NRC Generic Letter 89-07, Power Reactor Safeguards Contingency Planning for Surface Vehicle Bombs

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April 28, 1989

TO: ALL LICENSEES OF OPERATING PLANTS, APPLICANTS FOR OPERATING LICENSES, AND HOLDERS OF CONSTRUCTION PERMITS


SUBJECT: POWER REACTOR SAFEGUARDS CONTINGENCY PLANNING FOR SURFACE VEHICLE BOMBS (GENERIC LETTER 89-07)

Each application for a license to operate a nuclear power reactor is required by 10 CFR 50.34(d) to include a licensee safeguards contingency plan in accor-

dance with the criteria set forth in Appendix C to 10 CFR Part 73. Each plan identifies and defines the perceived dangers and incidents that it covers and the general way in which they should be handled. In accordance with 10 CFR 73, Appendix C, Section 1.a., the statement of perceived danger should conform with that issued by the U.S. Nuclear Regulatory Commis-sion.

Recognizing terrorist use of explosive-laden vehicles as bombs, particularly in the Middle East, the Commission concluded it would be prudent to have power reactor licensees include in their safeguards contingency plans short-term actions to protect against attempted radiological sabotage involving a land vehicle bomb if such a threat were to materialize. Accord-ingly, for the sole purpose of safeguards contingency planning for licensed power reactors, the perceived danger should include a land vehicle bomb with the characteristics described in a Safeguards Information addendum to this letter. The addendum is being forwarded separately with a copy of this generic letter to nuclear power reactor addressees authorized to receive Safeguards Information in accordance with 10 CFR 73.21.

Each power reactor licensee is required by 10 CFR 50.54(p)(1) to prepare and maintain safeguards contingency plan procedures in accordance with Appendix C to 10 CFR Part 73. In response to this letter, licensees should modify their safeguards contingency procedures to address the possibility of a land vehicle bomb. The following approach to developing these contingency procedures would be acceptable:

1. Determine safe standoff distances for vital equipment. (The Safeguards Information addendum to this letter provides guidance on standoff dis-tances).

2. Review site features to determine land vehicle access approach paths and distances.

3. Identify short-range measures which could be implemented within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after notification by NRC to protect against unauthorized vehicle access closer than safe standoff distances.

4. Prepare plans and make advance arrangements to facilitate the short-

range contingency measures in the event a land vehicle bomb threat arises. The NRC will notify licensees in the event that the threat level changes in a manner which warrants implementation of these contingency measures.Generic Letter 89-07April 28, 1989

A contractor report, NUREG/CR-5246, will be forwarded with the Safeguards Information addendum. It is being provided for your information and use as you see appropriate in performing analyses to develop contingency procedures for vehicle bombs. Please note that although NUREG/CR-5246 does not contain any Safeguards Information, site-specific analyses and associated safeguards contingency planning documents prepared by licensees would be expected to contain Safeguards Information and require protection in accordance with 10 CFR 73.21.

Pursuant to 10 CFR Part 73, Appendix C, safeguards contingency implementing procedures need not be submitted to the Commission for approval but will be subject to verification by the NRC staff commencing approximately six 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-

logical 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 Commis-sion 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 need to alter physical protection systems established under 10 CFR 73.55 for licensed power reactors.

To the extent that a credible land vehicle threat could develop in the future, this effort would result in an increase in the overall protection of the public health and safety and the common defense and security by ensuring that power reactor licensees are prepared to take short-term measures to protect against such a threat. The Commission believes that the costs of contingency planning for protection against a land vehicle bomb should the threat level increase are justified in view of this increased preparedness.

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 Commission 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 Commission, ATTN: Document Control Desk, Washington, D.C. 20555.

.Generic Letter 89-07April 28, 1989

This request is covered by Office of Management and Budget Clearance Number 3150-0011, which expires December 31, 1989. Where plant systems, structures, layout and topography are amenable to simple analysis the average burden for the requested contingency planning is estimated to be in the range of 350 to 500 man-hours per licensee response, including assessment of the new requirements, searching data sources, gather-ing and analyzing the data, and preparing the required records. Where a licensee chooses to do more rigorous analysis, several thousand man-hours could be required. Comments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Paperwork Reduction Project (3150-0011), Office of Management and Budget, Washington, D.C. 20503, and to the U.S. Nuclear Regulatory Commission, Records and Reports Management Branch, Office of Information Resources Management, Washington, D.C. 20555.

James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation

Enclosure:

Listing of Recently Issued NRC Generic Letters