ML22278A090
| ML22278A090 | |
| Person / Time | |
|---|---|
| Issue date: | 01/28/2021 |
| From: | Robert Schaaf NRC/NMSS/DREFS/ENRB |
| To: | |
| MSHOEMAKER NMSS/DFM/MCAB 3014157363 | |
| References | |
| Download: ML22278A090 (15) | |
Text
Oklo Aurora Micro-Reactor Combined License Application Robert Schaaf, Sr. Project Manager Environmental Review New Reactor Branch Division of Rulemaking, Environmental, and Financial Support January 28, 2021 Risk Informed Decision-Making (RIDM)
In NEPA Environmental Reviews
Objectives Applying the Be RiskSMART Framework National Environmental Policy Act (NEPA)
Environmental Review for the Oklo Aurora Micro-Reactor Combined License Application 2
Key Principles of Risk-Informed Integrated Decisionmaking NRC Uses Its NEPA Environmental Review Process Guidance and Tools to Guidance or Processes Risk Informed Standard Review Plans S
M A
R T
Integrated Acceptance Reviews S
M A
R T
Pre Licensing Interaction Enhancement S
M A
R T
Graded Approach to Licensing S
M A
R T
Graded Approach to Rulemaking S
M A
R T
Assignment and Alignment Process S
M A
R T
Low Safety Significance Guidance S
M A
R T
Fuel Management Licensing Risk Tool S
M A
R T
Regulations Met Defense-in-Depth Consistency Maintenance of Safety Margins Risk Insights -Operational Experience Performance Monitoring 3
- NEPA environmental review for the Oklo Aurora combined license application
- Three levels of NEPA Reviews:
- Environmental Impact Statement or EIS - Major Federal actions significantly affecting the quality of the human environment [10 CFR 51.20 (b)]
- Environmental Assessment or EA - To determine if an action significantly affects the quality of the human environment (10 CFR 51.21).
Conclusion:
Finding of no significant impact; otherwise prepare EIS
- Categorical Exclusion - Categories of actions already determined to not be major Federal actions significantly affecting the quality of the human environment [10 CFR 51.22(c)]
4
- Commission and staff goal to streamline advanced reactor environmental reviews.
- 10 CFR Part 51 requires an EIS for power reactor applications.
- Oklo Aurora expected to have minimal environmental impacts, such that an EA and finding of no significant impact (FONSI) might be appropriate.
- We asked:
- Could we prepare an EA instead of an EIS for a power reactor application review?
- What are the potential advantages and challenges for each approach?
5
Lets start with the first step in the framework, SPOT, and work through each of the questions.
6
What could happen?
1)
Could an EA be authorized?
2)
Could potential challenges to the licensing review be greater? (e.g., FONSI, public participation) 3)
Could coordination of the review with key stakeholders be compromised? (e.g, NRR, DOE) 4)
Could potential savings be less than anticipated?
7
Now lets look at the second step in the framework, MANAGE.
8
What can I manage?
- 1) NEPA Process:
- Authority to prepare EA
- Options for enhancing confidence in FONSI and improving stakeholder engagement
- Advantages and challenges of strategies.
- 2) Decision-making Process:
- Obtain management alignment on review strategy.
- 3) Communications:
- Coordinate with stakeholders
- Inform Commission as needed 9
Now lets look at the third step in the frameworkits time to ACT on a decision.
10
What actions will I take?
- 1) Reach internal alignment and make decision Prepare briefing material on advantages and challenges of each review strategy Brief management on options and recommendations
- 2) Inform Commission, if required
- 3) Implement selected review strategy 11
Now lets look at the fourth step in the frameworkits time to REALIZE the result of our decision.
12
What happened when I acted?
- 1) Achieved management alignment on review strategy - develop streamlined EIS.
- 2) EIS process currently on hold pending resolution of several key safety review issues.
- 3) Refining schedule and evaluating opportunities to reduce resources to complete review.
13
Now lets look at the fifth step in the frameworkits time to TEACH others what we learned throughout this process.
14
How can I teach others?
- 1) Share briefing notes and discuss decision process with Env. PMs
- 2) Provide input to ongoing NEPA transformation efforts
- 3) Seminars, such as these 15