ML18177A265
| ML18177A265 | |
| Person / Time | |
|---|---|
| Issue date: | 06/20/2018 |
| From: | Robert Kahler Policy and Oversight Branch |
| To: | |
| References | |
| Download: ML18177A265 (25) | |
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Power Reactors Transitioning to Decommissioning Rulemaking FEMA IX Workshop San Luis Obispo, CA June 20, 2018 Robert Kahler, Chief Policy and Oversight Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission
Recent Decommissioning Sites
Future Decommissioning Sites 3
Illustrative Milestones 4
Decommissioning Rulemaking
- Regulations do not fully address risk at permanently shutdown and permanently defueled reactor sites.
- Exemptions from regulations provide relief on a case-by-case basis.
- Commission directed rulemaking to include consideration of a graded approach to EP (SRM SECY-14-0118).
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Advanced Notice of Proposed Rulemaking 6
Emergency Preparedness Physical Security Fitness for Duty Requirements for Certified Fuel Handlers Regulatory Approach for Decommissioning Application of Backfitting Protection Decommissioning Trust Funds Offsite and Onsite Liability Protection General Questions (e.g., Cumulative Effects of Regulation)
Federal Register (80 FR 72358), November 19, 2015
Rulemaking Goals
- Maintain reasonable assurance of adequate protection of the public health and safety
- Maintain EP as an independent layer of defense-in-depth
- Provide regulatory certainty and clarity
- Gain efficiencies from previous efforts Exemption requests Prior decommissioning rulemaking efforts Supporting studies 7
EP Planning Basis
- The overall objective of EP is to provide dose savings for a spectrum of accidents that could produce offsite doses in excess of PAGs
- Planning basis elements consider distance, timing, materials
- EPZs are areas for which planning is needed to assure that prompt and effective actions can be taken to protect the public in the event of an accident
- After permanent cessation of operations:
8 The spectrum of accidents are fewer DBAs will not exceed EPA PAGs offsite At least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> available before release occurs
Research to Support Rulemaking NUREG-1738, Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants NUREG-2161, Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor Supporting Research Studies (ADAMS ML16110A416)
Analysis of Mitigative Actions Spent Fuel Decay Time Dose Rate of Accidental Radiological Release from Spent Fuel Pool 9
Draft Proposed Rulemaking
- The following contains information that was provided to the Commission on May 7th to support the Draft Proposed Transition to Decommissioning Rulemaking.
- Although made public on May 22nd, the rulemaking has not been issued for public comment.
- The Commission will vote on the rulemaking and provide a Staff Requirements Memorandum (SRM) with direction on how to proceed.
- As such, the rule language and accompanying guidance may change and should not be considered final.
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Graded Approach Level 1 Permanent cessation of operations and all fuel in spent fuel pool Level 2 Spent fuel has sufficiently decayed (10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> adiabatic heatup time)
Level 3 All fuel is in dry cask storage Level 4 All fuel removed from site 11
Decommissioning EP Levels 12 Level 1 Post Shutdown Emergency Plan (PSEP) 10 months (BWR) 16 months (PWR)
Level 2 Permanently Defueled Emergency Plan (PDEP)
Level 3 ISFSI Only Emergency Plan (IOEP)
> 5 years Cessation of Power Operations and Defueled Power Operations Level 4 No Spent Fuel Onsite
Regulatory Framework
- Current Framework Planning Standards (10 CFR 50.47(b), 10 CFR 72.32(a))
Content of Emergency Plans (Appendix E to 10 CFR Part 50)
Conditions of License (10 CFR 50.54(q), 50.54(t))
Content of Emergency Plans (specific to PSEP, PDEP, IOEP)
Conditions of License 10 CFR 50.200 13
- PSEP may start after NRC dockets licensees certifications of certifications of permanent cessation of operations and permanent removal of all fuel from the reactor vessel.
- PSEP is a transition period
- May only last 10 months (BWR) to 16 months (PWR)
- Significant changes to plan not anticipated
- No changes to regulations for offsite emergency plan 14
- Proposed Rule provides for:
- Reduced ERO staffing
- Revisions to EALs
- ETE updates no longer required
- Annual dissemination of information to the public future plant status
- Revised exercise schedule (drill cycle maintained) 15
Permanently Defueled EP (PDEP)
- Spent fuel has sufficiently decayed such that a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> exists before onset of SFP fire.
- Design-basis accidents would not exceed 1 Rem offsite
- For beyond design-basis accidents, sufficient time is available to implement successful mitigation measures, or, if necessary, initiate protective actions 16
Permanently Defueled EP (PDEP)
- 10 CFR 50.200(b) and (c)
- Proposed Rule provides for:
- Reduced ERO staffing
- Classification and Notification timeliness commensurate to risk and accident timing
- Events classified as NOUE or Alert
- No offsite (REP) planning requirements o No defined EPZs beyond the site boundary o No demonstration of capability for prompt public alerting o No pre-determined Protective Actions 17
Permanently Defueled EP (PDEP)
- Proposed Rule provides for:
- Revisions to EALs
- Emergency response facilities (TSC, OSC, EOF) may be combined
- Biennial exercise within 2 years of entering into decommissioning (drill cycle maintained)
- No hostile action requirements (security EALs maintained) 18
Permanently Defueled EP (PDEP)
- 10 CFR 50.47(f) Planning standards do not apply to offsite EP if EPZ does not extend beyond the site boundary.
- 10 CFR 50.54(s)(3) Clarifies how NRC will make findings and determinations of reasonable assurance when planning standards do not apply to offsite.
- (s)(3)If the planning standards for radiological emergency preparedness apply to offsite radiological emergency response plans, the NRC will base its finding on a review of the FEMA findings and determinations as to whether State and local emergency plans are adequate and capable of being implemented, and on the NRC assessment as to whether the licensee's emergency plans are adequate and capable of being implemented.
- 10 CFR 50.54(t) EP program element review at 2 year intervals until all fuel in dry cask storage.
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- IOEP may start after all spent fuel is in dry cask storage
- IOEP utilizes established EP planning standards for ISFSIs contained in 10 CFR 72.32(a)
- Part 50 and Part 52 licensees are granted a general Part 72 license
- Application for a specific Part 72 license would require NRC approval of emergency plan 20
Coordination with OROs
- Close coordination with OROs maintained in proposed rule
- Arrangements for offsite services support
- Communications maintained and tested periodically
- Annual review of EALs
- Radiological orientation training program for local services
- Voluntary participation in exercises
- 10 CFR 50.54(t) evaluation of State and local interfaces 21
Decommissioning Rulemaking Emergency Plan Change Process Transition to Levels Changes within Levels Changes in Final Safety Analysis Report (FSAR)
Changes in Emergency Action Levels (EALs) Classifications and Scheme(s) 10 CFR 50.54(q)(7) Licensee may elect to follow and maintain a Level standard when conditions are met.
10 CFR 50.54(q)(8) Clarifies need for Reduction in Effectiveness (RIE)
Transition between levels is not an RIE if changes comply with standards.
Changes to e-plan are not RIEs if supported by Final Safety Analysis Report (FSAR) for Safety Systems and Components (SSCs) out of service.
Changes to EAL not RIE if physically unattainable.
Draft EP Regulatory Guide to accompany proposed rule
- DG-1346, Emergency Planning for Decommissioning Nuclear Power Reactors (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17311B018),
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Decommissioning Rule Schedule
- Final Regulatory Basis November 2017, ML17215A012
- Proposed Rule/Draft Regulatory Guidance Provided to Commission in May 7, 2018 Public May 22, 2018, ADAMS Package ML18012A019
- Start of 75-day Public Comment Period December 2018
- Final Rule/Final Regulatory Guidance Goal: Provide to Commission CY2019
- Regulations.gov Docket ID NRC-2015-0070 24
Contact Information Robert Kahler, Chief NSIR/DPR/POB (301) 287-3756 robert.kahler.@nrc.gov Todd Smith, PhD Ed Roach EP Specialist Senior EP Specialist NSIR/DPR/POB NSIR/DPR/POB (301)-287-3744 (301) 287-9229 todd.Smith@nrc.gov ed.roach@nrc.gov 25