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NEI Slides for 06-27-2024 Public Meeting Structures as IROFS at Fuel Cycle Facilities
	ML24172A195
Person / Time
Site:	Nuclear Energy Institute
Issue date:	06/27/2024
From:	Schlueter J; Nuclear Energy Institute
To:	; Office of Nuclear Material Safety and Safeguards
References
	Download: ML24172A195 (1)
	v • d • e

Buildings as Items Relied on for Safety

Janet Schlueter, NEI &

Fuel Cycle Industry Representatives

June 27, 2024 at NRC

Sept 2000: NRC amended Part 70 to require site specific Integrated Safety Analysis (ISAs) at fuel cycle facilities April 2001: Existing licensees required to submit site specific ISA plans Sept 2003: NRC held ISA workshops & issued summaries Oct 2004: Existing licensees required to submit ISA summaries for NRC review & approval Sept 2008: All ISA summaries approved by NRC after revisions made to original submittals

NRC reviews documented compliance with Part 70 Subpart H requirements (ISA) using NUREG -1520 (2002), NUREG -1513 (2001) and other relevant guidance documents

NRC issued NUREG-1520, Revision 1 in May 2010 Appendix D provided additional guidance for addressing Natural Phenomena Hazards (NPH) accident sequences NRC staff believe many existing facilities demonstrate compliance with performance requirements by accounting for conservatisms in the seismic, flooding and wind designs of the facility New structures are built to current model building codes which includes meeting a design-basis earthquake and baseline design criteria The new building design must withstand the most severe documented historical NPH events

Basis: Recent NRC public statements causing confusion on whether NRC expects licensees/applicants to identify buildings as IROFS regardless of ISA results.

Key Facts and Industry Concerns (see 5/24/24 NEI letter)

1. Part 70 regulatory framework stable since 2000

2. Facility-specific ISAs are appropriate analytical tool &

based on postulated initiating events and accident sequences to prevent or mitigate a high or intermediate consequence event; results provide ISA boundary

3. Building Code compliance supports determination that initiating event frequency-even in NPH scenarios-results in low consequence event

4. Configuration Management Programs required by 10 CFR 70.72, Facility Changes and Change Process to evaluate impact of plant changes and personnel activity. This includes buildings that are/are not designated as an IROFS

5. Baseline Design Criteria in 10 CFR 70.64(a)(2) requires a building to withstand most severe documented historical NPH event, thus accidents with high or intermediate consequences will not be initiated by NPH -related damage

6. NRCs Generic Letter 15-01 resulted in licensees reevaluation of sites and buildings, some modifications made, all determined adequate by NRC

7. 10 CFR 70.72 allows for facility modifications including constructing a new building in some cases without NRC prior approval; NRC inspects such changes; process is safe

ML24172A195

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