ML19148A622
| 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: |
| References | |
| Download: ML19148A622 (7) | |
Text
Recommended Changes to Regulatory Guide 5.81 MAY 15, 2019
©2018 Nuclear Energy Institute 2 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 NEI Letter Dated January 9, 2019
©2018 Nuclear Energy Institute 3 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 NEI Proposed Changes to RG 5.81 (RG 5.81 R0 section / DG-5047 section)
©2018 Nuclear Energy Institute 4 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 NEI Proposed Changes to RG 5.81 Additional information since 1/9/19 letter
©2018 Nuclear Energy Institute 5 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 Changes not being sought
©2018 Nuclear Energy Institute 6 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 Summary
Questions and Discussion