ML19148A622

NEI Slides for NRC (5-15-19) - Enclosure 3

ML19148A622
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/15/2019
From:	Nuclear Energy Institute
To:	NRC/NSIR/DPCP/MWSB
Stapleton B
Shared Package
ML19148A619	List: ML19148A620 ML19148A621 ML19148A622
References
Download: ML19148A622 (7)

Text

Recommended Changes to Regulatory Guide 5.81 M AY 1 5 , 2 0 1 9

NEI Letter Dated January 9, 2019 Provided answers to NRC staff questions from 12/17/18 meeting (attachment 1) and a mark-up of RG 5.81 (attachment 2)

RG 5.81 mark-up shows suggested changes for:

• Determining adversary interference with an operator action

• Allowance for responder use of guidelines

• Preferred method for determination of time to core damage We continue to the support the answers and recommended changes provided in the letter Letter also discussed changes concerning Security Bounding Time (SBT) and mitigation actions; these topics are beyond the scope of this meeting

©2018 Nuclear Energy Institute 2

NEI Proposed Changes to RG 5.81 (RG 5.81 R0 section / DG-5047 section)

Section 5.2.6 / 4.3.6

• Use of PRAs as a method to develop time to core damage Section 6.4.1.3 / Section 5.5.3

• Permit consideration of armed response force capabilities when assessing criterion #3 Section 6.4.1.5 / Section 5.5.5

• Permit consideration of guidelines for responder use when assessing criterion #5

©2018 Nuclear Energy Institute 3

NEI Proposed Changes to RG 5.81 Additional information since 1/9/19 letter Incorporate by reference the guidance in NUREG/CR-7145, Nuclear Power Plant Security Assessment Guide, as a means to determine adversary timelines

• The NRC also encourages operating reactor licensees to use this guidance in planning and executing changes and upgrades of physical protection systems at existing sites.

• Addresses armed response force capabilities Consider Target Set Characterization in design of site protective strategy

©2018 Nuclear Energy Institute 4

Changes not being sought An assumption that the site will neutralize all adversaries in a short period of time and free movement will be quickly restored Stand-alone target sets

©2018 Nuclear Energy Institute 5

Summary RG 5.81, Revision 1, should reflect a reasonable assurance standard (i.e., not apply a zero risk mentality)

• Commission direction in SRM-SECY-16-0073

• Address through recognition of realistically expected licensee actions NEI and members urge consideration of our comments and recommendations in January 9th letter Licensee guidance on development of adversary timelines should be consistent between RG 5.81 and NUREG/CR-7145

• Credit for armed response force capabilities

©2018 Nuclear Energy Institute 6

Questions and Discussion