ML21301A034

11/2/2021 - NRC Presentation to Support the Advisory Committee on Reactor Safeguards Full Committee Emergency Preparedness for Small Modular Reactors and Other New Technologies

ML21301A034
Person / Time
Issue date:	11/02/2021
From:	Soto S NRC/NMSS/DREFS/RRPB
To:
Soto S
References
10 CFR Part 50, 10 CFR Part 52, EP SMR ONT, NRC-2015-0225, RIN 3150-AJ68
Download: ML21301A034 (31)

Text

Advisory Committee on Reactor Safeguards 10 CFR Parts 50 and 52 Emergency Preparedness for Small Modular Reactors and Other New Technologies November 2, 2021

NRC Staff Presenters

• Soly Soto Lugo, NMSS - Rulemaking PM

• Eric Schrader, NSIR - Technical Lead

• Charles Murray, NSIR - RG 1.242 Lead

• Michelle Hart, NRR - Senior Reactor Engineer 2

Background

• Proposed rule

- Published the proposed rule for public comments on May 12, 2020

- Comment period: total of 135 days (ended on Sept 25, 2020)

• Public comments

- Received comments from 2,212 individuals and organizations, including 2,087 form letters

- Identified 649 unique comments on the proposed rule

- Responses to public comments will be published upon Commission approval of the final rule

• Draft final rule due to the Commission by December 30, 2021 4

5 Draft Final Rule Language

Draft Final Rule Language Technical Basis and Major Provisions

• Graded approach to EP:

- Performance-Based

- Technology-Inclusive

- Risk-Informed

- Consequence-Oriented

- Hazard analysis 6

Draft Final Rule Language (cont.)

7 New Alternative Performance-Based Framework

Draft Final Rule Language (cont.)

• New Alternative Performance-Based Framework

- Section 50.160(b)(1) demonstrate effective response in drills and exercises for emergency and accident conditions

• Scalable approach for determining plume exposure pathway EPZ size

- Section 50.33(g)(2) CP, OL, ESP or COL applicants complying with § 50.160 must submit the analysis used to determine the EPZ size 8

Draft Final Rule Language (cont.)

Regulatory Oversight

• Section 50.160(b)(1) requires applicants and licensees to use drills and exercises to demonstrate their capabilities in the required emergency response functions

• The NRC staff is in the process of developing a regulatory oversight framework that is technology-inclusive, risk-informed, and performance-based

• Performance Objectives -vs-Performance Indicators 9

Draft Final Rule Language (cont.)

• EPZ Boundary and Physical Characteristics

- Section 50.33(g)(2) applicants must propose their EPZ

- Section 50.160(b)(3) requires applicants to describe in their emergency plans the boundary and physical characteristics of the EPZ

• Requirement to Describe Ingestion Response Planning

- Section 50.160(b)(4) establishes ingestion response planning requirements 10

Draft Final Rule Language (cont.)

• Onsite and Offsite Planning Activities

- Section 50.160(b)(1)(iv)(A) contains required onsite and offsite planning activities for all applicants and licensees

• Offsite Planning Activities

- Section 50.160(b)(1)(iv)(B) contains required offsite planning activities for applicants with a plume exposure pathway EPZ that extends beyond the site boundary 11

Draft Final Rule Language (cont.)

• Requirement for Hazard Analysis

- Section 50.160(b)(2) requires a hazard analysis of facilities contiguous to or near an SMR or ONT facility

• Consideration of Credible Hazards

- Activate the emergency plan

- negatively impact implementation of the emergency plan 12

Presidential Policy Directive 8 / PPD-8, National Preparedness PPD-8 National Planning Framework requires:

• A Planning Framework, covering five areas -

Prevention, Protection, Mitigation, Response and Recovery

• Response and Recovery area - Nuclear/Radiological Incident Annex

• Annexes describe response and resources available

• Part of the Nuclear/Radiological Incident Annex is the DOE/National Nuclear Security Administration (NNSA)

Federal Radiological Monitoring and Assessment Center (FRMAC) 13

FRMAC Activation Timeline 14 Activation Sequence for Various DOE-Related Assets Once Authorized DOE/NV/25946-980 FRMAC Operations Manual (May 2010)

Approximate Readiness Time After Activation - Emergency (Early) Phase

FEMA and DOE Public Comments

• Federal Emergency Management Agency

- Supported modifying regulatory framework, but opposed potential for site boundary EPZs

- Argued the rule does not consider full spectrum of threats and beyond design basis accidents

• U.S. Department of Energy

- Supported the proposed rule

- The revised EP framework would provide more appropriate approach for SMRs 15

Significant Changes to the Proposed Rule

• Revised section 50.33(g)(2) EPZ sizing criteria

• Revised section 50.160(b)(3) to include entry criteria

• Revised sections 50.160(c)(1)-(2) to allow licensees greater flexibility for initial exercise demonstration 16

Other Changes to the Proposed Rule

• Revised section 50.2 definition of small modular reactor

• Revised section 72.32(c) to clarify that the emergency plan that meets the requirements of sections 50.47 or 50.160 satisfies the EP requirements of section 72.32

• Revised section 50.160(b) to state the reasonable assurance finding required in section 50.47(a)(1) apply to section 50.160 applicant 17

Other Changes to the Proposed Rule (cont.)

• Added new paragraph 50.47(f) denoting when the offsite emergency response plan requirements in § 50.47(a)(2), (b), and (c)(2) do not apply

• Revised sections 50.160(b)(1)(iii)(F)(1), (3) and (4) to refer to applicable response organizations

• Revised section 50.160(b)(1)(iv)(B)(4) to ensure ETEs include area within the site boundary 18

Other Changes to the Proposed Rule (cont.)

• Clarified that an applicant complying with section 50.160 needs to submit an emergency plan of a participating Tribal government

• Relocated requirements for site familiarization and maintenance of emergency plan to section 50.160(b)(1)(iv)(A) to ensure requirements are applicable to all applicants and licensees 19

Draft Regulatory Guidance 20 RG 1.242, Performance-Based Emergency Preparedness for Small Modular Reactors, Non-Light Water Reactors, and Non-Power Production or Utilization Facilities

Draft Regulatory Guidance

• Conforming changes to the regulatory guide

- Made conforming changes based on changes to the draft final rule language

- Included additional reference documents

- Enhanced the guidance on accident likelihood, source term, timing of the accident sequence, and meteorology

- Added the definition of safe conditions to the glossary 21

Draft Regulatory Guidance (cont.)

• Appendix A, General Methodology for Establishing Plume Exposure Pathway Emergency Planning Zone Size

- Provides a general methodology acceptable to the NRC for the analysis for establishing plume exposure pathway EPZ size

- Added Section A-3.1, Event Selection, which discusses the applicants consideration of accident likelihood 22

Draft Regulatory Guidance (cont.)

• Appendix B, Development of Information on Source Terms

- Provides guidance to develop source terms for plume exposure pathway EPZ size evaluations 23

Draft Regulatory Guidance (cont.)

• Appendix A-3.1 Event Selection

- Use licensing basis events as candidate radiological release scenarios

- Considerations

• Internal and external initiators

• All sources

• Multi-module and multiunit

• Event likelihood including uncertainty

• Timing of the releases 24

Questions 25

Acronyms and Abbreviations AMS - Aerial Measuring System ACRS - Advisory Committee on Reactor Safeguards CFR - Code of Federal Regulations CMHT - Consequence Management Home Team CMRT - Consequence Management Response Teams CP - construction permit COL - combined license DOE - Department of Energy EP - emergency preparedness EPZ - emergency planning zone ESP - early site permit ETE - evacuation time estimate FEMA - Federal Emergency Management Agency FRMAC - Federal Radiological Monitoring and Assessment Center NARAC - National Atmospheric Release Advisory Center NMSS - Office of Nuclear Material Safety and Safeguards NRC - U.S. Nuclear Regulatory Commission NRR - Office of Nuclear Reactor Regulation NSIR - Office of Nuclear Security and Incident Response OL - operating license ONT - other new technologies PM - project manager REAC/TS - Radiation Emergency Assistance Center/Training Site RAP - Radiological Assistance Program RG - Regulatory Guide SMR - small modular reactor 26

27

Protective Action Recommendation 28 DOE/NV/25946-980 FRMAC Operations Manual (May 2010)

Key Messages 29 DOE/NV/25946-980 FRMAC Operations Manual (May 2010)

Supporting Graphics 30 DOE/NV/25946-980 FRMAC Operations Manual (May 2010)

Speaker Notes 31 DOE/NV/25946-980 FRMAC Operations Manual (May 2010)