ML20090J791
| ML20090J791 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 05/10/1984 |
| From: | Aftergood S COMMITTEE TO BRIDGE THE GAP |
| To: | Bright G, Frye J, Luebke E Atomic Safety and Licensing Board Panel |
| References | |
| OL, NUDOCS 8405230240 | |
| Download: ML20090J791 (25) | |
Text
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COMMITTEE TO BRIDGE THE GAP
- 1637 BUTLER AVENUE #203
- LOS ANGELES, CALIFORNIA 90025 00CKETED (213) 478 0829 USNRC May 10, fS$4 MY 22 All :39 John H. F rye, III, Chairman Dr. Errrneth A. Luebke Glenn O. Bright Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 in the Matter of THE REGENTS OF THE UNIVERSITY OF CAllFORNIA (UCt.A Research Reactor)
Docket No. 50-142 Ok (Proposed Renewal of Facility License)
Dear Administrative Judges:
Enclosed please find the attachments to "CBG Response to Applicant's Request for Reversal of the Board's April 13 Finding of Haterial False Statements" (May 9,1984).
Sincerely yours,
.4 ji ,
f W '
GQ Steven Aftergood / y i
cc w/ enclosures: service list 8405230240 840510 PDR ADOCK 05000142 0 PDR
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Attachments to "CBG RESPONSE TO APPLICANT'S REQUEST FOR REVERSAL OF THE BOARD'S APRIL 13 FINDING OF MATERIAL FALSE STATEMENTS" (May 9,1984)
(
Attachment A Letter of November 30, 1973 from AEC's Donald J.
Skovholt.to UCLA's NEL (1 page)
Attachment B Regulatory Guide 1.17 (2 pages) o Attachment C Letter of July 15, 1974 f rom Karl R. Goller !
to UCLA's= NEL with 2 enclosures: (t) deficiencies in UCLA proposed securlty plan; (2) Interim Guidance for Organization and Content of Security (
Plans (5 pages) ,
Attachment D Letter of November 18, 1974 f rom George Lear to HEL (I page) '
Attachment E Letter oi January 8,1975 f rom' George Lear to NEL (1 page) cAttachment F Letter of" September 30, 1976 from UCLA's Ivan Catton- to NP.C, l'ndicating compliance with 10 CFR l
/ 73.40 (1 page)
Attachment G' Letter of Julyfil,1977 f rom George Lear to UCLA .(2pagns):
' Attachment H Memorandum of Ju.nc 28, 1979 from James R. Miller (
to Robert Burnett (2 pages)
Attachment i Letter of ragust' 9,1979 from Frank Pagano (1 page) (
' Attachment J Excerpts from Svnple Physical Security Plan, Revision I, June 14, 1979 (3 pages) >
Attachment ~K Excerpts f rom SECY-79-187C,-December 19, 1979 e (2 pages)
Attachment'll Uni ted Press, international wi re service story, January 4,1984 (1 page)
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d,'y ,V UNITED STATES 3.:~E 2
.\ [ N 't ATOMIC ENERGY COMMISSION h:1
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W ASHINGTON, D.C. 20545 1.. . . .
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November 30, 1973 kst No.-50-142 . -.l;;;lF#
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The Regents of the University .:::sGl:.
of California Nuclear Energy Laboratory e. -
ATTN: Mr. Thomas E. Hicks -
Director 1.os Angeles, California 90024
, Gentlemen: V..
=i2$
On hbvember 6,1973, the Commission adopted amendments to its regulations E05 in 10 CFR Parts 50, 70, and 73 which are to strengthen the physical .Z protection of reactor facilities and of special nuclear s terials. The f...........
new mies require in part that licensees of pmduction and utilization !E F facilities submit a physical security plan to the Comission by ...,,;....
January 7, 1974. A copy of the amendments is enclosed for your use. . ~:;.~ ,
.:= ::
Tne submitted plan should be as described in the new 10 CFR Part 50.34(c) and comply with the requirements stated in the new Part 73. Regulatory \ ~~1.. .
Guide 1.17, " Protection of hbclear Pcwer Plants Against Industrial . l' ..u.;
Sabotage", states an acceptable Regulatory position for complying with . . . . .
this requirement. Reactor facilities other than power reactors should .se use the position in the Regulatory Guide to the extent practicable. =2=
e If you have previously submitted a security plan, please review it with respect to the requirements in these regulations. If you conclude that "~i,;...
all applicable requirements of Part 73 are met by your plan, indicate .
this conclusion and provide specific reference to the plan. If all =
requirements are not met an amendment or revised plan should be filed.
Three copies of your plan should be submitted. Your letter of transmittal should request that the plan be withheld from public disclosure pursuant -
I to Section 2.790 of 10 CFR Part 2. e Sincerely,
.**:. i. ;.'
, .==
- W DonalaJ.Alovholt/h f fkh?
Assistant Director for
"==
Operating Reactors eig.c:=.
Directorate of Licensing "9E=
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Enclosure:
{
Amendments to 10 CFR Parts 50, 70, _. .;
and 73 published November 6, 1973 4
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Attechrnent B
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, l /'g,a U.S. ATp!IC ENERGY CEMMISClON June 1973 1 1 -
c,' eras oi
! R EGULATO RY GURDE Dir.ECTORATE OF REGULATORY GTANDARDS 0
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REGULATORY GUIDE 1.17 f PROTECTION OF NUCLEAR POWER PLANTS AGAINST INDUSTRIAL SABOTAGE
. A, INTRODUCTION i National Standards Committee NIS and is in final review '
by Be American National Standards Institute (ANSI)
On February 1, 1973, the Atomic Energy Board of Standards Review.
Commission had published in the Fedcral Regirte ;
proposed amendments to its regulation in 10 CFR Part '
in addition to the procedural measures described in 50, "Umnsing of Production and Utihzation ANSI N18.17, the design of structures. systems. and Facilities." Proposed [ 50.55c would require each components important to safety (e.E., such features as beensee authorized to operate a nuclear reactor to redundancy, automation, independence. dh e rsity. ,
pronde appropriate protection against industrial protection against common-mode failures, and the '
s:botage. Proposed paragraph (c), " Physical Security placement of facilities and equipment) can also provide Plan
- of { 50.34 would require each application for protection against acts ofindustrial sabotage.Therefore. l an operating licens: to include a physical security plan. it is considered prudent to enhance this form of Proposed paragraph (p) of { 50.34 would require protection by protecting the vital equipment against existing licensees who have not submitted a physical surreptitious acts of industrial sabotage that could secunty plan to submit such a plan to the Commission impair the performance of its intended safety functions. j for approval within 60 days after the publication of it is important that such protection be considered early these amendments in effective form. Furthermore, {
in the design stage and that protective measures be
} 50.34 requires that an application for a construction described in the application for a construction permit.
permit melude the principal design criteria to be satisfied At a later stage, these measures would be described in :
in meeting the requirements for structures, systems,and greater detail in the applicant's security plan identified {
components essential to safety This regulatory guide in proposed paragraphs (c) and (p) of Q 50.34.
describes physical security criteria that are Senerally acceptable for the protection of nuclear power plants C. REGULATORY POSITION against acts of industrial sabotage which could lead to a threat to the health and safety of the public. The The requirements and recommendations contained .
Advisory Committee on Reactor Safeguards has been in the proposed ANSI Standard N18.17. " Industrial (
consuhed conceming this guide and has concurred in the Security for Nudear Pov er Plants,". dated March 23, regulatory position. 1973, are generally acceptable and, with due consideration for the unique characteristics of the plant B. DISCUSSION and its owner organaation, provide an adequate basis for I a physical security plan for the prc,tection of nuclear Subcommittee ANS 3 of the Ameriern Nudcar power plants apinst industrial sabotage, as Soacty St:.ndads Comnuttee has developed a standard supplemented by the following:
that proddes criteria for industrial security propams to protcer oparational nudear power plants from acts of 1. Security Sytrems mdaunal sabotag which could lead to a threat to the a. The plant *.ecurity forces should base onsite, health and safety of the pubbe. This sta*,dard, to be arrned, and uniformed ind.viduals w hose primary duties despa ted ANSI NIS.17. " Industrial Security for are the protection of facilities from acts that could Nudcar Pt wer Plams,"' has !;een reviewed by American endanpr the health and safety of the pubhc.
- b. All security alarms should annunciate in a
'( eries may te ottamed from the Amerian Nuc! car continuoasi) mant ed, ensite central klarm st2 tion and in Sme t) . 44 E. OJgen Otnue. Hinsdale,In.noi 60521. at least one other continuously tranned station not i USAEc (EOULAToRY GUIDES coe.= ce vei r .*=c pA<t e., to cc..,-s t, ,=p ,6w g v. e.. e o ee in ce v s. Aie-ac
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- rom eri t6e Sof >wey pas. tefarf das,ere P. ph.*fte . ell te m ses2tahe. el they gare,vt. a toe ne for e.g. f.p.*eq,, reg ...te to
'*45 'h t -tre e' coet***tre of a swarstel O' I ce"m. %.y f*.e CfunPwhaqq. 1. P 2.aae betterg f. P 'tsbru
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t necessarily onsite. A11 alarminhould be self checking and communication equipment, should be functionally tamper indicating. Le annunctation of an alarm at the tested for operability at the commencement and
, l ,8 ons!te central shrm station should indi:ste the type of completion of esch interval during utJch such alarm (e.g., intrualon alarm, emerp: rey exit alstm) and equ!pm:nt is used for se'eurity, but no less frequently location, ne annunciation at the other alarm station than once e:ch anen days.
should, as a rrinimum, provide indications that an b. Communication equipment used for security intrusion or Chpl entry has occuned. De affected should be tested with a minimum frequency of once at armunciator should be reset only after satisfactory the beginning of each security force work shift.
communications have taken place between alarm stations. All intrusion alarms, emergency exit alarms, 3. Protection of Vital Equiptrx nt alarm systems, and line supervisory systems should,as a Approprinte design fr.atures and equipment rninimum, meet the level of performance and reliability arrarEements should be provided and be consistent with indicated by GSA In Federal Spcification er sa ety requirunents to reduce 6e cpportunity for W.A 00450 A (GSA FSS)*,terim successful industrial ssbotage of stal equipment.To the extent feasible, these features should include measures
- 2. Equipment Teeting to protect gainst undetected intentionalacts that could
- a. Security related equipment, except for impair equiptrient perforracnce, such as automatic
'Ceples reay be obtained from budness service centers of the General Services Adminisustion Reponal Offices located in th' f E*
- i 'E *i** Detailed s-curity measures for the . physical Protection of the facility against indtistrialsabotage will rnston. Mn a. Denver.colo. Kansa s City, Mo.
Nr York. N.Y. San Francisen, Ca. tes Argeles.Ca. be withheld from pJblic discloture as provided in wnMr,rt on. D.C. Atlanta Ga.
Seattle. Wash. I 2.790 of the Commission's regulations in 10CFR Ft. Worth. Te nas Chicago, Itt. Part 2.
- 1. I i.'
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- Attachment C t N 'STRIBUTION ,
, acket File :.:::
AEC PDR(w/o encl.1) ,y ::7 Branch Reading 1)i===:5 JRBuchanan, ORNL (w/o eacl. ;.:::
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KRColler, L:0R . _ . . . . . .
JUL.1 5 1974 RAPeepie r-LtGR-1 ' ... " 'r:
Docket No. 50-142 IfBranchChief,OR - - - ~ ~
! Project Manager, OR
,.The Regents of the University Y# Licensing Assistant, OR ___
of California d TPFlood, L:0R-1 . . . _ . .
Nuclear Energy Laboratory TJCarter, L:0R ATTN: Mr. Thomas E. Ricks SVarga, L:RP Director OGC Los Angeles, California RBouston, L:0SB . ..
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Gentlemen: "EEE
.EsE" We have reviewed your proposed security plan dated January 14, 1974. _
At this -time, we are unable to complete our evaluation with the infor- ==!!:
mation provided. Enclosure 1 identifies deficiencies in your plan with ===
respect to the interim guide, enclosure 2, against which your plan was =E s evaluated. (Enclosure 2 titled " Interim Guidance.- Organization and .:=55:
Power Easaarch and Training Rasctors" ~==
Content of Security Plans for is furnished for your asidance.)L " l=5.~Ji :
=.=.-
We request that you smend your plan to incorporate the information indi- E cated in the interin guide. Also, identify any feature of your plan c.E that cannot be implemented within 30 days and describe the interim :E meaqures that would be taken to provide an equivalent level of protection. . i= :
We request that your revised plan be submitted within 30 days from the _
date of this letter. Your security plan submittal is exempt from public 18 9 diaelosure pursuant to 10 CFR Part 2, Section 2.790(d) and should be so . "= E marked when transmitted. 'lig.
Sincerely, i
_ =.:
Original Signed by, "~9 Karl Gouer Karl R. Coller, Assistant Director . . .
for Operating Raactors . - . -
Directorats of Licensing . .:.=;.
EEis
Enclosures:
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- 1. Request for Additional Information !!=!jii;.
- 2. Interim Guidance =: -
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't WITHHELD FRO:4 PUBLIC . DISCLOSURE 4
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Docket lio. 50-142 5
, Enclosure i:o.1 The foflowing' paragraph nu.ders refer to th.ose sections of the
' (
interim guidance document (Enclosure 2) which are not addressed
. in sufficient detail to permit a thorough evaluation of your w security plan.
Paraora oh 'i!o. Subject .
I.A. Essential Equipment I.B. Security Area I . C. ' Security Systems .
II.A. Organization II.B. Access Control (
- . II.C. Surveillance II.D. .. Procedures ..
II.E. Security Program !!eview You are reminded that since your license authorizes possession of Stiti -
in excess of 5. kilograms U-235, that compliance with 10CFR73.50 and 73.60 would be required if your inventory of non-exempt S!N equals or exceeds the formula quahtity specified in,14CFR73.1.
. WITHHELD FRG:4 PUBLIC DISCLOSURE L'
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Enclosura 2 Interim Guidance - Orgaaization and Cpntent of Security Plans for .. ,
Lou Po.ler Research and Training Reactors Applicability - This interim guidance is for use in developing and evaluatinc security plans for low power research and training reactors. For purposes of this guide, these reactors are defined as'TRIGA reactors with authorized power
~ levels less than or equal to 250 KW and all other researen and training reactors with power levels less than or equal to 100 K.l, including AG'I's, zero power, and critical facilities. o
~
Purpose - The purpose of the security plan developed according to this guidance is to protect the reactor against acts of sabotage. It is intended for use by the licensee to demonstrate compliance with 10CFR50.34(c) and 10CFR73.40. Conformance with this guide will not assure compliance with 10CFR73.50 and 10CFR73.60, if these parts are applicable to tne license'e.' ~
[l
- 1. Design Features A. Essential Equipment - Essential equipment should be designated in the security plan. This should include, but not necessarily be limited to, the following: the reactor, the reactor coolant system, reactor controls, and any associated equipment the m
9
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( . 4 failure of which could endanger ~ the health and safety of the .public. .
B. Security Area - security areas should be identified and described, including plan drawings or s' ketches showing these in context of the site location and showing access points.
At least the fuel storage area, the reactor control room, and the reactor room or building sho,uld be described as security areas. ,
C. Security Systems
- 1. Locks and Keys - a d'scription e of the lock and k.ey system should be provided; describe how keys 'are controlled; ioent1Ty tne specific individuci (*uy positivo LiLie) responsible for the security of the keys.
- 2. Communications - the.. communication system to be used in the event of a security violation should be described. -
II. Administrative Controls A. Organization
- 1. Security organization - the person responsible for the facility security program should be identified (by position title); the person (s) or group (s) having security functions and responsibilities on a day to day basis should be identified.
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- 2. , Local Law Enforcement Authorities - arrand(ments with the local law enforcement agencies for aid in the event of a security violation at the reactor faciliti should be described.
B. Access Control -
- 1. Pe,rsonnel - the categories of personnel who are authorized to enter security areas should be identified.
. 2. Control - the means employed to control access to security areas should be aescribed.
C. Surveillance - Plans for providing surveillance of essential equipment and security areas durinp working and non-working hours should be Gescr1bec.
D. Procedures - procedures and plans for dealing with the following situations should be Bri.efly described:
- 1. Response to detected unauthorized intrusions of security '
areas.
- 2. Security violations by authorized personnel.
- 3. Bomb threats.
Acts of civil disorder.
- 4. .
E. Security Prooram Review
- 1. The security program should be reviewed not less frequently .
i than once every two years by the indi9(dual designated in item II.A.1. This provision should be documented in the
. security plan itself. In this connection the licensee is directed to the provisions of 10CFR50.54(p).
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The Regents of the' University- extra copies' ,
of California l TFlood % ,,;,, , # i--;d t
Nuclear Energy Laboratory 4 . . 9 # ;= =
ATTN: Mr. Thomas E.111cks '
[5"5 Director -
los Angles, California *: !}'
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centlemen: i '
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Tour letter of Octobert28,,?1974 sta'ed t t. hat UCLA was considering methods' J _..
to reduce their Special! Huhl. ear Material inventory bslow the forcula [jl':
quantity specified in Title'10 Code of Federal Regulations, Part 73.
-l- .
As of this date we bave ist received a written confircation that you EMJJ have reduced your Special Nuclear Material inventory nor have we received 555 a request to review your security plan assuming the inventory was reduced. E.M.}..
You are reminded that your ' original plan, as submitted, was not acceptable ;==3.-
and that you may be in' violation of Titic 10, Code of Federal Regulations, ties Part 73. Moncompliance with the Regulations would require that appropriate EEE-enforcement action be 'taken 'by us.
M ==
Tour response is requested dthin seven days of the receipt of this letter. 'i5IE
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Sincerely, J..}E..
M. rid Original Signed f:5
=
George Lear, Chief 525 5.
i Operating Reactors Branch #3 Directorate of Licensing i=1 g::.
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10aEEe Docket No. 50-142-
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The Regents of the thiversity GLear of California Nuclear Energy Laboratory ACRS (16) extra cps ATTN: Mr. Thomas E. Hicks Director "I d ==
los Angeles, California 90024 Gentlemen: e" We have reviewed your reactor security plan dated August 21, 1974, and the revision dated August 29, 1974. "!j}s Based upon your reduction in Sef inventory, connunicated *
-in your letter dated December 12, 1974, we find that your ,
plan complies with the requirements of 10 CFR Part 50 ""'
Section 50.34 (c) and is acceptable.
Sincerely, ,
. f.
Original SigJn E
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_ _.. .:.~2:.
.sE George Lear, Chief W=
Operating Reactors Brandt #3 Directorate of Licensing
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UN!"VF.llSITY Ol? cal.11roWia,TiiS ANURTRO -- 3 Attachment F
- . N-I gANTA StAnastAttA . siANTA t rttf4 4j
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- 9.6915 A$st;. f.FA . StavFittlleet
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September 30, 1976
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," f:1M,, .bh i .0CT7 Mr. Bernard C. Rusche, Director p 1976> 3 u,,,,ivar.u.wicu Office of Nuclear Reactor Regulation , ,
f, %fg4 y *, D United States Nuc1 car Regulatory Commission /'r Washington, D. C. 20555 Docket 50-142 .
]' I3
Dear Mr. Rusche:
The attached Draft-Security Plan is intended to replace our existing,T i
approved Plan and Amendments thereto.of the existing Plan to the stat and approval by a laboratory Security Comittee. f the ex-nor current planning demand immediate changes llo- in the greater flexibility to meet the increasing activity and changing space a cation / utilization within the Nuclear Energy Laboratory.
Please note that the locations of clar= systan transducers (Figures 11,12, and 13) remain a portion of the Draft Plan, bitt that adoption of th Plan will remove the door-keying information from those figures to a written .
procedure status. ,
it is our intent to secure an " Approval in Principic" of the Draft Plan before proceeding with the creation of the SecurityDuring Committee this and the c lation of Written Procedures for approval by that committee T Security Plan. I The Draft Plan is believed to be in conformity with the requirements of Due to the sensitive nature of the contents of this letter, !
10 CPR Part 73.40.
we request that this document be withheld from public disclosure pursuant t Section 2.790 of 10 CFR Part 2.
4
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Siticc$cy, I ,
I - l hvan Ca on, Director Nuclear Energy Laboratory CEA:NCO:vl ec:
Mr. V.N. Rizzolo, Chief, Safeguards Branch, U.S. Nuclear Regulatory Co Region V, Suite 202, Walnut Creek Plaza,1990 N. California Blvd.
Walnut Creek, California, 94596 20, 1976)
(In accordance with our letter of August 1u149
Attechment G .
' =:===
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JUL 11 1977 [..h;;..
C::~~
Docket No. 50-142 '
~
t $rr The Regents of.the University. u F==
' ~~~
of California -
~'
ATTN: Mr. Harold V. Brown =
Environmental Health .
and Safety Officer :==
Los Angeles, California 90024 ,j
~
Gentlemen:
- "T**::'
I am pleased to respond to the enclosed letter of May 27, 1977 which -"'
has been fomarded to me for reply. You fomarded a letter dated ..'.lf".
May 19, 1977- from Ivan Catton, Director, Nuclear Energy Laboratory. ===
We have reviewed Dr. Catton's letter requesting (1) a clarification -= .
of the status of the UCLA Security Plan with regard to the Facility .T Operating License for the UCLA Training Reactor, and (2) whether the ME Security Plan is conceived as having radiological safety aspects that 'iT interact with the license. . lit With regard to the status of your Security Plan,10 CFR Part 50, .e.
Section 50.34 " Contents of Application, Technical Information" : ..?
and Section 50.54, " Conditions of Licenses" clearly require you to 5.5 have a security plan and also provide guidance for making changes to the plan. Although your Security Plan is not specifically incorporated G
. 1.2E in your license, we consider it to be a part of the license. In fact. ~
we.are presently requesting licensees to agree to incorporating the ~ ==
security plan in the license by reference. We have already contacted
~~
. .1 your staff on this subject. * ==
~~
95
/ ._. --With regard to radiological safety aspects of your Security Plan, ~T.
/ implementation of the plan provides reasonable assurance that sabotage ,
, and the theft or diversion of Special Nuclear Material (SNft) willnnot take place. Theft of SNM can have radiological implications far in excess of those activities for which your license was issued. The .:. .
securi.ty plan, thus, is similar to other safety related components of
.=
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of California '"! f5 g==: hm== If we can be of further assistance in this matter, please contact us. s:J-]-
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Operating Reactors Branch #3 2: Division of Operating Reactors . . . . . . . gc= .-
Enclosure:
Letter dated May 27, 1977, ~ . - - - . . H. Brwn to E. Case * = - cc: FM
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University of California .71.' ATTN: Dr. Ivan Catton, Director EMB Nuclear Energy Laboratory .::M Los Angeles, California 90024 .'.::?.if
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DISTRIBUTION: ' E= Docket : ;=2 ORB #3 Rdg NRC PDR == inueergy , 3SI VStello ==' KRGoller - JMil1er =". GLear DJaffe :}1~T~! ~ CParrish .5 Ol&E (3) RClark ACRS (16) TBAbernathy JRBuchanan ., File '
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_s 6k JUN 2 81979 s - MEMORANDUM FOR: . Robert Burnett, Director, Division of Safeguards, NMSS *" FROM:
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James 00R R. Miller, Assistant Director for Site and Safeguards,
SUBJECT:
NEW COMMISSION PAPER ON
- UPGRADE RULE" I understand that you are pro'ceeding on the subject paper on a schedule that would have the paper to the Comission by Monday, July 2,1979 Since some
- of the Commiss' ion's questions were directed at reactors, I am available to assist you on whatever schedule you desire. My basic interests are:
1) As suggested by Commissioner Kennedy, the following footnote should be added to 573.55: Footnote: In the physical protection of all nuclear reactors, the term "High Assurance" has the same meaning as the tem
" Reasonable Assurance" as is used in reactor public health and safety determinations.
2) We suggest'that an urgent meettng be held with ELO to discuss some of the language that you presented to the Commission dealing with ". . .objec-tive to provide high assurance. . . ." My specific concern is legal backup during a public hearing. , 3) As we have discussed, non-power reactors must be deferred from the Upgrade NRR believes the deferral will be for a period of about 2 - 3 yea of the indepth studies we will be conducting. During this period, we will 4 rely on 173.60 for those facilities with greater than formula quantities of i
- SSNM and 5173.40 and 73.47 for all othe.'s. This will maintain the status
- quo and closely parallels the coments of Chairman Hendrie. Also NRR will continue studying the need for a separate rule 'for non-power reactor ,
facilities and comence preparing such a rule should it be determined necessary. { 4) AstoanyinvestigationintotheSurryincident,itmustbefullycoord-I nated with NRR and I&E. We will provide any assistance necessary in this matter an;l a joint meeting laying out the plan of attack should be held prior to any efforts expended. / 5 James R. illier, Assistant Director
- for Site and Safeguards Division of Operating Reactors
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A UNITED STATES f (, 3 t NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20565 q w g *s. *
. AUG 9 1979 .
Mr. Don Alger University of Missouri Columbia, Missouri 65201 .
Dear Mr. Alger:
SUBJECT:
SAMPLE PHYSICAL SECURITY PLAN FOR HON-POWER NUCLEAR REACTOR FACILITIES POSSESSING SPECIAL NUCLEAR MATERIAL CF MODERATE STRATEGIC SIGNIFICANCE - The Comission has amended its regulations to require physical protection measures at non-power reactors, to detect theft of special nuclear material of moderat4 and low str.ategic significance. This new regulation ( 73.47) is designed to provide a level of protection equivalent to the.reconnendations of Information Circular 225 Rev.1 published by the International Atomic Energy Agency. Concurrently, the Commission published a regulatory guide entitled,
" Standard Format and Content for the Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance."
Applicable non-power reactor licensees must meet these requirements for detectih j of theft in addition to previous regulatory requirements for protection against sabotage. As a result of discussions with the non-power reactor licensees, we havedraftedtheattachedSamplePlanasanaidtouniformityandcompletenessin) the preparation of physical security plans. ~ v - I would appreciate your coments on the proposed Sample Plan by September 15, 1979. Sincerel ,_.4 W- . jjl D Fran ' (Aagado Chief Reac' tor Saleg'uar,ds Development Branch Division of Operating Reactors
Enclosure:
Propose'd Sample Plan - e.
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Attachment J CONTAINS 10 CFR 2.790(d) INFORMATION
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a WITHHELD FROM PUBLIC DISCLOSURE
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Sample Physical Security Plan for Non-Power Nuclear Reactor Facilities Possessing Special Nuclear Material of Moderate Strategic Significance 9 Reactor Safeguards Development Branch Division of Operating Reactors Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission v
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l l . l l l l t l Revision 1 l June 14, 1979 l
CONTAINS 10 CFR 2.790(d) INFORMATION
*l WITHHELD FROM PUBLIC DISCLOSURE Table of Contents Pagg Purpose .
General Performance Objectives Identification of Special Nuclear Material on Site Implementation General Site Layout Security Areas
' Controlled Access Areas (Use)
Controlled Access Areas (Storage) Vital Areas N Detection Devices or Procedures Surveillance of Vital Areas. Preauthorization Screening Badging System Lock System Access Control Description Escori. System
\ earchS Description ,
Administrative and Security Organization Communication , Response Procedures Material Transportation Requirements . Receiver Requirements Export and Import Requirements Revision 1 June 14, 1979
C' ' ' CONTAINS 10 CFR 2.790(d) INFORMATION WITHHELD FROM PUBLIC DISCLOSURE Purpose
'This security plan describes the physic'al protection system and security organization which will provide protection against radiological sabotage and detect the theft of special nuclear material at the Sample Facility.
It demonstrates compliance with 10 CFR 50.34(c), 10 CFR'73.40 and 10 CFR 73.47. Revision 1 June 14, 1979 a _ _ _ _ _ _ . _ _ . _ -
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. l. UNITED STATES At trchment K NUCLEAR REGULATORY COMYISSION . WASHINGTON, D. C. 2 css 5 .- Cecember 19, 1979 SECY-79-187C INFORMATION REPORT gcyp For: The Commissioners '
d4N a 7 19 % From: William J. Dircks, Director , k Office of Nuclear Material Safety and Safeguards k g Thru: Executive Director for Operations 8 p L A
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Suoiect: IMPACT OF THE SAFEGUARDS UPGRADE RULE ON NONPOWER h2 ACTOR LICENSEES . Purocse: To provide th~e Ccmmissioners with the following information: a status report on the impact of the Safeguards Upgrade Rule on the 22 nonpower reactor (NPR) licensees listed in SECY 79-187B; review of safeguards measures in force at NPRs; the status of the reevaluation of the 100 rem /hr at 3 . feet self protection exemption criterion; and the status of NRC staff reviews and " studies which might lead to giving safeguarcs credit for enrich-ment, type and form of the SSNM located at NPRs. Discussion: Backorcund On July 24, 1979, the Commission helc an open meeting on the impact of the Safeguards Upgrade Rule on nonpower reactor licensees (SECY 79-1878). The discussion concerned the staff recommendation that nonpowet reactor licensees be defarred from implementing the requirements of the Safeguards Upgrade Rule and that in the interim the new Category II (573.67) physical protection requirements as well as the current (973.60) require-ments be applied to nonpower reactor licensees with greater than formula quantities of SSNM. During the meeting the Ccmmissioners asked questions concerning the numoer of Category I nonpower reactors that would oe subject to the physical protection recuirements of the Safeguards Upgrade Rule as well as what physical protection is presently in place at those nonpower reactors. The Commissic,ners were also concerned with what physical protecticn requirements were actually needed at Category I nonpower reactor facilities given the unique type form and enric N,ent level of the reactor fuel. This concerr, was expressco in relation to the amount of time nonpower reactors shculd be deferred from imolementing the recairements of the Safecuards Uccrade Rule. The Cccmission asked the staff for an in.erim status reocrt in 120 days whicn would give a more cefinitive exolanation of the Category I nc power reactor prcolem and actions being taken tc cetermine the appropriate i pnysical protect on re':uirenents for these f acilities. This Cc, mission pacer is the interim status report. Oca:ac.: C . "', Nulsen
- -7:131
D (.- T. 4 Additionally eleven NPR licensees indicated that they could be exempted from the Upgrade Rule requirements based solely on the 100 rem /hr at 3 feet exemption as discussed earlier. However the licensees cited a variety of problems that they may encoun,ter. Enclosure 2 enumerates these problems and includes a table that has been developed to give a quick breakdewn by licensee on the ease withlevel. radiation which each one can maintain its fuel at the 100 rem / Again it should be noted that some may not meet the radiation levels during short periods of time. One course of action that the staff is investigating is the idea of requiring increased physical protection, on an interim basis, for the NPR SNM during the periods it is not self , protecting. . Current NPR Safeauards Measures in Force Since late 1973 NPR licensees have been required to submit a l physical security plan as part of their application for a license to operate. NPR licensees wno oossessed less than a formula quantity of SSNM were sucject to the provisions of 550.34(c) and 973.40 anc those who possessed more than a formula quantity of SSNM were subject to the provisions of 973.50 and 973.60, as applicable, in addition to 550.34(c) and 573.40. In 1974, the staff developed guidance in supoort of the foregoing - requirements to aid applicants and licensees in the development of security plans to protect reactors against acts of sabotage. The guidance was contained in 3 documents and was sent to aporopriate licensees. The guidance occucents addressed'sec-urity systems power levels: that were applicable to NPRs of three different
>5000 kw.
(1) <250* kw, (2) >250 kw, but <5000 kw and (3) All of the currently aporoved security plans for the reacters in cuestion were reviewed and analy:ad with respect to prevent-ing sabotage and a few were evaluated by NRR to determine the adequacy of their physical protection system to protect against the theft or diversion of SNM. All NPRs have been inspected against 1975-1979. their security olans for comoliance during the period While some items of noncccoliance have been noted, there was no adverse effect en public nealth and safety. In addition, staff members of NRR have visited and assessed 50 NPRs in the past two years. All 22 NPRs wnich SECY 79-1875 listed as Category I facilities, based on autneri:ed possession limits, have security systems in place and have teen inscected and fcund in concliance with their security plans -nich are based on present re:uirements under !50.3 (c), s73.40, 573.50 and 973.60, as applicabie , The ty-staffsecurity memoerssystems at all 22 NPRs have ::een examined during visits of NER. ! i
/
'ints is tne Category limit for TRIGA reactors, the training rea tor limit was > cr <100 kw.
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Attachment L [ t { f V-Ftf Nuclear foes: Temxists may attack UCLA reactor UCLA's nuclear reactor could be the target of aLOS ANG possible terrorist attack during the 1984 Olymples, and have asked the federal government to shut it down { before the Summer Games.
'Ihc Committee to Bridge the Gap said in papers filed 1 f security plan for the 23 year-old research rea with the Nuclear Regulatory Commission that the
, des to protect against sabotage.
j" maintained that reseArch reacttook the s same position in separate paper, l
'~ federal regulation to have sabotageors are not required by tection.
1he NRC Atomic Safety and -l ng Board is scheduled to examine the security question when relicensing hearing continue next month. ( Reactor enough time ents said this means there will not im the board decides such an action is needed; remove the fuel before the Olympic
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