Text

February 20, 2020 Advanced Reactor Stakeholder Meeting Slides
	ML20050E155
Person / Time
Issue date:	02/20/2020
From:	Jordan Hoellman; NRC/NRR/DANU/UARP
To:	;
	Hoellman J, NRR/DANU/UARP, 301-415-5481
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	Download: ML20050E155 (87)
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Advanced Reactor Stakeholder Public Meeting February 20, 2020 Telephone Bridgeline: (888) 593-8429 Passcode: 6767863#

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Time Agenda Speaker 9:00 - 9:10 am Opening Remarks and Agenda NRC/NEI 9:10 - 9:45 am Status of NRC readiness for non-LWRs and planned update of public website Monninger/Hayes, NRC 9:45 - 10:00 am Nuclear Materials Management and Safeguards System (NMMSS) Overview Shoemaker, NMSS 10:00 - 10:30 am NRC update on Generic Environmental Impact Statement (GEIS)

Sutton, NRR 10:30 - 10:50 am NEI Environmental Review Report Austgen, NEI 10:50 - 11:00 am Break ALL 11:00 - 11:45 am Technology Inclusive Content of Applications Project (TICAP)

Afzali, Southern 11:45 - 12:00 pm Introduction of NRC Project on Severe Accident Phenomenology and Source Terms Calculations for Representative Designs Schaperow, NRR 12:00 - 1:00 pm Lunch ALL 1:00 - 1:30 pm Industry Priorities for Codes and Standards Nichol, NEI 1:30 - 2:00 pm Update on NRC Plan for Endorsement of Non-LWR PRA Standard Phan, NRR 2:00 - 2:30 pm Update from Department of Energy on Non-LWR topics including Micro Reactors Sowinski, DOE 2:30 - 2:45 pm Break ALL 2:45 - 3:15 pm Update on Non-LWR Policy Issues Cubbage/Reckley, NRR 3:15 - 3:30 pm Physical Security Rulemaking Update Valliere/Andrukat, NRC 3:30 - 3:45 pm Emergency Planning Rulemaking Path Forward Segala, NRR 3:45 - 4:00 pm Future meeting planning and open discussion ALL Opportunities for public comments and questions at designated times 2 of 87

Status of NRC Readiness for Non-LWRs and Planned Update of Public Website

John Monninger and Michelle Hayes, NRC

- https://www.nrc.gov/reactors/new-reactors/advanced.html

- https://www.nrc.gov/reactors/operating/oversight/rop-enhancement.html 3 of 87

The Nuclear Materials Management and Safeguards System Mirabelle Shoemaker Material Control and Accounting Branch Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 4 of 87

The Nuclear Materials Management and Safeguards System (NMMSS)

U.S. Government database for tracking physical inventory and nuclear material transactions for source and special nuclear material (SNM)

DOE Sites and NRC licensees with source or special nuclear material that meet the requirements of the applicable regulations report to NMMSS.

Information submitted to NMMSS allows the U.S.

Government to fulfill its commitments for safeguards on material within the U.S.

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Reporting to NMMSS 3

Nuclear Power Reactors Research and Test Reactors Independent Spent Fuel Storage Installations (IFSIs)

Fuel Cycle Facilities Greater-Than-Critical-Mass Facilities Uranium Mills Waste Facilities Department of Defense (DOD)/Federal possessors of commercial material Agreement State Licensees

Reportable material types and units Depleted Uranium (Kg)

Natural Uranium (Kg)

Thorium (Kg)

Uranium-233 (g)

Uranium-235 (g)

Plutonium (g)

Plutonium-238, when >10% (0.1g) 6 of 87

Reporting to NMMSS (cont.)

4 DOE/NRC Form 741, Nuclear Material Transaction Report DOE/NRC Form 742, Material Balance Report DOE/NRC Form 742C, Physical Inventory Listing DOE/NRC Form 740M, Concise Note

Key Reporting Guidance NUREG/BR-0006, Instructions for Completing Material Transaction Reports (DOE/NRC Forms 741 and 740M)

NUREG/BR-0007, Instructions for the Preparation and Distribution of Material Status Reports (DOE/NRC Forms 742 and 742C)

NMMSS Report D-24, Personal Computer Data Input for NRC Licensees 7 of 87

2020 Annual NMMSS Users Training 5

- NMMSS Reporting

- Materials Management

- Nonproliferation

- Facility Operations

No cost to attend training

Registration, agenda, and lodging information:

https://nmmss2020.linksolutions.com/

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Questions 6

mirabelle.shoemaker@nrc.gov, 301-415-7363 9 of 87

Update on Generic Environmental Impact Statement for Advanced Reactors Mallecia Sutton NRC February 20, 2020 10 of 87

2 Status Comment period closed for the exploratory process -January 24, 2020 Staff is preparing responses to public comments on the exploratory process Staff developing information paper to describe GEIS structure and potential benefits; currently under management review 11 of 87

©2020 Nuclear Energy Institute 2 National Environmental Policy Act (NEPA) intent to inform federal actions based on an assessment of their likely environmental impacts implementation of NEPA has yielded unjustified increases in both length of time to complete the review and associated costs Advanced Reactors review proportionate to potential environmental impacts expected to result in small environmental risks environmental benefits and avoided carbon emissions Challenges & Opportunities 13 of 87

Allow for the flexibility to use environmental assessments (EAs) and categorical exclusions 2)

Increase the use of generic environmental impact statements (GEISs) 3)

Incorporate existing environmental analyses into a projects EA or EIS 4)

Flexibility to use the applicants environmental report (ER) as the basis for the draft EA or EIS 5)

Reduce unnecessary burden in alternative site analysis 6)

Increase efficiency of environmental reviews Overview of Recommendations 14 of 87

©2020 Nuclear Energy Institute 4 Requiring an EIS without consideration of the characteristics of advanced reactors and the history of current reactors is not commensurate with anticipated environmental impacts per NEPA.

For the NRC to leverage EAs in the environmental reviews of advanced reactors, the NRC will have to change the current regulations which prescribe to the NRC which actions require an EIS.

This recommendation is focused on the NRC considering how it can provide more latitude to consider categorical exclusions based on the circumstances of the proposed action.

1) Allow for the flexibility to use EAs and categorical exclusions 15 of 87

©2020 Nuclear Energy Institute 5 NEI recommends that NRC leverage the experience of the current reactor fleet, their existing GEISs and drive towards smart environmental reviews that are effective and efficient.

2) Increase the use of GEISs 16 of 87

The NRC should further expedite the NEPA review process by specifically codifying circumstances where EAs and EISs can reference externally prepared analyses.

Given the often-duplicative nature of NEPA reviews, heavier reliance on existing environmental analyses has the potential to save significant time and resources for both project applicants and the NRC.

3) Incorporate existing environmental analyses into a projects EA or EIS 17 of 87

Unfortunately, as conducted to-date, the NRCs EIS preparations duplicate the applicants efforts to develop an ER, wasting time and level of effort, and resulting in costs that are then charged back to the applicant.

The NRC can amend its regulations by looking to federal agencies that allow more applicant participation in the environmental review process.

FERC FAA

4) Flexibility to use the applicants ER as the basis for the draft EA or EIS.

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©2020 Nuclear Energy Institute 8 The CEQ has proposed a revised definition to reasonable alternatives that the NRC should consider. Reasonable alternatives should be analyzed with the lens of what is actually feasible, based on the purpose and need of the applicants goals and the agencys statutory authority.

It would be more appropriate to limit the requirement to a description of the process used to select the site, which is likely more important for advanced reactors, many of which will be sited in specific locations to meet a specific need.

5) Reduce unnecessary burden in alternative site analysis 19 of 87

Many of the procedural efficiencies identified for the safety review should also be considered to increase the efficiency of environmental reviews.

Additional contributing factors that once addressed in the environmental review context should help achieve and sustain increased efficiency.

6) Increase efficiency of environmental reviews 20 of 87

©2020 Nuclear Energy Institute 10 Next Steps NEPA milestones Jan-20 Feb-20 Mar-20 Apr-20 May-20 Jun-20 Jul-20 Aug-20 Sep-20 Oct-20 Nov-20 Dec-20 1Q21 2Q21 3Q21 4Q21 1H22 2H22 CEQ Final Rule Streamlining NRC Environmental Reviews Vote SECY SRM SECY 1 EA or CatEx NRC WP NEI Comments Staff Rec. RM in SECY SRM SECY Draft RM Basis Final Rule 2 ANR GEIS FRN Comments Draft NUREG NEI Comments Final NUREG 4 Incorp. Existing Analyses NRC WP NEI Comments Staff Rec. Policy in SECY SRM SECY Is there staff action after policy is set (e.g., guidance)?

4 Use ER as draft EA or EIS NRC WP NEI Comments Staff Rec. Policy in SECY SRM SECY Is there staff action after policy is set (e.g., guidance)?

5 Alt. Sites Scope Issue ISG NEI Comments Final ISG RG Update (Placeholder) 6 Efficiency of Review NRC Mgmt expectations Implement efficiencies Legend NEI Deliverable Interim Decision Maker Deliverable Final Decision Maker Deliverable NEI CEQ Comments Proposed Rule NEI ER Paper Contingency NUREG update 21 of 87

Break Meeting/Webinar will begin shortly Telephone Bridgeline: (888) 593-8429 Passcode: 6767863#

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Frank Akstulewicz AtoZ Reactor Consulting Services NRC Stakeholder Meeting February 20, 2020 Mapping Fundamental Safety Functions (FSF) to Regulations Technology Inclusive Content of Application Project (TICAP) 23 of 87

2 Outline of the Presentation

Background

TICAP Goal

Next Steps for the FSF Report

Preview the Content of FSF Mapping Report

Early Conclusions

Next Steps and Schedule

Summary and Questions 2

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3 TICAP Goal Develop an endorsable document that outlines the content of an application in a manner that is technology inclusive, risk-informed, performance-based and its scope is limited by LMP methodology and can be submitted to NRC for endorsement

Output will likely be a process for developing content of application as opposed to a specific set of required information 25 of 87

4 Key TICAP Products 4

2020 Nov Dec Jan Feb March April May June July Aug Sept Oct Fundamental Safety Functions (FSFs)

Definition (to NRC 11/2019)

Regulation Mapping to FSFs (to NRC 5/2020)

Formulation of Technology Inclusive Content of Application (to NRC 10/2020)

NEI Guidance Document Annotated Outline (to NRC 10/2020)

LMP-Related Safety Case (To NRC 6/2020)

Tabletop Exercises 26 of 87

5 Key TICAP Products (cont.)

2021 Nov Dec Jan Feb March April May June July Aug Sept Oct Differences Between Licensing Paths (to NRC 1/2021)

NEI Guidance Document (draft to NRC 4/2021)

(final to NRC 7/2021)

Tabletop Exercises NRC Review 27 of 87

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Comments received on January 17, 2020

Conference call on January 29, 2020 to clarify staff comments

General alignment on scope and direction of paper

- Comments in two specific areas

>> FSF and adequate protection

>> Hierarchy of FSF

Next steps

- Update the paper to align with SECY 19-0117 hierarchy of FSF

- Continue discussion about role of FSF in determining adequate protection

- Return FSF paper to TICAP internal review process Next Steps for the FSF White Paper 28 of 87

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The purpose of the FSF Mapping Report is to demonstrate that the existing body of Part 50 regulatory requirements will map to one or more fundamental safety functions

This is not a gap analysis exercise in that we are looking for where holes exist for licensing non-LWR technologies

Will demonstrate equivalence between prescriptive regulatory requirements and performance based fundamental safety functions Purpose of the FSF Mapping Report 29 of 87

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Background Section

Section that discusses several efforts related to mapping

Fundamental safety functions and mapping process

Overview results table

Conclusion

References

Appendices for content of application mapping Structure of Report 30 of 87

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Mapping follows outline of Part 50

Mapping tracks

- Design requirements

- Programmatic requirements

- Administrative requirements

Mapping applied to regulations at a macro level

Mapping applied to contents of applications sections at the sub-paragraph level for both Part 50 and 52

Mapping summarizes the safety objective for each regulation Mapping Process 31 of 87

10 10 50.58 Hearings and ACRS reviews X

50.59 Process for changes to approved licensing bases.

X Establishes process for changes to approved licensing basis -

preserves integrity of approved licensing basis 50.61 Preserve integrity of reactor vessel from temperature event X

X 50.61a Alternatives to 50.61 requirements X

X 50.62 Mitigate worst case failure to scram event X

Sample from Mapping Table Regulatio n

Description of the regulation and summary of safety objective, when appropriate Controlli ng Reactivity (1)

Removing Heat from the Reactor and Waste Stores (2)

Retaining Radioacti ve Materials (3)

Programmati c

Requirement s that support all three FSFs (4)

Administr ative or Procedur al Basis or Rationale 32 of 87

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All design requirement regulations contained in Part 50 and the Appendices can be mapped to one or more fundamental safety functions - notable exception is emergency preparedness

There are a few additional requirements for contents of applications in Part 52

- ITAAC

- Results of PRA

Referenced regulations also mapped to FSFs Conclusions from Mapping 33 of 87

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Complete the mapping process to assure that fundamental safety functions provide comprehensive examination of initiating events and external hazards appropriate for the technology

Obtain review and comment from ARRTF

Provide to NRC for review and comment in May 2020.

Next Steps 34 of 87

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Questions and Comments?

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ARRTF - Advanced Reactor Regulatory Task Force

FSF - Fundamental Safety Functions

ITAAC - Inspections, Tests and Acceptance Criteria

LMP - Licensing Modernization Project

LWR - Light Water Reactor

PRA - Probabilistic Risk Assessment

TICAP - Technology-Inclusive Content of Application Project List of Abbreviations 36 of 87

Advanced-Reactor Source Term Jason Schaperow Hossein Esmaili Advanced Reactor Stakeholder Meeting February 20, 2020 37 of 87

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Overall strategy

- NRC Vision and Strategy: Safety Achieving Effective and Efficient Non-Light Water Reactor Mission Readiness, December 2016, ML16356A670

Code strategy for source term

- NRC Non-Light Water Reactor Vision and Strategy, Volume 3 - Computer Code Development Plans for Severe Accident Progression, Source Term, and Consequence Analysis, Revision 1, January 2020, ML20030A178 38 of 87

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Technology inclusive

- Water-cooled reactor

- Gas-cooled reactor

- Sodium-cooled and heat-pipe-cooled

- Salt-cooled and salt-fueled reactor 39 of 87

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SCALE - calculates fission product inventories and decay power

MELCOR - calculates source term to environment

- Inputs

Fission product inventory and decay heat (from SCALE)

Geometry of reactor, containment, reactor building

Operation of pumps and valves 40 of 87

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Two staff efforts

- Advanced-reactor technology-inclusive guidance for developing mechanistic source terms

- Non-LWR pilot studies to illustrate how to perform source term analysis with MELCOR

Supports guidance development 41 of 87

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Phase 1

- MELCOR full-plant simulations for 3 representative non-LWR designs

- Based on publicly available design information

- E.g., LANL Megapower heat-pipe-cooled reactor 42 of 87

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Phase 2

- Workshops to train the staff on source term analysis for the 3 representative non-LWR designs

- One workshop for each design

- Prepare staff for design reviews 43 of 87

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Phase 3

- Workshops to inform stakeholders on the staffs approach to source term analysis for the 3 representative non-LWR designs

- One workshop for each design

- Promote dialogue between NRC and stakeholders 44 of 87

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Schedule

- 6 months for each of the 3 representative designs

- Work starts February 2020 45 of 87

Lunch Meeting/Webinar will begin shortly Telephone Bridgeline: (888) 593-8429 Passcode: 6767863#

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February 20, 2020 47 of 87

reflect interests from all relevant organizations establish conservatism in the designs provide a framework for standardization When endorsed by the regulator, they can:

make the regulatory process more efficient and predictable enable more efficient approvals internationally Benefits of Advanced Reactor Codes and Standards 48 of 87

©2020 Nuclear Energy Institute 3 Congress should fund a DOE program to Assist SDOs and developers Accelerate development/update to key standards Department of Energy should Coordinate with SDOs Solicit input from developers, NGOs, other stakeholders Identify and prioritize key codes and standards needs Establish time frame for development and regulatory acceptance ANS SPECIAL REPORT: Recommendations 49 of 87

©2020 Nuclear Energy Institute 4 Department of Energy should provide incentives to national laboratories ensure proactive participation in developing data and methods support a comprehensive overhaul of priority codes and standards Nuclear Regulatory Commission should implement process improvements and/or provide the resources ensure timely adoption of advanced reactor standards reevaluate the need for imposing margins in excess of standards DOE and/or NRC establish a formal process with the SDOs achieve harmonization of safety margins among consensus standards ANS SPECIAL REPORT: Recommendations(cont) 50 of 87

©2020 Nuclear Energy Institute 5 Timeliness development needs to support developer plans for licensing, construction and operations important to developers who are making multiyear capital investments Resources availability of funding resources to fully develop the desired codes and standards Re-invigoration of SDOs potential delays due to lack of resources and/or support information Decision process needed to facilitate prioritization of codes and standards development Challenges 51 of 87

Purpose:

To identify and prioritize needed codes and standards provide the greatest benefit for designs types being developed today To identify the need for more streamlined and timely efforts in the development and endorsement of codes and standards NEI 19-03, [Rev 0]

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1. Support design efforts;

2. Support licensing review;

3. Reduce component fabrication time and costs;

4. Reduce facility construction time and costs; and

5. Reduce O&M costs.

Assessing priorities for what needs to be done 53 of 87

1.

High - Codes and Standards that (1) support design and licensing, (2) support either design or licensing and at least two other criteria, or (3) satisfy at least three of the other criteria 2.

Medium - Codes and Standards that satisfied two of the criteria not specifically related to design or licensing 3.

Low - Codes and Standards that satisfied one of the criteria not specifically related to design or licensing Assessing priorities for what needs to be done (cont) 54 of 87

©2020 Nuclear Energy Institute 9 A total of 36 standards were included in the prioritization; 18 identified as High Priority for near-term development Need for new standards on advanced manufacturing methods should be evaluated for prioritization (see NEI Report on Advanced Manufacturing)

Need to establish an ongoing process to engage DOE, developers and SDOs in determination of near-term development activities Recommended that public-private partnerships be formed to provide financial support situations where R&D or other special needs is essential on a schedule that supports the deployment of advanced reactors Results of Prioritization 55 of 87

SDO Equivalent to ANSI/ANS 6.4-2006, Concrete for Passive Heat Removal Systems - Irradiation and Thermal Limits ANS ANS-30.1-201x Risk-informed Performance-Based Principles and Methods ANS ANS-30.2-201x Categorization and classification of SSCs ANS ASME/ANS RA-S-1.4-2013 PRA for Non-LWRs (trial use)

ASME/ANS ANSI/ANS 53.1 Nuclear Safety Design Process for Modular Helium-Cooled Reactor Plants, 2011 ANS ASME BPVC Division 1 and 2, Subsection NCA, Containment Barrier ASME New standards equivalent to SFR-DC 73 for sodium leak detection and mitigation (see NRC RG 1.232)

ANS ANS 56.2-1984 (ANSI N271-1976), Containment Isolation for Fluid Systems ANS ASME AG-1-2009, Air and Gas Treatment ASME ASME BPVC Section III, Construction of plant components ASME New Standards for Advanced Manufacturing Techniques, including Additive manufacturing ASME ASME BPVC Section III Division 1, Subsection NE and Division 2, Containment ASME ASME BPVC Section III, Division 5, High Temperature Reactors ASME ASME N509-2002, Air Cleaning Units and Components ASME ASME QME-1-2007, Qualification of Active Mechanical Components ASME NFPA 251, Methods of Tests of Fire Resistance of Building Construction and Materials NFPA ACI 349.1R-07, Reinforced Concrete Design for Thermal Effects ACI ACI 349-2013, Nuclear Safety-related Concrete Structures and Structural Members ACI 56 of 87

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Update on NRC Plan for Endorsement of ASME/ANS RA-S-1.4 PRA Standard for Advanced Non-LWR Nuclear Power Plants Advanced Reactor Stakeholder Meeting Hanh Phan, NRR/DANU Michelle Gonzalez, RES/DRA February 20, 2020 59 of 87

Objective

Update on the staffs endorsement plan

Update on the gap analysis of PRA standard

Update on the industry peer review guidance 60 of 87

Regulations and Guidance 10 CFR 52.47 & 52.79 10 CFR 50.71 NEI 18-04 ASME/ANS RA-S-1.4 RG 1.200 61 of 87

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Background===

June 27, 2019, staff informed the stakeholders of its plan to:

1. Endorse the ASME/ANS trial use advanced non-light-water reactor (non-LWR)

PRA standard, developed by the ASME/ANS Joint Committee on Nuclear Risk Management (JCNRM), and

2. Perform a gap analysis of non-LWR PRA standard to ensure fit for Licensing Modernization Project (LMP) purpose August 15, 2019, staff updated the stakeholders of its plan and discussed industry guidance on the peer review process August 16, 2019, staff established the guidelines for review and endorsement of non-LWR PRA standard (ML19235A285)

September 26, 2019, staff notified the JCNRM of its endorsement Plan October 2, 2019, staff briefed the ACRS on its endorsement plan November 26, 2019, JCNRM transmitted a letter to the NRC (ML20031D602) expressing concerns about the staffs endorsement of the trial-use standard and proposing that the NRC wait for a new version 62 of 87

Staffs Endorsement Plan JCNRMs letter indicated changes in priority and schedule to ballot the standard in March 2020 and issuing the pre-final-editing version of the standard by December 2020 Staff considered the JCNRMs schedule and agreed to endorse the pending revision to the standard Staff to issue the endorsement plan in March 2020, which includes:

Task 1 - Supporting development of the standard Task 2 - Preparation for review of the standard Task 3 - Reviewing the standard Task 4 - Maintaining PRA standard Task 5 - Development of schedule Task 6 - Identification of resources Task 7 - Development of communication plan 63 of 87

Staffs Endorsement Plan Staff to endorse the PRA standard with the development of a new regulatory guide (RG), similar to RG 1.200 Staff to include an appendix on peer review process and PRA acceptability for LMP, risk-informed applications, and the uses of PRA during DC and COL stages Staff anticipates publishing the draft RG for public review and comment by Summer 2021 and the final RG by Summer 2022 The staffs schedule is dependent on the JCNRM adhering to their proposed schedule of issuance of the standard 64 of 87

Gap Analysis of PRA Standard Assess the technical applicability of ASME/ANS non-LWR PRA standard to PRAs developed for the DC and COL LMP applications to ensure fit-for-purpose standard requirements To be performed between March and September 2020 using the pre-final-editing version of the standard Results will be incorporated into the RG to convey the staffs position on the use of the non-LWR PRA standard for LMP 65 of 87

PRA Peer Review Guidance All three elements must work together 66 of 87

PRA Peer Review - NEI 17-07 67 of 87

PRA Peer Review Guidance An acceptable PRA peer review is one that is performed according to an established process and by qualified personnel, documents the results, and identifies both strengths and weaknesses of the PRA Staff to review the industry guidance for an acceptable peer review process, acceptable team qualifications, and acceptable documentation Staff to document its position in the RG describing the needed attributes and characteristics for an acceptable peer review process of a PRA for a non-LWR Is NEI going to develop the guidance? If so, when?

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Update from Department of Energy on Non-LWR topics including Micro Reactors

Tom Sowinski, DOE 69 of 87

Break Meeting/Webinar will begin shortly Telephone Bridgeline: (888) 593-8429 Passcode: 6767863#

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Update on Policy Issues

Amy Cubbage and Bill Reckley, NRC 71 of 87

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Periodic Advanced Reactor Stakeholder Meeting Rulemaking for ALTERNATIVE PHYSICAL SECURITY REQUIREMENT FOR ADVANCED REACTORS Proposed Rule (NRC Docket ID: NRC-2017-0227)

February 20, 2020 1

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2 PURPOSE

Discuss NRC staffs proposed rule approach

Discuss staffs review and screening of the December 12, 2019 public meeting comments

Discuss development of guidance

Discuss next steps Purpose 77 of 87

3 The staff identified the following three performance criteria that could be used to identify reactors that could make use of the alternative security requirements provided in this proposed rule:

1) The radiological consequences from a hypothetical, unmitigated event involving the loss of engineered systems for decay heat removal and possible breaches in physical structures surrounding the reactor, spent fuel, and other inventories of radioactive materials result in offsite doses below the reference values defined in 10 CFR 50.34(a)(1)(ii)(D) and 52.79(a)(1)(vi); or

2) The plant features necessary to mitigate an event and maintain offsite doses below the reference values in 10 CFR 50.34(a)(1)(ii)(D) and 52.79(a)(1)(vi) cannot reasonably be compromised by the Design Basis Threat for radiological sabotage; or

3) The plant features include inherent reactor characteristics combined with engineered safety and security features that allow for facility recovery and mitigation strategy implementation if a target set is compromised, destroyed, or rendered nonfunctional, such that offsite radiological consequences are maintained below the reference values defined in 10 CFR 50.34(a)(1)(ii)(D) and 52.79(a)(1)(vi)

Performance Criteria 78 of 87

4 Most likely, 10 CFR 73.55(a) would contain the three performance criteria with applicability and process language Used to identify reactors that could make use of the alternatives provided in this proposed rule Most likely, a new paragraph under 10 CFR 73.55 would contain the proposed alternative security requirements Staff reviewed and screened proposed alternatives identified during the December 12, 2019 public meeting Staff identified several for potential inclusion in the proposed rule Current Rulemaking Approach 79 of 87

5 Alternative to the requirement in 10 CFR 73.55(k)(5)(ii) that the number of armed responders shall not be less than ten Alternative to the requirement in 10 CFR 73.55(i) for the secondary alarm station to be onsite Alternative to the requirements in 10 CFR 73.55(e)(9) addressing the designation of vital areas Alternative to certain requirements in 10 CFR 73.55(e) addressing physical barriers Proposed Alternatives 80 of 87

6

Staff plans to develop a draft Regulatory Guide that will:

endorse NEI guidance that NRC finds acceptable for use in meeting one or more of the three performance criteria

identify existing relevant NRC guidance or develop new guidance, if needed, for the alternatives Draft Guidance 81 of 87

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Next Public Meeting: April 2020 (tentative)

Proposed Rule and Draft Guidance Provide to the Commission in December 2020 Issue for public comment in early 2021

Final Rule and Final Guidance Provide to the Commission in May 2022

Contact:

Dennis Andrukat, Rulemaking Project Manager Email: Dennis.Andrukat@nrc.gov Next Steps 82 of 87

NON-LWR STAKEHOLDER MEETING EMERGENCY PREPAREDNESS REQUIREMENTS FOR SMALL MODULAR REACTORS AND OTHER NEW TECHNOLOGIES Proposed Rule (NRC Docket ID: NRC-2015-0225)

February 20, 2020 1

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2 Major provisions of the proposed rule include:

Performance-based alternative to the current EP framework.

Provision for a scalable determination of the plume exposure emergency EPZ size.

Requirement to describe ingestion pathway planning capabilities.

Provision for a hazard analysis of nearby facilities.

EP Requirements for SMRs and ONTs Proposed Rule 84 of 87

3 NRC staff submitted the draft proposed rule package to the Commission on October 12, 2018, for review and approval (ADAMS Accession No. ML18134A086).

The Commission issued SRM-SECY-18-0103 and approved the publication of the proposed rule in the Federal Register in December 2019 (Accession Number: ML19351C729).

Commission comments were made publicly available in of the SRM.

EP Requirements for SMRs and ONTs Proposed Rule 85 of 87

4 EP Requirements for SMRs and ONTs Proposed Rule

The staff is addressing the Commission comments.

The revised proposed rule package will be sent to the Commission Secretary (SECY) by March 6th.

If the Commission approves the revised package, the proposed rule will be subsequently published in the Federal Register for a 75-day comment period.

After a period of approximately 30-45 days, the staff will hold a public meeting during the comment period.

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Future Meeting Planning and Open Discussion 2020 Tentative Schedule for Periodic Stakeholder Meetings April 2 May 7 June 18 August 6 September 24 November 5 87 of 87

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