ML20238C853
| ML20238C853 | |
| Person / Time | |
|---|---|
| Issue date: | 09/02/1987 |
| From: | Randy Erickson Office of Nuclear Reactor Regulation |
| To: | King T NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| PROJECT-674F NUDOCS 8709100412 | |
| Download: ML20238C853 (3) | |
Text
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.g SEP 081987 Project No. 674 MEMORANDUM FOR:
Thoinas L. King, Acting Chief Advanced Reactors Generic Issues Branch l
Office of Nuclear Regulatory Research FROM:
Robert A. Erickson, Chief Safeguards Branch 1
Office of Nuclear Reactor Regulation I
SUBJECT:
PRISM SAFEGUARD AND SECURITY REPORT Bechtel National, Inc. report BNI-8603, " Safeguards and Security", dated June 1986, was delivered to my staff at the August 5, 1987 PRISM PSID review meeting. As a result of a review of that report, enclosed are some j
additional questions provided as part of our review of the DOE PRISM LKR Preliminary Safety Information Document.
As previously stated, we plan to cover in the current PRISM review only the reactor facility, not the J
co-located fuel cycle facility also mentioned in the PSID.
Therefore, we 1
have not reviewed chapters 3.2, Material Measurement and Accounting Requirements, or 4.5, On-site Fuel Cycle facility.
1 1
Robert A. Erickson, Chief Safeguards Branch j
Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation
Enclosure:
DISTRIBUTION j
As stated
. Central Flies MDCS '016)?
RSGB r/f j
cc: Ralph Landry RSGB Advanced Reactors s/f R.J.Dube L. Bush l
B.T.Mendelsohn I
PDR l
CONTACT B.T.Mendelsohn, NRR/RSGB ext. 29671 0FC :NRR/RSGp
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- NRR/ l;B
....:..ffp,__:.RR/RSGB NAME:BMendelsohn:RJDube
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i DATE: 9] I /87
- 9/ N 87
- 9/ '/87 0FFICIAL RECORD COPY 1
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8709100412 B70902 674F PDR l
Thomas L. King ENCLOSURE Discussion of PRISM Safeguard and Security Report I. Questions and Comments For Formal Response 1.
When will the insider study indicated on page 3-5 be available for our review?
2.
54.2 mentions the inherent safety provided by the negative reactivity temperature coefficient.
Is there any possibility of intentionally induced overcooling transients causing recriticality instabilities ?
3.
94.3.3 discusses 3 ways of removing shutdown decay heat.
Which of these methods would be available if the transmission lines to the site were cut?
What is the power source to the IHTS pony motor?
l 4.
What is the spacing between the grating rods described in SS 4.3.5 and 5.57 I
What delay times were used in the vulnerability analysis for the redesigned rods? Are these times censistent with the statement on page 4-15 that delays in penetrating ducts and vents will be comparable to eight iuches of reinforced concrete? Note that to be comparable could require an intrusion detection device to alert security before penetration is completed (explosive penetration of reinforced concrete involves a delay after the sound of the explosion has alerted security to the penetration attempt).
l II. Suggestions for Textual Improvement 1
1.
Clarify that the list of vital systems and equipment on page 5.2 it.cludes all seismic category I safety related equipment (per Review Guideline 17) and that no equipment in the balance-of-plant (B0P) area is classified as seismic category I.
2.
Page 2-4 states that the relative openness of the site, due to the reactor j
modules being placed underground, is a significant factor enhancing securi-ty.
A statement that it will be necessary for the plant owner to commit to keeping the area free from construction and maintenance clutter after completion of a module would support this contention.
3.
It would be useful if $5.2, Vital Systems and Structures, listed potential l
vital areas (and their boundaries) separately from proposed vital systems and equipment. Also, 10CFR73.55(e)(1) requires the central alarm station to be considered a vital area. This should be included in the list of vital areas.
4.
Note that examples included in the description of the design basis threat in $3.3 are not to be regarded as comprehensive, and are not intended to exclude any aspect of the design basis threat contained in 10CFR73.1.
5.
The PRISM Inherent Safety Features discussion of $4.2 does not need to be l
protected as safeguards information and could be placed in Appendix C of I
the PSID.
J j
Thomas L. King, Enclosure I
6.
54.3.1 claims no damage from any " credible" loss-of-cooling or i
transient-overpower scenarios.
Clarify that credible is not eliminating
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any scenarios that might have low probabilities from occurring randomly but could be caused by. deliberate actions.
7.
In the personnel access control discussion on page'4-12, clarify that all 4
persons, and materials they are carrying, will be r;equired to pass through metal and explosive detectors before entering the protected area.
8.
The list of applicable documents (Appendix A) should include 10 CFR Part 73, $573.20, 73.45 and 73.46, for protection of. strategic special nuclear material from theft, and Reg. Guide 5.65.
III. Comments for Future Consideration 1.
Page 2-4 says the small size of the PA is a significant factor enhancing security because it allows a rapid response to alarms. We require an adequately rapid response to alarms even for large facilities. Further-more, a small PA may benefit outsider r.dversaries by reducing the time'
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between first alarm and the adversaries arrival at a vital area.
2.
See comment # III.5 of July 14, 198* 1etter with respect to $$3.1.4 and 3.1.8 of the report. Automatic switchover to the on-site standby power source could still result in an unacceptable delay before required lighting-
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levels are restored because of time to get generators to speed and restrike
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delays of typical are lamps (see NUREG/CR-1327).
I 3.
The description of the perimeter intrusion detection and assessment systems
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on pages 4-13 and 14 does not describe the sensors at locations where building walls and roofs (Warehouse, Operations Center) comprise part of
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the perimeter. Also, has consideration been given to intrusion detection systems on the interior walls of the Operations Center where they form
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part of the protected area boundary (see PSID Fig. 1.2-25) ?
i 4.
The criteria for positioning of cameras on page 4-14 should also include preventing the fencing from obstructing the view.
I 5.
Page 4-15 states that building doors have a hardened construction to yield a delay comparable to at least eight inches of reinforced concrete.
Reliability of locking mechanisms and alarms on heavy doors have not always been good. Describe the doors and locking and alarm hardware considered for this delay. Will they be compatible with rapid access in a health, fire or safety emergency? Will they be compatible with routine traffic requirements without excessive falsa alarms or failures to open?'
6.
55.3 says the size of the response force in Table 5.3-1'was determined by establishing the number of armed security officers required'during normal operations and then subtracting from these those that would not be immedi-ately available for response.
Instead, the minimum rize of the armed response force must be determined and provided for even if this results in more armed officers than required for normal operations.
10CFR73.55(h)(3) specifies that this number shall nominally be 10.
(Thef t protection requirements, not being reviewed at this time, may result in additional armed security officers.)
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