ML20023E144
| ML20023E144 | |
| Person / Time | |
|---|---|
| Issue date: | 06/01/1983 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Jennifer Davis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20023E145 | List: |
| References | |
| FRN-49FR30726, RTR-REGGD-05.XXX, RTR-REGGD-5.XXX, RULE-PR-50, RULE-PR-73, RULE-PR-MISC NUDOCS 8306140712 | |
| Download: ML20023E144 (5) | |
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JUH 1 1383 MEMORANDUM FOR: John G. Davis, Director Office of Nuclear Material Safety & Safeguards FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
INSIDER SAFEGUARDS RULE PACKAGE As requested in your memorandum of May 10, 1983, we have reviewed and concur with the " Insider Safeguards Rule Package", subject to appropriate consideration of our connents. Our connents (see enclosure) also address the concerns (Protection of Vital Areas / Islanos) contained in Robert F.
Burnett's April 14, 1983 memorandum to Darrell G. Eisenhut.
Originst Siped W H. R. Denton Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated DISTRIBUTION: w/ incoming
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- M. Garver (NRR 83-154)
NRC PDR*
OELD, Attorney L PDR*
T. Speis PRC*
R. Mattson i
NSIC*
I R. Voller SSPB Reading H. Thompson C. Thomas N. Grace i
E. McPeek B. Snyder P. Anderson Mq3 H. Denton/E. Case D. Eisenhut/R. Purple
/jI M. Jambor 1
F. Miraglia/ Lee
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- SEE PREVIOUS PAGE FOR CONCURRENCES
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w JUN 1 m HEMORANDUM FOR: J n G. Davis, Director Of ice of Nuclear Material Safety &
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Haro d R. Denton, Director Offic of Nuclear Reactor Regula on
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SUBJECT:
INSIDE SAFEGUARDS RULE PACKA c
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As ested in your morandum of Ha 10, 1983, we have reviewed and concur in the " Insider Safe ards Rule P ckage",i-for pcHe-comment. Our connents (see enclosure) also address the concerns (Protection of Vital Areas /
Islands) contained in Robert F. Bu ett's April 14, 1983 memorandum to Darrell G. Eisenhut.
Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated DISTRIBUTION: w/inco ing*
'Docunant Control
- M. Garver (NRR#8 154)
NRC PDR*
Attorney, DELD L PDR*
T. Speis PRC
- R. Mattson NSIC*
R. Vollmer SSPB Reading H. Thompson C. Thomas N. Grace E. 'icPeek B. Snyder P. Anderson H. Denton/E Case D. Eisenhu /R. Purple M. Jambor F.'1irag}ia/ Lee
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ENCLOSURE INSIDER SAFEGUARDS RULE PACKAGE i
PROTECTION OF VITAL AREAS (ISLANDS) i General Coninents:
'
- As noted in the insider rule package,.10 CFR 73.55 currently requires that all vital areas (areas in which radiological sabotage can be accomplished) be protected. The insider rule package contains a proposed change which would require protection only to the extent necessary to interrupt sabotage. The proposed requirement implies some knowledge of the capability of the saboteur. We believe this concept should be revised to consider protection of the shutdown systems, then rather..than review numerous chains of events and event sequences which lead to radiological releases, the licensees should be required to provide some minimum fully " protected" (secured) shutdown capability similar to what was done as part of the Appendix R fire protection rule backfit.
The Appendix R fire protection rule itself reinforces this point, since as part of that evaluation, licensees were required to identify single areas in the plant where fire damage to cables could prevent safe shut-down. This information is available in the public docket. file. However, the present vital areas analyses do not even consider destruction of cables in trays, and therefore, an essential portion of plant's shutdown 4
capability is readily identified but would go unprotected.
We suggest that the following criteria be used to determine the equipmen.t to be located in vital islands within vital areas:
- 1) protection of the reactor coolant pressure boundary and 2) protection of one train of systems needed to achieve and maintain hot shutdown / hot standby including control and support systems. This closely parallels the basic licensing requirement of 10 CFR Parts 50 and 100 for identification of " safety-related" equipment needed for prevention of release of an unacceptable offsite dose. Protection of the reactor coolant pressure boundary would include designating the containment (drywell in BWRs) as a vital island as reconsnended by the consnittee. Protection of the reactor coolant pressure would also include protecting equipment outside containment which could also breach the pressure boundary if failed. For example, if the redundant RHR suction valves were opened during plar.t operation, an interfacing LOCA would result. Thus, these valves should be part of a vital island.
By protecting all means of violating the reactor coolant pressure boundary integrity, the systems needed to mitigate the consequences of a LOCA do not require protection.
. The second criteria is to protect one train of systems needed to achieve and maintain hot standby / shutdown, given any act of sabotage putside a
-vital area / island.
Since LOCAs are " prevented" as a result of sabotage by proper designation of the reactor coolant prersure boundary within a vital island, the acts of sabotage would more likely result in " anticipated operational occurrences" as defined in Part 10 CFR 50. This would result in the control room, a water source, one train of diesel generators, batteries, and the associated electrical distribution system, being included in vital islands similar to the safeguards comittee's recomendation.
However, the safeguards comittee's recomendation included both diesel generators and iixcluded the electrical distribution system from vital islands. Only one complete train of electrical power is necessary for safe shutdown. Also included in the vital islands by this approach would be one train of auxiliary feedwater and atmospheric dump valves (PWR), and HPCI, RCIC and ADVs (BWR) with one train of the associated support and control systems.
We believe the above approach more closely follows that taken by the staff when pursuing licensing actions for protection of,public health and safety following various off-normal events.
- The rule package for miscellaneous amendments to 10 CFR 573.55 states that, the "NRC will be conducting studies on each reactor to identify items of equipment considered vital." Our present thinking is that, not all. facilities will require a site-visit to conduct Vital Area Validation reviews.
It is, therefore, recomended that this requirement be deleted from the proposed rule package. -
Specific Coments:
- Change the requirements in the paragraph (Temporary Workers) on page 2, enclosure A, to the Access Authorization rule, to read as follows:
Temporary Workers - Temporary Workers needing unescorted access authorization should meet the same screening and continual behavior observation requirements as permanent workers. Once received, this authorization may be transferred between nuclear power reactor licensees. Under cold shutdown or refueling operations, however, licensees would have the option of granting a temporary unescorted access authorization to unscreened individuals provided that all requirements of section 73.55 are met including a thorough search of affected areas is conducted prior to restart and a performance of the tech spec required surveillance requirements of all equipment in such areas prior to entering an operational mode or condition in which the requirement is required operable by the plants tech specs.
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t Delete (3) on page 6, attachment 1 to Enclosure A of the access authorization rule to read as follows:
All equipment in the affected protected area and vital islands are demonstrated operable by performance of the tech spec required surveillance requirements for all equipment in these areas prior to entering an Operational Mode or Condition in which the equipment is required operable by the plants tech specs.
Make (3) on page 15, Eclosure A, t.o the access authorization rule. attachment to En Workers) on page 2, E On page 1 of Enclosure C, the scope of the program is discribed requiring protection only to the extent necessary to interrupt saLotage. The phrase
" interrupt sabotage" should be clarified. The intent is to do more than
" Interrupt" and less than all " sabotage." Specifically, it is to defeat the assumed ob; ective of a release in excess of 10 CFR Part 100 limits.
This comment a'so applies to the top of page 3 of Attachment 1 to Enclosure C, and to page 3 of Attachment 2 to Enclosure C.
The discussions of vital area designations specify the inclusion of the control room in all cases. We feel this should be extended to include control panels outside the control room from which the plant can be taken to hot standby, e.g., the remote shutdown panel. Th'e reason for this expansion is that a saboteur could possibly take control of systems away-from the control room operator and then reach the assumed objective. This change is necessary on page 2 of Enclosure C and pages 3 and 8 of Attachment i
1 to Enclosure C.
Additionally, we feel that designation of the onsite diesel generators as a vital item should be extended to include diesel generator support systems (e.g., fuel oil, cooling water) and switchgear
, which supply to vital buses.
1 The discussions concerning retrieving access control devices from involuntarily terminated individuals on page 2 of Enclosure C and page 3 of Attachment 1 to Enclosure C are inconsistent with the proposed rule, page 9 of Attachment 1 to Enclosure C.
The rule requires retrieval prior to or simultaneously with notification of termination while the discussions on the previous pages stated that retrieval was required prior to termination. The wording of the discussions should be made consistent with the rule.
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