ML20265A196

Industry Presentation for NRC Public Meeting on DG-4028

ML20265A196
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/22/2020
From:	Nuclear Energy Institute
To:	Jerrica Johnson NRC/NRR/DEX/EMIB
Jenise Thompson 415-7000
References
DG-4028
Download: ML20265A196 (7)

Text

DG-4028, Volcanic Hazards Assessment for Proposed Nuclear Power Reactor Sites" NEI / Member Comments NRC Public Meeting September 22nd, 2020

©2020 Nuclear Energy Institute

Introductions

NEI Marc Nichol, NEI Kati Austgen, NEI Frankie Pimentel, NEI

©2020 Nuclear Energy Institute

General Concerns

• The proposed approach forces potential applicants in areas without potential volcanic hazards (e.g., the eastern United States) to perform unnecessary analyses, and creates implementation challenges for applicants in regions with potential volcanic hazards, such as the northwestern United States

• Application of IAEA guidance referenced in its entirety would result in excessive conservatism and could preclude the ability to site advanced reactors in much of the western United States

©2020 Nuclear Energy Institute 3

General Concerns

• The guidance is not consistent with the regulatory approach for addressing other external hazards

• Under the proposed guidance, the potential radiological consequences resulting from volcanic hazards are not considered, despite the stated purpose of being risk-informed

• Lack of clarity makes it unusable - for example, the guidance depends on many undefined terms

©2020 Nuclear Energy Institute 4

Key Recommendations:

• Specifically delineating regions of the continental U.S. where this particular hazard does not apply, thereby eliminating any unnecessary content for potential applications regarding volcanic hazards, would be beneficial

• The USGS-National Volcanic Threat Assessment, could be used as the technical basis to state that applications for sites located in the continental US east of 98 degrees 30 minutes W longitude do not have to prepare content regarding volcanic hazards

• The regulatory guide should provide a more clearly risk-informed process that considers potential radiological consequences and the ability to design for, or mitigate, those potential radiological consequences due to volcanic hazards

©2020 Nuclear Energy Institute 5

Key Recommendations:

• The guidance should have a performance based approach to characterize volcanic hazard regions of effects to determine the areas where they need to be considered, e.g., using the USGS National Volcanic Threat Assessment, rather than the current draft guidance to search for hazards based on distance from the site selected

• The NRC should avoid referencing IAEA-TECDOC-1795 and SSG-21, since there are portions of those guidance documents that are inconsistent with the NRC approach to regulating other external events

• The guidance should consider the technology-inclusive, risk-informed, performance-based approach in NRC RG 1.233 endorsement of NEI 18-04, Risk-Informed Performance-Based Technology Inclusive Guidance for Non-Light Water Reactor Licensing Basis Development

©2020 Nuclear Energy Institute 6

==

Conclusions:==

• While this draft guidance seeks to implement important concepts in risk-informing the consideration of volcanic hazards, we have significant concerns that the approach would be unworkable in its current form

• Significant changes are needed to DG-4028 to incorporate a more risk-informed, performance-based approach that is consistent with the regulatory framework for addressing external hazards

• We recommend that the NRC work with industry to revise and reissue the draft regulatory guide for public comment

©2020 Nuclear Energy Institute 7