ML20196L770
| ML20196L770 | |
| Person / Time | |
|---|---|
| Issue date: | 07/14/2020 |
| From: | Dan Barss NRC |
| To: | |
| SECY/RAS | |
| References | |
| 85FR28436, NRC-2015-0225, PR-50, PR-52, RIN 3150-AJ68 | |
| Download: ML20196L770 (3) | |
Text
From:
Barss, Dan To:
Beall, Bob Cc:
Anderson, Joseph; Musico, Bruce; Mott, Kenneth; Schrader, Eric; Kahler, Robert
Subject:
Comments on SMR/ONT rulemaking Date:
Tuesday, July 14, 2020 7:42:17 AM
- Bob, See below for my comments on the SMR/ONT rulemaking. I understand you will incorporate them into rest of public comments for resolution. Feel free to contact me as needed to help resolve comments.
Dan Significant Comments -
Credible Accident 10 CFR 50.33(g)(2) - proposed change resulting from a spectrum of credible accidents for the facility.
(This same term is used many times in the document, Pg. 32, 53, 62, and in DG-1350, pg.
7, A-1.) On page 33, it states spectrum of credible accidents (design-basis accidents, less severe accidents, and less probable but more severe accidents).
What is a credible accident? Is there somewhere else the term credible accident is defined? Also, should address continuing question as to whether an accident that could impact multiple modules/units would be considered under credible accidents.
Credible accident needs to be defined, or a pointer need to be added to direct one to where it can be determined what a credible accident is. Without a clear understanding of how a credible accident is defined, identified, or determined, the whole basis of this proposed rule is weak and subject to interpretation and confusion in the future.
18 Months 10 CFR 50.160(c)(1) and (c)(2) - proposed rule basically says something like initial exercise to demonstrate effectiveness of EP program no later than 18 months before issuance of OL or 18 months before fuel load for a COL.
Based on current experience with Vogtle Unit 3 COL, this is an unrealistic and unworkable time frame. For example, Vogtle 3 is currently within a few months of scheduled fuel load, the TSC is not yet completed, (construction delays). The licensee may not yet have hired and trained all the required staff needed to fill out EP rosters. For future applicants/licensees it is unlikely that 18 months out they will have EP facilities constructed, or staff hired and trained to support EP roster and conduct drills and/or exercises.
There is no radiological risk, and no need for EP, until fuel load. So this time frame needs to be much closer to issuance of OL or authorization for fuel load. As long as the EP is in place before OL or authorization of fuel load, there does not need to be a lead time of (X) months.
PR-50, 52 85 FR 28436 82
Page 50, Emergency Response Data System (ERDS), 50.160 applicant/licensee is required to describe the data link that will provide information to the NRC. No guidance is given on the key safety parameters or type of information at a minimum that should be provided, as applicable to design. Also, timeframe for activation of ERDS following an emergency event is not detailed.
Other comments -
Pg. 40 - the term safe condition is defined. Should this definition be included in 50.2 definitions?
Pg. 45 - Contacts and arrangements (Add text in red) - the regulation and guidance should make it clear that the application should discuss the contacts made with outside organizations, State, local governments, other organizations. The emergency plans need to document the arrangements made with outside organizations, State, local governments, other organizations.
Pg. 46 - Offsite drills and exercises - What standards would apply for offsite organizations?
Pg. 51 - credible hazards - What is a credible hazard? This needs to be defined. Also, the document should state the applicant or licensee to perform a hazard analysis to assess any credible hazard that would adversely impact the safe operation of the facility or the implementation of emergency plans (Add text in red.)
Pg. 91 - 50.54(gg)(1) - refers to FEMA deficiencies should this be edited to Level 1 Findings as now defined by FEMA?
DG-1350 comments-
Reference 10, NUREG-0654 appears to only indicate November 1980 revisions. Should it also include most recent revision also?
Credible accidents - see comments above.
Pg. 10 - Performance-based Framework - 5. Second paragraph, this characterizes much of DG-1350, it does not provide clear guidance to an applicant on what NRC may find acceptable, nor framework for NRC reviewer.
Pg. 11 - c.3(b) - See comment above Pg. 51.
Pg. 11 - What are the expectations for State and local review of EAL scheme, and initial NRC approval of EAL scheme?
Pg. 13 - e(1) Communications - also f(1) and g(1) - the text states personnel should this mean, or be, by title or position.
Pg. 17 - 6.b(8) deployment should be development.
Pg. 21 - g(1) and g(2) - 10 CFR 50.160(b)(1)(iv)(B)(7) - discusses offsite dose projections, does this apply or occur at all times or only with an offsite EPZ?
Pg. 22 - 8. - see comment Pg. 51, and Pg. 11, above.
Pg. 23 - MD 8.4 referenced. - This implies that an applicant or licensee would follow the NRC internal process in MD 8.4. Do MDs apply to applicant or licensees, or are they only internal to NRC?
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