ML20062M424
| ML20062M424 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/03/1994 |
| From: | Boulette E BOSTON EDISON CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR58804, FRN-59FR38889, RULE-PR-73 58FR58804-00021, 58FR58804-21, AE81-2, AE81-2-108, NUDOCS 9401070073 | |
| Download: ML20062M424 (2) | |
Text
.
gn cSENT'BYiXerox Telecopier 7021 T 1-3-9 'J U 41PM
- COMPLIANCE-* ~. 301 504 1672 4 # '2~
q g
a J 73
+
0858 5 W597~~~~
- ROSTON EDISON hl' Pilgrim Nuclear Power Stauon d
Rocky Hill Road Plymouth. Massachusetts 02360 JaltlarEh,-419f43N3 BECo Ltr. 94- 001
-l
- E. T. Boulette, PhD Sontor Vice rros
- dart-Nuclear i
Mr. Samuel J. Chilk i
Secretary of the Commission
. U.S. Nuclear Regulatory Commission i
Washington, D.C.
20555 L
Attn: Docketing and Sorvice Branch l
1 Docket No. 50-293 License No. OpR-35 Subiect:
Proposed Rule " Protection Acainst Malevolent Use of Vehicles at Nuclear; Power Plants (58FR58804) j
.1
' Boston Edison is opposed to the issuance of this proposed Rule regarding protection i
against' land vehicle intrusion at nuclear power plants.
Implementation of this-rule:
would not increase the safe operation of nuclear power plants.
The events assumed.
do not' warrant the significant expenditure of resources to implement- (see our cost' estimates - below).
Rather, the proposed rule will reduce the-likelihood -of an already low probability event.
Absent withdrawal of this proposed rulemaking, we support the comments submitted by j
NUMARC and have some additional comments.
We' agree with NUMARC that it is not necessary to make the Design ~ Basis Threat (DBT)'
any more unrealistic.
The events at Three Mile Island and the World Trade Center H
need to be uncoupled as a hypothetical threat before building further. conservatisms into the current DBT. Uncoupling these events allows for a more realistic basis for 1
a vehicle barrier system.
There would either be the potential for. a. land vehicular
'i intrusion attempt or the potential for an attempted bombing by. means! of remote detonation of explosives in a parked vehicle outside the protected" area, not, a -
combination of the two. - Similarly, the proposed rule increases. the ' design. basis-explosive well 'above; domestic experience to date.
The size of' the: design 1 basis.
. explosive should be no larger than the maximum explosive : equivalent-previously.
l detonated within this country.
Protecting the health and safety of the public and our employees is. the primary 1
concern in the operation of Pilgrim.
The emphasis of any new rule should-- be to protect those areas and/or systems necessary for safe shut down in the event of a security breach.
The proposed rule goes beyond, ensuring : safe. shutdown 'by
. prescribing additional ~ protection for all vital areas.
For example, the statements in sections 73.35(c)(7) and 73.55(c)(8)(ii) "to gain unauthorized proximity to~ vital areas" and."The Commission will approve the proposed alternative. measures if they -
1 provide substantial protection against a land - vehicle bomb" 'may be-unnecessary.
1 There may be a vital area that-could be lost due to an explosion and yet the plant i
l 9401070073.940103
- ' b).
R
.PDR
-PR' F-i 73 5BFR5BB04 PDR
.i 5
,5ENT.BY: Xerox Telecopier 7021 : 1-3-94 ; 3:42FM :
COMPLIANCE ~
301 504 1672 3
l Boston Edison Company U.S. Nuclear Regulatory Commission Page 2 could still be
'ely shut down.
This approach is consistent with the NRC's philosophy used Juring the Operations Safeguards Response Evaluations (OSRE) currently being conducted at plantt.
Imolementation 5chedule Beyond NUMARC's comments, we believe it is imperative that any rulemaking process be delayed until the NRC's blast effect analyses have been completed and are available for industry review, with an appropriate comment and discussion period.
The safe standoff distance is key in determining the implementation expense of this rule making.
While the Regulatory Analysis states that most existing protected area boundaries tre probably at acceptable standoff distances, until the blast effect analyses are known this is an unsupported statement.
Furthermore, we propose that utilities who have an approved integrated schedula (such as the Pilgrim "Long Term Program" required by our Condition of License #3.H) have the option to schedule the implementation of this rule through that process instead of required dates in the code.
The current wording of the proposed rule would require a formal exemption to change the date.
We suggest the proposed 73.55(c)(9)(i) and (ii) be combined into one m.? lon and a new (ii) be added to read: "Those utilities with an NRC approved "Interated Schedule" (57FR43888) shall prioritize implementation of the requirements of this part as a " Level !" item and include it in their next required NRC submittal of the schedule",
p.ackfit Analysis We cannot realistically comment on the Backfit Analysis as it relates to Pilgrim Station until we can determine the safe standoff distance for all of our vital areas.
However, we agree with NUMARC that the NRC has not provided quantifiable justification for the statement that this rulemaking will provide a substantial increase in public health and safety.
We have performe<1 rough calculations and have detarmined that the cost of implementation for Pilgrim Station could be a least $1.7 million.
We expect that when formal calculations are performed using realistic blast effect analyses, that the costs may increase.
We appreciate the opportunity to comment on the proposed rule.
Should you have any questions regarding our comments, please call our Security Manager, Mr. John Neal at 508-830-8788.
hA tN E. 1. Boulette, PhD ML/bal/9401 cc:
Mr. R. B. Eaton Div. of Reactor Projects I/II Office ef NRR - USNRC One White Flint North - Mail Stop 14D1 11555 Rockville Pike Rockville, MD 20852 Sr. NRC Resident Inspector - Pilgrim Station
_