ML20049A018

Email - SBT Definition and Submittal Issue

ML20049A018
Person / Time
Site:	Nuclear Energy Institute
Issue date:	02/14/2020
From:	Young D Nuclear Energy Institute
To:	Sabrina Atack Division of Security Operations
Richardson R
References
Download: ML20049A018 (2)

Text

Wall, Yvonne From: YOUNG, David <dly@nei.org>

Sent: Friday, February 14, 2020 2:19 PM To: Atack, Sabrina

Subject:

[External_Sender] SBT Definition and Submittal Issue

Sabrina, Good afternoon.

As discussed, below is a description of the issue that industry mentioned during the public meeting on 1/23/20. Three potential solutions are also provided for your consideration.

Feel free to contact me with any questions.

David Young l Technical Advisor Nuclear Security & Incident Preparedness Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004 (202) 739-8127 Issue: The NRC-proposed definition for a site-specific SBT is the elapsed amount of time following recognition of an attack (i.e., initiating event), after which further adversary interference is precluded and additional actions that may prevent radiological sabotage can be taken by licensees. Each site has many target sets and target elements, and there may be multiple operator actions and 10 CFR 50.155 strategies that could be implemented to prevent radiological sabotage following the loss of a given target set or element. Consequently, a site could have a significant number of potential additional actions that may prevent radiological sabotage and associated elapsed times for implementation (i.e., a significant number of SBTs). The actions, strategies and implementation times will need to be assessed and updated as conditions affecting target set analyses change over time. Including SBT times in an LAR submittal could make the update process much more burdensome because the current numbers would be approved by the NRC, leading to an expectation that subsequent changes must also be submitted for review. Licensees should have the capability to make SBT updates in target set analyses without the need for NRC review of those updates prior to implementation.

Recommended Solution: NEI proposes three options to address this issue (in preferred order).

1. Maintain the NEI-proposed definition of SBT and have the regulatory framework recognize two time components - SBT + action execution time. An LAR would provide the offsite response time (i.e.,

one SBT), whether based on LLEA or security recall, and a description of the process used to determine action execution times to be included in target set analyses.

2. Using the NRC SBT definition, a licensee LAR describes the process used to determine site-specific SBTs but does not include the times, and confirms that SBTs are maintained in target analyses for inspection. This approach is similar to that used for oversight of operator actions.

3. Using the NRC SBT definition, if the NRC staff believes that specific times must be included in an LAR for compliance with the proposed SBT regulatory framework, then guidance should instruct a licensee to include a) a description of the process used to determine site-specific SBTs, b) a summary table of the SBTs for each target set/element, and c) a statement that subsequent changes to SBTs will not be submitted to the NRC but, rather, made in accordance with site procedures and retained for inspection.

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