ML24298A063
| ML24298A063 | |
| Person / Time | |
|---|---|
| Issue date: | 10/23/2024 |
| From: | Brenner A Holtec, SMR |
| To: | Carrie Safford NRC/SECY |
| References | |
| NRC-2017-0227, 89FR65226 00008 | |
| Download: ML24298A063 (1) | |
Text
PUBLIC SUBMISSION As of: 10/23/24, 12:18 PM Received: October 23, 2024 Status: Pending_Post Tracking No. m2l-yyi9-pk98 Comments Due: October 23, 2024 Submission Type: Web Docket: NRC-2017-0227 Alternative Physical Security Requirements for Advanced Reactors Comment On: NRC-2017-0227-0038 Alternative Physical Security Requirements for Advanced Reactors Document: NRC-2017-0227-DRAFT-0046 Comment from Andrew Brenner on behalf of Holtec International on Alternative Physical Security Requirements for Advanced Reactors Submitter Information Email:abrenner@holtec.com Organization:Holtec International General Comment See attached file(s)
Attachments Alternative Physical Security for ARs Public Comment SMR LLC 10/23/24, 12:18 PM blob:https://www.fdms.gov/26f0ca15-ef26-4704-a4c0-66da5efd284d blob:https://www.fdms.gov/26f0ca15-ef26-4704-a4c0-66da5efd284d 1/1
SMR, LLC. A Holtec International Company Krishna P. Singh Technology Campus,1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Page 1 of 2 October 23, 2024 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
Subject:
SMR, LLC Comment on Proposed Rule, Alternative Physical Security Requirements for Advanced Reactors (Docket ID NRC-2017-0227)
Rulemakings and Adjudications Staff:
SMR, LLC (SMR), a wholly owned subsidiary of Holtec International, appreciates the opportunity to publicly comment on the Proposed Rule Alternate Physical Security Requirements for Advanced Reactors, and the associated guidance.
SMR endorses the industry comments supplied by the Nuclear Energy Institute (NEI) in their October 2024 letter. In particular, SMR agrees with the NEI comment on the proposed rule that requests the NRC to reconsider linking the term small modular reactor to the definition provided in 10 CFR 171.5 Definitions, which states:
Small modular reactor (SMR) for the purposes of calculating fees means the class of power reactors having a licensed thermal power rating less than or equal to 1,000 MWt per module. This rating is based on the thermal power equivalent of an SMR with an electrical power generating capacity of 300 MWe or less per module.
SMR agrees with the conclusion of NEIs comment that the NRC should not tie the eligibility to use the alternative requirements provided in the proposed 10 CFR 73.55 rule to arbitrary reactor power levels. However, SMR understands the intent of the proposed rule is to preclude use by the current operating fleet of large light-water reactors. In lieu of removing the reference to 10 CFR 171.5, SMR requests the NRC consider instead referencing newly added definition of small modular reactor in 10 CFR 50.2 Definitions, which was added as part of the 10 CFR 50.160 Emergency preparedness for small modular reactors, non-light-water reactors, and non-power production or utilization facilities rule. The 10 CFR 50.2 definition of small modular reactor states:
Small modular reactor means a power reactor, which may be of modular design as defined in § 52.1 of this chapter, licensed under § 50.21 or § 50.22 to produce heat energy up to 1,000 megawatts thermal per module.
Updating the proposed rule to refer to 10 CFR 50.2 ensures the intent for the 10 CFR 171.5 remains for the purposes of calculating fees only, while aligning the definition used for technical and performance-based regulations that delineate large and small light water reactors (e.g., 10 CFR 50.160 and the proposed 10 CFR 73.55 rule).
SMR, LLC. A Holtec International Company Krishna P. Singh Technology Campus,1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Page 2 of 2 Respectfully, Andrew Brenner Digitally signed by Andrew Brenner DN: cn=Andrew Brenner, c=US, o=Holtec, ou=SMR, email=A.Brenner@holtec.com Date: 2024.10.23 09:26:42 -04'00' Andrew Brenner Director of Licensing, SMR, LLC CC:
K. Trice (SMR, LLC, President)
J. Fleming (Holtec International, LLC, VP of Licensing & Regulatory Affairs)
J. Hawkins (SMR, LLC, Executive Director of SMR)
M. Hayes (USNRC, DNRL, NLIB, Branch Chief)
V. Huckabay (USNRC, DNRL, NLIB, Senior Project Manager)
M. Sayoc (USNRC, DNRL, NLIB, Project Manager)
I. Banks (USNRC, DNRL, NLIB, Project Manager)