ML21257A235

Rulemaking: Proposed Rule: Advanced Reactor Physical Security, Email Exchange Between Nrc and NEI Draft Pages from NEI-20-05 Rev. E

ML21257A235
Person / Time
Site:	Nuclear Energy Institute
Issue date:	08/19/2021
From:	Stacy Prasad Nuclear Energy Institute
To:	Dennis Andrukat, Young D NRC/NMSS/DREFS/RRPB, Nuclear Energy Institute
Andrukat, Dennis
References
10 CFR Part 73, NEI-20-05, NRC-2017-0227, RIN 3150-AK19 NEI 20-05, Rev E
Download: ML21257A235 (7)

Text

From: Prasad, Stacy To: Andrukat, Dennis; YOUNG, David

Subject:

RE: DRAFT pages from NEI 20-05 Rev. E Date: Thursday, August 19, 2021 9:22:52 PM

Hey, Mostly. The presentation discussed the following (that are categorized a little differently in the attached):

achievable target sets included: results in a release that cannot be mitigated prior to offsite release.

achievable target sets result (not could result) in an offsite site dose greater than reference values (i.e. consequence analysis is already performed, if needed, to determine the set is achievable).

With respect to the flowchart:

A and B can be screened without a consequence analysis (Criterion A should determine if the worst case failure of the target set, including a failure by a DBT tactic, is bounded by the safety analysis. Criterion B is that the DBT cannot achieve the target set.)

Only C may require a consequence analysis to determine if reference values are exceeded and the target set is achievable otherwise, Criterion A may not be helpful.

Criterion A is really only for those reactors that have inherent physical or chemical characteristics of hazardous material and/or the size of the reactor design is such that a DBT tactic cannot be used create a release thats outside of the safety analysis.

The table works the way you have it.

The flow chart would have to have is the criterion met without the need to perform a consequence analysis to align with what was discussed at the meeting. Also, both boxes for meeting alternative requirements would mean no achievable target set.

Im out until August 30th, but if something is urgent, Dennis can get ahold of me.

Thanks, Stacy From: Andrukat, Dennis <Dennis.Andrukat@nrc.gov>

Sent: Thursday, August 19, 2021 4:45 PM To: YOUNG, David <dly@nei.org>; Prasad, Stacy <stacy.prasad@nrc.gov>

Subject:

RE: DRAFT pages from NEI 20-05 Rev. E Thanks, David.

Stacy - would you mind taking a quick look and letting us know if David is on the right track compared to what we presented on 8/17.

Thanks, D

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

Sent: Thursday, August 19, 2021 4:37 PM To: Andrukat, Dennis <Dennis.Andrukat@nrc.gov>; Prasad, Stacy <stacy.prasad@nrc.gov>

Subject:

[External_Sender] DRAFT pages from NEI 20-05 Rev. E

Dennis, As discussed, Im working on the revision to NEI 20-05 (DRAFT Rev. E) to address the comments provided to us during the public meeting on 8/17/21. Ive developed the updated flowchart and key text that addresses the development and use of target sets - see attached. Before I revise the rest of the document (to blend these concepts into the other sections), I was hoping I could get a quick review to ensure Ive accurately captured the target set information discussed in the meeting.

To be clear - Im not looking for an approval at this time- just that the flowchart and text correctly reflect our meeting discussion. Again, these are DRAFT pages.

David Young l Senior 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.

NEI 20-05 Methodological Approach and Considerations for a Technical Analysis to Demonstrate Compliance with the Eligibility Criteria of 10 CFR 73.55(a)(7)

Prepared by the Nuclear Energy Institute September 2021

© NEI 2021. All rights reserved. **DRAFT E** nei.org

September 2021

© NEI 2021. All rights reserved. **DRAFT E** nei.org

September 2021 Figure 1 Overview of a Technical Analysis Develop understanding of the characteristics and attributes of the DBT.

Determine adversary objective(s) to achieve a significant radiological release.

Identify target elements (SSCs and actions that must be compromised to achieve an objective).

Generate target sets.

Screen for achievable target set by assessing Eligibility Criteria A, B and C.

No achievable Achievable target target set set The applicant / YES Is a NO Perform licensee qualifies for criterion consequence alternative met? analysis (determine requirements. offsite doses).

Applicant/licensee YES Is a NO Applicant/licensee qualifies for criterion does not qualify for alternative met? alternative requirements. requirements.

© NEI 2021. All rights reserved. **DRAFT E** Page 1

September 2021 1.1 Design Basis Threat 1.2 Target Sets As used in this document:

• A target set is the minimum combination of structures, systems, components, and manual actions, that, if all are prevented from performing their intended safety function or prevented from being accomplished, barring extraordinary actions by plant operations, may result in a significant release of radioactivity to the environment.

• An achievable target set is a target set that; (1) can be disrupted, damaged or otherwise made nonfunctional by the design basis threat, and (2) results in offsite consequences that could reasonably be expected to exceed the dose reference values defined in §§ 50.34(a)(1)(ii)(D) and 52.79(a)(1)(vi).

The relationship of a target set and achievable target set to each of the three eligibility criteria presented in § 73.55(a)(7)(i) is shown below.

Mitigation Could Facility Can the DBT Measures Exist release Eligibility Criterion Possesses a compromise a for Loss of a exceed dose Target Set? Target Set?

Target Set? limits?

§ 73.55(a)(7)(i)(A) Yes Yes N/A No

§ 73.55(a)(7)(i)(B) Yes No N/A No

§ 73.55(a)(7)(i)(C) Yes Yes Yes No Achievable target Yes Yes Yes or N/A Yes set The identification of a target set that may result in a significant release of radioactivity to the environment should be determined on a qualitative basis or with minimal analysis (e.g.,

comparing expected source terms or release rates to results from accident and consequence analyses supporting the facility licensing basis). Likewise, the identification of an achievable target set with offsite consequences that could reasonably be expected to exceed the dose reference values defined in §§ 50.34(a)(1)(ii)(D) and 52.79(a)(1)(vi) should be determined on a qualitative basis or with minimal analysis. The intent is to screen target sets to identify achievable target sets, and then perform a consequence analysis only for achievable target sets.

Prior to beginning this effort, the applicant or licensee is encouraged to become familiar with the guidance in RG 5.81, Target Set Identification and Development for Nuclear Power Reactors. Although RG 5.81 was developed with large LWRs in mind, the discussion on generating target sets, including the use of information and insights from a Probabilistic Risk

© NEI 2021. All rights reserved. **DRAFT E** Page 2

September 2021 Assessment (PRA), can help inform the development of target sets for a non-LWR or SMR facility. Additional guidance on establishing target sets may be found in NEI 13-05, Target Set Template, and Sandia Report SAND2008-5644, Vital Area Identification for U.S. Regulatory Nuclear Power Reactor Licensees and New Reactor Applicants, prepared by Sandia National Laboratories.

© NEI 2021. All rights reserved. **DRAFT E** Page 3