ML20045F572
| ML20045F572 | |
| Person / Time | |
|---|---|
| Issue date: | 06/28/1993 |
| From: | Curtiss NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9307080061 | |
| Download: ML20045F572 (2) | |
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V0TEg RELEASED TO THE PDR NOTATION (o/96 9/'
6g L _,3 RESPONSE SHEET
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SAMUEL J. CHILK, SECRETARY OF THE COMMISSION FROM:
C0144ISSIONER CURTISS
SUBJECT:
SECY-93-166 - STAFF REC 0l44ENDATION FOR PROTECTION AGAINST MALEVOLENT USE OF VEHICiES AT NUCLEAR POWER PLANTS X/in X/in APPROVED __part DISAPPROVED part ABSTAIN Nor PARTICIPATING REQUEST DISCUSSION C0144ENTS:
See attached comments.
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U SIGNATURE RELEASE VOTE
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June 28, 1993 DATE WITHHOLD VOTE
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ENTERED ON "AS" YES X
NO i
I ISE788AAA%S88**'
i CORRESPONDENCE PDR
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Commissioncr Curtiss' comments on SECY-93-166:
I approve the staff's proposals to --
1.
modify the design basis threat (DBT) for radiological sabotage to include a land vehicle for the transport of I
personnel, hand-carried equipment and/or explosives; 2.
modify 10 CFR 73.55 to reflect the change to the DBT and allow for alternative security measures when establishing standoff distances; and s
3.
undertake expedited rulemaking to implement these changes.
With regard to the standard to be applied-in determining when alternative security measures would be accepted, I do not support the use of the staff's proposed " disproportionate cost" test.
In my view, the existing backfit standard contained in 10 CFR 50.109 has generally served us quite wall, and I see no reason to dapart from that standard here.
Adoption of the proposed i
" disproportionate cost" concept would introduce a separate set of standards and criteria to be applied in the backfit context and needlessly require the development of additional definitions and guidance on the application of th9 new standard.
Rather than invent a new concept for applice
.cn1 in the security area, I would recommend that we rely on che normal bacxfit analysis required by 10 CFR 50.109 to determine whether the " costs of fully meeting the. design goals and criteria" are justified.
In this regard, I would propose that we modify the last sentence of the proposed subsection 73.55 (c) (8) to remove the
" disproportionate cost" concept and refer to the normal backfit i
analysis as follows --
The Commission will accept the proposed alternative i
measures if they provide substantial protection against a land vehicle bomb, and it is determined by an analysis under 10 CFR 50.109 that the costs of fully meeting the design goals and criteria are not iustified by the added protection that would be provided.
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