ML19221B610

20190808 NEI Comments on Draft Regulatory Basis - Physical Security for Advanced Reactors Rulemaking.Pdf

ML19221B610
Person / Time
Site:	Nuclear Energy Institute
Issue date:	08/08/2019
From:	Austgen K Nuclear Energy Institute
To:	Office of Nuclear Material Safety and Safeguards
Berrios I
References
Download: ML19221B610 (4)

Text

Comments on Draft Regulatory Basis -

Physical Security for Advanced Reactors Rulemaking Kati Austgen August 8, 2019

©2019 Nuclear Energy Institute

General/Overall Comment NEI and our members support the rulemaking The performance-based approach is technically sound and will lead to security requirements sufficient to protect public health and safety Codification will achieve NRC staff goals (e.g.,

reduce need for exemptions and improve regulatory stability & predictability)

©2019 Nuclear Energy Institute 2

Comments Support staffs willingness to identify additional requirements that may be eliminated or modified to reduce the number of exemptions

• New requirements should allow security personnel to have additional duties and/or be located outside the Protected Area provided the NRC-approved security plan can be effectively implemented

©2019 Nuclear Energy Institute 3

Comments Requirements and guidance for reliance upon offsite resources to support recovery and mitigation strategies will need to be clearly articulated

• Programmatic documents

• Letters of Agreement/MOUs and contracts

• Design change and configuration management controls

• Implementing procedures

• Training and drill program

©2019 Nuclear Energy Institute 4