EXAMINATION OF SECURITY EVENTS AS DBES FOR MGDS IMPORTANT TO SAFETY SSCS
PURPOSE A portion of the safeguards and security system for the Mined Geologic Disposal System (MGDS) has been identified as QA-1 based on the classification of structures, systems, and components (SSCs) perfomed in accordance with QAP-2-3, Classification of Permanent Items (Reference 5.2). The classification analysis, Classification of the Preliminary MGDS Repository Design (Reference 5.9, identifies the 'Safeguards Material Control and Accountability' system as a QA-1 SSC based on the
... cation of unauthorized intrusion, sabotage, theft, and diversion as potential Design Basis Events (DBEs). The purpose of this analysis is to provide justification to eliminate these events as DBEs for the MGDS based on a review of the Codes of Federal Regulation (CFRs) for geologic repositories (10 CFR 60), commercial reactor facilities (10 CFR 50), independent spent fie1 storage installations (ISFSIs) and monitored retrievable storage (MRS) installations (10 CFR 72), and other relevant guidance documents in an effort to clarify that security events should not be considered in the QA design process of irnportant to safety SSCs for the MGDS. The MGDS is a h t of a kind geologic repository and no licensing precedent has been established for this type of facility. -.. 2.0 QUALITY ASSURANCE This analysis is performed in accordance with Quality Administrative Procedure QAP-3-9, Design Analysis (Reference 5.3) per Quality Administrative Procedure QAP-2-0, Conduct of Activities (Reference 5.1). Refer to the activity evaluation entitled 3-9 Analysis Supporting the QA Status of the MGDS Security System With Respect to Sabotage as a DBE (Reference 5.4). METHOD The rationale for-the QA classification of the MGDS Safeguards Material Control and Accountability system is presented to clarify the current QA-1 designation. 10 CFR 60 (Reference 5.8) for a geologic repository is reviewed to examhe the regulatory requirements for safeguards and security system. Regulatory requirements h r n 10 CFR 50 (Reference 5.7), 10 CFR 72 (Reference 5.9), and other guidance documents are also reviewed for licensing precedents established for safeguards and security systems at other types of nuclear facilities. From a review of these documents, two major arguments are presented to support the conclusion that u~uthorked intrusion, sabotage, theft., and diversion should not be considered as potential DBEs in the design of important to safety SSCs for the MGDS. Rationale h m each of the reviewed documents is presented to support this conclusion. DESIGN INPUTS Design inputs and requirements utilized in this analysis include requirements developed by the Nuclear Regulatory Commission (NRC), information developed by, and for, the nuclear industry, design codes and standards, and information developed by the Management and Operating Contractor (M&O) regarding design requirements. All tire summarized in the following sections.