ML20245H189
| ML20245H189 | |
| Person / Time | |
|---|---|
| Issue date: | 02/02/1989 |
| From: | Jordan E Committee To Review Generic Requirements |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20244B588 | List: |
| References | |
| NUDOCS 8902160415 | |
| Download: ML20245H189 (13) | |
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February 2,1989 MEMORANDUM FOR:
Victor Stello, Jr.
Executive Director for Operations FROM:
Edward L. Jordan, Chairman Committee to Review Generic Requirements
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 156 The Committee to Review Generic Requirements (CRGR) met on Wednesday, January 25, 1988 from 1:00 p.m. - 3:00 p.m.
A list of attendees for this meeting.is attached (Enclosure 1).
The following items were addressed at the meeting:
1.
B. Grimes (NRR) presented for CRGR review a proposed Generic Letter-requesting that power reactor licensees evaluate their facilities using guidance provided by the NRC staff, and include in revised Contingency Plans short-term actions that could be taken to protect their facilities against~ attempted radiological sabotage involving a land vehicle bomb if information becomes available indicating that a credible threat exists.
The Committee recommended in favor of isuing the proposed Generic Letter, subject to clarification of the basis for its issuance, and several other modifications to increase licensees' flexibility in implementing the actions requested (all changes to be coordinated with the CRGR staff).
This matter is discussed in Enclosure 2.
2.
The Committee considered two additional items to determine whether they required formal review by CRGR:
a.
A draft final rule amendment (10 CFR 50.54(w)(5)(i)) extending the implementation of the Property Insurance Rule.
b.
A draft Safety Evaluation Report for topical report BAW-10163P,
" Core Operating Limit Methodology for Westinghouse Design PWRs."
After brief discussion of each item, the Committee recommended in favor of issuance of both as proposed by the staff without the need for further formal review at a subsequent meeting.
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In accordance with the ED0's July 18, 1983 directive concerning "Feedbre;:K and Closure on CRGR reviews," a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes.
The response, which is required within five working days after receipt of these minutes, is to be forwarded to the CRGR Chairman and if there l
is disagreement with CRGR recommendations, to the ED0 for decisionmaking.
Questions concerning these meeting minutes should be referred to Jim Conran (492-9855).
brig;nci 5M"5 30 E. L hrden Edward L. Jordan, Chairman Committee to Review Generic Requirements
Enclosures:
As stated cc/w enclosures:
Commission (5)
SECY Office Directors Regional Administrators CRGR Members Distribution: w/o enclosures Central File PDR (NRC/CRGR)
S. Treby W. Little M. Lesar P. Kadambi (w/t.nc.)
CRGR SF (w/ enc.)
M. Taylor (w/ enc.)
1 E. Jordan (w/ enc.)
J. Heltemes (w/ enc.)
J. Conran (w/ enc.),
- C.nSakenas'(w/ enc.)'
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Attendance List - CRGR Meeting No. 156 January 25, 1989 CRGR Members E. i.. Jordan J.H. Sniezek J. Goldberg C. Paperiello R..Burnett (for R. Bernero)
D. Ross NRC Staff B. Grimes R. Dube B. Mendelsohn R. Erickson R. Fonner M. Taylor E. Davis l
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, to the Minutes of CRGR Meeting No. 156 Proposed Generic Letter on Truck Bomb Threat January 25, 1989 TOPIC B. Grimes (NRR) presented for CRGR review a proposed Generic Letter requesting power reactor licensees evaluate their facilities using guidance provided by the staff, and include in their Contingency Plans short term actions that could be taken to protect against attempted radiological sabotage involving a land vehicle bomb if information becomes available indicating that a credible threat exists.
Copies of briefing slides'used by the staff to guide their presentation and the discussions at this meeting are attpched (Attachment 1).
o BACKGROUND 1.
The package submitted initially by the staff for CRGR review in this matter was transmitted by memorandum dated January 9,1989, J. H. Sniezek to E.L. Jordan; that package included the following documents:
Draft Commission Paper, undated, " Power Reactor Contingency Planning a.
for a Possible Land Vehicle Bomb in the Event Such a Threat Arises",
and attachments as follows:
i.
Draft Generic Letter, undated, " Power Reactor Safeguards Contingency Planning for Surface Vehicle Bombs" ii.
SAFEGUARDS INFORMATION: " Characteristics of a Land Vehicle Bomb for Purposes of Safeguards Contingency Planning" iii. NUREG/CR-5246, "A Method to Assist in Contingency Planning for Protection of Nuclear Power Plants Against Land Vehicle Bombs" iv.
Backfit Analysis, " Contingency Planning for Land Vehicle Bomb" v.
Memorandum dated June 16, 1988, S.J. Chilk to V. Stello, "SECY-88-187 - Contingency Planning to Counteract Possible Land Vehicle Bomb" vi.
SECY-88-127, dated May 10, 1988, " Contingency Planning to Counteract Possible Surface Vehicle Threat" b.
" Supplemental Information" (provided in accordance with Section IV.B. of the CRGR Charter) 2.
At Meeting No. 156, the staff provided directly to CRGR members additional background material and revised portions of the review package submitted earlier, as follows:
a.
Revised draft Commission Paper (Item i. above).
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b.
Revised pages 2 and 3 of the proposed Generic Letter (Item 1.a.
above).
c.
Memorandum dated January 18, 1989, R.F. Burnett to B.K. Grimes,
" Circumstances =for Implementation of Licensee Short-Term Contingency Plan for Vehicle Bomb Threat."
d.
Letter-dated January 19, 1989, L.W. Zech to Congressman Gejdenson, responding to December 13, 1988 l ette r.-
e.
" Appendix C - Licensee Safeguards Contingency Plans" (as published in the Federal Register).
Documents 2.a through 2.d are attached to these Minutes (Attachment 2).
CONCLUSIONS / RECOMMENDATIONS The. Committee noted that the staff's finding in this matter (i.e., that the proposed action could provide a subtantial increase in the overall protection of the public health and safety, if a truck bomb threat should develop) is not a proper statement of the requisite finding under the Backfit Rule needed to justify the proposed action.
In fact, owing to that provisional / conditional statement of the " perceived danger" in this case, it does not appear that the proposed action can be justified in a straightforward manner in accordance with the provisions of 10 CFR 50.109.
However, the Committee also took note of the fact that the Commission has made the basic policy decision that power reactor licensees should take into account a possible vehicle bomb threat in their Safeguards Contingency Plans.
In that context, the Committee concluded that the staff has taken an acceptable approach to implementing that Commis-sion decision; and the Committee recommended in favor of issuing the proposed Generic Letter, subject to several modifications that will make clearer the basis for the backfits being imposed, and make available to licensees more cost effective means of achieving the objectives of this action:
1.
The staff should include in the proposed Generic Letter a simpler alterna-tive method that licensees can use (in lieu of the NUREG/CR-5246 methodolgy provided in the current version) to determine the location of the protective perimeter that is to be established on short notice around their facilities.
The Committee suggested specifically that the staff develop, and provide with the proposed Generic Letter, a table of acceptable " standoff distances",
corresponding to the amount of explosive specified Background Information Item 1.a.ii. above, for a variety of typical plant buildings / structures, construction materials, wall dimensions, etc., which licensees could apply easily and directly to existing drawings of site / building arrangements to generate the protective envelope for their facilities.
1 2.
The Backfit Analysis should be revised to reflect: (a) that the Generic Letter actions are specified pursuant to a Commission decision that it is prudent for licensees to take into account now in their contingency planning a truck bomb threat, and (b) although the proposed actions have not been justified in accordance with 50.109 criteria, they have been evaluated in the standard 50.109 format to better assure that cost benefit...
considerations are taken into account to the extent possible to minimize the impact of these actions.
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3.
Change the third sentence of the last pargraph on page 3 of the Generic Letter to read as follows:
"Where a licensee elects to do more rigorous analysis..."
All changes to the proposed package should be coordinated with the CRGR staff.
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CONTINGENCY PLANNING FOR LAND VEHICLE BOMB I
JUNE 16, 1988 STAFF REQUIREMENTS MENORANDUM APPROVED:
' DEVELOPMENT OF GENERIC CONTINGENCY PLANS FOR POWER REACTORS FOR USE BY THE NRC STAFF IN THE EVENT THAT A VEHICLE BOMB THREAT ARISES (ACTION-AE00-FEB.28,1989)
A REQUIREMENT FOR POWER REACTOR LICENSEES TO DEVELOP SHORT RANGE CONTINGENCYPLANS(ACTION-NRR-JAN. 31,1989)
THE STAFF SHOULD COMPLETE REVIEW OF THE ISSUES RELATED TO THE WATER '
BORNE VEHICLE BOMB AND PROVIDE A PAPER TO THE COMMISSION (ACTION-NRR-DUE MARCH 31,1989)
EROPOSEDREGULATORYAPPROACHFORLICENSEECONTINGENCYPLANNING NO CHANGE IN DESIGN BASIS THREAT FOR RADIOLOGICAL SAB0TAGE NO CHANGE IN SAFEGUARDS REQUIREMENTS FOR PROTECTION OF POWER REACTORS BASE REGULATORY ACTION ON CONTINGENCY PLANNING RULE (PART 73, APPENDIX C)
ISSUE GENERIC LETTER TO POWER REACTOR LICENSEES EXPANDING " PERCEIVED DANGER" FOR CONTINGENCY PLANNING ONLY TO INCLUDE SURFACE VEHICLE BOMB GIVE GUIDANCE TO LICENSEES (NUREG/CR-5246) 1 EMPHASIZE SHORT-TERM SAFEGUARDS AND/0R OPERATIONAL CONTINGENCY MEASURES DESCRIBE CHARACTERISTICS OF VEHICLE BOMB FOR LICENSEE USE IN CONTINGENCY PLANNING (PROTECTED AS SAFEGUARDS INFORMATION )
L NO NEED FOR NRC LICENSING REVIEW AND APPROYAL [10 CFR 50.54(p)]
LICENSEE PLANS AND PROCEDURES SUBJECT TO INSPECTION AFTER SIX MONTHS WITH EXISTING NRC RESOURCES 1.
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Generic Letter 3 l
Pursuant to 10 CFR Part 73, Appendix C, safeguardt contingency implementing procedures need not be submitted to the Commissicn for approval but will be subject to inspection by the NRC staff commencing approximately 6 months from the date of this letter. If land vehicle bomb considerations require changes in existing contingency plans, licensees may make them in accordance with 10 CFR 50.54(p)(2). Such changes will not require specific NRC approval unless they could decrease the effectiveness of existing contingency plans.
A power reactor licensee is required by 10 CFR 73.55(a) to establish and main-tain an onsite physical protection system and security organization that will provide a high degree of protection against the design-basis threat of radio-Icgical sabotage as stated in 10 CFR 73.1(a). The design-basis threat in 10 CFR 73.1(a) includes the possibility of a determined violent external assault by several persons. The Comission has concluded that the current design-basis threat for radiological sabotage continues to be adequate and appropriate for establishing and maintaining onsite physical protection systems.
Accordingly, the consideration of a land vehicle bomb is pertinent only to safeguards _ contingency planning and does not imply any neeo to alter physical protection systems established under 10 CFR 73.55 for licensed power reactors.
This contingency planning is for temporary measures that licensees would be expected to have implemented within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of a warning notice from the NRC.
This effort will result in an increase in the overall protection of the pubife health and safety and the common defense by ensuring that power reactor licensees are prepared to take short-term measures to protect against a land vehicle bomb l
if such a threat develops. The Comission believes that the costs of contingency planning for protection against a land vehicle bomb are justified in view of this increased preparedness.
ENCLOSURE 1 Abd ~cb 7 50 %ck n L
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Pursuant to 10 CFR 50.54(f), within 180 days from the date of receipt of this generic letter all addressees must confirm in writing that they have included in their safeguards contingency planning short-term actions that could be taken to protect against attempted radiological sabotage involving a land vehicle bomb if such a-threat were to materialize. This information is to be provided under oath'or affirmation and is necessary to enable the Comission to determine
.whether or not your license should be modified, suspended, or revoked. This information is necessary to verify compliance with the current licensing basis for your facility. This report shall be addressed to the U.S. Nuclear Regulatory l
Comission, ATTN: Document Control Desk, Washington, D.C.
20333.
This request is covered by Office of Management and Budget Clearance Number 3250-0011, which expires December 31, 1989. Where plant systems, structures, I
layout and topography are amenable to simple analysis the average burden for the requested contingency planning is estimated to be in the range of l
350 to 500 man-hours per licensee response, including assessment of the new requirements, searching data sources, gathering and analyzing the data, and preparing the required records. Where a licensee must do more rigorous analysis, several thousand man-hours could be required. Coments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of Management and Budget, Room 3208, New Executive Office Butiding, Washington, D.C.
20503, and to the U.S. Nuclear Regulatory Comission, Records L
and Reports Management Branch Office of Administration and Resources Management, Washington, D.C.
20555.
Steven A. Varga Acting Associate Director for Projects Office of Nuclear Reactor Regulation l
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ENCLOSURE 1 l
For:
The Commissioners From:
Victor Stello, Jr.
Executive Director for. Operations
Subject:
POWER REACTOR CONTINGENCY PLANNING FOR A POSSIBLE LAND
\\EHICLE B07:B IN THE EVENT SUCH A THREAT ARISES
Purpose:
To report on staff actions in response tn item 3 in the Secretary's memorandum of June 16, 1988 (Enclosure 5),
approving a requirement for power reactor licensees to develop short-range contingency plans for use in the I
event that a credible lano vehicle bomb threat arises.
(The two other staff actions in the June 16, 1968 memorandum will be addressed in subsequent Commission papers.)
Eackground:
Following incidents in the Middle East involving terrorist use of explosive-laden vehicles as bombs, the NRC staff provided the Conmission with its reconnendations cn responding to such a threat at nuclear power plc.nts in two Commission papers: SECY-86-101, dated March 31, 1986, and SECY-86-101A (Confidential), dated June 12, 1986, both entitled " Design-Basis Threat - Options for Considerations."
The staff further provided the Commission with a range of options for counteracting a surface vehicle threat in SECY-58-127 (Limited Distribution), dated May 10, 1968 (Enclosure 6).
The Conmission decided that it would not be necessary(10 CFR 73.1[a][1])gn-basis threat for radiological to change the desi sabotage ror to require long-range planning by power reactor licensees for permanent protection measures against land vehicle bombs. Pcwever, as a matter of prudence, the Commission approved development of NRC and l
licersee contingency plans for dealing with a possible land vehicle bomb threat to power reactors, should one arise.
CONTACT: Brian K. Grimes, NRR/DRIS 492-0903
The Commissioners Discussion:
Regulatory Approach 10 CFR 50.34(d) requires that each application for a license to operate a nuclear power reactor include a safeguards contingency plan. Such a plan, prepared in accordance with
._10 CFR Part 73, Appendix C, identifies and defines "the perceived dangers and incidents with which the plan will deal and the general way it will handle these." The plan should contain a statement of perceived danger conforming with that published by the Commission. For this purpose, Appendix C indicates that the design-basis threat in 10 CFR 73.1(a) "or subsequent Commission statements will suffice."
Accordingly, for the purpose only of safeguards contingency planning for licensed power reactors, the staff will inform licensees that the statement of perceived danger should
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include the threat of a land vehicle bomb. Enclosure 1 is a draft generic letter conveying this position. Enclosure 4 is a backfit analysis for this proposed action.
Implementing Contingency Planning The draft generic letter makes clear that this " statement of perceived danger" is pertinent only to safeguards contingency planning. The draft generic letter also explains that this planning is only for temporary short-term measures to be imple-mented in n ;..ugacy er in response to a warning notice from the NRC.
It does not affect the design-basis threat in 10 CFR 73.1(a) and does not imply any need to alter physical protection currently required by 10 CFR 73.55.
In accordance with existing regulations, the necessary changes to contingency plans and procedures need not be submitted for NRC approval before implementation.
Implementing plans and procedures will be subject to inspection by the NRC staff commencing approximately 6 months from the date of the generic letter. These inspections can be absorbed in the NRC inspection program with no increase in resources.
Guidance for Licensees Possible characteristics of a land vehicle bomb, for purposes of contingency planning} will be provided to licensees in an attachment (Enclosure 2 to the generic letter controlled as Safeguards Information (as defined in 10 CFR 73.21).
These planning characteristics are based on a staff review that included an exchange of information with cognizant Federal agencies and a review of data on 194 land vehicle bomb events worldwide.
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The Commissioners NUREG/CR-5246, "A Methodology to Assist in Contingency Planning for Protection of Nuclear Power Plants Against Land Vehicle Bombs" (Enclosure 3), will be forwarded with the generic letter to assist licensees in the required planning.-
NUREG/CR-5246 provides a methodology and illustrative guidance to licensees regarding analysis and planning for a possible land vehicle bomb contingency. Licensees following the methodology of NUREG/CR-5246 would be expected to:
(1)
Identify system options available to establish and maintain safe shutdown conditions.
(2) Identify buildings containing components and equipment associated with each system option.
(3) Determine " survivability envelopes" fo; the system options.
(4) Review site features to determine land vehicle access approach paths and distances.
(5)
Identify short-range measures to limit or thwart vehicle access and protect and preserve preferred system options.
(6) Prepare plans and make advance arrangements to facilitate the short-range contingency measures in the event a land vehicle bomb threat arises.
NUREG/CR-5246 does not contain any Safeguards Information..
However, site-specific analyses and associated safeguards contingency planning documents developed by licensees based on NUREG/CR-5246 guidance will likely contain Safeguards Infomation requiring protection in accordance with 10 CFR 73.21.
Short-range planning for security actions could incluoe such items as advance arrangements to facilitate rapid emplacement of emergency temporary vehicle barriers to limit and centrol land vehicle access.
Planning should also consider :,hort-range operational measures to ir. crease plant readiness in the event of a credible plant-specific land vehicle bomb threat.
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- The Commissioners The Office of General Counsel has reviewed this paper and has no legal objection.
Recommendations: That the Commission:
Note that, if the Commission does not object, the staff wiTT issue a generic letter to initiate short-range contingency planning by power reactor licensees for emergency temporary measures to be implemented in the event that a credible surface vehicle bomb threat arises.
Victor Stello, Jr.
Executive Director for Operations
Enclosures:
1.
Draft Generic Letter to All Power Reactor Licensees and Applicants 2.
Characteristics of Perceived Danger for Contingency Planning Purposes (SAFEGUARDS IllFORMATION) 3.
NUREG/CR-5246, "A Methodology to Assist in Contingency Planning for Protection of Nuclear Power Plants Against Land Vehicle Bombs" 4.
Backfit Analysis 5.
Memorandum from Samuel J. Chilk, "SECY-88-127 - Contingency Planning to Counteract Possible Surface Vehicle Threat," June 16, 1988 6.
SECY-88-127, " Contingency Planning to Counteract Possible Surface Vehicle Threat," May 10, 1988 4
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