ML20094J047

Comment on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Fuel or High Level Radwaste

ML20094J047
Person / Time
Site:	Prairie Island
Issue date:	10/11/1995
From:	Wadley M NORTHERN STATES POWER CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-60FR42079, RULE-PR-60, RULE-PR-72, RULE-PR-73, RULE-PR-75 60FR42079-00004, 60FR42079-4, NUDOCS 9511150068
Download: ML20094J047 (5)

Text

y 00CKETED Northern States Power Company Prairie Island Nuclear Generating Plant 1717 Wakonade Dr. East

'95 NOV 13 P3 :18 wen.unne ssoa9 0FFICE OF SECRETARY DOCKETING & SERVICE November 10, 1995 BRANCH DOCKET NUMBERnn PROPOSED RULE rlltn,a:,%76 i (Wa 4ao79')

Secretary U S Nuclear Re ulato Commission Washington, DC 20555-0001 Comments on Proposed Rule Changes - Safeguards for Spent Nuclear Fuel or ~

Hich-Level Radioactive Waste (60 FR 42079 of Aunust 15. 1995)

Northern States Power Company has reviewed the Federal Register notice of August 15, 1995 referenced above, and would like to offer comments as '

indicated in Attachment 1 to this letter.

If you have any questions, please direct them to David Axt at 612-388-1121 Extension 4880.

Michael D Wadley Plant Manager Prairie Island Nuclear Generating Plant c: Regional Administrator - Region III, NRC Senior Resident Inspector, NRC NRR Project Manager, NRC J E Silberg Attachment 1 - Comments to the Nuclear Regulatory Commission from Northern States Power Company - November 10, 1995 9511150068 951011 PDR PR 60 60FR42079 PDR O pt

'- Attachment 1 Comments to the Nuclear Regulatory Commission from Northern States Power Company l November 10,1995

Subject:

Safeguards for Spent Nuclear Fuel or High-Level Radioactive  ;

Waste (60 FR 42079 of August 15,1995)

Issue #1: No Credible Target-Threat Association for ISFSis When considering basic security risk assessment methodology, a target must be credible before it can linked to a corresponding threat. With regards to sabotage, a target is unattractive unless the sabotage act can produce undesired consequences.

For nuclear power plants, these undesired consequences are codified as a 10 CFR, Part 100 release, resulting from radiological sabotage. On the other hand, sabotage scenarios and consequence analyses commissioned by the NRC and other organizations, to date, conclude that a Part 100 release from an ISFSI dry cask system is highly improbable and quantitatively not feasible.

In the NRC's Part 72 Proposed Rule Making of May 31,1989 it does, however, state that:

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. . . consequence modeling assumptions more severe. . .are possible if l unconstrained sabotage resources or protracted loss of control of the storage site are allowed.

Such an act, however, would require an enormous amount of time, tools, equipment .

and several saboteurs. Even if such a scenario were successfully carried out, the saboteur would still not achieve a Part 100 release. It is therefore reasonable to conclude that ISFSI casks should be afforded protection commensurate with the target sabotage consequences and threat (or lack thereof).

According to a former Sandia National Laboratories employee, who personally oversaw penetration tests of dry casks, there are two plausible sabotage scenarios which could breach an ISFSi cask (given unconstrained sabotage resources and a protracted time period). One scenario involves explosives; however, the particular explosive package is:

• Extremely difficult to set-up

. Would take a combined total of approximately 130 lbs of explosives & projectile

. Must be positioned, leveled and aimed precisely

. Must be fired from the optimum distance

. Will miss a target the size of a standard cask about 80% of the time in the second scenario,' the saboteur would need a specific type of military oxygen torch. This particular torch system is, however, accessible only to a distinct military -

organization, and it would require the saboteur to be exposed to the potential radiological release as well as the tremendous heat given off by the oxygen torch.

Nonetheless, the saboteur in both scenarios would still not achieve a Part 100 release.

lasue #2: Use of Deadly Force Contradiction 1 Security Officers are justified in using deadly force in order to protect the public against - 1 radiological sabotage (Part 100 release) by the design basis threat. This is justifiable.

There is linkage between sabotage consequences and potential threats. On the other l hand, NRC doctrine (verbally communicated) is that security personnel are not required l to use deadly force in protecting an ISFSI cask. This would seem to indicate a Part l 100 release - the basis for 10 CFR Part 73 security criteria - is not feasible by sabotaging an ISFSI cask. This contradiction, in and of itself, would indicate that the application of Part 73 level security is duplicitous and indeed excessive.

Issue #3: NRC Security inspection Burden NRC inspection efforts for nuclear reactor sites are manpower intensive. If ISFSI security licensing criteria parallel a nuclear site (10 CFR Part 73) then, from an inspection standpoint, the licensing of an off-site ISFSI or an ISFSI in the owner controlled area (OCA) is analogous to creating several new nuclear power plants. Like most of the private sector, the NRC faces manpower cut-backs and shrinking resources. Notwithstanding the rational of Issues 1 and 2 above, how then will the NRC handle the increased inspection efforts imposed by the additional ISFSis?

Summary The absence of a credible target-threat combination for ISFSI dry cask systems ignores basic fundamental vulnerability assessment rationale. The proposed amendments to part 73.51 which specify safeguard requirements for ISFSis are categorically excessive. Dry casks cannot realistically be stolen, maligned or sabotaged in any way which would produce a 10 CFR Part 100 release. The' correlation of reactor and ISFSI site security criteria is baseless and would therefore result in unnecessary licensee expenditures, j

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Responses to Specific Proposed Rule Questions l l

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1. Would the proposed amendments impose any signi6 cant additional costs for I

safeguards of currently stored spent nuclear fuel beyond what is now incurred for that purpose?

Response: Yes. For ISFSis located outside of a licensee's owner controlled area i (OCA), the licensee would need to provide two (2) watchpersons around the clock.

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This is approximately 20,000 man-hours a year. Depending on the LLEA agreement, l the licensee may also need to provide a dedicated response force which is appendix .

"B" trained and certified. j l

2. Is there reason to expect the costs to future licensees to differ substantially from those of currentlicensees?

Response: Yes, for those facilities which might be required to re-locate their ISFSis to outside their OCA. The costs would increase for reasons stated in question #1 above.

3. NIA.

4.- Are the costsjustified by the benefits that would be afforded by the proposed amendments? Are there althmatives that would afford essentially the same benefits, but be more cost effective?

Response: No, the costs are not justified; the benefits are excessive and unnecessary l for those reasons stated in issues 1,2 & 3, above. Yes. One alternative would require l that the NRC: (1) not lump all spent nuclear fuel storage facilities together, mandating l' one blanket set of security criteria, (2) develop physical protection criteria which is tailored for the threat-target combination. For dry cask storage facilities, see the attached recommended ISFSI Physical Protection Alternatives.

5. NIA.

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Attachment 1a ISFSI Physical Protection Alternatives EW 7 51 REQUIREMENT' * - * '

e >

1. Two physical barriers: Two physical barriers: perimeter, The level of protection offered by pmtected area perimeter fence, nuisance fence with posted "No a protected area and isolation defined by 73.2, with isolation Trespassing" signs, with locked zone perimeter fence does not zone & the cask itself as second access. correspond with the target-threat barrier combination; the protection it does provide is negligible

2. Illumination around protected illumination just around the casks same as above area perimeter (along with intrusion detection &

CCTV)

3. Complete protected area see above same as above i

perimeter intrusion detection system

4. Random patrols not less than Random patrols only by LLEA or With CCTV and detection system every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> authorized security personnel. directly enveloping the casks, and no credible threat, deterrence value of patrols is negligible

5. Security organization; two No dedicated secunty organization Target-threat combination does watchpersons per shift for required, other than random not support costs associated with a monitoring detection equipment patrols or other security personnel. dedicated security organization S. Documented liaison with None N/A designated response force or LLEA

7. Specified screening before None lN/A granting unescorted access l

8. Controlled ID & lock system None lN/A

9. Escorted individuals under None lN/A constant escort l

10. Redundant communications Not necessary. Target-threat combination does between security organization not support costs

& designated response force or LLEA

11. Searches of all hand-carried Not necessary With CCTV and detection system packages and vehicles directly enveloping the casks, and no credible threat, deterrence value of perimeter search is negligible

12. Written response procedures No safeguards response Target-threat combination for unauthorized penetration - procedures necessary, incongruent with Appendix C to

- including contingencies part 73 covered in App.C to part 73

13. All detection and surveillance None N/A systems must be tamper-indicating with line supervision - with comp measures when necessary

14. Security program review At discretion of licensee Security program not sufficient every 24 months scope or importance to mandate program review frequency

15. All documentation retained for At discretion of licensee l Paperwork reduction. Not 3 years l necessary