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Category:General FR Notice Comment Letter
MONTHYEARML24200A1852024-07-17017 July 2024 Comment (1) of Frances A. Pimentel on Draft Regulatory Guides: Design-Basis Floods for Nuclear Power Plants and Guidance for Assessment of Flooding Hazards Due to Water Control Structure Failures and Incidents ML24173A0042024-06-14014 June 2024 Comment (1) of Individual on Draft NUREG: Event Report Guidelines ML24173A0052024-06-14014 June 2024 Comment (2) of Tony Brown on Behalf of Nuclear Energy Institute (NEI) on Draft NUREG: Event Report Guidelines ML24114A0252024-04-0808 April 2024 Comment (4) of Charlotte Shields on DG-5080 Uas Question ML24009A0372023-12-13013 December 2023 Comment (2) of Bruce Montgomery on Draft DUWP-ISG-02, Radiological Survey and Dose Modeling of the Subsurface to Support License Termination ML23353A2442023-12-13013 December 2023 Comment (2) of Bruce Montgomery on Interim Staff Guidance on Subsurface Investigations, Radiological Survey and Dose Modeling of the Subsurface to Support License Termination ML23348A0732023-12-11011 December 2023 Comment (2) of Charlotte Shields on Behalf of Nuclear Energy Institute on Draft Regulatory Guide: Physical Security Event Notifications, Reports, and Records ML23348A0772023-12-11011 December 2023 Comment (1) of Charlotte Shields on Behalf of Nuclear Energy Institute on Draft Regulatory Guide: Preemption Authority, Enhanced Weapons Authority, and Firearms Background Checks ML23349A0442023-12-11011 December 2023 Comment (1) of Charlotte Shields on Draft Regulatory Guide: Suspicious Activity Reports ML23326A1172023-11-21021 November 2023 Comment (1) of Alan Campbell on Proposed Revision to Standard Review Plan Branch Technical Position 7-19, Guidance for Evaluation of Defense-In-Depth and Diversity to Address Common-Cause Failure Due to Latent Design Defects in Digital Safe ML23326A0312023-11-17017 November 2023 Comment (2) of Kati R. Austgen on Draft Regulatory Guide: General Site Suitability Criteria for Nuclear Power Stations ML23284A3892023-10-10010 October 2023 Comment (8) of Ben Holtzman on Guidance for a Technology-Inclusive Content of Application Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Advanced Reactors ML23270B9552023-09-27027 September 2023 Comment (2) of Stewart Yuen on Proposed Revision to Standard Review Plan Section 15.0, Introduction - Transient and Accident Analyses ML23242A0412023-08-25025 August 2023 Comment (2) of Brett Titus on Behalf of NEI on Draft NUREG: Revision to Subsequent License Renewal Guidance Documents, and Supplement to Associated Technical Bases Document ML23236A5292023-08-21021 August 2023 Comment (6) of Bruce S. Montgomery on Draft Interim Staff Guidance: Use of the Decommissioning Trust Fund During Operations for Major Radioactive Component Disposal ML23256A1122023-08-10010 August 2023 Comment (3) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1132023-08-10010 August 2023 Comment (4) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1152023-08-10010 August 2023 Comment (2) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1162023-08-10010 August 2023 Comment (1) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1192023-08-10010 August 2023 Comment (4) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1202023-08-10010 August 2023 Comment (2) of Ben Holtzman on Behalf of Nuclear Energy Institute on Draft Interim Staff Guidance: Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications-Roadmap ML23256A1222023-08-10010 August 2023 Comment (5) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1232023-08-10010 August 2023 Comment (4) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1252023-08-10010 August 2023 Comment (4) of Ben Holtzman on Behalf of Nuclear Energy Institute on Draft Interim Staff Guidance: Review of Risk-Informed, Technology Inclusive Advanced Reactor Applicationsroadmap ML23234A0392023-08-10010 August 2023 Comment (4) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23181A0292023-06-29029 June 2023 Comment (2) of Rod Mccullum on Draft Regulatory Guide: Weather-Related Administrative Controls at Independent Spent Fuel Storage Installations ML23174A0492023-06-16016 June 2023 Comment (2) of Ben Holtzman on Behalf of Nuclear Energy Institute on Draft Interim Staff Guidance: Review of Risk-Informed, Technology Inclusive Advanced Reactor Applicationsroadmap ML23158A2162023-06-0202 June 2023 Comment (2) of Alan Campbell on Draft Regulatory Guide: Guidelines for Lightning Protection for Production and Utilization Facilities ML23159A2472023-05-22022 May 2023 Comment (4) of William Gross on Perimeter Intrusion Alarm Systems ML23143A1982023-05-18018 May 2023 Comment (1) of Richard Mogavero on Behalf of Nuclear Energy Institute on Draft Regulatory Guide: Cybersecurity Event Notifications ML23130A2082023-05-0808 May 2023 Comment (9) of Mark A. Richter on Behalf of Nuclear Energy Institute on Material Compatibility for Non-Light Water Reactors ML23115A0152023-04-0707 April 2023 Comment (1) of Alan Campbell on Draft Regulatory Guide: Criteria for Programmable Digital Devices in Safety-Related Systems of Nuclear Power Plants ML24120A2702023-04-0404 April 2023 Melody Rodridguez NEI Comment on Controlled Unclassified Information ML23089A0012023-03-28028 March 2023 OMB 3150-0035, NEI Comment on 10 CFR Part 21 Information Collection Renewal 2023 ML23094A0632023-03-28028 March 2023 NRC-2022-0145- NEI Official Comment Attachment on 10 CFR Part 21 Information Collection Renewal ML23115A0172023-03-23023 March 2023 Comment (3) of Alan Campbell on Draft Regulatory Guide: Criteria for Programmable Digital Devices in Safety-Related Systems of Nuclear Power Plants ML23074A0472023-03-14014 March 2023 Comment (2) of A. J. Clore on Perimeter Intrusion Alarm Systems ML22354A2422022-12-19019 December 2022 Comment (4) of Thomas Basso on Behalf of Nuclear Energy Institute on Performance-Based Containment Leak Test Program ML23005A2412022-12-16016 December 2022 Comment (1) of Janet R. Schlueter on Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities ML22244A1732022-08-31031 August 2022 Comment (1) of Tony Brown on Behalf of Nuclear Energy Institute on Industry Comments on Draft Appendices to NUREG/BR-0058, Revision 5, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission ML22242A0302022-08-29029 August 2022 Comment (1) of Victoria K. Anderson on High Energy Arcing Fault Hazard Frequency and Consequence Modeling ML22231B0532022-08-19019 August 2022 Comment (6) of James E. Slider on Nrc'S Fiscal Years 2023-2027 Artificial Intelligence Strategic Plan ML22230A0402022-08-15015 August 2022 Comment (4) of William R. Gross on Behalf of NEI on Update of Facility Security Clearance ML22224A1942022-08-12012 August 2022 Comment (1) of William R. Gross on Behalf of Nuclear Energy Institute on Personnel Access Authorization Requirements for Non-Immigrant Foreign Nationals Working at Nuclear Power Plants ML22174A0722022-06-21021 June 2022 Comment (11) of Frances A. Pimentel on Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Plants ML22174A3422022-06-21021 June 2022 Comment (2) of Victoria K. Anderson on Level 3 PRA Project Documentation (Volume 3x) ML22165A2082022-06-13013 June 2022 Comment (2) of Victoria K. Anderson on Draft Research Information Letter Reports Determining the Zone of Influence for High Energy Arcing Faults Using Fire Dynamics Simulator, and Predicting High Energy Arcing Fault Zones of Influence for ML22145A2992022-05-23023 May 2022 Comment (2) of Victoria K. Anderson on Acceptability of Probabilistic Risk Assessment Results for Advanced Non-Light Water Reactor Risk-Informed Activities ML22152A0632022-05-23023 May 2022 Comment (1) of Kati R. Austgen on Safety Review of Light-Water Reactor Construction Permit Applications ML22124A0812022-05-0202 May 2022 Comment (3) of Richard Mogavero on Cyber Security Programs for Nuclear Power Reactors 2024-07-17
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WILLIAM GROSS Director, Incident Preparedness 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8123 wrg@nei.org SUNSI Review Complete nei.org Template = ADM-013 E-RIDS=ADM-03 ADD= Jazel Parks, Mekonen Bayssie COMMENT #4 September 13, 2018 PUBLICATION DATE: 5/14/2018 CITATION # 83 FR 22297 Ms. May Ma Mail Stop: TWFN-7-A60M Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Comments on Draft Regulatory Guide 5048, Standard Format and Content of Physical Security Plans, Training and Qualifications Plans and Safeguards Contingency Plans for Nuclear Power Plants (NRC Docket ID NRC-2018-0092)
Project Number: 689
Dear Ms. Ma:
On behalf of its members, the Nuclear Energy Institute (NEI) 1 appreciates the opportunity to provide comments on Draft Regulatory Guide (DG) 5048, Standard Format and Content of Physical Security Plans, Training and Qualifications Plans and Safeguards Contingency Plans for Nuclear Power Plants. The purpose of this DG is to describe the standard format and content for licensee physical security plans, training and qualifications plans and safeguards contingency plans that the U.S. Nuclear Regulatory Commission (NRC) staff finds acceptable. The DG provides general guidance for the level of detail that licensees should provide in these plans relative to the types of information that should be addressed, including site-specific conditions, to ensure that security plans are complete and accurate.
The material in DG-5048 goes well beyond that contained in Regulatory Guide (RG) 5.54, "Standard Format and Content of Safeguards Contingency Plans for Nuclear Power Plants," Revision 1 (i.e., the preceding issued revision of RG 5.54). As the change in document title implies, the RG scope has been expanded to cover physical security plans and training and qualification plans. The expanded guidance is, in many cases, duplicative of the requirements in 10 CFR 73.55 and the NRC-endorsed guidance in NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Plan]. We are unaware of any issues with NEI 03-12 substantive enough to warrant superseding it with the proposed guidance in DG-5048.
1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Ms. May Ma September 13, 2018 Page 2 Further, DG-5048 does not comport with the guidance in NUREG-0800, Standard Review Plan (SRP) for Safety Evaluation Reports, Section 13.6.1, SRP Acceptance Criteria. Section 13.6.1 clearly states that a Security Plan is considered acceptable if it conforms to the most recent revision of the NRC-endorsed NEI 03-12 format and the requirements listed in Appendices I, II and III of this document.
We also note that DG-5048 appears to contradict certain requirements in 10 CFR 73.55, Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage. For example, the document directs incorporation of certain information related to access controls, search programs and communication requirements that § 73.55 states should be contained in implementing procedures.
Following the proposed guidance in DG-5048 would lead a licensee to significantly increase the level of detail of information contained in site security plans and, for this reason, would have several undesirable outcomes.
First, it would unnecessarily burden the industry and the NRC by driving an increase in security plan changes which, in turn, necessitates more licensing submittals and NRC reviews. The NRC-approved security plans for each power reactor facility are based on the NRC-endorsed template and development guidance presented in NEI 03-12. The template and guidance were written to meet all the requirements of 10 CFR 73.55 and to direct the placement of implementing details in procedures, as permitted by regulations. The processes in 10 CFR 50.54(p) and 10 CFR 50.90 provide the appropriate framework to permit licensees to modify their plans and implementing procedures while ensuring the NRC is notified of changes that may decrease the effectiveness of a security plan.
Second, licensees may be discouraged from making enhancements to their security plans and procedures due to the increase in required processing time and resources. For example, licensees may effect changes to their site implementing procedures throughout the year to address lessons learned, operating experience and observations from critiques. Faced with an increased burden to make changes to security plans that contain the same procedure-level information, licensees may choose to delay or eschew making these enhancements. Changes that improve a site security program would occur less frequently due to higher implementation costs.
Finally, despite the NRCs indication that DG-5048 does not modify any existing requirements or plan details and thus does not constitute a backfit concern, all licensees will, as a matter of prudence, expend significant resources reviewing the revision to RG 5.54. These reviews are conducted to ensure that differences in language between the revised guide and their approved plan are identified and assessed for future inspection compliance risk or licensing risk as they contemplate future changes to site-specific security plans.
Ms. May Ma September 13, 2018 Page 3 Given the fundamental nature of our concerns, NEI recommends the NRC remove DG-5048 from the review process and engage directly with stakeholders to develop a revision that addresses the comments above.
The revised version can then be placed into a public comment review process. Alternatively, the staff may wish to consider whether further investment of stakeholder resources in DG-5048 is warranted in light of our comments and, if not, terminate the revision effort.
If you have questions or require additional information, please contact AJ Clore at (202) 739-8025 or ajc@nei.org, or me.
Sincerely, William R. Gross Attachment c: Mr. David Curits, NSIR/DPCP, NRC Mr. Dennis Gordon, NSIR/DPCP/RSB, NRC Ms. Alison Rivera, NSIR/DPCP/RSB, NRC