ML080860489

Comment (4) of David P. Helker on Behalf of Exelon Generation and Amergen Supporting Draft Regulatory Guide DG-5015, Training and Qualification of Security Personnel at Nuclear Power Reactor Facilities.

ML080860489
Person / Time
Site:	Dresden, Peach Bottom, Oyster Creek, Byron, Three Mile Island, Braidwood, Limerick, Clinton, Quad Cities, Zion, LaSalle
Issue date:	03/13/2008
From:	David Helker AmerGen Energy Co, Exelon Corp, Exelon Generation Co, Exelon Nuclear
To:	Rulemaking, Directives, and Editing Branch
References
73FR2435 00004, DG-5015
Download: ML080860489 (4)

Text

AmerGem, An Exelon Company www.exeloncorp.com Exel1n. v AmerGen Energy Company, LLC Nuclear 4300 Winfield Road Exelon Generation Warrenville, IL 6o555 4300 Winfield Road Warrenville, IL 60555 C-March 13, 2008 Fl Rulemaking, Directives, and Editing Branch 'T, rn Office of Administration C2' U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 U, rn,

Subject:

Response to Request for Comments Concerning Draft Regulatory Guide DG-5015, "Trainingand Qualificationof Security Personnelat Nuclear Power Reactor Facilities,"dated January 2008 Exelon Generation Company, LLC (Exelon) and AmerGen Energy Company, LLC (AmerGen) are submitting this letter in response to a request from the Nuclear Regulatory Commission (NRC) for comments concerning Draft Regulatory Guide DG-5015, "Trainingand Qualificationof Security Personnelat Nuclear Power Reactor Facilities,"dated January 2008.

Exelon/AmerGen appreciate the opportunity to comment on DG-5015, and offer the following comments for consideration by the NRC. In addition, Exelon/AmerGen participated in the Nuclear Energy Institute (NEI) review of DG-5015, and therefore, endorse the comments submitted by NEI on behalf of the industry.

Specific Comments Section 2.1 - Suitability The language in the first sentence of the second paragraph is not consistent with the NRC draft final rule language stipulated in 10 CFR 73, Appendix B, paragraph B.1 .a.(3). Specifically, the word "unarmed"is included in the draft RG language but not in the draft rule. Exelon/AmerGen recommend that the word "unarmed"be removed from the draft RG.

Section 2.2 - General Physical Qualifications

• The draft rule (i.e., 10 CFR 73, Appendix B, Section VI, paragraph B.2.a) stipulates an individual may not have any physical conditions that would adversely affect their performance of assigned security duties and responsibilities. The RG regarding physical and cardiovascular health and strength suggests a more rigorous assessment of cardiovascular stamina such as a stress test. Also, a physical examination of an individual does not document strength capability.

Exelon/AmerGen recommend that the NRC consider revising the sentence to read as follows: "Personnelmay not have any identifiedphysical conditions that would adversely affect their ability to perform their assignedsecurity duties."

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U. S. Nuclear Regulatory Commission Comments on Draft RG DG-5015 March 13, 2008 Page 2 Section 2.3 - Physical Examinations The first sentence, in the first paragraph, discusses the need of physical examinations for personnel. Exelon/AmerGen consider that the requirement for physical examinations should only apply to armed and unarmed security personnel.

Expanding the scope of this area to cover non-security personnel is not consistent with NRC Security Order. Exelon/AmerGen do not consider physicals necessary for non-security personnel performing security duties that present minimal physical challenge and stress, such as material searches and vehicle and personnel escort.

Licensees should have the discretion to make the determination of whether to administer the physical before or after employment. The appropriate requirement is to perform the physical before the individual performs a physical fitness test and is assigned security duties.

Section 2.4 - Vision and Hearing

° See comments provided in Section 2.3 above regarding armed and unarmed individuals. The NRC Security Order only places vision and hearing requirements on armed security personnel.

Section 2.5 - Existing Medical Conditions See comments provided in Sections 2.3 and 2.4 above regarding armed and unarmed individuals.

Section 2.6 - Addiction

• See comments provided in Sections 2.3 and 2.4 above regarding armed and unarmed individuals.

Section 2.7 - Other Physical Requirements

• See comments provided in Sections 2.3 and 2.4 above regarding armed and unarmed individuals. In addition, Exelon/AmerGen recommend that the NRC consider revising the first sentence to only apply to armed security officers.

Section 4. - On-the-Job Training Exelon/AmerGen recommend that the NRC consider removing all references to a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training, since there is no basis for this number.

Licensees should have the discretion to make this determination using a systematic approach to training methodology. In addition Exelon/AmerGen suggest that the duty position "securitysupervisor"be eliminated. This position is not mentioned or discussed in any of the current security critical task matrices in NEI 03-09, "SecurityOfficer Training Program,"or NEI 03-12, "Template for the Security Plan, Trainingand QualificationPlan, Safeguards Contingency Plan, [and Independent Spent Fuel Storage InstallationSecurity Program]."

U. S. Nuclear Regulatory Commission Comments on Draft RG DG-5015 March 13, 2008 Page 3 There are no tasks delineated that are security supervisor specific. This comment applies to Section 4.1 as well.

Exelon/AmerGen also recommend that the NRC consider removing the minimum 40-hour training requirement from the draft rule 10 CFR 73, Appendix B, Section VI, paragraph C.2.b.

Section 6.1.4 - Subiect Matter Expert Exelon/AmerGen recommend that the NRC consider deleting the second paragraph.

This paragraph discusses an expectation that the Subject Matter Expert (SME) will receive initial instructor training. This appears to contradict the first'sentence, in the first paragraph, which states the SME may or may not be a qualified security instructor. The requisite skills to perform as an SME are delineated in the first paragraph.

Section 6.1.6 - Armorer The draft rule proposes new requirements in 10 CFR 73, Appendix B, Section VI, paragraph G.3.a. for armorer training and qualification. Exelon/AmerGen consider that the proposed requirement for armorer certification is not discussed in the current NRC Security Order requirements. The proposed requirement limits licensee flexibility to use experienced personnel. Licensees should have the discretion to determine the appropriate manner for armorer training and qualification.

Manufacturer certification is one method that may be used by the licensee.

Therefore, Exelon/AmerGen recommend that the NRC consider deleting all of the sentences after the first sentence.

Section 7.6.4 - Semiautomatic Rifle The second paragraph states that security officers should qualify separately on each sighting system. Exelon/AmerGen consider this an unnecessary requirement and inconsistent with other RG guidance. Specifically, section 7.6.7.2 of the RG, discusses that sighting systems will be included in the familiarization and marksmanship qualification courses. Exelon/AmerGen believe that these are the appropriate courses to address the various sighting systems. Exelon/AmerGen recommend that the NRC consider rewording the paragraph in section 7.6.7.2 as follows:

"Forlicensees that use multiple sighting systems, all armed members of the security organizationshould qualify through the familiarizationand marksmanship qualification courses on each primary, backup, and alternate sighting system (i.e., optics, thermal scope, iron sights) requiredto implement the site's protective strategy."

U. S. Nuclear Regulatory Commission Comments on Draft RG DG-5015 March 13, 2008 Page 4 Section 7.6.7.2 - Course of First Stages for the Tactical Qualifications Course This section discusses aspects of reloading firearms with the support-dominant hand. This is a new expectation and Exelon/AmerGen recommend that the NRC consider eliminating this objective from this section of the RG. Attempting to load with one hand only is a safety issue that requires critical instructor oversight. This technique could be trained in the advanced course of instruction, and therefore, should not be included in a qualification course of fire.

Section 8.3.1 .d - Accountability (Weapons and Ammunition)

The first paragraph discusses that: "Licenseesshould account for all in-service and out-of-service firearms once each shift." Exelon/AmerGen consider the once-per-shift accounting for out-of-service firearms to be a new requirement that will impose an additional, unnecessary, burden on the licensee. Exelon/AmerGen recommend that the NRC consider revising the third sentence as follows in an effort to reduce the burden:

"Licenseesshould account for all in-service firearms and duty ammunition daily and periodically account for out-of-service firearms and additionalammunition."

Licensees should have the discretion to determine the appropriate frequency, through their site procedures, for out-of-service firearms and additional ammunition.

The last paragraph discusses that: 'The licensee should account for additional ammunition (i.e., trainingammunition and blank ammunition) once every 6 months."

Exelon/AmerGen consider the 6-month frequency and accounting for blank ammunition as new requirements. Exelon/AmerGen recommend that the NRC consider revising the first sentence in the last paragraph to read: "The licensee should periodically account for additionalammunition (i.e., trainingammunition)."

If you have any questions or require additional information, please do not hesitate to contact Mr. Richard Gropp at 610-765-5557.

Respectfully, David P. Helker Manager - Licensing