ML21175A049
| ML21175A049 | |
| Person / Time | |
|---|---|
| Issue date: | 04/28/2021 |
| From: | Dennis Andrukat, Ilka Berrios, Pamela Lee, Nanette Valliere Office of Nuclear Material Safety and Safeguards |
| To: | Austgen K, Young D Nuclear Energy Institute |
| Andrukat, Dennis | |
| References | |
| NRC-2017-0090, RIN 3150-AK04 | |
| Download: ML21175A049 (3) | |
Text
From: Andrukat, Dennis To: YOUNG, David; AUSTGEN, Kati Cc: Valliere, Nanette; Lee, Pete; Berrios, Ilka
Subject:
NRC Comments on NEI"s Summary table showing key attributes for eligibility criteria l Advanced Reactor Security rulemaking Date: Wednesday, April 28, 2021 1:03:00 PM Attachments: NRC mark-up of NEI"s ARPS Rule Eligibility Criteria Attribute Summary Table.pdf Hi David, Project: Alternative Physical Security Requirements for Advanced Reactors rulemaking and the development of its implementation guidance We appreciate the opportunity to provide any additional clarification on the topic discussed below.
Thank you for sharing the table outlining NEIs understanding of the key attributes associated with each of the eligibility criteria for the Alternative Physical Security Requirements for Advanced Reactors Rulemaking. This information was a helpful addition to the discussions we had during the April 21, 2021 public meeting on the draft guidance NEI is developing for that rulemaking in NEI 20-05, Methodological Approach and Considerations for a Technical Analysis to Demonstrate Compliance with the Performance Eligibility Criteria of 10 CFR 73.55(a)(7).
A markup of the table is attached showing that the Staff suggests removing the first two target set rows which are viewed as unnecessary and not consistent with the objective of the remaining rows to provide information about how to perform an analysis to demonstrate that a facility meets one of the eligibility criteria.
The rulemaking working group has reviewed the table and concluded that, although some items in the table represent a different view of the criteria than NRC staff had previously held, we have no technical objection to the interpretation represented by the NEI table as it would lead to an outcome that is equally protective of public health and safety.
We look forward to the submittal of the next draft of NEI 20-05 for NRC review.
Sincerely, Dennis Dennis Andrukat Rulemaking Project Manager US NRC From: YOUNG, David <dly@nei.org>
Sent: Wednesday, April 21, 2021 12:57 PM To: Valliere, Nanette <Nanette.Valliere@nrc.gov>
Cc: Andrukat, Dennis <Dennis.Andrukat@nrc.gov>; Lee, Pete <Pete.Lee@nrc.gov>; Helton, Shana
<Shana.Helton@nrc.gov>
Subject:
[External_Sender] Summary table showing key attributes for eligibility criteria 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 Young l Technical Advisor Nuclear Security and Incident Preparedness Nuclear Energy Institute (202) 739-8127 This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS and other taxing authorities, we inform you that any tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
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ARPS Rule - Eligibility Criteria Attribute Summary Table Eligibility Criterion Attributes
§ 73.55(a)(7)(i)(A) § 73.55(a)(7)(i)(B) § 73.55(a)(7)(i)(C)
Facility Possesses a Target Set (see No Yes Yes definition below)?
Facility Possesses an Achievable N/A No Yes Target Set (see definition below)?
Credit engineered safety and security Yes Yes Yes features described in licensing basis?
Credit on-shift operator actions to No Yes Yes prevent or mitigate consequences?
Credit post-facility recovery actions to No No Yes prevent or mitigate consequences?
How is release Analysis assumes DBT Analysis assumes DBT Analysis assumes DBT timing and attack starts at T=0 attack starts at T=0 attack starts at T=0 magnitude and determines and determines and determines determined? subsequent SSC subsequent SSC subsequent SSC failures failures failures Credit physical and chemical processes that prevent or Yes Yes Yes mitigate consequences?
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, within the ability of the DBT, 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.