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 2014 March 6, 2014
PURPOSE Di NRC t ff li ti f
d t i th Discuss NRC staffs application of precedent in 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 A
t li ti f th t t di
- Aspects or application of the recent studies -
- Consequence Study of a Beyond Design Basis Earthquake Affecting the Spent Fuel Pool for a Mark I Boiling Water Reactor g
p g
(ML13256A342), or
- Related Regulatory Analysis for Japan Lessons-Learned Tier 3 Issue on Expedited Transfer of Spent Fuel (ML13273A628)
Issue on Expedited Transfer of Spent Fuel (ML13273A628).
3
Regulatory Basis
- Regulations require licensee under Part 50 to maintain an emergency plan that meets all requirements emergency plan that meets all requirements
- Current EP regulations do NOT take into consideration reduced consequences associated with potential q
p accidents that may occur at a permanently shutdown NPP
- Historically, exemptions have been used to grant l t li f b
b i
regulatory relief on a case-by-case basis
- Until an exemption is issued, onsite and offsite EP programs must be maintained and all EP requirements 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 regulation 5
Regulatory Basis
- SRM-SECY-08-0024 (May 19, 2008):
(
y
)
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 direction provided Co ss o d ect o p 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, 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 M t
C i
i
(
t 9/11)
- EDO Memo to Commission (post 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:
[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 if necessary to take sufficient time would be available, if 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 id f
E l
ti f D i
i i
- Guidance for Evaluation of Decommissioning Emergency Plans (Attachment 1)
I t d d t t
l t
(
t bl lt ti
)
- Intended to serve as template (acceptable alternative) 9
85
Transition Phases
- Operating Power Reactor Emergency Plan to p
g g
y 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 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 9300 (301) 287-9300 joseph.anderson@nrc.gov Michael Norris, Leader O
ti R
t Li i
T Operating Reactor Licensing Team (301) 287-3754 michael.norris@nrc.gov Mi h l W Michael Wasem Emergency Preparedness Specialist (301) 287-3793 michael.wasem@nrc.gov 13