ML18227A030

(E-mail) NEI Comments on DG-5039, Draft Revision 1 of Regulatory Guide 5.69, Guidance for the Application of Radiological Sabotage Design-Basis Threat in the Design, Development, and Implementation of a Physical Security Program

ML18227A030
Person / Time
Site:	Nuclear Energy Institute
Issue date:	08/03/2018
From:	Perkins-Grew S Nuclear Energy Institute
To:	Andersen J W NRC/NSIR/DPCP
Vaughn J E
Shared Package
ML18227A029	List: ML18227A030 ML18227A031
References
DG-5039, RG-5.069, Rev 1
Download: ML18227A030 (2)

Text

From: PERKINS-GREW, Susan To: Andersen, James Cc: Bailey, Marissa

Curtis, David

Zobler, Marian

Subject:

[External_Sender] Comments on DG-5039, Draft Revision 1 of Regulatory Guide 5.69, "Guidance for the Application of Radiological Sabotage Design-Basis Threat in the Design, Development, and Implementation of a

Physical Security Program that Meets 10 CFR...

Date: Friday, August 03, 2018 9:23:02 AM Attachments:

08-03-18_NRC_NEI Comments on DG-5039 Draft Revision 1 of Regulatory Guide 5.69.pdf THE ATTACHMENT CONTAINS THE COMPLETE CONTENTS OF THE LETTER August 3, 2018 Mr. James Andersen Director, Division of Physical and Cyber Security Policy

Office of Nuclear Security and Incident Response

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Subject:

Comments on DG-5039, Draft Revision 1 of Regulatory Guide 5.69, "Guidance for the Application of Radiological Sabotage Design-Basis Threat in the Design, Development, and

Implementation of a Physical Security Program that Meets 10 CFR 73.55 Requirements," dated

June 2018 Project Number: 689

Dear Mr. Andersen:

The Nuclear Energy Institute (NEI) is pleased to provide comments on Draft Guide-5039, Draft Revision 1 of Regulatory Guide 5.69, dated June 2018 ("DG-5039" or "Draft Guide"). The focus of

NEI's review was to ensure that the language in DG-5039 addressing coordinated attacks, breaching, and use of explosives against personnel was the same as the language addressing

those topics in revision 0 of Regulatory Guide 5.69 (dated August 2007), and to identify any

additional fatal flaws in the Draft Guide.

Our review confirmed that the descriptions of the coordinated attack, breaching, and use of

explosives against personnel tactics outlined in DG-5039 are the same as the descriptions of those

tactics provided in revision 0 to Regulatory Guide 5.69, dated August 2007. As recommended by

the Committee to Review Generic Requirements (CRGR) in their May 22, 2018, memorandum, NEI and its members look forward to continued dialogue with the NRC staff to develop reasonable

limits on the use of the breaching tactic.

Additionally, in regards to vehicle characteristics, NEI and its members recommend that section

10.10 of the January 2017 version of DG-5039 be inserted into the final published document in

place of section 10.12, currently found in the June 2018 version of DG-5039. The language

contained within the January 2017 version provides more clarity and direction to licensees if there were to be changes made to their vehicle denial systems.

If you have any questions or require additional information, please contact AJ Clore at (202) 739-8025; ajc@nei.org or myself.

Sincerely, Susan Perkins-Grew

Senior Director, Nuclear Security and Incident Preparedness Nuclear Energy Institute

1201 F Street N.W., Suite 1100

Washington, DC 20004

www.nei.org P: 202.739.8016

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