ML20081F905
| ML20081F905 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/24/1995 |
| From: | Marsh W SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9503220326 | |
| Download: ML20081F905 (13) | |
Text
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23 PARKER STREET.
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February 24,.1995 l
WAMER C MARSei m,_
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m.,.. - a, U. S. Nuclear Regulatory Commissian Document Control Desk i
-Washington, D.C. 20555 l
Gentlemen:
l
Subject:
Docket Nos. 50-361 and 50-362 i
Proposed Vehicle Control Measures San Onofre Nuclear Generating Station, Units 2 and 3 j
Reference:
10 CFR 73 Rule Change, published in Federal Register Document 94-18638, v. 59, pp. 38889-38900, dated August 1, 1994 l
As required by 10 CFR 73.55 (c)(9), enclosed is a summary description of l
proposed vehicle control measures and results of a vehicle bomb comparative analysis for San Onofre, Units 2 and 3.
The proposed Vehicle Barrier System l
(VBS) for San Onofre will provide a continuous boundary, capable of stopping i
the design basis land vehicle, which completely encompasses all vital areas.
l The required vehicle bomb comparative analysis concluded that all San Onofre vital equipment would remain functional'following a land vehicle bomb explosion at the VBS perimeter. Therefore, Southern California Edison concludes that the proposed VBS meets the NRC's design _ goals and criteria for.
protection against a land vehicle bomb.
-l If you have any questions, please call me.
Sincerely,
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i Enclosure cc:
L. J. Callan, Regional Administrator, NRC Region IV A. B. Beach, Director, Division of Reactor Projects, Region IV K. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3
'f, M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 I
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Lp' 9503220326 950224 PDR ADOCK 05000361
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RFSPONSE TO 10 CFR 73 RULE CIIANGE San Onofre Units 2 and 3 1.0 Executive Summary This submittal provides a summary description of proposed vehicle ccmtrol measures and results of a vehicle bomb comparative analysis, as required by 10 CFR 73.55 (c)(9), for San Onofre Nuclear Generating Station (SONGS), Units 2 and 3.
He summary description presents an overview of a proposed Vehicle Barrier System (VBS) for the site that will proviac, when installed, a continuous vehicle boundary completely encompassing all SONGS vital areas. Active and passive mmponents of the proposed VBS are identified, as well as natural terrain features and man-made obstructions that will complete the VBS. Each segment of the proposed VBS is capable of stopping the forward motion of the design basis land vehicle. A site drawing that outlines the proposed VBS is included with the description.
The vehicle bomb comparative analysis included both a screening analysis and a detailed analysis. The screening analysis showed that the proposed VBS provides an adequate standoff distance to protect all exposed vitas equipment at SONGS and all but three vital area structures from damage due to detonation of a land vehicle bomb. Detailed analyses for the three unprotected vital area structures determined that they do not ccmtain any vital equipment. The evaluation concluded that all SONGS vital equipment would remain functional following a land vehicle bomb explosion at the VBS perimeter. Therefore, the proposed VBS meets the NRC's design goals and criteria for protection against a land vehicle bomb.
t 2.0 llackground On August 1,1991, the NRC issued a final rule revising 10 CFR 73 in the Federal Register.
The rule change (Reference 1) requires all operating nuclear power plant licensecs to protect against malevolent use of vehicles.
The rule change modified 10 CFR 73.1 to include two new design basis threats: (1) a four-whcci drive land vehicle used for transporting personnel and their hand-carried equipment to the proximity of vital areas, and (2) a four-whcci drive land vehicle bomb. The new 10 CFR 73.55 rule requires all operating nuclear power plant licensecs to establish vehicle control measures, to perform a vehicle bomb comparative analysis, and to provide this summary description to the NRC.
3.0 Compliance Criteria in part, the rule change added paragraphs 73.55 (c)(7) and (8):
- $73.55 Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage.
"... (c)...
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'(7) Vehicle control measures, including vehicle barrier systems, must be established to protect against use of a land vehicle, as specified by the Commission, as a means of transportation to gain unauthorized proximi'y to vital areas.
"(8) Each licensee shall compare the vehicle control measures established in accordance with 10 CFR 73.55 (c)(7) to the Commission's design goals (i.e., to protect equipment, systems, devices, or material, the failure of which could directly or indiratly endanger public health and safety by exposure to radiation) and criteria for protection against a land vehicle bomb. Each licensee shall cither:
'(i) Confirm to the Commission that the vehicle control measures meet the design goals and criteria specified; or
"(11) Propose alternative measures. "
The characteristics of the design basis land vehicle and the size of the design basis vehicle bomb explosive charge are specified in a separate NRC letter (Reference 2).
4.0 Reporting Requirement 10 CFR 73.55 (c)(9), added by the rule change, ccmtains the following reporting requirement:
'By February 28,1995 submit to the Commission a summary description of the proposed vehicle control measures as required by 10 CFR 73.55 (c)(7) and the results of the vehicle bomb comparison as required by 10 CFR 73.55 (c)(8).'
5.0 Guidance Documents Regulatory Guide 5.68 (Reference 3) provides guidance for designing vehicle barriers, for performing blast effects analyses, for developing alternative measures, and for preparing this submittal.
NUREG/CR-6190 (Reference 4) gives specific design criteria for locating the VBS and summarizes available crash ratings for several commercially available active and passive barriers.
Additional specific guidance and design criteria,in the form of answers to liccasu gestions regarding the rule change, have been provided by the NRC in Reference 5.
6.0 Summary Description of Proposed Vehicle Control Measures Required by 10 CFR 73.55 (c)(7)
The attached figure shows the SONGS site, the location of the existing Protected Area (PA) boundary, the outermost abovc-grade vital area barriers, and the location of the proposed VBS. As the figure shows, the proposed VBS is a continuous vehicle barrier tha; completely encompasses all SONGS vital areas. The proposed VBS is made up of twenty.five separate segments, designated by number on this figure, Table 1 identifics the barrier type and general features of cach of the twenty-five VBS segments. Each segment of the proposed VBS has been determined (Reference 6) to be capable of stopping the forward motion of the design basis land vehicle.
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6.1 Active Components of the VBS The proposed VBS includes four active barriers. Two of these active barriers are the existing vehicle control gates MOG-1 (segment R) and MOG-2 (segment 11); two will be new barriers (segments 13 and 21).
The existing gates, MOG 1 and MOG-2 are engineered vehicle crash gates that were installed at two entrances to the SONGS, Unit 1, PA in 1978. Each gate incorporates a crash bar consisting of an 18" deep wide flange beam into its structural frame. The crash bar is laterally supported by reinforced concrete buttresses when the gate is in the closed position. The gates are electrically powered and have local controls. Unauthorized access through MOG-1 and MOG-2 is prevented by security padlocks on the gates. Approaching vehicles are forced to execute turns which limit their maximum possible approach velocity to a value that is less than the design basis vehicle speed specified in Reference 2. Crash ratings for these two gates, established by engineering analysis, show that the gates are capable of stopping the design basis land vehicle at its maximum possible approach velocity.
The two new active barricts will be procured by competitive bid. The specification for these gates will include the following requirements:
Reiractable bollard type.
Minimum 36* high when closed.
Minimum manufacturer-established crash rating corresponding to the design basis land vehicle travelling at the design basis vehicle speed specified by Reference 2.
The controls for the new active barrier between the Unit 1 PA boundary and the A%o building (segment 13) will be located in the existing hardened post ncxt to the north wall of the Security Processing Facility. The controls for the new active barrier at ILe South Vehicle Processing Facility (segment 21) will be located in the existing hardened post of the South Security Processing Facility. These barrier control locations will prevent unauthorized manipulation of the new active barrier controls, consistent with guidance given by Reference i
5.
6.2 Passive Components of the VBS Two types of passive barriers will be used: Jersey barriers and fixed bollards. C(mstruction details for both types will meet or execed those provided in NUREG/CR-6190.
Jersey barriers will be anchored by 3' long, l' diameter bolts spaced at 4', At one of the proposed locations (part of segment 17), an engineering analysis has shown that approaching vehicles will be forced to reduce speed to a value that is less than the design basis vehicle speed specified in Reference 2. Jersey barricts at this location will be founded on grade, with anchor bolts driven into the sand subgrade. No credit has been taken for approach speed reductions at other locations (VBS segment 2 remaining portion of segment 17, and segment 18). Jersey barricts at these locations will be founded on a 3' wide by 4" deep (minimum) reinforced ccmcrete pad.
Fixed I ollards will amsist of a 7'section of 8" schedule 80 pipe, concret: filled and placed in a concrctc foundation 4' deep by 2' wide. Where engineering analysis has shown that approaching vehicles will be forced to reduce speed to a sufficiently low value (VBS segments 7,9 and 16), bollards will be spaced 4' apart. At other locations (part of segment 13, segment 18), where no credit has been taken for approach speed reductions, bollards will be spaced 2* apart.
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l 6.3 Natural Terrain Features included in the VBS i
At two locations on the south side of the SONGS site (segments 19 and 24), existing steep -
l cliffs are included in the proposed VBS. Both locations are impassible to vehicles due to the following features-s De minimum cliff height is 20 feet, e
De cliff surfaces have been graded to greater than 2:1_ pitch.
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The transition to level grade at the base of both cliffs is very abrupt, such that a vehicle descending the cliff would impact the ground.
Existing multistory buildings near (within 10*) both cliff bases would prevent i
continued forward motion of a vehic!c after impact at the base, i
Segment 23 of the proposed VBS involves a second type of impassible feature. This location is a narrow gap between the reinforced masomy wall of the South Security Processing Facility l
and the base of the clili that forms the next VBS segment. He gap between the westernmost southwest (x>rner of the South Security Processing Facility and the cliff base,less than four
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icct wide, is too narrow to be penetrated by the design basis land vehicle, f
6.4 Man.made Obstructions included in the VBS The existing SONGS, Units 2 and 3, seawall provides a substantial vehicle barrier on the west side of the plant (segments 1 and 4, part of segment 25). He seawall, constructed from
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reinforced concrete,is 2* 9" thick at its base, tapering to l'-6" thick at its crown. It rises i
approximately fifteen Icct above the beach access roadway that extends the length of the SONGS PA's west side.
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%c reinforced concrete outer wall of the vehicle ramp on the west side of the plant (segment
- 3) is l'-9" thick and backfilled with sand. Over the portion credited as a vehicle barrict, the i
wall height varies from 8' to 16'.
i The shecipile seawalls on the west side of Unit 1 and near the southwest corner of Unit 3 I
(segments 5 and 25) are formed from 3M" steel into 12" deep ribbed sections. An engineering analysis of the seawall section showed that it would stop the design basis land vehicle impscting at the design basis vehicle speed specified by Reference 2.
5 He proposed VBS includes three sections of reinforced concrete wall that are part of the
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SONGS PA boundary on the north and cast sides of Unit 1. He PA boundary wall along the north side of the SONGS PA (VBS segment 6) is 14" thick reinforced concrete,6' high and founded on a 7' wide concrete base. De PA boundary wall along the cast side of Unit 1 (VBS segments 10 and 12) is 8" thick reinforced concrete,8' tall. An enginecting analysis of l
the 8* wall section showed that it would stop the design basis land vehicle impacting at the design basis vehicic speed specified by Reference 2.
The Administration, Warehouse & Shop (AWS) building is a large (approximately 120' by 470') reinforced concrete building. He exterior walls that are credited as vehicle barriers (segments 14 and 15) are 8" thick reinforced musonry or 8" thick reinforced coccrete, in particular, an engineering analysis determined ths.t the 8" thick reinforced concrete wall on the west and south sides of the AWS building roof parking area is capable of stopping the design basis land vehicle.
The K-40 building is a large (100' by 200 ), enginected, sheet. metal clad, two-story office building. The west and south exterior walls credited as part of the VBS (segment 20) are additionally protected by reinforced masonry retaining walls. Furthermore, the staging -
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1 warehouse, a 75' by 75', enginecred, reinforced masonry building, is located immediately south of the K-40 building, providing further protection from direct vehicle impacts to the K-40 building south wall.
ne South Security Processing Facility is a reinforced masonry building, approvimately 20' by i
1(XT in plan (VBS segment 22). The long dimension of the building is parallel to the direction of travel of a vehicle attempting to penetrate the VBS and projects outward from l
the adjacent VBS segments on each side.
7.0 Results of Vehicle llomb Comparison Required by 10 CFR 73.55 (c)(8)
A vehicle bomb comparative analysis has been performed (Reference 6) for the proposed VBS, as required by 10 CFR 73.55(c)(8). Following Regulatory Guide SI28, Section 2.1.1, the evaluation began with a screening analysis to determine whether more detailed analyses of explosive blast effects would be required. Considering each SONGS sital area individually, the evaluation showed that the proposed VBS provides an adequate standoff distance to protect all exposed vital equipment and all but three vital area structures from damage due to detonation of a land vehicle bomb. Detailed analyses were performed for these three unprotected vital area structures, in accordance with Regulatory Guide 5.68, Section 2.1.2.
Two of the three unprotected vital arca structures house cach unit's security-related uninterruptible power supplies. Although these power supplies are contained in vital areas, as required by 10 CFR 73.55(e)(1), they are 1.01 considered vital equipment. The evaluation determined that there is no other vital equipment in these vital areas. Therefore, according to Regulatory Guide 5/d, Section 2.1.1, these vital areas need not be considered as areas needing protection from vehicle bombs.
The other unprotected vital area structure is an addition to the auxiliary building which contains a storage area for contaminated hand tools, a laundry facility for protective clothing, and locker rooms for use by radiation workers. The evaluation determined that there is no sital equipment in this vital area.
Since the screening analysis showed that all other vital area structures and all exposed vital equipment are protected adequately, the evaluation concluded that all SONGS vital equipment would remain functional following a land vehicle bomb cxplosion at the VBS perimeter. Regulatory Guide 5 68, Section 2.1.2, states that if " analysis determines that all vital equipment remains functional., the design goals and criteria' for protection against a land vehicle bomb are considered fully met." Herefore, the proposed VBS meets the NRC's design goals and criteria.
8.0 References 1.
Federal Register Document 94-18638, published in Federal Register v. 59, pp. 38889-38900,
' Protection Against Malevolent Use of Vehicles at Nuclear Power Plants," containing amendments to 10 CFR Part 73,' Physical Protection of Plants and Materials."
2.
Lctier from Mel B. Fields (NRC) to Harold B. Ray (SCE) and Edwin A. Guiles (SDG&E),
dated October 25,1994,
Subject:
Summary of Regional Workshops on Malevolent Use of Vehicles at Nuclear Power Reactors, Attachment 3," Regional Workshops on Malevolent Use of Vehicles at Nuclear Power Reactors Questions."
3.
Regulatory Guide 5.68," Protection Against Malevolent Use of Vehicles at Nuclear Power Plants," August 1994.
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4.
NUREG/CR-6190," Protection Against Malevolent Use of Vehicles at Nuclear Power Plants,"
Rev 1 Dcamber 1994.
L 5.
Letter from Theodore R. Quay (NRC) to Harold B. Ray (SCE) and Edwin A. Guiles j
(SDG&E), dated July 26,1994,
Subject:
- Characteristics of the Design. Basis Vehicle.
j 6.
Calculation C.140.04,'Vehicic Barrier System Standoff Distance Evaluation."
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1 Talite 1. IDENTIFICATION OF VilS COMPONENTS'2 VBS Serment Number and location Component TVoc Component Description 1.
From the southwest corner of the SONGS Man-made Existing reinforced concrete seawall.
PA, North 1300' along SONGS 2 & 3 obstruction, seawall to a point halfway up the vehicle ramp leading from the SONGS PA to the beach access road.
2.
West 15' across vehicle ramp.
Passive barrier.
Anchored Jersey barrier founded on reinforced concrete pad.
3.
North 70' and cast 15' along vehicle ramp Man-made Existing reinforced concrete vehicle retaining wall, returning to SONGS 2 & 3 obstruction.
ramp retaining wall.
seawall.
4.
North 30' along SONGS 2 & 3 seawall to Man-made Existing reinforced concrete seawall.
junction with SONGS 1 seawall.
obstruction.
5.
North 620' along SONGS 1 seawall to Man-made Existing shectpile seawall.
SONGS PA northwest corner, obstruction.
6.
East 330' along PA boundary to curve, Man.made Existing 6' high by 14" thick continue 30' along curve to point near obstruction.
reinforced concrete wall.
vehicle access gate MOG-1, 7.
Southeast 10' along PA boundary to Passive barrier.
Fixed bollards spaced at 4'.
vehicle access gate MOG-1.
8.
East 40' along MOG-1 to PA boundary Active barrier.
Existing vehicle access gate MOG-1.
corner.
9.
Southeast 70' along PA boundary to Passive barrier.
Fixed bollards spaced at 4*.
corner.
- 10. Southwest 38(r along PA boundary to Man-made Existing 8' high by 8" thick vehicle access gate MOG-2.
obstruction.
reinforced concrete wall.
I1. Southwest 35' along MOG-2 to its south Active barrier.
Existing vehicle access gate MOG-2.
end.
obstruction.
reinforced concrete wall.
- 13. Southeast 9(T to AWS building retaining Passive and active Fixed bollards spaced at 2', or other wall.
barriers.
vendor-supplied barrier with equivalent crash rating, and active barrier featuring retractable bollards.
- 14. Northeast 120', then cast 10' along AWS Man-made Existing reinforced masonry and building retaining walls to AWS building obstruction.
reinforced concrete AWS building west wall.
retaining walls.
- 15. South 23(r, west 60', and south 150' along Man-made Existing reinforced c(mcrete AWS AWS building west wall, then cast 100' obstruction.
building exterior walls.
along AWS building south wall to top of bluff.
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4 Table 1. IDENTIFICATION OF VitS COMPONENTS *8 VBS Seement Number and b> cation Component Tvoe Component Description i
- 16. Southeast 60* to west edge oflower Passive barrier.
Fixed bollards spaced at 4'.
switchyard road.
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- 17. South 1050' along west edge of lower Passive barrict.
Anchored Jersey barriers. For j
switchyard road to north edge of K-40 barriers located at the center 150' building chiller foundation pad.
and south 150', also provide reinforced concrete foundation.
- 18. West 30' along north edge of chiller Passive barrier.
Fixed bollards spaced at 2', and/or foundation pad to top of bluff.
anchored Jersey barriers on reinforced concrete foundation.
- 19. South 80' along bluff to corner of K-40 Natural terrain Existing gunite-finished bluff, building.
- feature, vertical drop of 20 feet at > 2:1 j
pitch.
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- 20. West 20*, south 20', west 180' along south Man-made Existing sheet metal clad K-40 wall of K-40 building, then north 20' along obstruction.
building exterior walls.
west wall of K-40 building.
- 21. West 20' through south vehicle processing Active barrier.
Retractable bollards.
facility to northeast corner of south j
security processing facility.
- 22. South 100', west 15', northwest 15', north Man-made Existing south security processing 60', and west 8' along exterior walls of obstruction.
facility masonry walls.
j south security processing facility to westernmost southwest corner.
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- 23. West less than 4' to bluff.
Natural terrain Existing narrow gap is impassible to feature.
vehicles.
- 24. North 20' and west 150' along bluff to Natural terrain Existing gunite-finished and seawall closure.
feat ure.
unfinished bluff, vertical drop of 40 t
icct at > 2:1 pitch.
- 25. Northwest 80' along seawall to place of Man-made Existing shecipile and reinforced beginning.
obstruction.
ccmcrete seawall.
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Notes:
1.
Directions indwated in "VBS Component location" column are referenced to l
- station north."
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2.
Except for those specified to the nearest foot, lengths of VBS segments were determined by measurement from a scaled (l* = 100') aerial photograph and are i
provided for reference only.
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