ML21180A273: Difference between revisions

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{{#Wiki_filter:Regulatory Guide 5.75 Areas to Discuss Questions/Comments Pertaining to the Critical Task List The must performs added to the Critical Task/Duty Function/Site Specific Duty Functions section of RG 5.75, revision 1, are new from the previously applicable staff position, and a regulatory analysis was not performed justifying the change in agency position. The two new must performs should be removed until such time as a regulatory analysis can be performed.
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The Critical Task List is referenced in the security plan template and is, therefore, contained in a sites licensing basis. As the plan describes how a licensee meets the 10 CFR 73.55 requirements, the functions listed as must performs are additional requirements and/or changes in agency position.
Specifically, Critical Task 9 - Conduct Security Communications contains two sub-bullets that were additions from the previous version of RG 5.75 (dated - July 2009). These bullets state:
* Understand in plant areas where communications are difficult or non-existent.
* Establish alternate communications where communications are difficult or non-existent.
Revision 1 to RG 5.75 identifies both these functions as must perform on an annual frequency.
While Regulatory Guides are one way to meet the regulation, RG 5.75 is one regulatory guide to which licensees commit. Licensee Security Plans commit to the Critical Task List and the Systematic Approach to Training. Licensees commit to the Critical Task List to meet Appendix B of Part 73:
Consistent with Section VI, paragraph A.1 and C.1 of Appendix B to 10 CFR Part 73, the licensee shall ensure that the personnel who are assigned duties and responsibilities required to implement the Commission-approved security plans meet minimum training and qualification requirements to ensure each individual possesses the knowledge, skills, and abilities required to effectively perform assigned duties and responsibilities.
 
Regulatory Guide 5.75 Areas to Discuss Questions/Comments Pertaining to the Mock Adversary Force Does the NRC plan to revise the 71130.05 IP and/or 71130.07 IP to address changes made in RG 5.75, revision 1?
Is there an NRC expectation on aspects of training, weapons, and/or equipment pertaining to the changes in revision 1? Specifically, the language in Appendix B to Part 73, section VI, C.3. (l)(2),
that states:
The mock adversary force replicates, as closely as possible, adversary characteristics and capabilities of the design basis threat described in 10 CFR 73.1(a)(1), and is capable of exploiting and challenging the licensees protective strategy, personnel, command and control, and implementing procedures.
Whereas RG 5.75 (dated July 2009) only references the Mock Adversary Force (MAF) as it pertains to the language listed above in Appendix B, revision 1 is much more prescriptive on training, etc. While this section is not committed to in a Plan, the questions below highlight the concern with this section.
The industry would like clarity on:
: 1. If a licensee/site were to commit to revision 1 of RG 5.75, what is the periodicity of the should within the MAF?
: 2. If a site does not commit to revision 1, what will the regional inspectors inspect to?
Part 73, Appendix B, Section VI, F.2, describes what licensees are required to meet pertaining to tactical weapons qualification. Licensees meet the rule, and are inspected to RG 5.75 per the 71130.05 and 71130.07 Inspection Procedures. As revision 1 has expanded the expectations for tactical weapons qualification, licensees are concerned they will receive violations.
Overall Comment9s)
Regulatory Guides are one way to meet the regulation. The specific descriptions above detail the concerns and clarity needed regarding the Critical Task List and Mock Adversary Force.
Industry would like clarity on how NRC intends to use the guidance in revision 1 during inspections.
While licensees may not receive violations (e.g., during 71130.05 or 71130.07 inspections that use RG 5.75), they will likely receive observations, that ultimately drive increased burden and costs.}}

Revision as of 08:08, 17 January 2022

06-08-2021 Attachment Fm Aj Clore, NEI, Re Regulatory Guide 5.75 Areas to Discuss
ML21180A273
Person / Time
Issue date: 06/08/2021
From:
NRC/NSIR/DPCP/RSB
To:
Simonian N
References
RG-5.075
Download: ML21180A273 (2)
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