ML18227A030
| ML18227A030 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 08/03/2018 |
| From: | Perkins-Grew S Nuclear Energy Institute |
| To: | Andersen J NRC/NSIR/DPCP |
| Vaughn J | |
| Shared Package | |
| ML18227A029 | List: |
| References | |
| DG-5039, RG-5.069, Rev 1 | |
| Download: ML18227A030 (2) | |
Text
From:
PERKINS-GREW, Susan To:
Andersen, James Cc:
Bailey, Marissa; Curtis, David; Zobler, Marian
Subject:
[External_Sender] Comments on DG-5039, Draft Revision 1 of Regulatory Guide 5.69, Guidance for the Application of Radiological Sabotage Design-Basis Threat in the Design, Development, and Implementation of a Physical Security Program that Meets 10 CFR...
Date:
Friday, August 03, 2018 9:23:02 AM Attachments:
08-03-18_NRC_NEI Comments on DG-5039 Draft Revision 1 of Regulatory Guide 5.69.pdf THE ATTACHMENT CONTAINS THE COMPLETE CONTENTS OF THE LETTER August 3, 2018 Mr. James Andersen Director, Division of Physical and Cyber Security Policy Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Comments on DG-5039, Draft Revision 1 of Regulatory Guide 5.69, Guidance for the Application of Radiological Sabotage Design-Basis Threat in the Design, Development, and Implementation of a Physical Security Program that Meets 10 CFR 73.55 Requirements, dated June 2018 Project Number: 689
Dear Mr. Andersen:
The Nuclear Energy Institute (NEI) is pleased to provide comments on Draft Guide-5039, Draft Revision 1 of Regulatory Guide 5.69, dated June 2018 (DG-5039 or Draft Guide). The focus of NEIs review was to ensure that the language in DG-5039 addressing coordinated attacks, breaching, and use of explosives against personnel was the same as the language addressing those topics in revision 0 of Regulatory Guide 5.69 (dated August 2007), and to identify any additional fatal flaws in the Draft Guide.
Our review confirmed that the descriptions of the coordinated attack, breaching, and use of explosives against personnel tactics outlined in DG-5039 are the same as the descriptions of those tactics provided in revision 0 to Regulatory Guide 5.69, dated August 2007. As recommended by the Committee to Review Generic Requirements (CRGR) in their May 22, 2018, memorandum, NEI and its members look forward to continued dialogue with the NRC staff to develop reasonable limits on the use of the breaching tactic.
Additionally, in regards to vehicle characteristics, NEI and its members recommend that section 10.10 of the January 2017 version of DG-5039 be inserted into the final published document in place of section 10.12, currently found in the June 2018 version of DG-5039. The language contained within the January 2017 version provides more clarity and direction to licensees if there ML18227A030
were to be changes made to their vehicle denial systems.
If you have any questions or require additional information, please contact AJ Clore at (202) 739-8025; ajc@nei.org or myself.
Sincerely, Susan Perkins-Grew Senior Director, Nuclear Security and Incident Preparedness Nuclear Energy Institute 1201 F Street N.W., Suite 1100 Washington, DC 20004 www.nei.org P: 202.739.8016 E: spg@nei.org This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS and other taxing authorities, we inform you that any tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
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