ML21175A036

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Rulemaking: Proposed Rule: Advanced Reactor Physical Security Email from D. Young, NEI to N. Valliere, D Andrukat, S. Helton, P. Lee, NRC Summary Table Showing Key Attributes for Eligibility Criteria
ML21175A036
Person / Time
Site: Nuclear Energy Institute
Issue date: 04/21/2021
From: Young D
Nuclear Energy Institute
To: Nanette Valliere
NRC/NRR/DANU
Andrukat, Dennis
References
NRC-2017-0090, RIN 3150-AK04
Download: ML21175A036 (2)


Text

From:

YOUNG, David To:

Valliere, Nanette Cc:

Andrukat, Dennis; Lee, Pete; Helton, Shana

Subject:

[External_Sender] Summary table showing key attributes for eligibility criteria Date:

Wednesday, April 21, 2021 12:57:13 PM Attachments:

ARPS Rule Eligibility Criteria Attribute Summary Table.docx Importance:

High

Nan,

Good afternoon.

As discussed during the meeting this morning, the attached table shows our understanding of the key attributes associated with each of the eligibility criteria. I ask that your folks review the table and then let me know if were aligned in our understanding or if adjustments are needed. Given my commitment to get you the guidance in time to support the near-term rulemaking schedule milestones, I request a timely review and return of staff feedback. Any method of providing the feedback is fine with me - telephone call, email or meeting.

David YounglTechnical Advisor Nuclear Security and Incident Preparedness Nuclear Energy Institute (202) 739-8127

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ARPS Rule - Eligibility Criteria Attribute Summary Table Attributes Eligibility Criterion

§ 73.55(a)(7)(i)(A)

§ 73.55(a)(7)(i)(B)

§ 73.55(a)(7)(i)(C)

Facility Possesses a Target Set (see definition below)?

No Yes Yes Facility Possesses an Achievable Target Set (see definition below)?

N/A No Yes Credit engineered safety and security features described in licensing basis?

Yes Yes Yes Credit on-shift operator actions to prevent or mitigate consequences?

No Yes Yes Credit post-facility recovery actions to prevent or mitigate consequences?

No No Yes How is release timing and magnitude determined?

Analysis assumes DBT attack starts at T=0 and determines subsequent SSC failures Analysis assumes DBT attack starts at T=0 and determines subsequent SSC failures Analysis assumes DBT attack starts at T=0 and determines subsequent SSC failures Credit physical and chemical processes that prevent or mitigate consequences?

Yes Yes Yes A target set is the minimum combination of equipment or operator actions which, if all are prevented from performing their intended safety function or prevented from being accomplished, would result in offsite doses greater than the reference values in §§ 50.34(a)(1)(ii)(D) and 52.79(a)(1)(vi).

An achievable target set means a target set that is within the ability of the DBT to compromise, destroy, or render nonfunctional, absent actions by an onsite armed response force.