ML20247L585
| ML20247L585 | |
| Person / Time | |
|---|---|
| Issue date: | 04/26/1988 |
| From: | Erickson B NRC |
| To: | Partlow J NRC |
| Shared Package | |
| ML20245D207 | List:
|
| References | |
| FRN-54FR19379, RULE-PR-170, RULE-PR-50, RULE-PR-72 AC76-1-17, NUDOCS 8906020209 | |
| Download: ML20247L585 (1) | |
Text
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p, UNITED STATES NUCLEAR REGULATORY COMMISSION
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% ***** } APR 2 61988
'ji NOTE FOR: Jim Partlow ;;
FROM: Bob Erickson We have reviewed the enclosed memorandum from NMSS to.RES regarding a proposed rule for storage of spent nuclear fuel in NRC-approved storage casks at nuclear power reactor sites. We agree with the concept of a general licensee for cask storage at licensed nuclear power reactors. However, we have concerns regarding
'the proposed security requirements proposed by NMSS which are described as "a subset of the overall protection requirements currently in force at every opera-ting nuclear power reactor." We support the concept of a general license to allow cask storage in protected areas at licensed reactor sites in accordance with existing NRC-approved security plans. However, the NMSS proposal would allow the reactor licensee to use a separate security organization to protect the storage casks which raises a question about integrated command and control.
We consider it essential that cask storage under the general license not degrade physical security of vital equipment at the power reactor. This is partially addressed by NMSS in their proposed 73.53(a)(2) by requiring that the security j organization be staffed to simultaneously carry out the requirements of 73.53 and armed response requirements of 73.55(h)(3). However, we prefer a broad statement that existing protection of vital equipment not be degraded.
Finally, the general licensee should not impose new or more restrictive require-ments on reactor licensees,'since the public health and safety risks involved
> in cask storage are less than those involved in operating the reactor. Neverthe-less, the NMSS proposal appears to involve backfitting of power reactor security programs in several areas, including the following: requiring new weapons train- ,
ing requirements including night firing qualification of guards; requiring pro-tected area intrusion detection systems to be volumetric; requiring that respond-ing guards interpose themselves between the protected area and any adversary attempting entry (this could be accomplished only by placing the intrusion detec-tion system a considerable distance outside the protected area); and requiring licensees to submit security plan amendments to the NRC for approval (see foot-note to Appendix G).
. 1 We intend to discuss these concerns with NMSS staff. Bob Dube is taking the lead for us.
Bob Erickson cc: W. Brach, NMSS l J. Stone, NRR i J. Telford, RES/RDB
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Enclosure:
As stated 8906020209 890526 PDR PR . fl 50 54FR19379 PDR .
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