ML22217A078
| ML22217A078 | |
| Person / Time | |
|---|---|
| Site: | 99902071 |
| Issue date: | 04/08/2022 |
| From: | Michael Orenak NRC/NRR/DANU/UAL1 |
| To: | X-Energy |
| Orenak M | |
| References | |
| Download: ML22217A078 (7) | |
Text
SUBMITTAL OF THE X-ENERGY XE-100 WHITE PAPER, PHYSICAL PROTECTION SYSTEM APPROACH, REVISION 2 SPONSOR INFORMATION Sponsor:
X Energy, LLC (X-energy)
Sponsor Address:
801 Thompson Avenue Rockville, MD 20852 Docket /Project No(s).:
99902071 DOCUMENT INFORMATION Submittal Date: April 8, 2022 Submittal Agencywide Documents Access and Management System (ADAMS)
Accession No.: ADAMS Accession No. ML22098A228 Brief Description of the White Paper: The purpose of this white paper is to describe the elements of the approach X-energy is employing to develop a physical security program template for an Xe-100 high temperature, gas-cooled reactor (HTGR) plant. X-energy requested that the U.S. Nuclear Regulatory Commission (NRC) provide comments on the physical security approach to inform X-energys development of licensing topical reports and project-specific applications associated with the Advanced Reactor Demonstration Project (ARDP).
REGULATORY ASSESSMENT Regulatory Basis NRC staff are making no regulatory findings on this white paper and nothing herein should be interpreted as an official agency position.
The NRC staff observations are focused on the physical security protection approach detailed in the white paper. Physical protection programs are required by Title 10 of the Code of Federal Regulations (10 CFR), Part 73, Physical Protection of Plants and Materials. Accordingly, NRC staff observations are associated with the following regulatory requirements from Part 73.
10 CFR 73.55, Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage, provides the requirements for physical protection programs for nuclear power reactors.
10 CFR 73.67, Licensee fixed site and in-transit requirements for the physical protection of special nuclear material of moderate and low strategic significance, provides the requirements for the physical protection system for the transportation of special nuclear material of moderate and low strategic significance.
TECHNICAL ASSESSMENT General Comments 1.
X-energys proposed development of a licensing topical report (TR) for a standard Xe-100 physical protection system (PPS) for meeting requirements of 10 CFR 73.55 should conform to the current revision of guidance in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 13.6.1, Physical Security - Combined License and Operating Reactors and Section 13.6.2, Physical Security Review of Physical Security Designs - Standard Design Certification and Operating Reactor Licensing Applications. Because the requirements in 10 CFR Part 73 are technology-independent, the guidance in these NUREG-0800 sections are generally applicable to HTGRs. The development of the proposed TR should pay specific attention to the guidance within NUREG-0800 with respect to the scope of the technical review for physical security, addressing the necessary information for the NRC staff to determine that the regulatory requirements are met.
2.
X-energys white paper describes several changes to 10 CFR 73.55 that are currently in draft and not yet approved by the Commission. The proposed TR on the standardized Xe-100 PPS design should focus on addressing the current 10 CFR 73.55 requirements.
However, X-energy may include methods or approaches to the PPS design that are not described in 10 CFR 73.55 to meet the performance objective and requirements of 10 CFR 73.55(b). X-energy may consider alternatives to the existing requirements in 10 CFR 73.55 through use of 10 CFR 73.55(r), and/or request regulatory exemptions from these requirements utilizing the regulatory guidance/technical basis from the proposed limited scope rule, Alternative Physical Security for Advance Reactors, (RIN 3150-AK19) to the extent appropriate for developing their site protective strategy.
3.
The proposed TR for the design of the standard Xe-100 PPS should address only the portion of the design that would be standardized for all Xe-100 plants. Details of the site-specific conditions and related PPS design features should be included in applications that use the proposed TR. For example, a method of accomplishing the interdiction/neutralization function in the PPS design may be the use of local law enforcement (LE), where the local LE capabilities and response times to support the required function will vary with the LE entities present at the specific Xe-100 plant site.
4.
Throughout the white paper, the protection scheme goal is discussed as being either the prevention of significant core damage and/or the prevention of significant radiological release. The proposed TR should clarify the intended goal of the overall protection scheme (i.e., prevention of significant core damage, or prevention of offsite release above 10 CFR 100.11 (10 CFR 50.34) reference values.
If the goal is the prevention of significant core damage, then the term significant core damage should be defined in the proposed TR. Also clarify if it is based on damage just to the fuel, or the potential release from damaged fuel. If the definition relies on a potential release, consider clarifying the level (dose) that would be considered and how it relates to the objective of protecting the plant personnel and facility and preventing sabotage that could result in offsite doses above 25 rem total effective dose equivalent (TEDE) in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at the site boundary.
5.
The proposed TR should clarify the use of the term theft as it pertains to fresh fuel, irradiated fuel, or both. Identify if X-energy is proposing additional security measures to protect against theft of irradiated fuel beyond the self-protection qualities that exempt a PPS pursuant to 10 CFR 73.67(b)(1)(i).
Specific Observations by Section:
Section 1, INTRODUCTION Section 1.1, PURPOSE Consider clarifying the white papers first use of the term security plan by identifying that it includes a physical security plan (PSP), training and qualification plan (T&QP),
safeguards contingency plan (SCP), and cyber security plan (CSP), if applicable.
Section 1.2, SCOPE No Comment Section 1.3, RELATIONSHIP TO OTHER DOCUMENTS No Comment Section 2, XE-100 PLANT DESCRIPTION Section 2.1, OVERVIEW No Comment Section 2.2, REACTOR SAFETY DESIGN Page 14, identify the specific regulation and regulatory limits when discussing an offsite release from a Design Basis Accident at 400 meters. Are these the regulatory limits defined in Section 3.3 of this white paper?
Section 2.3, REFUELING OPERATIONS No Comment Section 2.4, XE-100 OPERATIONS No Comment Section 3, XE-100 INHERENT AND PASSIVE SAFETY CHARACTERISTICS Section 3.1, XE-100 PLANT FEATURES AFFECTING SECURITY APPROACH No Comment Section 3.2, SECURITY BY DESIGN Describe how the definition of vital areas will be changed for the Xe-100 in the proposed TR.
Section 3.3, CONSEQUENCE-BASED PERFORMANCE OBJECTIVE No Comment Section 4, XE-100 PLANT SECURITY STRATEGY (1) In the second paragraph, identify if the NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, [and Independent Spent Fuel Storage Installation Security Program], security plan template will be used to develop the site security plan. If so, identify if it will be NEI 03-12, Revision 7, or NEI 03-12, Revision 7.1 (with alternate compensatory measures). Otherwise, state if X-energy has developed their own security plan template design based on NRC regulations, orders, etc. Additionally, state if NEI 11-08, Guidance on Submitting Security Plan Changes, will be utilized for any security plan updates submitted under 10 CFR 50.54(p)(2).
(2) Confirm if a recommended testing option and/or any other recommendation in the most current revision of Regulatory Guide 5.44, Perimeter Intrusion Alarm Systems, will be utilized in the proposed TR.
(3) In the second paragraph, the last sentence mentions early adversary detection, commonly known as an early warning system (EWS). As per the May 26, 2016, NRC letter, The U.S. Nuclear Regulatory Commission Inspection Approach Related to Industry Implementation of Early Warning Systems, (letter is Official Use Only - Security Related Information, therefore is not publicly available) consider if the EWS will be a requirement for the success of your protective strategy or as an enhancement to the protective strategy (voluntary). If determined to be a requirement for a reactor site and will be credited in the PPS, consider the following (not all-inclusive):
EWS must satisfy the requirements of 10 CFR 73.55(b).
EWS barriers in the owner controlled area are subject to the requirements of 10 CFR 73.55(e)(1), through (e)(4); and (e)(6).
EWS is subject to the requirements of 10 CFR 73.55(e)(10) where vehicle control measures are performed as a function of the EWS.
EWS intrusion detection and assessment system is subject to the requirements of 10 CFR 73.55(i).
EWS is subject to the Maintenance, Testing, and Calibration requirements of 73.55(n).
EWS is subject to the Compensatory Measure requirements of 73.55(o).
(4) Ensure that all available information on new technologies to be used in the PPS is available for NRC staff review and audit. Ensure that cyber security considerations are included in the review of digital systems (e.g., artificial intelligence, robotics, etc.).
(5) The second paragraph indicates that the principal security objective for the Xe-100 plant is the protection of the plant personnel and facility and the prevention of sabotage that could result in offsite doses above 25 rem total effective dose equivalent (TEDE) in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at the site boundary. Later in the document, it is stated that the program will be designed to prevent core damage. The proposed TR should clarify if these objectives are considered the same by X-energy (i.e., core damage that could cause offsite release) or are considered two different objectives.
Section 4.1, PHYSICAL PROTECTION PROGRAM (1) Page 20, Section 4.1 discusses that Xe-100 plants will establish and maintain a Physical Protection Program which will include a security organization and agreements with Local Law Enforcement Agencies (LLEA) for support as needed, but no other details are discussed on the role of LLEA. The proposed TR should be more specific about the type of support and duties that LLEA will be expected to fulfill.
(2) Identify in the proposed TR if there are there any other areas at the site that might have inventories of radionuclide's that may cause a significant release (>25 rem). If so, identify if the program be designed to protect these areas.
Section 4.2, PLANT SECURITY ORGANIZATION No Comment Section 4.3, LOCAL LAW ENFORCEMENT ORGANIZATION No Comment Section 4.4, SECURITY PROGRAM PERFORMANCE EVALUATION Page 21, Section 4.4 describes in part, the drill and exercise program. Identify in the proposed TR if this program will include force-on-force drills.
Section 4.5, PHYSICAL PROTECTION SYSTEM DESIGN PRINCIPLES Section 4.5.1, Owner Controlled Area Design Consider referencing all applicable Regulatory Guides applicable to materials and plant protection (i.e., Division 5) when designing the PPS.
Section 4.5.2, Protected Area Design (1) Regarding tethered drones or any drone/unmanned aerial system that may be considered for the site protective strategy, ensure all applicable Federal Agencies rule(s)/proposed rule(s) have been reviewed and adhered to prior to implementation.
(2) Consider a compensatory measure(s) in case of bad weather, which could inhibit the intended function of a tethered drone.
Section 4.5.3, Vital Area Design No Comment Section 4.6, RESPONSE AGAINST THEFT/SABOTAGE No Comment Section 5, LICENSING APPROACH Section 5.1, OVERVIEW OF US REGULATORY REQUIREMENTS No Comment Section 5.1.1, Anticipated Exemptions No Comment Section 6, CONCLUSION No Comment Section 7, BACKGROUND RESEARCH No Comment Section 8, APPENDIX A (§73.55 COMPARISON MATRIX)
(1) The beginning of Section 8 states, in part, The Proposed Rule Language column lists changes (in red text) that is currently under review by the industry and the NRC as it pertains to advance reactors. However, no red text was found in this section.
(2) Page 35, Appendix A, Comparison Matrix (b)(3) Preliminary Xe-101 Analysis block, states, in part, that the Xe-100 is designed to operate so that material is protected against potential radiological theft. For power reactors, protection against theft is addressed by protecting against radiological sabotage and no extra measures are required. Once irradiated, the special nuclear material is considered radiologically resistant to theft (10 CFR 73.67). Identify if this statement in the block is referring to fresh fuel, irradiated fuel, or both.
(3) Page 36, Appendix A Comparison Matrix Preliminary Xe-101 Analysis block for (b)(3)(ii), clarify if the physical protection program will be designed to protect against radiological sabotage, offsite dose release, or both in the proposed TR. Define significant core damage in the proposed TR, if applicable.
(4) Page 59, Appendix A Comparison Matrix (f) Preliminary Xe-101 Analysis block, if the protection strategy is to prevent off-site dose above 10 CFR 100.11(a)(1) limits, identify why target sets and significant core damage are mentioned here. If target sets are being used, identify if there could be a release from somewhere other than the core and should that be considered in the target set identification process.
(5) Pages 117-124, Appendix A Comparison Matrix (r) Preliminary Xe-101 Analysis blocks, identify in the proposed TR what criterion will be used in the technical basis to support the use of alternatives. State whether the criterion be based on the function of the alternative being equal to the original, based on the ability to maintain protection against significant core damage, or based on protecting against offsite release, etc.
Principal Contributor(s):
Judy Petrucelli, NSIR/DPCP/RSB Pete Lee, NSIR/DPCP/RSB Beth Reed, NRR/DANU/UARP