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"Power Reactor Safeguards Contigency Planning For Surface Vehicle Bombs" (Generic Letter 89-07, Supplement 1)
August 21, 1989 TO: ALL LICENSEES OF OPERATING PLANTS, APPLICANTS FOR OPERATING LICENSES, AND HOLDERS OF CONSTRUCTION PERMITS SUBJECT: SUPPLEMENT 1 TO GENERIC LETTER 89-07, "POWER REACTOR SAFEGUARDS CONTINGENCY PLANNING FOR SURFACE VEHICLE BOMBS" On April 28, 1989, the NRC staff issued Generic Letter 89-07 which requested power reactor licensees to modify their safeguards contingency procedures to address the possibility of a land vehicle bomb, if such a threat were to materialize. Several telephone requests for additional information have been received from affected licensees. The purpose of Enclosure 1 to this supplement is to share the responses to these requests. No additional burden or response is required by this supplement, which is intended only as clarification of the original request. This supplement is not expected to affect the date by which affected licensees must provide con- firmation that they have modified their safeguards contingency planning. James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosures: 1. Clarification of Vehicle Bomb Generic Letter 2. Listing of Most Recently Issued NRC Generic Letters Technical Contact: Barry Mendelsohn, NRR (301) 492-3207 8908210212 . Enclosure 1 Clarification of Vehicle Bomb Generic Letter 1) QUESTION In response to a specific threat to our plant, we have plans to dig a ditch across our plant access road at a choke point and to park a truck across the road; but we wouldn't be able to keep this road blocked indefinitely because it is needed for plant operation and maintenance. Does the generic letter require plans for a more permanent protective measure? ANSWER No. Generic Letter 89-07 does not require licensees to plan for permanent measures against vehicle bombs. Plans for short-range temporary measures that could be implemented within 12 hours after notification would be responsive to the generic letter. These could include ditches to temporarily bar all land vehicular traffic. 2) QUESTION We can block our roads without difficulty, but we are concerned that an off-road vehicle would be able to get around these blocks. Do we have to plan to block such a vehicle too? ANSWER Yes. Commercially available four-wheel-drive, off-road vehicles, within the bounds of the vehicle characteristics provided in the Safe- guards Information Addendum to Generic Letter 89-07, should be considered if the licensee believes that the characteristics of its sites make it prudent to consider such capabilities. (Military type tracked vehicles need not be considered.) Although typical four-wheel-drive vehicles are smaller, GMC Trucks sells a four-wheel-drive, dual rear wheel truck with 11,000 lb. gross vehicle weight and 8,000 lb. payload capacity. 3) QUESTION Do you have any guidance on the dimensions of a ditch that would be necessary to block a vehicle with the characteristics defined in the Safeguards Information Addendum? ANSWER Sandia National Laboratories, SAND 85-0935 (NUREG/CR-4250), "Vehicle Barriers: Emphasis on Natural Features," July 1985, contains information that licensees may find beneficial for planning emergency construction of ditches as barriers, as well as in estimating the value of natural terrain and soil conditions for restricting off-road vehicles. 4) QUESTION Our terrain is completely flat and isolated, and there are no convenient choke points on our property. There aren't enough trucks in the area that we could borrow to use as temporary barriers. We could install some concrete posts on which to string cables as barriers should a need arise, but that would involve an immediate capital expense. That doesn't seem to jibe with the guidance that only paper plans are needed in response to the generic letter. ANSWER You are correct. Changes in physical plant are not required. The generic letter is principally intended to elicit creative and innovative thinking and planning by licensees that capitalizes upon the unique features and characteristics of each site and environs. In that regard, your flat and isolated terrain may make it possible for you to readily detect and intercept a vehicle before it can get close to your plant during a period of alert following a warning from the NRC. Moreover, it is not essential that plans be limited to what a licensee can do on licensee property. You may wish to discuss with your local law enforce- ment authority what road block assistance they could offer in this . contingency. Again, each site is unique and will require thoughtful consideration of site-specific features and characteristics in its contingency planning. 5) QUESTION We are going to rebuild our CAS for other reasons. The CAS is a vital area and the generic letter suggests determining safe standoff distances for all vital equipment. The CAS building we had planned would not have had the same standoff distance as our plant safety related structures. Must we go to the expense of constructing the new CAS with blast hardening features? ANSWER No. Specific requirements for the CAS are contained in 10 CFR 73.55(e)(1), which are not changed by Generic Letter 89-07. Contingency planning for protection against a vehicle bomb is principally concerned with protecting plant operations and safety systems from unacceptable damage. Accordingly, this contingency planning should focus upon systems essential to maintain the plant in a safe condition. 6) QUESTION Instead of the safety-related equipment subject to NRC's seismic criteria, our approved security plan designates as vital an alternate set of safe-shutdown equipment. However, after reviewing our plant layout and topography, we conclude that our contingency planning for a surface vehicle bomb would be most effective if it focused on basic safety-related equipment instead of our alternate safe-shutdown equipment. Would this be acceptable? ANSWER Yes. For purposes of vehicle bomb contingency planning, equipment to be protected to provide a safe shutdown capability need not be re- stricted to equipment that is designated as vital in the licensee's security plan. The important thing is to address vital safety functions such as: o Reactivity control o Reactor core cooling and heat removal from the primary system o Reactor coolant system integrity o Containment integrity o Radioactivity control For more detailed discussion see NUREG/CR-5246, "A Methodology to Assist in Contingency Planning for Protection of Nuclear Power Plants Against Land Vehicle Bombs". 7) QUESTION Our new reactor does not yet have an approved security plan. We think the methodology of NUREG/CR-5246, which was distributed with the generic letter, would give results similar to application of the vital equipment guidelines of NUREG-1178. We recognize that the generic letter does not require use of NUREG/CR-5246, but if we went to the expense of performing such a detailed analysis could we use its results also for our vital equipment designations? ANSWER No. Vital equipment is defined in 10 CFR 73.2 and further clari- fied in Review Guideline 17. NUREG-1178 is an internal staff report to the NRC that has not been implemented and is still being reviewed. 8) QUESTION We were sent the generic letter because we have an operating reactor; however, it is a non-power reactor and the subject of the generic . letter is power reactors. Must we respond in writing as requested of all addressees? ANSWER No. The generic letter was erroneously addressed to "all licensees of operating plants;" however, it was authorized to apply to power reactors only. Non-power reactor licensees need not provide a response. 9) QUESTION We have a reactor that's not yet licensed for operation. The generic letter requires a response within 180 days from receipt of the letter. Can we wait till we submit our security and contingency plans? ANSWER Yes. It would be appropriate to include contingency planning for a land vehicle bomb when you submit your contingency plan in compliance with 10 CFR 50.34(d). At that time the plan's statement of perceived dangers should include a land vehicle bomb with the characteristics described in the Safeguards Information Addendum to Generic Letter 89-07. 10) QUESTION We didn't receive the Safeguards Information Addendum until several weeks after receipt of the basic generic letter. Although we should not have any difficulty completing our planning in time, we want to understand when the 180 day clock starts for our written response. ANSWER The clock started when you received the final part of the generic letter, which was the Safeguards Information Addendum. You may wish to make a note of when that occurred. Although in a couple of cases there was some problem with the mail, each power reactor licensee should have received its copy by now.
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