NRC-98-0035, Comment on Draft RG DG-5008 (Rev 2 to Reg Guide 5.62), Reporting of Safeguards Events. Util Endorses Industry Comments Submitted by NEI

Comment on Draft RG DG-5008 (Rev 2 to Reg Guide 5.62), Reporting of Safeguards Events. Util Endorses Industry Comments Submitted by NEI

ML20216G086
Person / Time
Site:	Fermi
Issue date:	03/09/1998
From:	Borer P DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
CON-NRC-98-0035, CON-NRC-98-35, FRN-63FR275, RTR-REGGD-05.062, RTR-REGGD-5.062, TASK-*****, TASK-RE 63FR275-00016, 63FR275-16, NUDOCS 9803190203
Download: ML20216G086 (3)

Text

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. 6400 North Dixie Hwy., Newport, M148166 h[/' 2(( l NN Detroit Edison g March 9,1998 ia a NRC-98-0035 1

' Rules and Directives Branch Office of Administration U. S. Nuclear Regulatory Commission )

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References:

1) Fermi 2 NRC Docket No. 50-341 Si{ $ '*

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NRC License No. NPF-43  %  !!E <  ;

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2) NRC Draft Regulatory Guide DG-5008," Proposed Rev@onkf

' T C i Regulatory Guide 5.62, Reporting of Safeguards Events,"

(63 FR 275, dated January 5,1998) I

Subject:

Comments on NRC Draft Reculatory Guide DG-5008 1 Detroit Edison has reviewed the Draft Regulatory Guide DG-5008 (Reference 2). This Draft Regulatory Guide, when approved, will become Revision 2 to Regulatory Guide 5.62, Reporting of Safeguards Events. Detroit Edison endorses the industry comments submitted by the Nuclear Energy Institute (NEI) and would like to make additional comments, as described in the enclosure of this letter.

We appreciate the opportunity to comment on tne draft Regulatory Guide DG-5008. If you have any questions, please contact Mr. Norman K. Peterson, Director - Nuclear Licensing at (734) 586-4258.

S' rely, P. rer Vice President Nuclear Generation i

Enclosure  ;

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Enclosure to A ',

NRC-98-0035 g Page1

.e Detroit Edison Comments on NRC Draft Reeulatory Guide DG-5008. " Proposed Revision 2 of Reeulatory Guide 5.62. Reporting of Safeeuards Events".

1. In Draft Regulatory Guide DG-5008, Section 2.1 (d), the last sentence sbauld include the word "significant" before the word " reduction" to read as " Discovered vulnerabilities include significant flaws in the physical protection system that could result in a sinnificant reduction in overall protection at the site". Without such a qualifier, confusion would occur over what needs to be reported to the NRC within one hour.

2. Draft Regulatory Guide DG-5008, Section 2.2.2 describes a bomb threat or extortion threats as examples of safeguards events that should be reported within one hour.

However, the licensee should be given the flexibility to determine whether the threat is credible or not. Otherwise, one hour reportable events could add to the distractions for control room personnel when having to make one hour reports and subsequently to retract them when the information is determined not credible. Also, it should allow for the option to log unsubstantiated bomb or extortion threats.

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3. _ Dran Regulatory Guide DG-5098, Section 2.2.3 should be modified to add, ac the beginning of the first sentence " Discovery of a criminal act involving individuals granted unescorted access to the protected or vital area access that, in thejudgment of the

licensee, adversely affects radiological safety in licensed activities."

4. Draft Regulatory Guide DG-5008, Section 2.2.9 should be modified to clearly state that the one hour reporting time starts only when tampering has been confirmed to be of malevolent intent.

5. Draft Regulatory Guide DG-5008, Section 2.2.11 should be modified to add, in the first sentence, the word " intentionally" before " falsified identification badges or key cards."

6. Draft Regulatory Guide DG-5008, Section 2.4.2 states that properly compensated vital area card reader failures must be logged. However, NRC Generic Letter 91-03 already allows this event to be logged. This section should be changed to be consistent with NRC Generic Letter 91-03.

7. In Draft Regulatory Guide DG-5008, Section 2.4.9, the loss of backup capability is not clearly described. If the backup is lost, but not the primary system, is this a loggable event? This is also ambiguous unless reference is made for licensees who have the capability to activate a secondary computer.

Enclosure to

• ' NRC-98-0035 Page 2

8. Draft Regulatory Guide DG-5008, Section 2.4.12: It is not reasonable to require licensee to take all of these actions within one hour? Additionally, it is not clear what does unclassified safeguards information mean?

! 9. Draft Regulatory Guide DG-5008, Section 2.5.4: This section should be revised. It may not always be reasonable to determine the origin of a fire or explosion within one hour.

10. Draft Regulatory Guide DG-5008, Section 2.5.6: Making determination, within one hour, whether a suspected tampering with safety equipment is an actual tampering or not, is not realistic. It forces the licensee into reporting a one hour event. The licensee should be given flexibility ofinvestigating the incident and making a follow-up call if no tampering is discovered.

I 1. Draft Regulatory Guide DG-5008, Section 3.6.3: The licensee should not have to inchide compensatory measure description in the log just because detailed compensatory measure records are required in accordance with 10 CFR 73.55 (g)(1) & 10 CFR 73.70 (e).

1: bli b ,latory Guide DG-5008, Section 3.6.4: The licensee should not have to identify

- ,. .as in the log when it is obvious what areas are affected.

u. # Regulatory Guide DG-5008, Appendix C, Compensatory Measures: Generic Letter s,-03 allows flexibility for not reporting, when not able to compensate within 10 minutes, if there was no malevolent intent and nothing adverse resulted from the delay.

Additionally, posting security officers for loss of security system if compensatory measures are implemented within 10 minutes, should not be a one hour reportable event.

14. In general, Draft Regulatory Guide DG-5008 places more stringent reporting requirements on the security force than the previous regulatory guidance with regard to making reports within one hour. Requiring personnel to meet these reporting requirements has a potential detrimental effect to the safety of the plant. That is, the security supervision and the licensed control room operators will be raquired to focus on reporting an evi.nt within a very short period of time rather than the actual event for determining its cause and potential impact. Unnecessary one hour reports, later retracted when the aWitional information becomes available, only serve to distract the plant operation and the security force response.

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