ML20325A209
| ML20325A209 | |
| Person / Time | |
|---|---|
| Issue date: | 11/23/2020 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| Shared Package | |
| ML20307A607 | List: |
| References | |
| DG-5041, RG 5.76, Rev. 1 Comment Resolution Table, RG-5.076, Rev 1 | |
| Download: ML20325A209 (3) | |
Text
Response to Public Comments on Draft Regulatory Guide (DG)-5041 Physical Protection Programs at Nuclear Power Reactors (SGI)
Proposed Revision 1 of Regulatory Guide (RG) 5.76 On September 17, 2020, the NRC transmitted to stakeholders that Draft Regulatory Guide, DG-5041 (Proposed Revision 1 of RG 5.76), was available for stakeholders comment. The comment period ended on October 23, 2020. The NRC received comments from the organizations listed below. A combined total of 13 comments were received. The NRC has combined the comments and the NRC staffs disposition in the following table.
Resolution of PWR Owners Group Comments on DG 5041 Comment Resolution Page 7 - Section B. Discussion (U), 4th paragraph is missing a The word apply was added to the end of the sentence.
word from the last sentence (missing the word apply) from Revision 0 of RG-5.76 Page 32 - Section 5 (U) Search Programs should be re- Paragraph renumbered numbers as Section 7.
Page 32 - Second paragraph is not numbered - throwing off Paragraph numbered the paragraph numbers from Revision 0 of RG-5.76.
Page 39 - Top full paragraph is not numbered - throwing off the Paragraph numbered paragraph numbers from Revision 0 of RG-5.76.
Page 46 - Bottom paragraph is not numbered - throwing off the Paragraph numbered paragraph numbers from Revision 0 of RG-5.76.
Page 48 - Bottom paragraph is not numbered - throwing off the Paragraph numbered paragraph numbers from Revision 0 of RG-5.76.
Page 67 - Section 13 should be Section 15 and paragraph at Numbering issue fixed.
bottom not numbered - throwing off the paragraph numbers from Revision 0 of RG-5.76 from there to the end of the document 1
Resolution of PWR Owners Group Comments on DG 5041 Comment Resolution Section 1.2 states that to demonstrate reasonable assurance No change. The NRC is not imposing any new requirements that a licensees physical protection program must be able to through this revision of the RG. As noted by the commenter, independently defend against the DBT for a minimum of eight the RG already states that:
hours from the recognition of an attack. While it is understood what is meant by this -this wording could imply a possible new Section 1.2.2 - a licensee who meets the NRC's current requirement for testing, drills, etc. - when in 1.2.2 it clearly requirements would not need to implement additional states that a licensee who meets the NRCs current commitments in order to take advantage of the flexibility requirements would not need to implement additional provided by the RAPT.
commitments to take advantage of the flexibility provided by the RAPT. Suggest that this be re-worded something like: A Additionally, in Sec. 1.2 above, the RG states:
licensee who meets the NRCs current requirements is expected to be able to independently defend against the DBT A licensee may demonstrate reasonable assurance by having for a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from the recognition of an attack and a physical protection program that allows the site to as such demonstrates reasonable assurance. This removes independently defend against the DBT for a minimum of eight any suggestion of some additional action being required and hours from recognition of an attack.
lines up with the language in 1.2.2.
Accordingly, the 8-hour RAPT is one acceptable method for meeting NRC requirements and is not itself a new requirement imposed on a licensee.
Section 1.2.3 is quite long and covers several different (but No change. Discussion in paragraph is related to the use of the notably related) topics and might be better off split - adversary RAPT.
timelines, operator actions, target sets.
Section 1.2.3 also provides an example of operators moving Added footnote to clarify equipment that can be considered for FLEX equipment. Suggest that be expanded to say FLEX or operator actions:
other committed too equipment so that sites committing to additional protections or equipment (such as those doing so to Licensees may also consider the equipment that is used for improve core damage frequencies, for example) can credit Emergency Operating Procedures (EOPs) as this is equipment those protections. that prevents fuel damage (rather than equipment used to mitigate consequences of fuel damage). This may include equipment for the site-specific integrated use of FLEX Support Guidelines, Station Blackout and Advanced Accident Mitigation equipment, and some equipment for Extensive Damage Mitigation Guidelines as long as the operator action is proceduralized (i.e. in an emergency operating procedure). This should not include equipment specific to Severe Accident Mitigation Guidelines.
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Resolution of PWR Owners Group Comments on DG 5041 Comment Resolution Section 1.2.5 (not numbered but should be) discusses Section number added. Added footnote on accessibility of target consideration of supporting equipment - does not address set element.
accessibility but says all. Not consistent with what is said in 1.2.3 where accessibility is mentioned.
(Section 5) Paragraph numbering and classification markings Numbering and designation fixed.
not consistent.
(Section 5) Section 1.2.3 discusses 2 scenarios for adjustments Clarifying sentence added:
to target sets whereas the last paragraph in Section 5 only discusses the second of those two scenarios. Seems a little bit In development of target sets, credit can be taken for operator disconnected. actions that could be performed after the RAPT such as those accomplished with the support of additional security assistance from law enforcement.
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