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.