ML22123A158

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Slides - May 2022 Public Meeting to Discuss Options for a Potential Rulemaking on Security for ISFSIs
ML22123A158
Person / Time
Issue date: 05/24/2022
From: Johari Moore
NRC/NSIR/DPCP/MSB
To:
Moore J
References
Download: ML22123A158 (16)
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Text

Public Meeting to Discuss the NRC Staffs Consideration of Options for a Potential Rulemaking on Security for Independent Spent Fuel Storage Installations May 24, 2022

Purpose of this meeting

  • This is a Comment-Gathering Meeting.
  • Discuss the U.S. Nuclear Regulatory Commission (NRC) staffs development of an options paper for the Commission regarding security for independent spent fuel storage installations (ISFSIs).
  • At the appointed time, attendees will have the opportunity to ask questions and/or make comments about the options were considering and the evaluation criteria weve developed; however, the NRC will not provide written responses to comments or questions raised.

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Key Messages

  • Staff is evaluating the pros and cons of multiple options to develop a recommendation to the Commission in response to Staff Requirements Memorandum (SRM)-SECY-19-0100, Discontinuation of Rulemaking - Independent Spent Fuel Storage Installation Security Requirements (ADAMS* Accession No. ML21217A045).
  • The existing regulatory framework provides reasonable assurance of adequate protection of public health and safety and the common defense and security.
  • NRCs Agencywide Documents Access and Management System 3

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Background===

  • In SECY-07-0148, dated August 28, 2007 (ADAMS Accession No. ML080030050), the staff proposed to apply a risk-informed and performance-based approach to update the security requirements for ISFSIs.

- Address potential security vulnerability identified in post-9/11 security assessments.

- Improve regulatory clarity by implementing consistent requirements for general and specific ISFSI licensees regardless of ISFSI location.

- Apply a dose-based approach to all ISFSIs in a new Title 10 Code of Federal Regulations (CFR) Part 73 regulation that would use an acceptance criterion equivalent to the 10 CFR 72.106 0.05-Sv (5-rem) dose limit for safety-based events.

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Background (cont.)

  • On December 16, 2009, the staff published the draft regulatory basis for the proposed rulemaking to revise security requirements for facilities storing spent nuclear fuel and high-level radioactive waste (ADAMS Accession No. ML093280743).
  • In SECY-10-0114, dated August 26, 2010 (ADAMS Accession No. ML101880013), the staff recommended reassessing the technical approach based on stakeholder comments prior to developing the final regulatory basis.
  • In COMSECY-15-0024, dated September 11, 2015 (ADAMS Accession No. ML15229A231), the staff recommended re-evaluating whether rulemaking is warranted after five years, noting that the existing regulatory framework provides continued high assurance of adequate protection.

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Background (cont.)

  • In 2018, the Commission directed that resources be allocated for the expedited ISFSI security rulemaking with the exclusive scope of codifying the requirements of the post-9/11 security orders.
  • In SRM-SECY-19-0100, dated August 4, 2021 (ADAMS Accession No. ML21217A045), the Commission directed the staff to provide a notation vote paper with a full range of options for the ISFSI security rulemaking.

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Considerations for rulemaking options

  • Stakeholder feedback on 2009 draft regulatory basis
  • Insights from staffs efforts to develop an implementation framework for the dose-based approach
  • Current and future ISFSI-security regulatory landscape
  • Related NRC rulemaking activities
  • Stakeholder feedback from this public meeting 7

Initial options under consideration

  • Option 1 - no action (status quo)
  • Option 2 - codify orders only
  • Option 3 - resume 2007 rulemaking to implement the dose-based approach
  • Option 4 - perform future reassessment to identify rulemaking options for alternatives to the dose-based approach 8

Option 1 - no action (status quo)

  • Maintain the current regulatory requirements and the post-9/11 security orders, which provide reasonable assurance of adequate protection of public health and safety and the common defense and security.
  • Continue to address the appropriate security requirements for new license applicants on a case-by-case basis.

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Option 2 - codify orders only

  • Proceed with the ISFSI security rulemaking with the exclusive scope of codifying the requirements of the post-9/11 ISFSI security orders.
  • Due to the sensitive nature of some of the security requirements, some provisions would need to be maintained via orders.
  • Note: In SECY-19-0100, the staff determined that this limited-scope rulemaking is not necessary for adequate protection and would not be cost justified.

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Option 3 - resume 2007 rulemaking

  • Implement a framework where ISFSI licensees would use the information provided by the NRC in combination with site-specific information to perform a calculation to ensure a 0.05-Sv (5-rem) dose limit is currently met, and, if not, to revise their protective strategy.
  • Finalize the 2009 draft regulatory basis for the dose-based approach.
  • Complete vulnerability assessments to define credible and reasonable security scenarios.
  • Perform analyses to determine radiological release fraction values for all ISFSI cask types.
  • Develop guidance for licensees on methods for performing the required dose assessments.

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Option 4 - perform future reassessment of alternative technical approaches

  • Reassess alternative technical approaches to the dose-based approach to potentially identify technically viable, risk-informed rulemaking options for addressing any credible security vulnerability and to address any current concerns with regulatory clarity.
  • Conduct further research using credible analysis methodologies to clearly define the risks associated with the potential security vulnerability for ISFSIs.
  • Consider any implications arising from a final decommissioning rulemaking as well as current staff experience to reassess the concerns with regulatory clarity (e.g., unnecessarily complex) raised by staff in SECY-07-0148.
  • Consider any implications arising from an enhanced security of special nuclear material rulemaking effort on security requirements for ISFSIs if spent nuclear fuel is included within the rulemakings scope.

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Criteria for evaluating options In determining which option is best, the staff will apply attributes based on the NRCs Principles of Good Regulation

- Independence

- Openness

- Efficiency

- Clarity

- Reliability 13

Current criteria for evaluating options

  • Considers current threat environment
  • Considers current operational experience
  • Increases regulatory predictability and consistency
  • Requires access to classified information
  • Considers recurring costs for NRC and industry 14

Planned next steps

  • Staff will develop a SECY paper to the Commission with options and a recommendation on the path forward for ISFSI security with consideration of public input on the options and evaluation criteria.
  • Staff plans to provide the SECY paper to the Commission by the end of September 2022.

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Questions?

  • Link to NRC public meeting feedback form:

https://feedback.nrc.gov/pmfs/

  • Email feedback to Johari.Moore@nrc.gov 16
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