ML20070D909
| ML20070D909 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/21/1991 |
| From: | Skolds J SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-56FR3228, RULE-PRM-73-9 56FR3228-00002, 56FR3228-2, NUDOCS 9103040030 | |
| Download: ML20070D909 (2) | |
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FEB 211991
'91 FEC 25 P? :10 Mr. Samuel J. Chilk Secretary.
U. S. Nsclear Regu'atory Commission Washington, D. C.
20555 Attention:
Docketing and Service Branch Mr. Chiin:
Subject:
VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO.
50/395 OPERATING LICENSE NO. NPf.12 COMMENTS ON THE PETITION TO REv!SE 10CFR73.1 (PR910022-0)
In Federal Register 56fR3228-3229, dated January 29, 1991, the Nuclear Regulatory Commission (NRC) noticed the receipt of a petition for rulemaking filed by the Nuclear Control Institute (NCI) and the Committee to Bridge the Gap to revise 10CFR73.1.(a)(1)(1), " Radiological Sabotage." Specifically, the petition requests the NRC to revise the design basis threat for radiological sabotage to include surface vehicle bombs and to reflect the possibility of an assault by a larger number of attackers (up to twenty persons operating as two or more teams) using more sophisticated weapons than those assumed in the current design basis threat.
Furthermore, the petitioners requested the NRC to make the amendments effective immediately, without further public comment.
South Carolina Electric & Gas Company (SCE&G) disagrees with the petitioners' contention that purported increased terrorist threats necessitate the need te revise the design basis threat for radiological sabotage.
The NRC's current positions stated in 10CFR73.1, " Design Basis Threat," and the requirements outlined in 10CfR73.55, " Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological Sabotage," are adequate to protect against terrorist threats at nuclear facilities. SCE&G is not aware of any verifiable increase in the threat level, nor is any information available from the local law enforcement agencies, state agencies, the fed 6ral Bureau of Investigation, or the regulatory agencies (including the NRC and Department of Energy) to substantiate the NCI concern regarding increased terrorist activities. The petitioners' change to protect against "yp to twenty persons _ operatina as two or more teams" with suitable weapons, " incapacitating agents, and explosives for use as tools of entry or for otherwise destroying reactor, facility, transporter or Container t
l integrity or featyres of the safeguards system in cuantities transportable by vehiclg," is an overreaction to a perceived threat that is based on l
information unavailable to anyone else.
SCE&G does not consider the petitioners' request to be a realistic course of action given the threat level directed toward commercial nuclear power plants, l
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l Mr. Samuel J. Chilk i
PR 9100??-0 Page 2 of 2 Additionally, on April 28, 1989, the NRC issued Generic Letter 09-07, " Power Reactor Safeguards Contingency Planning for Surface Vehicle Bombs," requiring that licensees develop plans for protecting their plants against atte"7ted radiological sabotage involving surface vehicle bombs i? such a threat were to materialize. These contingency plans provide for the implementation of stated actions within twelve hours of notification of a received threat.
SCELG is ready to implement this contingency plan at the Virgil C. Summer Nuclear Station (VCSNS), but, as stated in 55FR3229, "the NRC staff determined that there continues to be no credible threat and terrorist actions against any NRC-licensed facility that warrants implementation of contingency plans against truck bombs at this time."
SCELG agrees with the NRC's assessment in 55fR3229 and maintains that the current level of protection afforded by VCSNS is more than sufficient to provide protection against radiological sabotage. As such, SCELG recommends that the subject petition for rulemaking be denied.
Thank you for the opportunity to provide comments on the petition.
Very truly yours John L. Skolds EWR:JLS:mtm c:
- 0. W. Dixon Jr.
G. F. Gibson R. R. Mahan NSRC R. J. White RTS (PR 910022)
G. F. Wunder File (811.02)
General Managers HUCLEAR EXCELLENCE - A SUMMER TRADITI0H1
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