ML20035E784
| ML20035E784 | |
| Person / Time | |
|---|---|
| Issue date: | 02/20/2020 |
| From: | Jack Cushing NRC/NMSS/DREFS/ENRB |
| To: | |
| Jack Cushing 415-1424 | |
| Shared Package | |
| ML20054B832 | List: |
| References | |
| Download: ML20035E784 (16) | |
Text
Regulatory Analysis for Draft Interim Staff Guidance (ISG) 029, Environmental Considerations Associated with Micro-reactors U.S. Nuclear Regulatory Commission Office of Nuclear Materials Safety and Safeguards Division of Rulemaking, Environmental, and Financial Support February 2020
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TABLE OF CONTENTS TABLE OF CONTENTS ............................................................................................................... iii LIST OF FIGURES ...................................................................................................................... iv LIST OF TABLES......................................................................................................................... iv ABBREVIATIONS AND ACRONYMS ........................................................................................... v 1 INTRODUCTION..................................................................................................................... 1
1.1 BACKGROUND
................................................................................................................ 1 1.2 STATEMENT OF THE PROBLEM .................................................................................... 1 1.3 OBJECTIVE ...................................................................................................................... 2 2 IDENTIFICATION AND PRELIMINARY ANALYSIS OF OPTIONS .......................................... 2 2.1 OPTION 1NO-ACTION .................................................................................................. 2 2.2 OPTION 2ISSUE INTERIM STAFF GUIDANCE FOR MICRO-REACTORS ................ 2 3 ESTIMATION AND EVALUATION OF COSTS AND BENEFITS ........................................... 3 3.1 AFFECTED ENTITIES ...................................................................................................... 3 3.2 ANALYTICAL METHOD .................................................................................................... 3 3.2.1 Identification of Affected Attributes .......................................................................... 4 3.2.2 Base Year ................................................................................................................ 4 3.2.3 Sign Conventions .................................................................................................... 5 3.2.4. Analysis Horizon ...................................................................................................... 5 3.2.5 Assumptions ............................................................................................................ 5 3.2.7 NRC Implementation ............................................................................................... 5 3.2.8 Regulatory Efficiency ............................................................................................... 6 3.3 UNCERTAINTY ANALYSIS .............................................................................................. 6 3.3.1 Uncertainty Analysis Results ................................................................................... 8 4 PRESENTATION OF RESULTS............................................................................................. 8 5 IMPLEMENTATION SCHEDULE............................................................................................ 9 6 REFERENCES........................................................................................................................ 9 iii
LIST OF FIGURES Figure 1 Option 2 Net Benefit Using a 7-Percent Discount Rate 8 LIST OF TABLES Table 1 NRC Implementation ....................................................................................................... 6 Table 2 Uncertainty Analysis Inputs ............................................................................................. 7 Table 3 Summary of Totals .......................................................................................................... 9 iv
ABBREVIATIONS AND ACRONYMS CFR Code of Federal Regulations COL combined license CP construction permit EIS environmental impact statement ESP early site permit ISG interim staff guidance LWR light-water reactor MWt megawatt thermal NRC U.S. Nuclear Regulatory Commission OL operating license PERT program evaluation and review technique v
1 INTRODUCTION This document presents the regulatory analysis of the U.S. Nuclear Regulatory Commissions (NRCs) draft interim staff guidance (ISG) 029, Environmental Considerations Associated with Micro-reactors. The purpose of this ISG is to assist the NRC staff in determining the appropriate scope, breadth, and depth of staffs environmental reviews associated with micro-reactor applications. The ISG highlights unique considerations for micro-reactors in each resource area expected to be covered in the staffs environmental review.
1.1 Background In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, the staff must prepare an environmental impact statement (EIS) or a supplement to an EIS for each combined license (COL), early site permit (ESP), or construction permit (CP) application for a nuclear power reactor, and applicants are required to submit an environmental report with their application. See 10 CFR 51.20; 10 CFR 51.45. The regulation at 10 CFR 51.45(b) requires a description of the environmental impacts to a proposed action, as follows:
The environmental report shall contain a description of the proposed action, a statement of its purposes, a description of the environment affected, and discussion of the following considerations: (1) The impact of the proposed action on the environment. Impacts shall be discussed in proportion to their significance [emphasis added]
1.2 Statement of the Problem The staff is preparing for the environmental reviews of prospective design, license, and permit applications for micro-reactors. Historically, the NRC has licensed various large light-water reactors (LWRs), which involved the construction of dozens of buildings and other structures covering hundreds of acres. The guidance for new nuclear power reactor applications is contained in Regulatory Guide 4.2, Preparation of Environmental Reports for Nuclear Power Stations, Revision 3, which identifies information that an applicant must include in its environmental report for any requested permit, license, or other authorization to site, construct, or operate a new nuclear power reactor. Although intended for use for all new nuclear power reactor applications, the guidance is most applicable for large LWRs. These large LWR projects often have environmental impacts on surrounding landscapes, stream and river systems, and rural communities. Compared to a large LWR, a micro-reactors environmental impact is proportionally less and likely would require less data and staff analysis to address most environmental issues.
For micro-reactors, the staff anticipates that the constructed facility would occupy only a small area of land, use small quantities of resources, release negligible quantities of emission, and 1
require only low levels of employment for construction and operation. These characteristics, in addition to other factors identified in the ISG, support the staffs expectation regarding the environmental impacts of micro-reactors. Furthermore, potential applicants indicate that micro-reactors may be sited within existing developed areas or very remote areas. These siting considerations have the potential to avoid environmentally sensitive areas and areas of historic and/or cultural significance.
1.3 Objective The regulation at 10 CFR 51.45(b) requires an environmental report to discuss environmental impacts in proportion to their significance. The objective of this regulatory action is to provide guidance to the staff on how to implement 10 CFR 51.45(b) in its environmental reviews for micro-reactor applications.
2 IDENTIFICATION AND PRELIMINARY ANALYSIS OF OPTIONS This section presents an analysis of the options that the NRC considered in meeting the regulatory objective. The staff considered two options: no-action and issuance of the ISG.
Revising NUREG-1555, Environmental Standard Review Plans, to include guidance on micro-reactors was eliminated from consideration as an option because the revision could not be accomplished in time to support potential micro-reactor applications. The staff considered the incremental costs and benefits between taking no action and issuing the ISG and also considered the regulatory impacts of each action. The following sections discuss each option.
The options would apply to the staffs environmental review of all new micro-reactor CP, OL, or COL applications.
2.1 Option 1No-Action Under this option, the NRC would not issue the ISG to address how the staff should focus its environmental reviews for micro-reactor applications. This option is considered the no-action option and serves as the baseline against which the impacts of the other options are measured.
Because the no-action option would not address concerns regarding the lack of micro-reactor guidance, the staff would have to apply the current guidance in NUREG 1555, which was written for large LWRs, and tailor the environmental review of a new micro-reactor application on a case-by-case basis. As a result, the staff expects this lack of guidance could contribute to waste and inefficiency, including unnecessary analysis, review costs, and inconsistent breadth and depth of reviews.
2.2 Option 2Issue Interim Staff Guidance for Micro-reactors Under this option, the NRC would provide guidance to the staff to focus the staffs environmental reviews for micro-reactor applications on those environmental considerations which share the following characteristics: low potential for transients and accidents, low potential for radioactive releases, low potential consequences from radiological releases, small 2
building and site footprints, operating power levels on the order of tens of megawatts thermal (MWt) or less, and increased reliance on passive systems and inherent characteristics used to control power remove and prevent radioactive releases.
The staffs expectation is that the guidance contained in the ISG will result in effectively streamlining the staffs environmental reviews by considering impacts in proportion to their significance. Since staff expects the impacts of a micro-reactor to be less than those of an LWR, the environmental reviews will likely be less resource intensive. By focusing the staffs review on impacts of significance, the staff expects to increase the efficiency of the review process and reduce the staffs review time. The staffs environmental reviews for micro-reactor applications are expected to be more focused and result in shorter review documents than those the NRC has issued for other new nuclear power reactors, such as large LWRs.
3 ESTIMATION AND EVALUATION OF COSTS AND BENEFITS This section evaluates the incremental costs and benefits expected to result from the use of the ISG in performing environmental reviews when compared to the no-action option.
3.1 Affected Entities The ISG is applicable to all environmental reviews of potential micro-reactor applications. To date, no micro-reactor applications have been submitted to the NRC, so no applicants are currently being affected. The ISG will be in effect for one year until it is incorporated into draft NUREG-1555. The NRC expects at least one micro-reactor application to be submitted during this time frame.
3.2 Analytical Method The staff developed this regulatory analysis following the guidance in NUREG/BR-0058, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission, Revision 5. In this regulatory analysis the staff has identified all attributes related to the regulatory action and analyzed them quantitatively and qualitatively. This regulatory analysis evaluates the incremental costs and benefits of these attributes relative to a baseline that reflects anticipated behavior if the NRC does not undertake any regulatory action (Option 1). Option 1 is the no-action option and serves as a baseline against which to evaluate Option 2. After performing the quantitative regulatory analysis, the staff addressed attributes that could only be evaluated qualitatively.
The staff developed expected values for each affected cost and benefit. The staff estimated the incremental level of effort between the two options for the staffs environmental review and the preparation of an EIS. Labor rates for NRC personnel were calculated to develop cost estimates. Because there is no cost data for previous staff environmental reviews of micro-reactor applications, the staff gathered data from previous environmental reviews for large LWRs to estimate the range of effort required for different projects. The staff used data from recent environmental reviews of new medical isotope facility applications as a proxy for the level 3
of effort needed to perform an environmental review of a micro-reactor application. This data was supplemented with professional knowledge and judgment to estimate the costs and benefits. The analysis evaluates NRC implementation on a quantitative basis and regulatory efficiency on a qualitative basis.
3.2.1 Identification of Affected Attributes This section identifies the components of the public and private sectors, commonly referred to as attributes, that are expected to be affected by the options identified in Section 2. The NRC developed an inventory of the impacted attributes using the list provided in NUREG/BR-0058.
Issuing the ISG would affect the following attributes:
- NRC Implementation-This attribute accounts for the projected net economic effect on the NRC for the development of a micro-reactor EIS using the ISG and the future revision of NUREG-1555, which will incorporate the contents of the ISG as an appendix.
The staff expects that the use of the ISG would improve efficiency and effectively streamline the staffs environmental review of micro-reactor applications.
- Regulatory Efficiency-This qualitative attribute accounts for potential nonquantifiable benefits in regulatory and compliance improvements beyond those efficiencies estimated in other attributes. Specifically, this attribute accounts for how Option 2 would set staff expectations aimed at optimizing environmental reviews.
Attributes not expected to be affected under any of the options include industry implementation and operation, NRC operation, considerations of public health (accident and routine),
occupational health (accident and routine), offsite property, onsite property, other governments, the general public, safeguards and security, the environment, improvements in knowledge, and other considerations. The staff acknowledge that there would be negligible incremental costs or benefits to micro-reactor applicants preparing applications because the applicants would rely primarily on the guidance contained in Regulatory Guide 4.2 and in the environmental standard review plans for the content and format of the environmental report. Greater benefits could be achieved if the applicant and the staff agree on the focus, scoping, content, and breadth of the environmental issues during preapplication meetings as one additional means of achieving greater regulatory efficiency, effectively streamlining environmental reviews, and reducing the likelihood of staff requests for additional information.
3.2.2 Base Year The staff assumes it will finalize the ISG in 2020, so the monetized costs and benefits in this analysis are expressed in base year 2020 dollars.
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3.2.3 Sign Conventions The sign conventions used in this analysis are that all favorable consequences for the option are positive and all adverse consequences for the option are negative. Negative costs are shown using parentheses (e.g., negative $500 is displayed as ($500)).
3.2.4. Analysis Horizon The NRC assumes the ISG will be issued in calendar year 2020. The staff assumes that the staff will use this ISG in performing environmental reviews of new micro-reactor applications and the method used will remain unchanged when the ISG is incorporated as a future appendix into NUREG-1555.
3.2.5 Assumptions This analysis employs the following assumptions and considerations:
- The ISG will be finalized in 2020 and will be incorporated as a future appendix to NUREG-1555
- One micro-reactor application will be submitted to the NRC within a year of the final ISG 3.2.7 NRC Implementation This regulatory analysis assumes that one micro-reactor application will be submitted in calendar year 2020 and that additional micro-reactor applications will be submitted in the subsequent four years, although the timing and number are uncertain. The staff also assumed that the ISG contents would be incorporated into an appendix to NUREG-1555 in the year 2021 without any substantive change in guidance. The staff would use this ISG to determine the appropriate scope, breadth, and depth of the staffs environmental reviews of new micro-reactor applications. As such, and consistent with the guidance in NUREG/BR-0058, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission, Rev. 5, the staff estimates a savings of $588,000, assuming a 7 percent discount rate over a five-year analysis horizon, as shown in Table 1.
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Table 1 NRC Implementation Staff Weighted Number Year Activity Labor Hourly Undiscounted 7% NPV 3% NPV of Items Hours Rate Savings resulting from 2020 focused environmental 1 1,044 131 $137,000 $137,000 $137,000 review Incorporate ISG into 1 (93) 131 ($12,000) ($11,000) ($12,000)
NUREG as Appendix 2021 Savings resulting from focused environmental 1 1,044 131 $137,000 $128,000 $133,000 review Savings resulting from 2022 focused environmental 1 1,044 131 $137,000 $119,000 $129,000 review Savings resulting from 2023 focused environmental 1 1,044 131 $137,000 $112,000 $125,000 review Savings resulting from 2024 focused environmental 1 1,044 131 $137,000 $104,000 $121,000 review Total NRC Implementation Benefit (Cost) $671,000 $588,000 $633,000 3.2.8 Regulatory Efficiency Compared to the no-action option, issuing the ISG would provide guidance and direction and demonstrate transparency on how to scale the environmental review to the small size and impacts of a micro-reactor, which will have the result of optimizing environmental reviews. The ISG also provides guidance on how to streamline the environmental review process and reduce unnecessary repetition of previous analyses by incorporating by reference (40 CFR 1502.21, Incorporation by Reference) publicly available documents. The regulatory efficiency gained by following the guidance in the ISG would be a shorter and more focused EIS that evaluates impacts in relation to their significance, with an expected result of a reduced review time and a reduced cost.
3.3 Uncertainty Analysis To determine the robustness of the estimated costs and benefits, the NRC examined how costs change due to uncertainties associated with the NRCs analytical assumptions and input data. The NRC used the Monte Carlo simulation to examine the impact of uncertainty on the estimated net benefits. These Monte Carlo simulations were performed using the @Risk software package by Palisade Corporation.
Monte Carlo simulations forecast uncertainty by replacing the point estimates of the input variables for the costs with probability distributions. Defining input variables as probability distributions, as opposed to point estimates, allows for modeling the effect of uncertainty on the results of the analysis (i.e., the net costs).
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The probability distributions chosen to represent the different input variables in the analysis were bounded by the range of referenced input, which the NRC staff determined based on its professional judgment. When defining the probability distributions in the Monte Carlo simulation, summary statistics are needed to characterize the distributions. These summary statistics include the minimum, most likely, and maximum values of a program evaluation and review technique (PERT) distribution.1 The staff used the PERT distribution to reflect the relative spread and skewness of the distribution defined by the three estimates.
The inputs for the uncertainty analysis are shown in Table 2.
Table 2 Uncertainty Analysis Inputs Mean Low Best High Source or Basis of Activity Distribution Estimate Estimate Estimate Estimate Estimate General Base Year 2020 Staff assumption Discount Rate 7% NUREG/BR-0058 Supplemental Discount 3% NUREG/BR-0058 Rate Calculated value NRC Labor Rate $131 based on previous NRC actuals Number of Micro-reactor Staff estimate based 1
Applications Submitted on vendor input to NRC in Year 2020 Number of Micro-reactor Staff assumption 1 Uniform 0 1 Applications Submitted based on vendor input to NRC after Year 2020 NRC Implementation Option 1-No-Action Best estimate based on hours spent on recent staff Staff hours to perform environmental reviews micro-reactor of new medical isotope 4,817 PERT 2,600 4,500 8,300 facility applications.
environmental review and issue EIS Low and high estimates are based on the range of effort required to complete previous staff 1
A PERT distribution is a special form of the beta distribution with a minimum, most likely, and maximum value specified. The PERT distribution is a special case of a beta distribution and can generally be considered to be superior to the triangular distribution when the parameters result in a skewed distribution, as the smooth shape of the PERT places less emphasis in the direction of skew.
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environmental reviews for large power reactor environmental reports Option 2-Issue ISG Percent reduction in staff review resources by focusing 22% PERT 10% 20% 40% Staff estimate environmental review on impacts of significance Staff estimate.
Incremental effort to Incorporate ISG into add final text as an NUREG-1555 as an 93 PERT 40 80 200 appendix into a appendix (hours) document undergoing revision 3.3.1 Uncertainty Analysis Results The uncertainty analysis provided as Figure 1 shows that Option 2, Issuing the ISG, has an estimated mean value of $360,000 in savings to the NRC over a five-year analysis horizon when using a 7-percent discount rate. Figure 1 also shows that for all simulation events, issuing the ISG is cost beneficial.
0.000 0.720 95.0% 5.0%
Total NRC Implementation Benefit (Cost) / 7% NPV Minimum $43,740 Maximum $1,430,043 Mean $356,839 Std Dev $188,673 Values 10000 0.00 0.20 0.40 0.60 0.80 1.00 1.20 1.40 1.60 Values in Millions ($)
Figure 2 Option 2 Net Benefit Using a 7-Percent Discount Rate 4 PRESENTATION OF RESULTS 8
Table 3 Summary of Totals, provides the quantified and qualified costs and benefits for Option 2. The net monetary savings values are best estimate values.
Table 3 Summary of Totals Net Monetary Savings (or Costs) Nonmonetary Benefits or Costs Option 1: No-Action
$0 None Option 2: Issue ISG-029 Regulatory Efficiency:
NRC:
- Encourages applicants and the NRC staff to
$588,000 using a 7% discount rate hold preapplication submittal discussions to
$633,000 using a 3% discount rate align on potential environmental impacts in proportion to their significance.
- Streamlines internal processes to improve efficiencies.
- Provides clarity and transparency.
- Simplifies and shortens the time required for staffs environmental reviews of micro-reactor applications.
5 IMPLEMENTATION SCHEDULE The ISG will become effective upon its publication, which is expected in the year 2020.
6 REFERENCES Office of Management of the Budget, Regulatory Analysis, Circular A-4, September 17, 2003.
Available at https://www.whitehouse.gov/omb/information-for-agencies/circulars/.
U.S. Department of Labor, Bureau of Labor Statistics, Databases, Tables & Calculators by Subject, Occupational Employment Statistics, Occupational Employment and Wages.
Available at https://www.bls.gov/data/.
U.S. Nuclear Regulatory Commission (NRC), NRC, 2000, Environmental Standard Review Plan, NUREG 1555. Available at https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1555/.
NRC, 2018a, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission, NUREG/BR-0058, draft Revision 5, March 28, 2018 (ADAMS Accession No. ML17221A000).
NRC, 2018b, Preparation of Environmental Reports for Nuclear Power Stations, Regulatory Guide 4.2, Revision 3, September 2018 9ADAMS Accession No. ML18071A400) 9
PKG: ML20035E782; RA: ML20035E784 *concurred via email OFFICE NMSS/REFS/PM NMSS/REFS/TL NMSS/REFS/ENRB/PM NMSS/REFS/ENRB/BC NAME Pam Noto Fred Schofer Jack Cushing Ken Erwin DATE 2/03/2020 2/03/2020 1/30/2020 2/03/2020 OFFICE OGC NMSS/REFS/D NAME Megan Wright John Tappert DATE 2/14/2020