View source for RBG-42925, Comment on Draft Reg Guide DG-5007, Perimeter Instrusion Alarm Sys. Word Splices Should Be Changed to Terminations

{{Adams
| number = ML20117K600
| issue date = 05/29/1996
| title = Comment on Draft Reg Guide DG-5007, Perimeter Instrusion Alarm Sys. Word Splices Should Be Changed to Terminations
| author name = King R
| author affiliation = ENTERGY OPERATIONS, INC.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION (ADM)
| docket = 05000458
| license number = 
| contact person = 
| case reference number = FRN-61FR16016, RTR-REGGD-05.044, RTR-REGGD-5.044, TASK-*****, TASK-RE
| document report number = 61FR16016-00001, 61FR16016-1, RBG-42925, NUDOCS 9606110401
| document type = LEGAL TRANSCRIPTS &amp; ORDERS &amp; PLEADINGS, PUBLIC COMMENTS ON PROPOSED RULES &amp; PETITIONS FOR
| page count = 2
}}

=Text=
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St. Francisvdle. LA 70775 Tet 504 336 6225 hkh]y                 Fax 504 635 50G8 Ric! J. King 2d       [N safety & Regulatory Affairs RULES REVIEy z 9;g,gg' USNRC May 29,1996 Rules . Review and Directive Branch l        DFIPS Office of Administration U.S. Nuclear Regulatory Commission Washington, D.C. 20555

==Subject:==
Comments for Draft Regulatory Guide DG-5007 (Proposed Revision 3 to Regulatory Guide 5.44)
River Bend Station - Unit 1 Docket No. 50-458
!                                                                                                                        I i
File No.:      G9.5, Gl.41.26                                                                                   i RBF1-96-0193 RBG-42925 Gentlemen:
Enclosed are River Bend Station's comments concerning Dran Regulatory Guide (RG) DG-5007,
        " Perimeter Intrusion Alarm Systems" If you have any questions or require additional information,please contact Mr. Ecward Hutchens at (504) 336-6245.
Sincerely, l
l WJF/kvm l       enclosure j      9606110401 960529
!      PDR     ADOCK 05000458.
P                       PDR I   I l

l                                                       Enclosure to RBG-42925 l
l l                                                                                                           page1 ofI Comments:
i
: 1.     (C.I.4), "At power reactor sites only, cable pull boxes and termination points need not be    l tamper-protected ifline supervision is used, unless there are splices at the location."
l
                       .1he word " splices" shoidd be changed to " terminations". A splice in a cable afinstalled correctly does not expose the wiring any *nore so than of the cable sheathing was cut open. A termination on the other handallows the cable to be exposed tojumpering or l                       shorting.
l                2.     (C.3.1), " Total number of tests 34, 52, and 67. Minimum number of successful detections 34,51, and 65. Maximum number of failures detected 0,1, and 2."
l l                       In theprevious RG 5.44, 30 out of 30 equated to 90% probability ofdetection with 95%
!                       confidence. It also only required a 10 test (total of 40) of there was afailure while this is 1
requiring 18 (total of 52) 1he increase in testing should bejustified.
l                3.     (C.3.2), "With this test option, one pass of a performance test is conducted in place of a weekly operational test." "Each segment should be tested by using a combination of all
!                       the applicable penetration approachee at the most vulnerable area at least once a week."
Define "one pass". Is this a one test or is it referring to thefull "34" test because further in the section it is stated to use a combination of approaches? Depending on how this is defined, the utilities willfind this option to be more of a burden and will use l                        Testing Option I as it is less manpower intensive thereby defeating the purpose of Testing l                       Option 11.
[                4.     (D), "However, no backfitting is intended or has been approved in connection with issuance of this guide; any backfitting that may result from imposition of the new position in this context must be separately justified in accordance with the criteria of 10CFR50.109 and approved NRC backfitting procedures."
Though no backfitting is intended as stated above, mostfacilities are committed to testing and'or design in accordimce with RG 5.14. Publication of this document as currently stated could cause changes to be made to testingprograms andfacility design.
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