ML14064A568
| ML14064A568 | |
| Person / Time | |
|---|---|
| Issue date: | 03/06/2014 |
| From: | NRC/NSIR/DPR |
| To: | Nuclear Energy Institute |
| Michael Norris | |
| References | |
| NRC-2014-0002, NSIR/DPR-ISG-02 | |
| Download: ML14064A568 (13) | |
Text
Proposed Interim Staff Guidance (NSIR/DPR ISG 02)
Emergency Preparedness Activities for Decommissioning Reactors Category 2 Public Meeting with NEI/Industry Representative March 6 6, 2014
PURPOSE Discuss NRC staffs Di t ff application li ti off precedent d t iin th the development of draft NSIR/DPR-ISG-02 to facilitate stakeholder review and comment
- Formal comments need to be submitted via www.regulations.gov (Docket No. NRC-2014-0002) 2
PURPOSE Meeting NOT intended to discuss:
- Application of draft ISG to any specific licensing activities currently under Staff review; or
- Aspects A t or application li ti off the th recentt studies t di -
- Consequence Study of a Beyond Design Basis Earthquake g the Spent Affecting p Fuel Pool for a Mark I Boiling g Water Reactor (ML13256A342), or
- Related Regulatory Analysis for Japan Lessons-Learned Tier 3 Issue on Expedited Transfer of Spent Fuel Fuel (ML13273A628).
(ML13273A628) 3
Regulatory Basis
- Regulations require licensee under Part 50 to maintain an emergency plan that meets all requirements
- Current EP regulations do NOT take into consideration reduced consequences q associated with p potential accidents that may occur at a permanently shutdown NPP
- Historically, exemptions have been used to grant regulatory l t relief li f on a case-by-case b b i basis
- Until an exemption is issued, onsite and offsite EP programs must be maintained and all EP requirements met, including exercises 4
Regulatory Basis
- Why not a License Amendment?
- 10 CFR 50.90 (amendment) applies to licensees seeking to change their license conditions in how they comply with regulations
- 10 CFR 50.54(q)(4) requires a licensee to submit a license amendment for emergency plan changes that reduce the effectiveness of the plan
- 10 CFR 50.12 (exemption) applies to licensees seeking regulatory relief - no longer needs to comply with regulation 5
Regulatory Basis
- SRM-SECY-08-0024 ((May y 19, 2008): )
The staff should request Commission approval for any reduction in effectiveness of a licensees emergency plan that requires an exemption from the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50
- Previous exemptions did not required Commission approval
- License-specific EP exemptions will be provided to the Commission via SECY Paper for approval until further Commission Co ss o d direction ect o p provided o ded 6
ISG Overview/Discussion
- PURPOSE / SCOPE (Sections 1.0 & 2.0)
- BACKGROUND / EXISTING GUIDANCE (Sections 3.0 & 4.0)
- Proposed Integrated NPP Decommissioning Rulemaking (EP (EP, insurance insurance, and safeguards) consistent with 10 CFR 72.32 EP requirements
- Returned w/o vote pending completion of supporting technical analysis (NUREG-1738)
- Provided options and recommendations
- EDO Memo M to t Commission C i i (post
( t 9/11)
- Recommended withdrawal of SECY-01-0100
- Continue to evaluate exemptions on an adhoc basis 7
ISG Overview/Discussion (Contd)
- Evaluation of EP Exemptions (Section 5.0)
[Exemption Precedent] SFP analyses demonstrating that:
- Applicable Design Basis Accident(s) could NOT result in projected doses to public exceeding EPA protective action guides; AND
- Spent fuel is NOT susceptible to a zirconium fire or sufficient time would be available, available if necessary necessary, to take offsite protective measures on an all hazards basis (without preplanning)
- NRC determined that >10 hours was sufficient time in its evaluation of previous site-specific exemption requests 8
ISG Overview/Discussion (Contd)
- EP Exemptions Consideration Discussion (Table 1)
- Cannot use to revise regulation intent or wording, rather identify portions that are no longer applicable (strikeout)
- G Guidance id ffor Evaluation E l ti off Decommissioning D i i i Emergency Plans (Attachment 1)
- Intended I t d d tto serve as template t l t (acceptable
( t bl alternative) lt ti )
9
58 Transition Phases
- Operating p g Power Reactor Emergency g y Plan to Decommissioning Emergency Plan/EALs
- Proposed use of EP Frequently Asked Question (EPFAQ) process http://www.nrc.gov/about-nrc/emerg-preparedness/faq/faq-contactus.html
- Decommissioning Emergency Plan/EALs (spent fuel pool) to ISFSI Emergency Plan/EALs 11
Opportunity for Public Comment 12
NRC Contacts (NSIR/DPR)
Joseph D. Anderson, Chief Operating Reactor Licensing and Outreach Branch (301) 28 287-9300 9300 joseph.anderson@nrc.gov Michael Norris, Leader O
Operating ti Reactor R t Licensing Li i Team T
(301) 287-3754 michael.norris@nrc.gov Michael Mi h l Wasem W
Emergency Preparedness Specialist (301) 287-3793 michael.wasem@nrc.gov 13