ML24340A139
| ML24340A139 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 11/21/2024 |
| From: | Austgen K Nuclear Energy Institute |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML24340A139 (1) | |
Text
© 2024 Nuclear Energy Institute ADVANCE Act Section 206 Brownfield Sites NRC Public Meeting November 21, 2024 Kati Austgen Senior PM, New Nuclear
©2024 Nuclear Energy Institute 2 Active since 2021 NEI member utilities, new reactor designers, engineering procurement, construction and other professional service firms Goals of Task Force Reduce costs of application preparation & NRC review Improve NRC approval timeliness Enhance the flexibility of the regulatory process Resolve common policy issues NEI Siting Task Force
©2024 Nuclear Energy Institute 3 Informing NEI member business planning, e.g.,
Five-State Assessment of State Permit Applicability/ Transferability Federal Interconnection Reforms: Key Issues Affecting New Nuclear Development Informing NEI member interactions with NRC Assessment of the NRC Environmental Requirements for Siting (ML24016A232) - January 2024 Assessment of NRC Safety Siting Requirements Appendices 10 & 11 in NEIs Regulation of Rapid High-Volume Deployable Reactors in Remote Applications (RHDRA) and Other Advanced Reactors (ML24213A337) - July 2024 Task Force Work To-Date
©2024 Nuclear Energy Institute 4 State permits and Federal interconnection Multiple processes with their own timelines that will need to be managed in parallel with NRC review(s)
Timely cooperating agency determinations may support NRC Assessment of the NRC Environmental Requirements for Siting Opportunity to streamline: purpose & need, alternative sites analysis Opportunity to allow use of environmental assessment (EA), possibly Categorical Exclusion (CatEx)
Assessment of NRC Safety Siting Requirements Opportunities to fully credit new design features and risk-informed performance-based (RIPB) review Key Findings Relevant to Brownfields
©2024 Nuclear Energy Institute 5 Alternative Methodology for Meteorological Data Collection Alternative Methodology for Seismic Hazard and Site Characterization Population-Related Siting Considerations Task Force Work In-Progress
©2024 Nuclear Energy Institute 6
§206(c)(2)(C) of the ADVANCE Act calls for the NRC to consider matters related to the availability of historical site-specific environmental data.
RG 1.23 is the sole NRC-endorsed methodology for site-specific meteorological data collection.
requires installation of an onsite tower additional time and capital costs 10 CFR 50.160 provides a performance-based framework for emergency preparedness (EP) for SMRs & other new technologies.
Meteorological Data Collection NEI developing alternative methodology for met data collection
©2024 Nuclear Energy Institute 7 1.
Identify meteorological data sources from existing environmental permits/reports for the site. E.g.,
A specific airport or other data source required by a state/local environmental agency An existing onsite meteorological tower 2.
Obtain meteorological data for the source identified in #1. E.g.,
Airport data from NCEI (National Centers for Environmental Information)
Mesonets - state-level networks of meteorological stations 3.
Perform computations to support permitting and licensing.
Alt. Methodology for Met. Data Collection
- Proposed Approach for Brownfield Sites
©2024 Nuclear Energy Institute 8 NRCs conceptual approach in Sept.
2024 Nth of a Kind (NOAK) microreactor white paper.
Seismic Hazard and Site Characterization
©2024 Nuclear Energy Institute 9 NEI comments on the NOAK White Paper are under development Proposes that sufficient margin on the Site Margin Parameter OR the exclusion area boundary (EAB) dose margin should justify reduced site characterization Proposes that minimal site characterization for seismic hazard could rely heavily on U.S. Geological Survey (USGS) National Seismic Hazard Model (NSHM) as opposed to a purely site-specific Senior Seismic Hazard Analysis Committee (SSHAC) process.
The above is aligned with the NEI RHDRA Proposal Paper (ML24213A337)
- July 2024 Alternative Methodology for Seismic Hazard and Site Characterization NEI developing alternative methodology for 2Q25 submittal
©2024 Nuclear Energy Institute 10 10 CFR 100.21(b), (h) and 100.3, and RG 4.7, may challenge the business case for widespread advanced reactor deployment as they are overly restrictive compared to the accepted level of protection provided by requirements for existing large light water reactors.
Opportunities Provide regulatory history & bases for alternative approaches Modify corresponding 10 CFR Part 100 requirements Appropriately enable Population Density Distances commensurate with characteristics of advanced reactors Population-Related Siting Considerations NEI developing bases for alternative pop.-related siting criteria
©2024 Nuclear Energy Institute 11 Why It Matters DOE found >300 existing & retired coal plants are suitable to host advanced nuclear A NPP replacing a CPP would employ more people &
create additional long-term jobs in host communities increase total income in host communities increase revenue for host communities, power plant operators, & local suppliers BUT, ~80% are in communities
>25,000 people Credit: DOEs April 2024, Stakeholder Guidebook for Coal-to-Nuclear Conversions, distribution of U.S. CPPs bound by the size of the community populations where they are located
©2024 Nuclear Energy Institute 12 NRC revise guidance (and regulations, as needed) to acknowledge brownfield sites are already impacted and site reuse may be environmentally preferable to additional land disturbance Brownfield site review should not be more resource intensive than greenfield Existing information for brownfield sites may be equivalent to what NRC needs NRC activities to respond to ADVANCE Act direction align with the opportunities identified in SECY 24-0046, Implementation of the Fiscal Responsibility Act of 2023 Staff recommends rulemaking to allow increased use of EAs, applicant preparation of draft EA/EIS, more narrowly-focused need statement and alternatives analyses Clear NRC summary position/guidance on what makes a brownfield site viable for nuclear Desired Outcomes
QUESTIONS?
By Third Way, GENSLER