ML19325F101
| ML19325F101 | |
| Person / Time | |
|---|---|
| Issue date: | 07/31/1984 |
| From: | Burnett R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19325C113 | List:
|
| References | |
| FOIA-88-451 NUDOCS 8911140098 | |
| Download: ML19325F101 (2) | |
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NEP.0RANDUM FOR: Darrell G. Eisennut, Director Division of Licensing, HRR FRON:
Robert F. Burnett, Director Division of Safeguards, INSS
SUBJECT:
ANALYSIS OF N0HPOWER REACTOR SAB0TAGE 1
Tne Comission has recently voted nes'atively on SECY 83-500 which proposed a rule. change to amend the langua0e of 10 CFR 73.40(a).
The change would have made the regulations clearly reflect the staff's current policy to not require specific physical protection against sabotage at nonpower reactors (NPRs).
In its assessment of this Comission Paper, OPE recomended that the work donc by los Alamos National Lab (LAHL) for NP.R in 1979, ilVREG CR-0843, on which the staff's position was cased, he reassessed to assure that the basis for not-requiring specific sabotage orotection at t' prs is still valid.
Also, in a note on the notation vote on SECY 03-500, tne Chaiman said that although he disapproved the proposed rulemaking he would consider a revised proposed rule that had an appropriate tecnnical basis, which he felt SECY 83-500 lacked.
In response to OPE's recomendation and the Chaiman's note, the Division of Safeguards is initiating a technical assistance project to verify the basis for detemining the extent of sabotage protection needed at NPRs.
The previous LAUL study, referenced above, used 10 CFR Part 100 criteria as the level that a sabotage act would have to exceed bei" ore any explicit protec-tion against sabotage would be required.
In recent discussions with your staff',M,have been advised that accident analyses for NPRs use 10 CFR Part 20 criteria to detemine if a license's proposed safety systems are sufficient to mitigate the consequences of a one time accident.
Please advise us concerning whicn criteria should be utilized for the consequence analysis.
In our technical assistance project to reconfirm the basis f'or the, staff's position on sabotage protection at NPRs, we will init1411y address acts by an external adversary.
However, members of the ACRS have expressed concern that acts by an insider also could be a problem (e.g., by improper manipulation of reactor controls, deactivation of safety systems, etc.).
Please advise us as to whether it is credible that accidental or willful operation of an NPR or some class of NPRs (e.g. those above 2tiW) in an improper manner could result in significant consequences to the public health and safety dnd wnether further study is ' warranted to detemine if protection against such events is neces-s a ry.
This situation nay have already been treated, in part, ir the safety analyses for UPRs and you may be able to draw a generalization from existing data.
8911140098 891101 PDR FOIA KUPERMA09-451 PDR
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