ML22147A109
| ML22147A109 | |
| Person / Time | |
|---|---|
| Issue date: | 05/24/2022 |
| From: | Johari Moore NRC/NSIR/DPCP/MSB |
| To: | |
| Moore J | |
| References | |
| Download: ML22147A109 (4) | |
Text
U.S. Nuclear Regulatory Commission Public Meeting Summary May 24, 2022
Title:
Public Meeting to Discuss the NRC Staffs Consideration of Options for a Potential Rulemaking on Independent Spent Fuel Storage Installation Security Date: May 24, 2022 Location: Webinar Category: Comment-Gathering Meeting Purpose of the Meeting: Discuss the NRC staffs development of a Commission paper presenting options for a proposed rulemaking on independent spent fuel storage installation (ISFSI) security requirements.
General Details: The meeting was attended by 80 individuals, including NRC staff, industry, other government organizations, non-government organizations, congressional staff, the public, and the press.
Summary of Presentation: The NRC staff provided background on the ISFSI security rulemaking, four rulemaking options staff identified for the Commission paper, and staffs criteria for evaluating the options.
Summary of Public Feedback: Following the staffs presentation, the staff opened the meeting for an interactive discussion where stakeholders could ask questions and provide comments on the rulemaking activity. Some stakeholders provided high-level feedback in support of the scope of rulemaking options presented and the clarity of the staffs presentation.
One commenter indicated a preference for Option 4 (Perform a future reassessment to identify alternatives to the dose-based approach). This commenter reiterated concerns with Option 3 (Continue the 2007 Commission-directed rulemaking to implement the dose-based approach) that the commenter had expressed during previous staff engagement with stakeholders on the ISFSI security rulemaking. The commenters specific concerns with Option 3 related to a lack of validation models necessary to provide an accurate assessment of source terms necessary to implement the dose-based approach. This commenter expressed a preference for a methodology where licensees would use a denial-of-task strategy to prevent identified attack modes that could lead to significant fuel damage. This commenter noted that, if the schedule for Option 4 would be lengthy, Option 3 would be preferable to Option 4, provided that a means for validation of the models to develop source terms could be established.
Another commenter expressed dissatisfaction that the paper would not include a comparison of the costs associated with requiring hardened on-site storage at ISFSIs and the transportation of spent fuel to a consolidated interim storage facility. This commenter requested more information on Item 11 of the Petition for Rulemaking-72-6 (74 FR 9178) on this topic that staff previously reserved for consideration within the scope of the ISFSI security rulemaking.
Some commenters requested information on the staffs position regarding the need to process facility and personnel clearances for stakeholders to allow the NRC staff to share classified information with stakeholders related to the technical basis for the rulemaking. A commenter
noted that the time associated with processing these clearances should be considered when evaluating the options.
Commenters requested that the staff explain the definition of the term release fraction, the definition of the term stakeholder, the relationship between this paper and the staffs concurrent paper on rulemaking options for enhancing security of special nuclear material, the relationship between the 5-rem dose-limit criterion described in Option 3 and protective action guides for emergency preparedness, and the relationship between the vulnerability assessments associated with the rulemaking options in this paper and the staffs ongoing activity to continuously monitor the threat environment.
One commenter noted the value in improving the clarity of the ISFSI-security requirements. Two commenters expressed opposing positions on the likelihood of specific threat scenarios previously considered by staff in the development of the ISFSI security rulemaking. One commenter asked if the post-9/11 security orders issued to ISFSI licensees would be codified under Options 3 and 4. Another commenter indicated that Option 3 is not cost justified and noted an interest in engaging with the staff to support development of a cost evaluation for this option.
A commenter requested information on staffs plans for additional public engagement on the development of the paper and requested that any draft versions of the paper be circulated to all stakeholders.
Action Items/Next Steps: Staff will develop a SECY paper to the Commission with options and a recommendation on the path forward for the ISFSI security rulemaking, with consideration of stakeholder input.
Attachments:
- Meeting notice and agenda - ML22144A102
- NRC staff presentation - ML22123A158 Accession No.: ML22147A109 OFFICE NSIR/DPCP/MSB NSIR/DPCP/MSB NAME Johari Moore Alison Rivera DATE 05/26/2022 05/27/2022 OFFICIAL RECORD COPY
MEETING ATTENDANCE PUBLIC MEETING TO DISCUSS THE NRC STAFFS CONSIDERATION OF OPTIONS FOR A POTENTIAL RULEMAKING ON INDEPENDENT SPENT FUEL STORAGE INSTALLATION SECURITY WEBINAR MAY 24, 2022, 1:00 PM to 3:00 PM Meeting Attendee* Affiliation Lance Rakovan U.S. Nuclear Regulatory Commission (NRC)
Bergman, Jana Curtiss-Wright Corporation Johari Moore NRC New Jersey Department of Environmental Veena Gubbi Protection Keith Waldrop not indicated Nathan Faith Constellation Nuclear Michele Sampson NRC New Jersey Department of Environmental Jerry Humphreys Protection Ray Kellar NRC Doug Garner NRC Adam Gendelman NRC Neil Sheehan NRC Martin C. Murphy Xcel Energy Inc.
Paul Hansen Florida Power & Light Company (FPL)
Bruce Montgomery Nuclear Energy Institute (NEI)
Eileen M. Moore EnergySolutions Fred Schofer NRC Cheryl Olson Dairyland Power Cooperative Cynthia Jones NRC Jeremiah Rey NRC Janet Schlueter NEI Joe Gillespie NRC Charity Pantalo NRC Alison Rivera NRC Gregory Trussell NRC Gary Purdy NRC Thomas Romay PGN Phil Couture not indicated Davis, J. Michael FPL Danna Hickey Xcel Energy Inc.
Vince Williams NRC Steven Dolley S&P Global Jan Boudart Nuclear Energy Information Service Michael Norris NRC Dana Caron NRC Carl Storms Portland General Electric Company Tom Eck NRC
Edwin Lyman Union of Concerned Scientists Katrina McMurrian KSM Strategies Tara Inverso NRC Marty Moe Dairyland Power Andrew M. Newman Idaho National Laboratory Daniel Forsyth NRC Senate Environment and Public Works Matthew Marzano Committee Phil Brochman NRC Jared Justice NRC Donald L. Karstetter EnergySolutions Marshall Kohen NRC Bradly J. McMahon Dominion Nuclear Projects, Inc.
Richard Mogavero NEI Jim Lenois Connecticut Yankee Stan Day 3 Yankee Companies Bill Gross NEI James Maltese NRC Geoffrey Miller NRC John Patrick North Star Matthew Widener not indicated David Schwarzbart Sacramento Municipal Utility District Jeff Isakson Interim Storage Partners John Tappert NRC Lisa Dimmick NRC Desiree Davis NRC Mike Callahan Decommissioning Plant Coalition Kris Cummings NuScale Power Jim Beardsley NRC Shana Helton NRC John Henkelman Dairyland Power David Brown NRC Jill Shepherd NRC John Pfabe Westinghouse Electric Company Richard Hardy Pennsylvania State Government
- Nine unnamed individuals participated via phone.