ML24049A001
| ML24049A001 | |
| Person / Time | |
|---|---|
| Issue date: | 03/07/2024 |
| From: | Raymond Furstenau NRC/EDO |
| To: | Rusco F US Government Accountability Office (GAO) |
| Shared Package | |
| ML24038A383 | List: |
| References | |
| LTR-24-0025-1, GAO-24-106326 | |
| Download: ML24049A001 (3) | |
Text
Frank Rusco, Director Natural Resources and Environment U.S. Government Accountability Office 441 G Street, NW Washington, DC 20548
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION COMMENTS ON DRAFT GOVERNMENT ACCOUNTABILITY OFFICE REPORT GAO24106326, NUCLEAR POWER PLANTS: NRC SHOULD TAKE ACTIONS TO FULLY CONSIDER THE POTENTIAL EFFECTS OF CLIMATE CHANGE
Dear Mr. Rusco:
Thank you for the opportunity to review and comment on the U.S. Government Accountability Office (GAO) draft report GAO-24-106326, Nuclear Power Plants: NRC Should Take Actions to Fully Consider the Potential Effects of Climate Change, which the U.S. Nuclear Regulatory Commission (NRC) received on February 6, 2024.
The NRC appreciates the constructive engagement we have had with the GAO throughout the audit and the GAOs thoroughness in seeking to understand the NRCs regulatory framework related to external hazards, particularly given the complexity of the detailed processes and programs that the NRC uses to support its safety mission.
We are in general agreement with the findings. The three recommendations in the draft report are very broad but are consistent with actions that are either underway or under development.
The NRC considers this report to be a fair characterization of its regulatory structure, processes, and strengths. However, considering the description of the conservatisms, safety margins, and defense-in-depth policies described in the report, the NRC does not agree with the conclusion that the agency does not address the impacts of climate change. In effect, the layers of conservatism and defense in depth incorporated into NRCs processes provide reasonable assurance regarding any plausible natural hazard and combinations at a site for the licensed operational lifetime of the reactor, including those that could result from climate change.
Specifically, the processes, tools, methods, models, data, and additional margins provide reasonable assurance of the ability to withstand or mitigate projected changes in natural hazards.
It is also important to note that the NRCs mission is focused on nuclear safety; as such, we cannot impose requirements that would increase energy resilience or require consideration of potential future climate impacts without a sufficient nuclear safety justification. This is an important distinction since the predominant concerns expressed often in the draft report are that a licensees operations may be disrupted more frequently by climate change and that the NRC should more fully consider future climate projections. The NRC is focused on nuclear safety and any potential increase in the risk of a radiological release, consistent with the NRCs mandate.
March 7, 2024
F. Rusco We note there was no focus during the audit and no mention in the report of the NRCs proactive approach to safety reviews to support the licensing of new reactors. This is a significant contribution by the NRC to climate resilience; specifically, the NRC is licensing safe new energy sources that are an alternative to fossil-fuel-based plants. As noted in the enclosure, we would recommend a brief reference to the NRCs contributions to climate resilience via the proactive planning and implementation of new and advanced reactor licensing and license renewals.
If you have any questions concerning the staffs comments, please contact John Jolicoeur.
Mr. Jolicoeur can be reached at (301) 415-1642 or by email to John.Jolicoeur@nrc.gov.
Sincerely, Ray V. Furstenau Acting Executive Director for Operations Signed by Furstenau, Raymond on 03/07/24
F. Rusco
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION COMMENTS ON DRAFT GOVERNMENT ACCOUNTABILITY OFFICE REPORT GAO24106326, NUCLEAR POWER PLANTS: NRC SHOULD TAKE ACTIONS TO FULLY CONSIDER THE POTENTIAL EFFECTS OF CLIMATE CHANGE DATED: 03/07/2024 DISTRIBUTION: LTR-24-0025-1 PUBLIC RidsEdoMailCenter Resource RidsOgcMailCenter Resource RidsNrrOd Resource RidsNrrMailCenter Resource RidsSecyMailCenter Resource JJolicouer, OEDO KQuinlan, NRR BHayes, NRR TMartinez Navedo, NRR ARamirez, NRR CHobbs, NRR ADAMS Accession Numbers: ML24038A383 (Package),
ML24049A001 (LTR - Public release 60 days after final signature),
ML24049A002 (Enclosure - Non-Public)
- e-concurrence EDO-002 OFFICE NRR/DEX/EXHB*
NRR/DEX/EXHB*
NRR/DEX/D*
QTE*
NAME KQuinlan BHayes TMartinez Navedo JDougherty DATE 2/21/2024 2/21/2024 2/21/2024 2/26/2024 OFFICE OGC/NLO*
NRR/D*
OEDO/EDO*
OCM*
NAME DRoth AVeil (AKock for)
RFurstenau RTaylor DATE 02/27/2024 02/27/2024 03/01/2024 03/07/2024 OFFICE OEDO/EDO*
NAME RFurstenau DATE 03/07/2024 OFFICIAL RECORD COPY