ML063310385

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Comment (1) Submitted by Ryan Pettus on Proposed Rules Pr 50, 72 and 73 Regarding Power Reactor Security Requirements
ML063310385
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 11/27/2006
From: Pettus R
Southern California Edison Co
To:
NRC/SECY
Ngbea E S
References
71FR62663 00001, PR-50, PR-72, PR-73
Download: ML063310385 (2)


Text

PR 50, 72 and 73 DOCKETED 11/27/06 (71FR62663)

Comment No. 1 From:

<Ryan.Pettus@sce.com>

To:

<SECY@nrc.gov>

Date:

Mon, Nov 27, 2006 5:00 AM

Subject:

Comments: 3150-AG63 I would like to submit the following comments for the proposed changes to the Power Reactor Security Requirements:

73.2 Definitions for enhanced weapons should include remote operated weapons. There is some pressure to regulate remotely operated weapons and rules may be set soon prohibiting these weapons. Some sites already implement these weapons to defend against a larger attacking force without having to expand the number of security armed responders. Concussion type devices, commonly referred to as "flash bags" should also be covered by this proposed rule as a significant addition the armed responders available equipment. There may be a need for armed responders to aggressively move through enclosed areas to interpose themselves at a vital target set, these enclosed areas my be occupied by adversaries and concussion type devices would help the responders.

73.55(b)(2) The proposed language to "detect, assess, intercept, challenge, delay, and neutralize...) The consideration to the language of "intercept would be the act of placing a person at an intersecting defensive position..." I believe this limits the licensee from employing futuristic and mechanical solutions to trap an adversary force. As a cost saving concept I would imagine the future implementation of man-traps, or other electronic/ mechanical means.

73.55(e)(6)(v) The level of the bullet-resisting barrier should be defined. A common definition used is the National Institute if Justice (NIJ) standards. A good recommendation for the control room envelope would be at least NIJ level IV bullet resistance.

Ryan Pettus Lead Nuclear Security Officer San Onofre Nuclear Generating Station Cell 951-505-3658 ryan.pettus@sce.com CC:

<ryan.pettus@sce.com>

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Comments: 3150-AG63 Creation Date Mon, Nov 27, 2006 4:59 AM From:

<Ryan.Pettus@sce.com>

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