ML23159A247

Comment (4) of William Gross on Perimeter Intrusion Alarm Systems

ML23159A247
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/22/2023
From:	Gross W Nuclear Energy Institute
To:	Office of Administration
References
88FR10481 00004, NRC-2022-0157
Download: ML23159A247 (1)

Text

6/8/23, 4:08 PM blob:https://www.fdms.gov/d2612833-b433-43d4-9942-826737bc4a90 SUNSI Review Complete Template=ADM-013 As of: 6/8/23, 4:08 PM E-RIDS=ADM-03 Received: May 22, 2023 PUBLIC SUBMISSION ADD: Stanley Gardocki, Bridget Curran, Mary Status: Pending_Post Tracking No. lhz-1pgn-3x0e Neely Comment (4) Comments Due: May 22, 2023 Publication Date: Submission Type: Web 2/21/2023 Citation: 88 FR 10481 Docket: NRC-2022-0157 Perimeter Intrusion Alarm Systems Comment On: NRC-2022-0157-0001 Draft Regulatory Guide: Perimeter Intrusion Alarm Systems Document: NRC-2022-0157-DRAFT-0004 Comment on FR Doc # 2023-03490 Submitter Information Email: txc@nei.org Organization: Nuclear Energy Institute General Comment NEI Comments on Draft Regulatory Guide, DG-5065, Perimeter Intrusion Alarm Systems [Docket ID NRC-2022-0157]

Attachments 05-22-23_NRC_NEI Comments on DG-5065 Perimeter Intrusion Alarm Systems blob:https://www.fdms.gov/d2612833-b433-43d4-9942-826737bc4a90 1/1

WILLIAM GROSS Sr. Director, Security & Incident Preparedness Technical and Regulatory Services 1201 F Street, NW, Suite 1100 Washington, DC 20004 NUCLEAR ENERGY INSTITUTE P: 202.739.8123 wrg@nei.org nei.org May 22, 2023 Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff Submitted via Regulations.gov

Subject:

NEI Comments on Draft Regulatory Guide, DG-5065, Perimeter Intrusion Alarm Systems [Docket ID NRC-2022-0157]

Project Number: 689

Dear Program Management,

Announcements and Editing Staff, On behalf of our members, the Nuclear Energy Institute (NEI) 1 appreciates the opportunity to provide our comments on Draft Regulatory Guide DG-5065, the proposed revision to Regulatory Guide 5.44, Perimeter Intrusion Alarm Systems. The guidance found in this Draft Guide (DG) is intended to provide an approach that is acceptable to the NRC to meet regulatory requirements for perimeter intrusion alarm systems.

Specifically, this revision describes acceptable approaches for intrusion detection system operability and performance tests.

The following comments are provided for your consideration.

1. The DG guidance on early warning systems (EWS) is not sufficient. Section 8.13.5 states: If it has been calculated that an early warning system (EWS) is necessary in order to meet the performance objective of 10 CFR 73.55(b), then that system should meet the established intrusion detection alarm system criterion. However, the DG does not clearly indicate what portions of 10 CFR 73.55 must be satisfied in order to credit the EWS. As many licensees have implemented EWS, NEI 1

The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

NUCLEAR. CLEAN AIR ENERGY

Program Management, Announcements and Editing Staff May 22, 2023 Page 2 recommends that the NRC engage with industry stakeholders to help inform NRCs refinement of this guidance before it is finalized.

2. The DG uses terms and phrases, such as to meet the NRC staffs expectation for this requirement, that imply the guidance is required to comply with the regulations. NEI recommends the language be modified so that it is clear the guidance provides one acceptable method to meet the regulations and other methods could be found acceptable.

3. There are examples that are inconsistent with facility threat characteristics. Section 8 of the DG provides an example associated with an adversary characteristic that is not applicable to the power reactor radiological sabotage design basis threat. NEI recommends that the NRC review the guidance and ensure examples are consistent with the adversary characteristics for the applicable facilities.

4. Finally, the DG includes an extensive bibliography and list of references but provides no clarity on the NRC expectations concerning applicability to the different categories of covered licensees. The Documents Discussed in Staff Regulatory Guidance section found on page 15 does not adequately address the aforementioned concern. The NRC should consider clarifying the applicability of the various references to each facility type for which the guidance is appropriate. NRC should further clarify which portions of those documents provide guidance acceptable to the NRC, and perhaps more importantly, those portions that are unacceptable. The references found in the DG are an extensive addition (the previous version has no references) and depending on how the NRC chooses to address this comment, it may be appropriate for the NRC to re-notice the DG for public comment.

If you have questions or require additional information, please contact me or AJ Clore (202.739.8025 or ajc@nei.org).

Sincerely, William Gross c: Mr. Gregory Bowman, NSIR/DPCP, NRC Mr. Anthony Bowers, NSIR/DPCP, NRC Ms. Rebecca Lagios, NSIR/DPCP, NRC Mr. Al Tardiff, NSIR/DPCP/MSB, NRC