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2024 NEI Early Warning System (EWS) Presentation - NEI Slides
	ML24228A210
Person / Time
Site:	Nuclear Energy Institute
Issue date:	08/20/2024
From:	; Nuclear Energy Institute
To:	Leach T; NRC/NSIR/DPCP/RPPB
References
	ML24228A209
	Download: ML24228A210 (1)
	v • d • e

Response

Requirements and Credit for Early Warning Systems

Terminology

Methodology and Analysis

Required Systems

Questions on Required Systems

Voluntary Systems

Questions on Voluntary Systems

©2024 Nuclear Energy Institute 3 Terminology The term early warning system (EWS) was used dating back to the mid-2010s to describe a system beyond the protected area barrier, which would be used to provide early engagement opportunities for some licensees protective strategies and would be the point needed to effectively implement other licensees response to ensure interdiction.

In 2016 the NRC and industry used the terms voluntary system and required system to differentiate between the two systems with different objectives.

©2024 Nuclear Energy Institute 4 Terminology For purposes of this presentation the terms voluntary system and required system will be used to ensure a common understanding of the system being discussed, however these terms are not defined in the 10 CFR and do not adequately represent the description of each system in meeting the specific objective for the system.

The industry proposes new terms be developed that more closely represent the intend function of the systems.

Analysis of 10 CFR 73.55 related to Required and Voluntary Systems

©2024 Nuclear Energy Institute 6 Analysis An excel spreadsheet (crosswalk) containing each section of 73.55 was reviewed to determine the minimum requirements as well as additional requirements a licensee may need to meet the specific objective of the sites required or voluntary system.

A clear indication of the licensees system objective related to existing regulations A basis for system design and capabilities A tie to existing inspection criteria A foundation to develop a Security Plan summary Evaluation of when a licensing action may be required

Although the description would still be required, the crosswalk eliminates ambiguity in the description of the plan and provides direct ties to inspectable criteria based on the systems specific objective.

Licensees Physical Security Plan

Required Systems

(4) Upon detection of abnormal presence of activity of persons or vehicles within an isolation zone, a protected area, or a vital area, or upon evidence of intrusion into a protected area or a vital area, the facility security organization shall:

(i) Determine whether or not a threat exists, (ii) Assess the extent of the threat, if any, (iii) Inform local law enforcement agencies of the threat and request assistance, if necessary.

(iv) Require guards or other armed response personnel to interpose themselves between vital areas and any adversary attempting entry for purposes of industrial sabotage, and -

(v) Instruct guards or other armed response personnel to prevent or delay an act of industrial sabotage by applying a sufficient degree of force to counter that degree of force directed at them, including the use of deadly force when there is a reasonable belief it is necessary in self-defense or in the defense of others.

(3) The physical protection program must be designed to prevent significant core damage and spent fuel sabotage. Specifically, the program must:

(i) Ensure that the capabilities to detect, assess, interdict, and neutralize threats up to and including the design basis threat of radiological sabotage as stated in § 73.1, are maintained at all times.

(ii) Provide defense-in-depth through the integration of systems, technologies, programs, equipment, supporting processes, and implementing procedures as needed to ensure the effectiveness of the physical protection program.

Required systems are designed to ensure one specific aspect of 10 CFR 73.55(b)(3) can be achieved. Specifically, the ability to interdict.

Detection X

X Assessment X*

X Initiate response X

X Storage for SNM X

Unescorted Access X

First barrier for Vital Area X

Required system vs. Protected Area

May be needed based on site specific design

73.55(i), Detection and assessment systems 73.55(n), Maintenance, testing, and calibration, and 73.55(o), Compensatory measures Additional section of 10 CFR 73.55 may be applicable depending on the site capability to meet the specific objective of interdiction.

Minimum Requirements of a Required System

©2024 Nuclear Energy Institute 14 In addition to 73.55(i), 73.55(n), and 73.55(o), licensees may need to meet additional sections of 10 CFR 73.55 depending on the sites capability to detect, assess, and interdict. These sections may include, as applicable:

73.55(e)(1)-(4), Physical barriers 73.55(e)(6), Owner controlled area 73.55(e)(7), Isolation zone 73.55(g), Access controls 73.55(h), Search programs Additional Requirements as Applicable

©2024 Nuclear Energy Institute 15 In certain circumstances a licensee may need a licensing action to meet the limited scope objective. In these instances, justification should be provided for NRC approval, as to how the system meets or exceeds the specific performance objective of which it was designed for.

Possible licensing actions include:

73.55(r), Alternative measures 73.5, Specific exemptions Alternative Measures and Exemptions

©2024 Nuclear Energy Institute 16 The crosswalk provides the appropriate sections of the existing 10 CFR 73.55 requirements the system is designed to meet. This crosswalk is essential for the licensee and regulator to have a common understanding of the design basis and intended capabilities of the required system.

This crosswalk can be used to develop a description in the security plan consistent with design and intended capabilities of the system.

Inspection criteria is already available for each section of the code credited. NEI 03-12, Revision 8, will contain a section to document the description and design requirements of the sites required system.

Documentation of a Required System

Voluntary Systems

©2024 Nuclear Energy Institute 19 Unlike a required system, voluntary systems are not needed to meet the performance objective of 73.55 and therefore have no minimum requirements, however, in addition to the specific sections the licensee identifies based on the sites enhancement, the following sections as applicable would apply to receive credit during inspections:

73.55(n), Maintenance, testing, and calibration, and 73.55(o), Compensatory measures 73.55(n) and 73.55(o) provides reasonable assurance that the system is adequately maintained and reliable.

Minimum Requirements of a Voluntary System

These 73.55(i) requirements combined with applicable sections of 73.55(n) and (o) comprise the requirements of the licensee voluntary system to be inspected and therefore given credit during inspections.

©2024 Nuclear Energy Institute 22 The crosswalk used in the previous slide provides the appropriate sections of the existing 10 CFR 73.55 requirements the system is designed to meet. This crosswalk is essential for the licensee and regulator to have a common understanding of the design basis and intended capabilities of a voluntary system.

This crosswalk can be used to develop a description in the security plan consistent with design and intended capabilities of the system.

Inspection criteria is already available for each section of the code credited. NEI 03-12, Revision 8, will contain a section to document the description and design requirements of the sites voluntary system.

Documentation of a Voluntary System

Example: Alarms are received at a static post other than an alarm station.

In this case the licensee would describe the design feature in the security plan without citing a specific section of 10 CFR 73.55.

Documentation of a Voluntary System

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