ML19254C471
| ML19254C471 | |
| Person / Time | |
|---|---|
| Issue date: | 09/06/1979 |
| From: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Watson W AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19254C472 | List: |
| References | |
| NUDOCS 7910160220 | |
| Download: ML19254C471 (7) | |
Text
__ _
- pa arc o
- o UNITED STATES E ', # (/(",i NUCLEAR REGULATORY COMMISSION Q, "dp ;E
//
WASHINGTON, D. C. 2C555
=
%..v 4]
SEP S 1979 Mr. William K. Watson 5409 Denver Avenue, S.
Seattle, Washingto,n 98108
Dear Mr. Watson:
Your letter of July 14, 1979 was transmitted to the Commission by Senator Warren Magnuson and Congressman Mike McComack. We regret the appearance of being unresponsive to your correspondence; however, we have checked our records for inccning mail and find no record of your correspondence including your letter dated July 14, 1979.
In reviewing your letter we find the questions posed, specifically those related to a nuclear weapon attack on a nuclear power plant, are addressed in 10 CFR 50.13.
In September of 1967 the Atomic Energy Commission promulgated Section 50.13 of the Commission's rules which provided that an applicant for a nuclear power reactor construction pemit or operating license need not provide for design features to protect against the effects of attacks by "an enemy of the United States". This regulation is still in effect. National defense is a govermental function, not one that private industry, even though heavily regulated, should be responsible for. This view was upheld by the Court of Appeals for the District of Columbia in Siegel vs. AEC, 400 F2d 778 (D.C. Cir.
1968). Consequently, events of this nature are not addressed by applicants or the NRC staff in the safety reviews for licensing nuclear power plants.
Infomation relative to your concerns regarding possible sabotage to a nuclear power plant and emergency plans is enclosed.
Sincerely,
- c7 w e.a M R.G.S
- 11 e tee V. Gossick j
Executive Director v
for Operations
Enclosures:
1.
Summary of Requirements for Physical Protection of Nuclear Reactor Power Plants Against Nuclear Sabotage 2.
Emergency P1ans gg cc w/ encl:
Senator Warren Magnuson United States Senate jD1016022n Congressman Mike McComack A
United States House of Representatives
~
m Summary of Requirements for Physical Protection of Nuclear Reactor Power Plants Against Industrial Sabotage 868 319
n m
1, The requirements for physical protection of licensed activities in nuclear power reactors are dedicated exclusively to protecting against acts of sabotage since the new fuel used in these reactors is of low enrichment and, as such, is not suitable for f ashioning into a weapon, and the irradiated fuel with its built-in plutonium is too radioactive and Dulky to successfully divert. Each licensee who is authorized to operate a nuclear power reactor has submitted a current physical security plan describing how the licensee will comply with all the requirements of Section 73.55 of the Code of Federal Regulations.
The historical. development of regulatory requirements to protect nuclear power plants from acts of sabotage is of interest in understanding the degree of protection currently being provided.
In September of 1967, the Atomic Energy Commission promulgated Section 50.13 of the Commission's rules which provided that nuclear power reactors need not be designed to resist attacks by "an enemy of the United States". This regulation is still in effect. At that time there were no explicit requirements to provide for protection of nuclear power plants against acts of sabotage.
Regulatory changes since 1973 have changed this concept with each successive regulatory change requiring a higher degree of protection.
In June of 1973, the Atomic Energy Commission issued Regulatory Guide 1.17 which provided guidance to licensees on the degree of protection desired. Commission required security plans for reactors to be sub-mitted for its review and approval.
In February,1977, the Nuclear Regulatory Commission (NRC) amended its rules by adding Section 73.55 which provided detailed regulatory require-ments for reactor security plans. The general perfonnance criteria is contained in Section (a), and Sections (b) through (h) contain require-ments on specific features. This is the framework for the security features currently applicable to operating nuclear power plants.
In order to meet the stated regulatory requirements the licensee must develop a security plan and submit it to the NRC for review and approval.
Although the details of the plan on a specific site are witnheld f rom public disclosure, a typical plan would need to address the regulatory requirements. The NRC in its " Interim Acceptance Criteria for a Physical Security Plan for Nuclear Power Plants", NUREG-0220, provided guidance on the data required; the typical plan would need to address:
1.
Security Organization - The security organization must be independent of the c.perating organization.
2.
Personnel Reliability - A program must be developed and conducted to screen personnel granted tinescorted access to the plant.
s' 868 320
m e
. ~
3.
Personnel Training - All persons must be trained in phys 1 cal security procedures.
4.
Local Law Enforcement Agencies - Arrangements must be developed with loc,al law enforcement agencies that may be called upon for support.
5.
Protected Area Perimeter - Physical barriers shall be established at the plant with isolation zones on each site of the barrier.
6-Protected Area 111umination - The protected area shall be illumi-nated.
7.
Surveillance of Protected Area - The protected area needs to be under the surveillance of the security force directly or by closed circuit TV.
8.
Intrusion Detection Hardware - An intrusion device shall monitor the barrier, be powered by emergency power, have high reliability that it will alarm upon an intrusion.
9.
Protected Area Patrols - The protected area needs to be patrolled on a periodic basis.
- 10. Personnel Access to Protected Area - The access to the protected area needs to be controlled by an individual in a bullet-resistant structure or, if opened, by two security persons.
11.
Package Searen - All packages entering a protected area must be searched to detect firearms, explosives and incenciary devices.
12.
Personnel Search - All persons entering a protected area must be searched to detect firearms, explosives and incendiary devices.
13.
Personnel Control - All persons entering a protected area must have authorization and a need for access. A numoered picture badge is used for purposes of identification.
- 14. Vehicle Access - All vehicles entering a protected area must be searched and unless it's classified " licensee cesignated vehicle" must be under escort.
- 15. Vital A.?as - Vital equipment will be located in vital areas within the p. otected area such that access to vital equipment requires passage through at least bvo~ physical barriers. The vital area barriers should be resistant to explosives and breaching tools.
s' 868 321
O
^
?.
3-
- 16. Access to Vital Areas - Access will be limited to those author-iled and have a need for access. The doors shall be locked and alarmed.
- 17. Establish'a Central Alarm Station (CAS) - A CAS will be in a vital area which is bullet resistant. All security alarms should sound in the CAS and indicate tr.e type of alarm and location. This station needs to be continuously manned.
- 18. Establish a Secondary Alarm Station (SAS) - The SAS shall also receive alarms and have the capability to summon assistance.
- 19. Communications - Redundant means of communication with local law enforcement agencies is required.
- 20. Tests, inspection and Maintenance - The security equipment needs to be tested, inspected and maintained in an operable condition.
To meet the postulated threat of armed incursion into a nuclear power plant there has been a dramatic increase in the past few years in Doth equipment and personnel to counter such a threat. As indicated earlier, all owners were required to identify vital equipment and provide features to positively control access to those areas containing the vital equipment.
In addition, a " buffer zone" or protected area is required to surround the vital plant area. This protected area is required to be fenced, with intrusion detection devices, illuminated, and maintained under surveillance. A minimum of five trained armed response personnel are required to be onsite at all times to respond to indications of incursion.
In addition, arrangements are made with the local law enforcement agencies to provide assistance as required.
868 322
g-a R
EMERGENCY PLANS The standards and criteria established by the Comission for the evaluation of proposed nuclear power plants include provisions for substantial con-servatisms in design and operating safety margins. Through the licensing and inspection proces.ses these are implemented in the design, construction, and operation of nuclear power plants such that their operation should pose no undue risk to the public health and safety.
Nevertheless, the NRC recognizes that emergencies can arise in the operation of nuclear power plants, and has, therefore, taken steps to assure the establishment of an acceptable state of preparedness to cope with emergency situations.
In 1962, the Atomic Energy Comission published its Reactor Site Criteria in 10 CFR Part 100. One of these criteria references a need for consideration of establishing a capability for taking protective measures, in the event of a serious accident, on behalf of the public within a region called the Low Population Zone.. The scope and extent of advance planning for such measures, e.g., evacuation of persons or instructions to take shelter on a timely basis, is explicitly identified (5100.3 (b)) as one of the factors to be considered in determining an adequate Low Population Zone.
In 1970, the Atomic Energy Comission published its requirements for plans to cope with emergencies in 10 CFR Part 50. These requirements, taken in conjunction with the referenced portion of the Reactor Site Criteria mentioned above, represent current NRC policy with regard to emergency planning that must be undertaken prior to issuance of a nuclear power plant operating license. At the construction permit phase, elements of preliminary planning are required as set forth in Appendix E (II) to Part 50, while at the operating license stage, tne elements of substantive planning are required as set forth also in Appendix E (III, IV) to Part 50.
It is important to note that while many of the planning elements identified in Appendix E are directed specifically to radiation emergencies, the scope of Appendix E has generally been understood as also having applicability to situations which have the potential for becoming radiation emergencies, e.g., fires, floods, and hurricanes.
Accordingly, under appropriate. circumstances, emergency planning might be required to encompass areas beyond the Low Population Zone to adequately protect the health and safety of the public.
Emergency plans are reviewed by the NRC staff and are frequently modified and improved by the utility as a result of this process.
At the conclusion of each review, the staff's findings are published in the Safety Evaluation Report for each proposed licensing action.
Before a plant is licensed to operate, the staff must find that these plans provide reasonable assurance that appropriate measures can and will be taken in the event of an emergency to protect public health and safety and prevent damage to property.
s' 868 323
p s,,
A continuing NRC inspection program is carried out to assure that each licensee maintains a satisfactory state of preparedness to effectively implement their plans. These emergency preparedness site inspections are conducted on an' annual basis and are divided among four major areas:
coordination with offsite agencies, written implementing procedures, equipment and facilities, and test exercises or drills.
Each of these areas is covered thoroughly and more than one site visit is frequently required to complete the inspection.
868 3?4
l-cQ46:
~ - ~ ' ' '. -
us-rm Wouse of Representatibes
' ' ' ' " * * ^ * * * * "
- c-m m,
..m i J C"~ ' -~
Essfyington, D.C. 20515
' q,",,,g,'"'
so. ret co-- rm:
July 23, 1979 ca cc= =imzs Caos) see.,sss r==
m.u Wee.,unass, wamme. asses tee 01 Qce) esk2214 Mr. William K. Watson 5409 Denver Avenue, S.
Seattle, Washington 98108
Dear Mr. Watson:
Thank you for your recent letter and the enclosed copy of your letter to the Nuclear Regulatory Commission.
As you can imagine, especially in the aftermath of Three Mile Island, the Nuclear Regulatory Commission has been extremely busy in responding to Congressional and Presidential investigations as well as letters from the general public.
Many well-meaning individuals have written to the Nuclear Regulatory Commission about potential safety problems.
If there is a delay in the Nuclear Regulatory Commission's responding to your letter, I am sure you can understand that they have been extremely busy.
Nevertheless, I am forwarding your letter to the Commission so that they can provide a response to your concerns.
Sinc
- ely,
- i. l Mike McCormack Member of Congress 5'S 868 325 bec:
Mr. Harold Denton (w/ incoming) 4*'
Ll
'J 2
'g c c f n
', i. < <
\\
b
-7 (
\\
E[L Tl x
7907300 M p [0 t
0' A
i g&e O
.--2
_ yao
.n.
6 6, b
,.3*.*'*
July 16,1979
Dear Representative McCo m ek:
Perhaps the enclosed letter to the Nuclear Regulatcry Cccx=issien ecvers
'Ihe scoe matters with which you are net familiar and would find interesting.
point at issue:
In an age of nuclear prcliferation, will it beceme pessible for a s=all natien who doesn't like us a=d has a few small cuclear der.ces available, to wreak encrocus, long lasting havec by using those devices to blew up a few 1000 }W =uclear p:,ver plant core centaiment buildings in this country?
Sheuld we be tMnking abcut undergreimr*4rg cuclear pcwer plants to prevent this possibility?
A previcus letter to the NRC cn this point went imanwered. Perhaps the knowledge a copy of this letter is going ycur way will sw.6 the NRC to respond, this ti:ne arcu=d. I will ferward a ecpy of their reply.
Very truly yours, William K. Watsen 5 M Cenver Av. S.
Seattle, WA 96106 868 326
_