EXAMINATION OF SECURITY EVENTS AS DBEs FOR MGDS IMPORTANT TO SAFETY SSCs

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) performed 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 identification 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 fuel 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 important to safety SSCs for the MGDS. The MGDS is a first of a kind geologic repository and no licensing precedent has been established for this type of facility