ML21061A065

Chds Risk Informed EP and SMR Rule Presentation 3/02/2021

ML21061A065
Person / Time
Issue date:	03/02/2021
From:	Robert Kahler Policy and Oversight Branch
To:
Murray C
References
Download: ML21061A065 (28)

Text

CHDS REP Executive Education Programs Graded approach to EPR and perspectives related to SMR deployment March 2, 2021 Robert Kahler, Chief - NSIR/DPR/POB Policy and Oversight Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission

2 Reactor technology is advancing, EP is evolving, but the NRCs mission to protect the health and safety of the public remains unchanged

Commission Policy Statement on Advanced Reactors the Commission expects, as a minimum, at least the same degree of protection of the environment and public health and safety and the common defense and security that is required for current generation light-water reactors (LWRs) the Commission expects that advanced reactors will provide enhanced margins of safety and/or use simplified, inherent, passive, or other innovative means to accomplish their safety and security functions. (emphasis added)1 1 73 FR 60612; October 14, 2008

NRC Safety Policy and Reasonable Assurance

• NRC safety policy expresses the Commission's views on acceptable level of risks to public health and safety and on safety-cost tradeoffs in regulatory decision making Reasonable assurance of adequate protection of public health and safety is defined by the totality of Commissions health and safety regulations

• Adequate protection does not mean absolute protectionSafe is not the equivalent of risk-free2 When applicant/licensee demonstrates compliance with NRC regulations, it follows that there is reasonable assurance of adequate protection of public health and safety Once adequate protection is achieved, NRC is not empowered to drive risk even lower - that would be unnecessary regulatory burden NRC has the sole authority to make determinations regarding requirements for emergency preparedness, both onsite and offsite 2 Union of Concerned Scientists vs NRC 824F.2.d 114, 118 D.C. Cir 1987

Modernizing Advanced Reactor Licensing

- Defined an advanced nuclear reactor to mean a nuclear fission or fusion reactor with significant improvements compared to commercial nuclear reactors that include improvements such as additional inherent safety features, greater fuel utilization, enhanced reliability, increased thermal efficiency, and ability to integrate into electric and nonelectric applications.

• NRCS Vision and Strategy (ML16356A670)

- Readiness for non-light water reactors to include policy issue resolution on EP requirements for high-safety, low-consequence designs.

Licensing Modernization Project provides endorsed guidance (RG-1.233) that focuses on evaluating defense in depth for advanced reactor designs.

• NRC is modernizing its approach to licensing advanced reactors

- transparent manner with participation of all stakeholders as outlined in its webpage at https://www.nrc.gov/reactors/new-reactors/advanced.html

Objective of Radiological Emergency

• The overall objective of emergency preparedness (EP) at NRC is to ensure that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency

- Reasonable Assurance finding is made before a nuclear facility is licensed

- Inspected over the lifetime of that facility EP provides for dose savings for a spectrum of accidents that could produce doses in excess of the Environment Protection Agency (EPA) protective action guides (PAG) 6

NUREG-0396 Planning Basis Rationales NUREG-0396 Task Force Considered Various Planning Basis Rationales:

Risk Probability Cost Effectiveness Consequence Spectrum

• Principal rationale behind planning The Task Force based the rationale on a full spectrum of accidents and corresponding consequences, tempered by probability considerations.

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NUREG-0396 EP Planning Basis A spectrum of accidents should be considered to scope

• The distance to which planning for predetermined protective actions is warranted The time dependent characteristics of a potential release The type of radioactive materials 8

NUREG-0396 Emergency Planning Zones (EPZ)

The EPZ guidance does not change the requirements for emergency planning, it only sets bounds on the planning problem. The Task Force does not recommend that massive emergency preparedness programs be established around all nuclear power stations.

So how do you set the boundary?

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Scalable EPZ EPZ size based on the consequences from a spectrum of accidents, tempered by probability considerations.

NRC regulations provide for scalable EPZs.

Reactors have been approved for a 5 mile EPZ in the past.

Depending on facility type, the EPZ may be the site-boundary.

Considerable amount of studies since the 1980s on sizing EPZs for passive and advanced reactor designs all based on NUREG-0396 methodology.

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Graded Approach to EP A risk-informed process in which the safety requirements and criteria are set commensurate to the risk of the facility Existing NRC regulations employ EP graded approach Power reactors (low-power testing, power operations, decommissioning)

Research and test reactors Fuel Fabrication Facilities Independent Spent Fuel Storage Installations Monitored Retrievable Storage 11

Graded Approach to EP and Scalable

• NRC proposed rule provides a graded approach to EP that would base EPZ sizing for small modular reactors (SMRs) and other new technologies (ONT) on the risk of the facility involved

• Could result in a site containing a very low-risk power reactor with EPZ not greater than the site boundary, or smaller than for current large reactors

• Once adequate protection is achieved, NRC is not empowered to drive risk even lower - that would be unnecessary regulatory burden 12

Graded Approach to EP and Scalable EPZ

• NRC has the sole authority to make determinations regarding EPZ size and the requirements for both onsite and offsite EP and the overall determination of reasonable assurance o If NRC determines an EPZ size is greater than the site boundary, then formal offsite radiological emergency preparedness is a requirement NRC will consult with FEMA for review of the adequacy of offsite preparedness o If NRC determines an EPZ size is not greater than the site boundary, then formal offsite radiological preparedness is not a requirement Consultation with FEMA is not necessary o In either case, the NRC makes the final determination of reasonable assurance 13

EP for SMRs & ONT Rulemaking to develop a clear set of rules and guidance for small modular reactors (SMRs) and other new technologies Technology Neutral Risk-Informed, Performance Based Principle of dose-at-distance and consequence-oriented approach to determine EPZ size

• New designs/technologies are including features to enhance the margin of safety through use of simple, inherent, or passive means to accomplish their safety and security functions.

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Purposes of the Rule

• Provide an alternative performance-based, regulatory framework for SMRs and ONTs Address policy, licensing, and technical issues associated with SMR emergency planning

• Does not source terms, security, and siting criteria for SMRs or ONTs

Framework 10 CFR 50.33 Current EP Requirements for Production and Utilization Proposed EP Requirements for SMRs and ONTs 10 CFR 50.34 10 CFR 50.54 10 CFR 50.16 Appendix E Onsite Existing EP for Non-Power Production or Utilization 10 CFR 50.160(c)(1)(i)

-(iv)(A) 10 CFR 50.160(c)

All SMRs and ONTs 10 CFR 50.160(c)(2)-(4) 10 CFR 50.160(c)(1)(i)

-(iv)(A) and (B) 10 CFR 50.47 Existing EP for Nuclear Power Reactors Reasonabl e

Onsite and Offsite

Major Provisions of Proposed NRC Rule Technology-inclusive for future SMRs and ONTs, including medical radioisotope facilities and non-light-water reactors Scalable performance based EP regulatory framework is proportional to the risk without unwarranted regulatory burden

• Scalable EPZ size based on the consequences (1 rem / 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />) from a spectrum of credible accidents, tempered by probability considerations.

Ingestion planning capabilities rather than defined ingestion planning zone Hazard analysis for contiguous facilities

• New designs/technologies are including additional features to meet the expectations of the Commission Policy Statement on Advanced Reactors, issued in 2008

• NRC as a matter of long standing principle has licensed facilities such as research and test reactors, reactors at low power operation, and fuel facilities with EPZs that do not require a formal off-site EP program 17

Scalable EPZ Scalable approach for plume exposure pathway EPZ Consistent with the analyses documented in NUREG-0396 Environmental Protection Agency (EPA) Protective Action Guides (PAG) manual supports the EPZ-PAG and planning relationship Consistent with the existing graded-approach afforded to:

Research and test reactors Fuel cycle facilities Independent spent fuel storage installations

• Same level of protection afforded to public health

Emergency Response Performance Event Classification and Accident Mitigation Assessment Protective Actions Communications Command and Control Staffing and Operations Protective Equipment Releases Reentry Critique and Corrective Actions

Offsite Planning Activities EPZ beyond site boundary Contacts and Arrangements Offsite organizations descriptions Protective measures Site familiarization training for onsite response Evacuation time estimates Offsite emergency response facilities Dose projections Public information, Alert and Notification System (ANS), prompt action descriptions Reentry Drills and exercises

Offsite Planning Activities EPZ within site boundary Contacts and Arrangements Offsite organizations descriptions Protective measures Site familiarization training for onsite response

• Evacuation time estimates

• Offsite emergency response facilities Dose projections Public information, ANS, prompt action descriptions

• Reentr

• Drills and exercises

22 The proposed rule simply allows the nuclear industry to be credited for recent and continuing design innovations and to deploy new designs employing these innovations in a way that enhances safety.

Department of Energy (DOE) Comment letter on the proposed Emergency Preparedness for SMR and ONT rulemaking.

• Proposed rule federal register notice for public comment

- https://www.gpo.go v/fdsys/pkg/FR-2020 12/pdf/2020-09666.pdf Proposed rule public comment period ended September 25, 2020

NRC Rulemaking Process A TYPICAL RULEMAKING PROCESS RULEMAKING TRIGGERS

• Congress/Executive order

• Comm ission/ EDO direction

• Staff -ident i fied need COMMISSION REVIEW AND APPROVAL OF DRAFT FINAL RULE

• Commission issues staff requirements memorandum

• Staff resolves C

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• Petition for COMMISSION REVIEW AND APPROVAL OF RULEM AKING PLAN PUBLIC INVOLVEMENT/

STAKEHOLDER INPUT

• Advance notice of proposed rulemak ing

• Regulatory basis

• Preli minary proposed rule language P bli ti STAKEHOLDER INPUT 1111 STAFF EVALUATES PUBLIC COMMENTS PUBLISH FINAL RULE

• Final environmental assessment

• Final regulatory analysiS

• Final guidance PUBLISH PROPOSED RULE FOR COMMENT

• Draft environmental assessment

• Draft regulatory analysis (cost -benefit )

• Draft guidance P bli ti COMMISSION REVIEW AND APPROVAL OF DRAFT PROPOSED RULE

• Commission issues staff requirements memorandum

• Staff resolves Commission comments U.S.NR C On l, <<J :S,a, a N"dc-1r Ft g,ul*oo*y Co n, rnln l., n ru-,i rig Pt:r,p lc n11d t b t:E mfl nm mn tt RULE COMPLIANCE DEADLINE I.

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• NRC Public Website for rule information

- https://www.nrc.gov/reading-rm/doc-collections/rulemaking-ruleforum/active/RuleDetails.html?id=18

• https://www.regulations.gov

- Search on Docket NRC-2015-0225

Contact Information Robert Kahler, Branch Chief Policy and Oversight Branch Office of Nuclear Security and Incident Response robert.kahler@nrc.gov

+1 301 287 3756

ANS - Alert and Notification System CFR - Code of Federal Regulations DOE - Department of Energy EPA - Environmental Protection Agency EPR - Emergency Preparedness and Response EPZ - Emergency Planning Zone FEMA - Federal Emergency Management Agency LWR - Light Water Reactor ONT - Other New Technology(ies)

PAG - Protective Action Guides NRC - Nuclear Regulatory Commission Acronyms