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| | number = ML21263A010 | | | number = ML21263A010 |
| | issue date = 09/17/2021 | | | issue date = 09/17/2021 |
| | title = Proposed Rule: Advanced Reactor Security - Email from NEI (D. Young) Ml#'S for Previous Comments on Topics Discussed and 2 Comments from Public Meeting on 9/17/2021 | | | title = Proposed Rule: Advanced Reactor Security - Email from NEI (D. Young) ML 'S for Previous Comments on Topics Discussed and 2 Comments from Public Meeting on 9/17/2021 |
| | author name = Young D | | | author name = Young D |
| | author affiliation = Nuclear Energy Institute (NEI) | | | author affiliation = Nuclear Energy Institute (NEI) |
Latest revision as of 18:00, 23 May 2022
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Category:E-Mail
MONTHYEARML23270B8992023-09-27027 September 2023 Email NEI Request for an Extension of Comment Period on Proposed Revision to Standard Review Plan Section 15.0, Introduction - Transient and Accident Analyses, Docket Id NRC 2023 0079 ML23229A1202023-08-17017 August 2023 NRR E-mail Capture - Information Email Capture of Advanced Reactor Content of Application Project and Technology Inclusive Content of Application Project Guidance Document Comments ML23214A2532023-08-0101 August 2023 (Nei), Request for Review and Endorsement of NEI 99-04, Rev. 1, Guideline for Managing NRC Commitment Changes ML23171A0212023-06-16016 June 2023 NRR E-mail Capture - (External_Sender) Request for an Extension of Comment Period on Draft Interim Staff Guidance Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap, Docket Id NRC-2022-0074 ML23153A1262023-06-0101 June 2023 NRR E-mail Capture - (External_Sender) Re Industry Discussion Topics for Arcapticap Discussion in June 7th 2023 Meeting ML23110A6772023-04-18018 April 2023 Email-Fee Exemption Request for Review and Endorsement of NEI 23-03 ML23110A6782023-04-18018 April 2023 Request for Review and Endorsement of NEI 23-03, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications at Non-Power Production or Utilization Facilities ML23138A1542023-03-24024 March 2023 Transmittal of NEI 22-05, Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07 ML22349A6582022-12-14014 December 2022 NEI Responses to NRC Comments on Draft NEI 99-01, Revision 7, Developments of EALs for Non-Passive Reactors ML22349A1012022-12-12012 December 2022 LTR-22-0343 Ellen Ginsberg, Sr. Vice President, General Counsel and Secretary, Nuclear Energy Institute, Expresses Concerns Related to Issuance of Regulatory Issue Summary 2022-02; Operational Leakage ML22019A2912022-01-12012 January 2022 (External-Sender) Submittal of Proposed Revisions to Aging Management Programs XI.M33, Selective Leaching and XI.E3 ML21270A1322021-09-24024 September 2021 Transmittal Email (External Sender - NEI) NEI 17-06 - NEI Response to NRC Comments ML21263A0102021-09-17017 September 2021 Proposed Rule: Advanced Reactor Security - Email from NEI (D. Young) ML 'S for Previous Comments on Topics Discussed and 2 Comments from Public Meeting on 9/17/2021 ML21236A2032021-08-24024 August 2021 NRC Comments on Npuf Guidance 2021 Draft Without Npuf Rule.Docx ML21236A0882021-08-23023 August 2021 Email-Request for Review and Endorsement of NEI 21-06 Guidelines for 10 CFR 50.59 Implementation at Non-Power Production or Utilization Facilities.Msg ML21257A2352021-08-19019 August 2021 Rulemaking: Proposed Rule: Advanced Reactor Physical Security, Email Exchange Between Nrc and NEI Draft Pages from NEI-20-05 Rev. E ML21223A1992021-08-0909 August 2021 Email to NRC - Rroar Discussion Items ML21208A1752021-07-26026 July 2021 Email from Bill Gross NEI, Associated with the White Paper Development of Adversary Timelines (Withheld Under 2.390) ML21161A0272021-05-31031 May 2021 NEI Industry Feedback on RG 1.183 5-31-2021 ML21153A1352021-05-26026 May 2021 Comments on NRC Proposal for TSTF-505 and PRA Methods - 05/26/2021 ML21175A0502021-05-20020 May 2021 Rulemaking: Proposed Rule: Advanced Reactor Physical Security, Email from D. Young, NEI to D. Andrukat, NRC Discussion of NEI 20-05 Target Set Term ML21137A0572021-05-14014 May 2021 Rulemaking: Proposed Rule: Advanced Reactor Physical Security-Email from Young to Andrukat, May 2021 Draft D of NEI 20-05 Methodological Approach and Considerations for a Tech Analy to Demonstrate Compliance with the Eligibility Criteria of ML21138A8872021-05-0707 May 2021 5_7 Email Transmittal for Fee Waiver Request for NEI 99-01 Rev 7 ML21120A0562021-04-29029 April 2021 NRR E-mail Capture - (External_Sender) Issuance of NEI 21-01: Industry Guidance to Support Implementation of Nrc'S Risk-Informed Process for Evaluations ML21175A0362021-04-21021 April 2021 Rulemaking: Proposed Rule: Advanced Reactor Physical Security Email from D. Young, NEI to N. Valliere, D Andrukat, S. Helton, P. Lee, NRC Summary Table Showing Key Attributes for Eligibility Criteria ML21175A0352021-04-15015 April 2021 Rulemaking: Proposed Rule: Advanced Reactor Physical Security, Email from D. Young, NEI to D. Andrukat, NRC Follow-up Questions on NRC Response to NEI Question Concerning Proposed Eligibility Criterion 10 CFR 73.55(a)(7)(i)(A) ML21175A0432021-03-22022 March 2021 Rulemaking: Proposed Rule: Advanced Reactor Physical Security, Email from D. Young, NEI to D. Andrukat, NRC Question on the Term Unmitigated as Used in Proposed Eligibility Criterion 10 CFR 73.55(a)(7)(i)(A) ML21085A0262021-03-22022 March 2021 NRR E-mail Capture - NEI Draft Industry Guidance to Support Implementation of Nrc'S Risk-Informed Process for Evaluations ML21006A3082020-12-21021 December 2020 Comments on Draft IMC-0335 ML20342A1702020-11-23023 November 2020 NEI Input on NRC Annual Fee Assessment for Non-Light Water Reactors ML20288A4992020-09-14014 September 2020 Additional Supporting Information for the Review of FAQ 20-03 ML20259C5882020-09-11011 September 2020 NEI 14-05A R1 NEI Transmittal Response 9-11 to July NRC RAIs (e-mail) ML20351A2182020-08-31031 August 2020 NEI 20-07 Guidance for Addressing Software Ccf_Kscarola ML20245E5612020-08-31031 August 2020 Guidance for Addressing Software Common Cause Failure in High Safety-Significant Safety Related Digital I&C Systems ML21050A0902020-08-31031 August 2020 Staff Detailed Comments - NEI 20_07 Draft Revision B -February 2021 ML20177A4952020-06-23023 June 2020 NEI Comments on BTP 7-19, Revision 8 Submitted June 23, 2020 ML20154K5542020-05-28028 May 2020 Email and Letter from Rmccullum: NEI Comments on Spent Fuel Reprocessing Rulemaking ML20142A2842020-05-21021 May 2020 NEI Initial Comments on RG 1.187 Rev 2 Prior to ACRS Meeting on May 20, 2020 (Email) ML20143A0292020-05-21021 May 2020 NEI Suggested Edits to RG 1.187 (Email) ML20142A2892020-05-19019 May 2020 Additional NEI Comments on RG 1.187 Rev 2 Prior to ACRS Meeting on May 20, 2020 (E-Mail) ML20135H2092020-05-13013 May 2020 5_13 Email of NEI Submittal of Response to RAI NEI 14-05A, Revision 1 ML20107D8942020-04-13013 April 2020 Email from D. Young Draft B of NEI 20-05, Methodological Approach and Considerations for a Security Assessment to Demonstrate Compliance with the Performance Criteria of 10 CFR 73.55(TBD) ML20104A3082020-04-10010 April 2020 NEI Email, Dated April 10, 2020, Draft a of NEI 20-05 ML20107G8142020-04-0606 April 2020 Email from Nuclear Energy Institute (NEI) to NRC Transmitting NEI Comments on Draft Temporary Instruction 2514/194 ML20049A0182020-02-14014 February 2020 Email - SBT Definition and Submittal Issue ML20043F4772020-02-11011 February 2020 NRC Acknowledgement E-mail to Nuclear Energy Institute 02112020 E-mail Draft COM-106 Review ML20043F4782020-02-11011 February 2020 02112020 Nuclear Energy Institute Email Draft COM-106 Review ML20038A1942020-02-0606 February 2020 NEI Di&C Wg Comments on Draft Rev 8 to BTP 7-19 in Support of the Feb 11, 2020 Public Meeting - Email ML20037B0872020-02-0404 February 2020 FAQ 20-01 Email ML20112F3292020-02-0303 February 2020 NEI Email (Mike Tschiltz) on Part 50/52 Rulemaking, February 3, 2020 2023-09-27
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From: YOUNG, David To: Valliere, Nanette; Reed, Beth Cc: Atack, Sabrina; Prasad, Stacy; Cubellis, Louis; Andrukat, Dennis; NICHOL, Marcus; Lee, Pete
Subject:
[External_Sender] ML#"s for previous comments on topics discussed yesterday + 2 comments Date: Friday, September 17, 2021 2:10:39 PM Nan and Beth, Good afternoon.
As I mentioned in my closing remark during yesterdays meeting, here are the links to our previous comments on proposed Criterion A:
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?
AccessionNumber=ML21175A043 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?
AccessionNumber=ML21175A036 Also, here are the two overarching comments we made during yesterdays meeting:
- 1. We intended the eligibility criteria to be performance-based facility design criteria and not criteria for applying a graded approach to security. The goal was to provide criteria that advanced reactor vendors could use to guide their design decisions, particularly with respect to features that could obviate the need for a dedicated onsite armed response force. As we said in our 2016 white paper:
In light of the above, the industry is proposing new physical security requirements for advanced reactor technologies. It is recognized that no design has yet been submitted to the NRC for review; therefore, the proposed requirements are grounded in a set of performance capabilities that serve as criteria for identifying facilities with designs that can prevent radiological sabotage primarily through engineered safety and security features. This approach allows new regulations to be established generically in advance of a design- or site-specific application. By demonstrating that a proposed facility can meet a performance capability, an applicant could obtain a license through compliance with a set of physical security requirements developed specifically for advanced reactor technologies. These same requirements would continue to apply to the licensee during operation of the facility.
Note: The term performance capabilities evolved into eligibility criteria.
Also, we previously responded to NRC staff questions about developing a graded approach - see here (ML17263B142), the responses to staff questions #5 and #7.
Our responses indicate that we were not supportive of that approach.
- 2. We believe it is critically important for technical/consequence analysis guidelines to allow realistic credit for all engineered safety and security features described in the facility licensing basis. Tangential guideline goals expressed by the staff such as ease of analysis and analysis flexibility should not preclude the first-order goal of driving realistic security assessments. The staffs presentation yesterday, which described an approach that would, in some cases, not provide realistic credit for
certain features in order to achieve benefits in analysis space, is concerning because the resulting eligibility criteria could lead to outcomes that are unnecessarily burdensome and exceed the reasonable assurance of adequate protection threshold. For example, its unclear why some features required by regulations (e.g.,
delay requirements) cannot be credited in an analysis for Criterion A. Advanced reactor vendors are expending significant resources to incorporate enhanced safety and security features with a reasonable expectation that those features will provide a rationale for a commensurate reduction in regulatory burden for a facility operator.
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.