ML15191A408
| ML15191A408 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 07/08/2015 |
| From: | Pietrangelo A Nuclear Energy Institute |
| To: | Stephen Burns NRC/Chairman |
| Shared Package | |
| ML15191A409 | List: |
| References | |
| LTR-15-0366 | |
| Download: ML15191A408 (1) | |
Text
ANTHONY R. PIETRANGELO Senior Vice President and Chief Nuclear Officer 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8081 arp@nei.org nei.org July 8, 2015 The Honorable Stephen G. Burns Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Industry Support for Establishing an Emergency Preparedness Framework Appropriate for Small Modular Reactors and Other New Technologies; SECY-15-0077 Project Number: 689
Dear Chairman Burns:
On behalf of the nuclear industry, the Nuclear Energy Institute (NEI)1 expresses support for the NRC staffs recommendation to establish emergency preparedness (EP) regulations and guidance appropriate for small modular reactors (SMRs) and other new technologies, as discussed in SECY-15-0077 Options for Emergency Preparedness for Small Modular Reactors and Other New Technologies. We encourage the Commission to provide timely direction to the staff in order to facilitate resolution of policy and technical issues prior to the submittal of SMR applications.
As nuclear reactor designs evolve to incorporate advanced safety features, it is important that the regulatory framework also evolve in a manner that reflects these features and allows for more efficient means to protect public health and safety. We have been working with the NRC for the last several years to proactively address generic SMR regulatory issues prior to the submittal of applications. NEI has submitted position papers on several issues, such as variable annual fees, decommissioning funding, and insurance and liability as input to the resolution of policy and technical issues related to SMR licensing.
1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.
The Honorable Stephen G. Burns July 8, 2015 Page 2 The establishment of an SMR-appropriate EP framework is vitally important to ensure that NRC requirements do not place undue economic burden on SMRs. The current regulatory framework for EP is tailored to large light water reactors and does not consider the enhanced safety features of SMRs and other new technologies. SMRs will significantly reduce the risk of a radiological release with offsite consequences due to their smaller cores and source terms, simplified designs that reduce potential accident sequences, and slower accident progressions that permit more time for mitigation. A technology-neutral, dose-based and consequence-oriented EP framework designed specifically for SMRs would enable these facilities to meet public and worker protection goals in a more effective and efficient manner.
Prospective design certification and license applicants are developing now the technical basis for an SMR-appropriate emergency planning zone based on a proposed methodology put forward by NEI in December 2013 and discussed in public meetings with the NRC. On July 8, 2015, NEI provided to the staff a white paper on proposed changes to EP regulations and guidance for SMRs to facilitate discussion with the NRC in the development of the EP framework for SMRs. Timely Commission approval of the staff recommendation in SECY-15-0077 (Option 1) will facilitate the public meetings and other interactions necessary to consider the proposed changes. This work would also provide a basis for consideration of applicant requests for exemption from certain existing EP requirements that would be necessary prior to completion of the envisioned SMR EP rulemaking. Currently, it is expected that SMR design certification and early site permit applications will be submitted to NRC in 2016, and an SMR combined license application will be submitted in 2017.
We look forward to the Commissions direction on this issue and to future interactions with the staff and other stakeholders.
Sincerely, Anthony R. Pietrangelo c:
The Honorable Kristine L. Svinicki, Commissioner, NRC The Honorable William C. Ostendorff, Commissioner, NRC The Honorable Jeff M. Baran, Commissioner, NRC Mr. Mark A. Satorius, EDO, NRC Mr. Glenn M. Tracy, NRO, NRC Mr. Brian E. Holian, NSIR, NRC Mr. Michael E. Mayfield, NRO/DARR, NRC Mr. Robert J. Lewis, NSIR/DPR, NRC NRC Document Control Desk
NRCExecSec Resource From:
Sent:
Subject:
Attachments:
July 8, 2015 PIETRANGELO, Tony <arp@nei.org>
Wednesday, July 08, 2015 2:04 PM Industry Support for Establishing an Emergency Preparedness Framework Appropriate for Small Modular Reactors and Other New Technologies; SECY-15-0077 07-08-15_NRC_Industry Support for Small Modular Reactor Emergency Planning; SECY-15-0077.pdf The Honorable Stephen G. Burns Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Industry Support for Establishing an Emergency Preparedness Framework Appropriate for Small Modular-Reactors and Other New Technologies; SECY-15-0077 Project Number: 689
Dear Chairman Burns:
On behalf of the nuclear industry, the Nuclear Energy Institute (NEI) expresses support for the NRC staffs recommendation to establish emergency preparedness (EP) regulations and guidance appropriate for small modular reactors (SM Rs) and other new technologies, as discussed in SECY-15-0077 Options for Emergency Preparedness for Small Modular Reactors and Other New Technologies. We encourage the Commission to provide timely direction to the staff in order to facilitate resolution of policy and technical issues prior to the submittal of SMR applications.
As nuclear reactor designs evolve to incorporate advanced safety features, it is important that the regulatory framework also evolve in a manner that reflects these features and allows for more efficient means to protect public health and safety. We have been working with the NRC for the last several years to proactively address generic SMR regulatory issues prior to the submittal of applications. NEI has submitted position papers on several issues, such as variable annual fees, decommissioning funding, and insurance and liability as input to the resolution of policy and technical issues related to SMR licensing.
The establishment of an SMR-appropriate EP framework is vitally important to ensure that NRC requirements do not place undue economic burden on SMRs. The current regulatory framework for EP is tailored to large light water reactors and does not consider the enhanced safety features of SM Rs and other new technologies.
SMRs will significantly reduce the risk of a radiological release with offsite consequences due to their smaller cores and source terms, simplified designs that reduce potential accident sequences, and slower accident progressions that permit more time for mitigation. A technology-neutral, dose-based and consequence-oriented EP framework designed specifically for SMRs would enable these facilities to meet public and worker protection goals in a more effective and efficient manner.
1
Prospective design certification and license applicants are developing now the technical basis for an SMR-appropriate emergency planning zone based on a proposed methodology put forward by NEI in December 2013 and discussed in public meetings with the NRC. On July 8, 2015, NEI provided to the staff a white paper on proposed changes to EP regulations and guidance for SMRs to facilitate discussion with the NRC in the development of the EP framework for SMRs. Timely Commission approval of the staff recommendation in SECY-15-0077 (Option 1) will facilitate the public meetings and other interactions necessary to consider the proposed changes. This work would also provide a basis for consideration of applicant requests for exemption from certain existing EP requirements that would be necessary prior to completion of the envisioned SMR EP rulemaking. Currently, it is expected that SMR design certification and early site permit applications will be submitted to NRC in 2016, and an SMR combined license application will be submitted in 2017.
We look forward to the Commission's direction on this issue and to future interactions with the staff and other stakeholders.
Sincerely, Anthony R. Pietrangelo Senior Vice President and Chief Nuclear Officer Nuclear Energy Institute 1201 F Street NW, Suite 1100 Washington, DC 20004 www.nei.org P: 202.739.8081 M: 202.439.2511 E: arp@nei.org TAKE THE NE/ FUTURE OF ENERGY QUIZ, www.NEl.org/futureofenergy FOLLOW USON 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, marketr'ng or recommending to another party any transaction or matter addressed herein.
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