ML21306A365

NEI Letter from D. Young to NRC S. Atack to Cease Work on Draft D of 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)

ML21306A365
Person / Time
Site:	Nuclear Energy Institute
Issue date:	10/29/2021
From:	Young D Nuclear Energy Institute
To:	Sabrina Atack NRC/NSIR/DPCP
Andrukat, Dennis
References
NEI 20-05, NRC-2017-0227, RIN 3150-AK19
Download: ML21306A365 (2)

Text

DAVID YOUNG Senior Technical Advisor, Nuclear Security and Incident Preparedness 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8127 dly@nei.org nei.org October 29, 2021 Ms. Sabrina Atack Director (Acting), Division of Physical and Cyber Security Policy Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Draft D of 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)

Dear Ms. Atack:

On October 19, 2021, the Nuclear Energy Institute (NEI) 1 and several of our members participated in a U.S.

Nuclear Regulatory Commission (NRC) public meeting to discuss the latest preliminary proposed language for the Alternative Physical Security Requirements for Advanced Reactors (APSRAR) Rule. During that meeting, discussions also took place concerning the subject document that NEI was developing to provide guidance to applicants performing an analysis to demonstrate compliance with the eligibility criteria related to the alternative physical security requirements. As outlined in previous public meetings, NEI was preparing NEI 20-05 to support the development, publication, and implementation of the APSRAR Rule. Revision D of the document has been under review by the NRC staff since May of this year.

As a result of the public discussion on October 19, 2021, NEI believes that since the rule language continues to evolve, it is likely more efficient for the NRC staff to write the guidance, and request comment from the public and the industry during its development. Therefore, NEI requests the NRC staff to cease its review of Draft D of NEI 20-05. NEI and the industry stand ready to participate in future public meetings on the guidance and will provide comments on the completed draft guidance during the public comment period for the proposed APSRAR Rule.

1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting its members, 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, suppliers and nuclear materials licensees, nuclear medicine and radiopharmaceutical companies, companies using nuclear technologies in the agricultural, food, and industrial sectors, universities and research laboratories, law firms, labor unions, and international electric utilities.

Ms. Sabrina Atack October 29, 2021 Page 2 Should you require additional information, please contact me at (202) 739-8127 or dly@nei.org.

Sincerely, David L. Young c: Mr. Dennis Andrukat, NMSS/REFS/RRPB, NRC