR 73.2(h)) and material access areas (10 CFR 73.2(j)). Thus, 
door locks must be of substantial construction and of such design, 
installation, and reinforcement that their neutralization or circumvention 
by common burglary techniques is precluded. Regulatory Guide 5.12, the 
Federal crime insurance guidelines, recent municipal codes and ordinances, 
and generally accepted practices within the profession of industrial 
building design and construction, advise that doors must be secured with a 
dead bolt. Further, in recognition of widely disseminated and publicized 
simple burglary techniques which can be accomplished with common tools 
without skill, the following limiting factors must be considered in 
determining whether the integrity of a vital area or material access area 
wall is maintained: 

     (a)  The door is secured with a dead bolt with either a one inch 
          lateral throw or multiple-vertical engagements with its strike. 

     (b)  Outswinging doors and inswinging double-doors without mullions, 
          are equipped with securely mounted astragals or guard plates. 

     (c)  Exterior or exposed cylinders are rim, bored-auxiliary, or mortise
          lock mounted, and are protected with (1) a cylinder guard or (2) 
          substantial collar which is tapered, extends beyond the face of 
          cylinder, and rotates independently when torque is applied. 

     (d)  All lock sets and associated hardware are effectively installed 
          and maintained. 

Hardware illustrations and standard lock terminology are enclosed as 
Appendix A. 
.

IE CIRCULAR No. 77-04                                 Date: MAR 17 1977
Page 3 of 3 

POSSIBLE SOLUTIONS: 

The identified generic deficiencies may be eliminated by the comprehensive 
implementation of one or more of the following solutions, in consonance with
the operational and safety considerations of the facility. 

     (a)  Institute measures to assure conformance with the four limiting 
          factors cited in the Discussion paragraph, above. 

     (b)  Obviate lock inadequacies by barring the door from within with a 
          wooden (min. 2" x 4") or pipe (min. 2" dia.) member extending 
          solidly across both stiles and jambs. 

     (c)  Obviate lock and other possible deficiencies by eliminating the 
          doorway and filling the resulting cavity with masonry or 
          construction materials equal to or exceeding the composition of 
          the wall. 

This information is provided for action you deem appropriate to insure that 
vital area and material access area doors are secured in a manner which does
not lessen the integrity of the walls and other physical barriers.