Publication Date: 8/1/94
    Pages: 7
    Date Entered: 8/11/94
    Title: Protection Against Malevolent Use of Vehicles at Nuclear Power Plants
    U.S. NUCLEAR REGULATORY COMMISSION
    August 1994
    REGULATORY GUIDE
    OFFICE OF NUCLEAR REGULATORY RESEARCH
    REGULATORY GUIDE 5.68
    (Draft was issued as DG-5006)
    PROTECTION AGAINST MALEVOLENT USE
    PROTECTION AGAINST MALEVOLENT USE OF VEHICLES AT NUCLEAR POWER PLANTS
A. INTRODUCTION
    In the amended 10 CFR Part 73, Physical Protection of Plants and
    Materials, the new Section 73.1(a)(1) requires a licensee to protect
    against a determined violent external assault, attack by stealth, or
    deceptive actions by several persons using a four-wheel drive land
    vehicle for the transport of personnel and their hand-carried
    equipment to the proximity of vital areas. The new 10 CFR
    73.1(a)(1)(iii) requires licensees to protect against a four-wheel
    drive land vehicle bomb. In 10 CFR 73.55, "Requirements for Physical
    Protection of Licensed Activities in Nuclear Power Reactors Against
    Radiological Sabotage, the new 10 CFR 73.55(c)(7) requires a licensee
    to establish vehicle control measures, including vehicle barriers, to
    protect against the use of a land vehicle, as specified by the
    Commission, as a means of transportation to gain unauthorized
    proximity to vital areas. The new 10 CFR 73.55(c)(8) requires a
    licensee to compare the vehicle control measures established in
    accordance with 10 CFR 73.55(c) (7) to the Commission's design goals
    and criteria for protection against a land vehicle bomb. Also, 10 CFR
    73.55(c) (8) provides for a process to use alternative measures for
    protection against a land vehicle bomb, for example, for those
    licensees with a particularly difficult site configuration. These
    alternative measures must provide substantial protection against a
    land vehicle bomb and must be supported by a licensee analysis, using
    the essential elements of the criteria in 10 CFR 50.109, demonstrating
    that the costs of fully meeting the design goals and criteria are not
    justified by the added protection that would be provided. The
    alternative measures must be submitted to the Commission for approval.
    The rule does not apply to licensees who are in the process of
    decommissioning and have amended their operating licenses to
    possession-only status. The rule would apply to licensees who plan to
    decommission in the near future but do not have a possession-only
    license. The Commission would need to evaluate each of these licensees
    individually to determine whether an exemption from the rule is
    appropriate.
    The new 10 CFR 73.55(c) (9) requires licensees to submit to the
    Commission summary descriptions of their proposed control measures as
    required by 10 CFR 73.55(c) (7) and the results of their vehicle bomb
    comparison. The new 10 CFR 73.55(c)(10) pertains to applicants for a
    license to operate a nuclear power reactor.
    This regulatory guide is being developed to provide guidance
    acceptable to the NRC staff by which the licensee can meet the
    requirements of the amended 10 CFR 73.1(a)(1) and 73.55(c)(7), (8),
    (9). and (10). This regulatory guide will be used by licensees in
    conjunction with separate Safeguards Information that has already been
    provided to affected licensees, but this Safeguards Information is not
    available to the general public. Also available is NUREG/CR-6190,
    "Protection Against Malevolent Use of Vehicles at Nuclear Power
    Plants," Volumes 1 and 2, which provides acceptable measures to
    satisfy the requirements of this rule.
    Any information collection activities mentioned in this regulatory
    guide are contained as requirements in 10 CFR Part 73. which provides
    the regulatory basis for this guide. The information collection
    requirements in 10 CFR Pan 73 have been approved by the Office of
    Management and Budget, Approval No. 3150-0002.
    The public reporting burden for this collection of information is
    estimated to average 500 hours per response, including the time for
    reviewing instructions, searching existing data sources, gathering and
    maintaining the data needed, and completing and reviewing the
    collection of information. Send comments regarding this burden
    estimate or any other aspect of this collection of information,
    including suggestions for reducing the burden, to the Information and
    Records Management Branch (T6 F33), U.S. Nuclear Regulatory
    Commission, Washington, DC 20555-0001; and to the Desk Officer, Office
    of Information and Regulatory Affairs, NEOB-30 19 (3150-0002), Office
    of Management and Budget, Washington, DC 20503.
B. DISCUSSION
    MEASURES TO PROTECT AGAINST UNAUTHORIZED USE OF A LAND VEHICLE AS A
    MEANS OF PERSONNEL TRANSPORT
    Protection against use of a land vehicle as a means to gain
    unauthorized proximity to vital areas can be provided by establishing
    a continuous barrier system that encompasses vital areas of the
    facility. The features and structures that form the barrier system
    would need to be sufficient to stop the forward motion of a land
    vehicle with the design characteristics established by the Commission.
    These design characteristics have been provided to affected NRC
    licensees in a separate document that is Safeguards Information, and
    therefore is not available to the public.
    Since the protected area perimeter serves as an outer barrier to vital
    areas, one approach would be to establish the vehicle barrier
    contiguous with or in close proximity to the protected area perimeter.
    At many facilities, natural terrain features such as water barriers,
    steep cliffs, large rocks, or existing structures such as buildings or
    cooling towers located adjacent to the protected area would be well
    suited and may be linked with barriers to serve as part of the
    continuous barrier. As a matter of economy and convenience, the
    barrier system would likely include the present vehicle access points
    to the protected area. At these locations, active barriers that would
    allow controlled vehicle entry would need to be installed.
    Passive vehicle barriers are appropriate for these portions of the
    barrier system that are not needed for vehicle access. The passive
    barriers may make use of natural topographic features and structures
    provided these features, along with other segments of the barrier,
    provide a continuous vehicle barrier against land access to the
    facility's vital areas. In considering a barrier, natural features or
    devices that limit vehicle direction and speed also may be appropriate
    to simplify or reduce the performance required of the vehicle barrier
    system.
    Active vehicle barriers are appropriate for those portions of the
    barrier system that need to provide for vehicle access. Active vehicle
    barriers have two positions: one position that denies passage of a
    vehicle and a second position that allows passage. Barriers remain in
    the denial position to prevent entry and are moved to allow entry only
    after authorization for the vehicle has been confirmed.
    The energy-absorbing capability of various vehicle barriers and the
    speed-reducing capability of natural and man-made obstacles can be
    based on presently available test data developed for other Federal
    agencies or by national laboratories or barrier manufacturers. Much of
    the available data is included in the Safeguards Information that has
    already been provided to affected licensees. For vehicle barriers and
    obstacles for which test data are not available, licensees can perform
    engineering analyses to determine their effectiveness in stopping or
    slowing a vehicle.
    Access control measures for vehicles crossing the boundary of the
    established vehicle barrier system need to be sufficient to provide
    assurance that the vehicle is appropriately authorized and not
    transporting an explosive device. In addition to barriers, access
    control measures include required vehicle searches, personnel
    searches, and escorts (if necessary). It would be expected that, at
    most facilities, one active vehicle barrier would be established for
    at least one of the present protected area vehicle access points.
    Searches of vehicles for explosives, and other personnel access
    control measures that remain in effect for protected area entry, are
    rigorous and provide assurance against unauthorized vehicle entries.
    Vehicle searches may be conducted inside the vehicle barrier system
    (VBS) at previously established search points after proper
    authorization of the vehicle has been obtained. For barrier system
    layouts that have vehicle denial barriers located outside the
    protected area boundary, vehicle access control measures, including
    searching for explosives, would have to be provided for vehicles
    permitted access inside the barrier, even if the vehicle did not enter
    the protected area.
    Portions of the VBS located outside the protected areas should be
    periodically observed to identify damage, deterioration, or
    indications of tampering that impact the effectiveness of the barrier.
    These observations may be performed as part of routine security patrols.
    The NRC anticipates that vehicle barriers, particularly passive
    barriers, will normally remain functional once installed. For those
    infrequent cases of failure, any compensatory measures should take
    into consideration the type and cause of the problem and the time the
    barrier will be nonfunctional. For example, for short-term problems
    with active or passive barriers, compensatory measures would not be
    expected to be extensive. When barriers are nonfunctional for longer
    periods, appropriate compensatory measures may include placement of
    heavy vehicular equipment, placement of concrete highway median
    bounces in a serpentine fashion, installation of strands of airplane
    arresting wires, or positioning an officer armed with a high-power
    contingency weapon.
    MEASURES TO PROTECT AGAINST USE OF A VEHICLE AS A MEANS OF TRANSPORT
    OF AN EXPLOSIVE DEVICE
    The design goal for protection against explosive devices transported
    by a vehicle is to protect equipment, systems, devices, or material if
    its failure, destruction, or release of which could directly or
    indirectly endanger the public health and safety by exposure to
    radiation. Such equipment, systems, devices, or material are
    designated by licensees as vital equipment and are required by 10 CFR
    73.55(c)(1) to be located within vital areas. Vital areas in turn are
    required to be located inside protected areas. At many facilities the
    vital area barrier, which separates vital equipment from the protected
    area, is located at a considerable distance from the protected area
    barrier. Further, vital area barriers generally are quite substantial.
    These features, assuming the vehicle barrier system is located along
    or adjacent to the protected area barrier, provide substantial
    protection for vital equipment from an explosive blast. Many of the
    issues discussed in the previous section related to active and passive
    barriers apply to the protection against explosives.
    The effects of an explosive device diminish rapidly with distance. The
    distance of the structure or equipment from the explosive blast is
    referred to as "stand-off distance." If a vehicle is transporting an
    explosive device and the device is detonated at the vehicle barrier,
    the standoff distance would be that distance between vital equipment
    and the closest exterior point of the vehicle barrier system.
    Different vital areas have different standoff distances depending on
    the postulated locations of the vehicle barriers. Considering typical
    plant layouts and the placement of vehicle barriers at or adjacent to
    the protected area, vital area barriers at many facilities would be
    afforded sufficient protection against a relatively large explosive
    device.
    In addition to the protection afforded by distance from the blast,
    vital equipment at most sites is provided substantial protection by
    structures containing the equipment. Vital equipment is frequently
    located within seismic structures (often reinforced concrete walls)
    "Safe standoff" distance is the distance between vital equipment or a
    structure housing vital equipment and the point of detonation of the
    design basis threat bomb that would protect the equipment or equipment
    within the structure to a medium level of protection. Safe standoff
    distances can be determined by blast effect analyses that take into
    account the size of the explosive, the distance between the explosive
    and the affected structure, and the characteristics of the structure.
    These analysis techniques are described in the separate Safeguards
    Information document that has been sent to licensees. When the blast
    analysis shows that a vital area barrier structure would be damaged,
    further analysis may be able to demonstrate that vital equipment
    within the structure is not damaged. For example, the vital equipment
    may be located in a separate cubicle within the main structure that is
    unaffected by the analyzed blast damage to an outer wall or a roof. If
    the blast effect analysis indicates that the explosion could damage
    vital equipment, the ability to shut down and maintain the facility in
    a safe shutdown condition may be demonstrated by identifying
    alternative plant equipment that could serve the same safety function
    as the equipment analyzed as being damaged by the explosion. Also, it
    may be demonstrated that damage control measures can be taken that
    could support plant shutdown and maintain the plant in a safe shutdown
    condition.
    If the blast effects analysis demonstrates that vital equipment would
    be damaged, that alternative equipment is not available, and that
    damage control measures can not adequately support plant shutdown and
    maintaining shutdown conditions, other measures (in addition to those
    required to protect against the use of a land vehicle as a means of
    transportation to gain proximity to vital areas) may be needed. To
    fully meet the Commission's design goals and criteria for protection
    against a land vehicle bomb, additional measures that can be taken
    include (1) extending the vehicle barrier location out from those
    positions shown by the analysis that the barrier does not provide
    sufficient safe standoff distance for vital area structures from the
    explosive, (2) constructing structures that shield the vital area
    barrier from blast effects, (3) installing equipment to back up that
    equipment assumed to be damaged, or (4) interconnecting other systems
    to the damaged equipment.
    Certain security-related electric power supplies and the central alarm
    station are required by 10 CFR Part 73 to be protected within vital
    areas; however, in the absence of safety-related equipment necessary
    for plant shutdown, these vital areas need not be considered as areas
    needing protection in the licensee's analysis.
    ALTERNATIVE MEASURES TO PROTECTION AGAINST A VEHICLE BOMB
    As provided in 10 CFR 73.55(c) (8), under certain circumstances a
    licensee may propose measures other than those needed to meet the
    design goals and criteria specified for protection against a land
    vehicle bomb. This does not relieve the licensee of the requirement to
    protect against use of a vehicle to gain proximity to vital areas.
    Alternative measures developed by a licensee will be acceptable to the
    NRC staff if it can be demonstrated that they, along with measures
    that protect against vehicle intrusions, provide substantial
    protection against a land vehicle bomb and if the licensee
    demonstrates by an analysis, using the essential elements of 10 CFR
    50.109, that the costs of fully meeting the design goals and criteria
    are not justified by the protection added by these additional
    measures. These alternative measures must be approved by the NRC
    staff.
    Factors to be considered in assessing proposed alternative measures to
    protect against a vehicle bomb include:
    0 The characteristics (e.g., size, location, and mobility) of the
    vehicle bomb that the alternative measure would protect against.
    0 The percent of the perimeter that would be vulnerable to a design
    basis vehicle explosion.
    0 The amount of time that the reactor could be maintained in a safe
    condition if subjected to a design basis vehicle explosion at the
    most vulnerable portion of the barrier system.
    0 The licensee's severe accident management program.
    0 The off-site consequences of a design basis vehicle explosion at
    the most vulnerable portion of the barrier system.
    0 The cost difference between the proposed alternative measures and
    measures that would fully meet the design goals and criteria for
    protection against a vehicle bomb.
    The NRC's approval of the licensee's proposal for alternative measures
    will be based on the extent that the vehicle barrier system, including
    alternative measures added to enhance protection against a vehicle
    bomb, provides protection against a vehicle transporting an explosive
    device.
    Definitions
    The following are definitions of terms used in this guide.
    'Design Basis Threat Bomb': An explosive device with the TNT-
    equivalent force that is described to licensees in the separate
    Safeguards In formation.
    'Design Basis Threat Land Vehicle': A vehicle with design
    characteristics described to licensees in the separate Safeguards
    Information.
    'Design Goals and Criteria for Protection Against a Land Vehicle
    Bomb': The design goal is to protect equipment, systems, devices, or
    material, the failure, destruction, or release of which could directly
    or indirectly endanger the public health and safety by exposure to
    radiation. The criteria are the protection needed to protect against
    the design basis threat land vehicle and the design basis threat bomb.
    'Level of Protection': The degree of protection from a bomb blast that
    a structure provides to equipment housed inside the structure.
    'Safe Standoff Distance': The distance between vital equipment or a
    structure housing vital equipment and the point of detonation of the
    design basis threat bomb that would protect the equipment or equipment
    within the structure to a medium level of protection. A medium level
    of protection is afforded vital equipment when there is a low
    probability of damage to the equipment from an explosion occurring at
    the vehicle barrier.
    'Standoff Distance': The distance between vital equipment or a
    structure housing vital equipment and the closest exterior point of
    the vehicle barrier system.
    'Vehicle Barrier System (VBS)': A continuous barrier, which may
    include buildings, natural barriers, commercially available barriers,
    and any combination of these items, utilized to stop a land vehicle
    used as transportation to gain proximity to vital areas or used to
    transport a bomb.
C. REGULATORY POSITION
1. MEASURES TO PROTECT AGAINST
    UNAUTHORIZED VEHICLE INTRUSION
    A vehicle barrier system (VBS) that is capable of preventing forced
    access of a land vehicle to gain proximity to vital areas should be
    established at each nuclear power reactor site. The VBS should provide
    a perimeter around vital areas of the facility such that no location
    along the perimeter would permit forced entry of a land vehicle. The
    VBS, regardless of the type of barriers used, should be of a design
    capable of stopping the forward motion of the design basis land
    vehicle (DBV). The VBS may be incorporated as part of the protected
    area perimeter system but should not diminish or remove any
    requirements established for the protected area.
    1.1 Passive Barriers
    The passive barrier portion of the VBS may include natural terrain
    features such as steep cliffs and large rocks, alone or in combination
    with man-made structures or barriers, provided the overall
    effectiveness of the barrier at any point is capable of stopping the
    forward motion of the DBV. Man-made or natural features that limit
    the direction and speed of the DBV may be used in conjunction with a
    barrier design. The separate Safeguards Information, which has already
    been sent to affected licensees, provides design guidance that is
    acceptable to the NRC on the performance capabilities of barriers and
    specifications for measures that reduce vehicle speed.
    1.2 Active Barriers
    Access by vehicles to locations inside the VBS should be through
    active vehicle denial barriers that, in the denial position, are
    capable of stopping the forward motion of the DBV. Operational design
    features of the active barrier or barrier system, when allowing access
    for authorized vehicles, should be capable of preventing being
    bypassed and allowing access of unauthorized vehicles. A single
    active barrier may be used in conjunction with other vehicle control
    measures to ensure denial of an unauthorized vehicle. The separate
    Safeguards Information that was sent to affected licensees provides
    design guidance that is acceptable to the NRC on the performance
    capabilities of barriers and specifications for measures that reduce
    vehicle speed.
    1.3 Vehicle and Personnel Access Authorization Measures
    Vehicles and their operators should be authorized for entry prior to
    being permitted access inside the VBS. Vehicle authorization should
    also include confirmation that the vehicle has a legitimate purpose
    for entering the VBS. Authorization for the vehicle operator should
    include confirmation that the individual has a legitimate purpose for
    operating the vehicle inside the VBS. For VBS designs that are
    adjacent to the protected area boundary and whose active vehicle
    barrier access points are the same as the protected area vehicle
    access points, vehicle and personnel authorization measures for
    entering the protected area provide adequate authorization controls.
    1.4 VBS Description
    The security plan should contain an attachment that describes the VBS.
    The description should include site drawings that identify the VBS,
    the various components and combinations of components that compose the
    VBS, and access authorization measures for vehicle and personnel
    within the VBS.
2. MEASURES TO PROTECT VITAL AREAS AGAINST A LAND VEHICLE BOMB
    The new 10 CFR 73.55(c)(8) requires a licensee to compare the vehicle
    control measures established in accordance with 10 CFR 73.55(c)(7)
    with the design goals and criteria for protection against a land
    vehicle bomb specified by the Commission. The design basis bomb size
    is specified in the separate Safeguards Information that has already
    been provided to affected licensees.
2. 1 Blast Effect Analysis
    The comparison of vehicle control measures with the design goals and
    criteria for protection against a land vehicle bomb should consist of
    an analysis that establishes that the capability of vital equipment to
    maintain the plant in a safe condition is not lost as a result of a
    detonation of a design basis bomb at the VBS boundary. Depending on
    the VBS design and site-specific considerations, this comparison could
    result in a determination that the design goals and criteria for
    protection against a land vehicle bomb are satisfied at the conclusion
    of any one of the following measures.
    2.1.1 Screening Analysis
    This screening process determines whether a more detailed analysis of
    the effects of an explosive blast of the size of the design basis bomb
    is required.
    For each location along the VBS perimeter the standoff distance
    (distance between vital equipment or a structure housing vital
    equipment and the closest exterior point of the VBS) should be
    determined. Certain security-related electric power supplies and the
    central alarm station are required by 10 CFR Part 73 to be protected
    within vital areas; however, in the absence of safety-related
    equipment necessary for plant shutdown, these vital areas need not be
    considered as areas needing protection in the licensee's analysis.
    Licensees should determine whether the standoff distances for each
    location along the VBS provide a safe standoff distance. This
    determination should be made by an analysis that takes into account
    the size of the explosive; both reflective and side-on blast loads on
    walls, roofs, and supporting members; the distance between the
    explosive and the affected structure; and the characteristics of the
    structure. Vital equipment can be assumed to remain operational if the
    structure containing the equipment provides such a level of protection
    that there is a low probability of damage to the equipment from an
    explosion occurring at the vehicle barrier. The separate Safeguards
    Information that has already been provided to affected licensees
    specifies approaches acceptable for determining safe standoff
    distances.
    If vital area structures and equipment are found to be located at
    distances equal to or greater than the safe standoff distance, the
    design goals and criteria for protection against a land vehicle bomb
    are considered fully met and no further analysis is necessary.
    2.1.2 Detailed Analysis
    If the screening analysis described in Section 2.1.1 of this guide
    cannot establish that vital equipment would be protected from damage
    by detonation of the design basis bomb at any location along the VBS
    boundary, the analysis should then consider:
    (1) Whether any obstructions in the blast path would affect the level
    of protection provided to vital equipment. The analysis may
    incorporate the effects of natural typography that diminish the
    effects of the bomb blast effect. The analysis may also include
    an assessment of interior building designs (e.g., interior walls,
    supports) that may protect vital equipment even if the outer wall
    or structure is significantly damaged. The analysis should show
    whether or not the blast damage impacts the functional
    operability of the vital equipment.
    (2) Whether the plant can be shut down and maintained in a shutdown
    condition with equipment not damaged by the explosion. The
    evaluation may allow for damage control actions to mitigate the
    consequences of the explosion. These damage control actions
    should be included in applicable station operating procedures and
    referenced in the safeguards contingency procedures. In addition,
    the analysis should consider loss of off-site power, an
    assumption that is compatible with the basic premise that
    equipment not designated and protected as vital is vulnerable to
    damage and is not available.
    If the detailed analysis determines that all vital equipment remains
    functional or that the ability to shut down the facility and maintain
    it in a shutdown condition can be provided even with the loss of vital
    equipment identified in the screening analysis, the design goals and
    criteria for protection against a land vehicle bomb are considered
    fully met and no further analysis is necessary.
    2.1.3 Additional Protection Measures
    If the screening and detailed analyses determine that the design goals
    and criteria for protection against a land vehicle bomb cannot be
    fully met, a determination should be made concerning additional
    measures needed to fully achieve the design goals and criteria.
    Additional measures may include installing blast shields, changing
    planned vehicle barriers to extend standoff distances, strengthening
    current structures, or installing or relocating plant equipment or
    systems.
    If analysis of the effects of additional measures finds that vital
    equipment remains functional or that the ability to shut down and
    maintain the facility in a safe condition can be provided, the design
    goals and criteria for protection against a land vehicle bomb are
    considered fully met and no further analysis is necessary.
    As provided in 10 CFR 73.55(c)(8), the licensee may propose to the NRC
    additional measures other than ones needed to fully meet the design
    goals and criteria, provided this approach provides substantial
    protection against a vehicle bomb and it can be demonstrated that the
    costs of measures to fully meet the design goals and criteria are not
    justified by the added protection that would be provided. if so, the
    actions in Regulatory Position 2.2 should be taken.
    2.2 Alternative Measures To Protect Against Explosives
    As provided in 10 CFR 73.55(c)(8), a licensee may propose to the NRC
    additional measures other than the ones needed to meet the design
    goals and criteria, provided this approach provides substantial
    protection against a vehicle bomb and provided it can be demonstrated
    that the costs of measures to fully meet the design goals and criteria
    are not justified by the added protection that would be provided. This
    submittal should include:
    (1) The findings regarding the extent of the protection against a
    vehicle bomb provided by the vehicle control measures designed to
    meet the requirements of 10 CFR 73.55(c)(7). These findings
    should be expressed in explicit terms such as the size of
    explosive for which the measures provide protection and the
    locations along the barrier system perimeter where the design
    goals for protection against a vehicle bomb cannot be fully met.
    (2) A description and analysis of additional measures needed to fully
    meet the design goals and criteria for protection against a
    vehicle bomb. The description should include an estimate of the
    cost of the measures.
    (3) A description and analysis of additional measures, alternative to
    those needed to fully meet the design goals and criteria, that
    are proposed to be taken. The analysis should address the
    enhanced protection provided by the additional measures. The
    description should include an estimate of the costs of the
    measures.
    (4) A comparison of the costs of the measures described in (2) and
    (3) above and an assessment supporting a finding that additional
    costs of fully meeting the design goals and criteria are not
    justified by the added protection that would be provided.
3. DOCUMENTATION
    in accordance with 10 CFR 73.55(c)(9), each licensee authorized to
    operate a nuclear power reactor is required to submit to the
    Commission a summary description of the proposed vehicle control
    measures and the results of the vehicle bomb comparative analysis. The
    summary description should include identification of active and
    passive components of the VBS and any natural terrain features or man-
    made obstructions that complete the VBS. A site drawing or diagram
    that outlines the VBS should be included with the description. The
    results of the vehicle bomb comparative analysis should identify the
    basis for determining that the Commission's design goals and criteria
    for protection against a land vehicle bomb are fully met. When
    applicable, the results of the comparison should include damage
    control actions that must be taken and additional security measures
    taken to protect against the design basis bomb.
    Licensees whose comparative analysis determines that they do not fully
    meet the design goals and criteria for protection against a vehicle
    bomb and who propose alternative measures should submit the analysis
    and justification for the alternatives as specified in Regulatory
    Position 2.2.
    Details of the "as built" VBS and of the land vehicle bomb analysis
    should be maintained on site.
4. CONTINGENCY PLANNING FOR SURFACE VEHICLE BOMBS
    Once implemented, the control measures required to meet these
    amendments to Part 73 supersede contingency requirements initiated in
    response to Generic Letter 89-07, "Power Reactor Safeguards
    Contingency Planning for Surface Vehicle Bombs," of April 28, 1989.
    However, licensees whose vehicle control measures do not fully meet
    the NRC's design goals and measures may choose to maintain vehicle
    bomb contingency planning as one element of proposed alternative
    measures.
D. IMPLEMENTATION
    The purpose of this section is to provide information to licensees and
    applicants regarding the NRC staff's plans for using this regulatory
    guide. Except in those cases in which an applicant proposes an
    acceptable alternative method for complying with specified portions of
    the Commission's regulations, the methods described in this guide will
    be used in the evaluation of submittals in response to the amendments
    to 10 CFR Part 73.
    REGULATORY ANALYSIS
    A separate regulatory analysis has not been provided for this
    regulatory guide. The regulatory analysis that was prepared for the
    rule provides the basis for this regulatory guide and examines the
    costs and benefits of the rule as implemented by this guide. A copy of
    Regulatory Analysis for Malevolent Use of Vehicles at Nuclear Power
    Plants" is available for inspection and copying for a fee at the
    Commission's Public Document Room, 2120 L Street NW., Washington, DC,
    under Regulatory Guide 5.68.