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{{#Wiki_filter:U.S. NRC Headquarters | {{#Wiki_filter:U.S. NRC Headquarters Update 2019 TOP Workshop February 6, 2019 Robert Kahler, Chief Policy and Oversight Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 1 | ||
2 | |||
*Licensee Interactions | 2 NRC Commissioners The Commission Kristine L. Svinicki, Chairman Jeff Baran Stephen G. Burns Annie Caputo David Wright Began Serving: March 2008 Began Serving: October 2014 Began Serving: November 2014 Confirmed: May 2018 Confirmed: May 2018 Term ending: June 2022 Term Ending: June 2023 Term Ending: June 2019 Term Ending: June 2021 Term Ending: June 2020 3 | ||
*EP Significance Determination Process (EP SDP) Focused Self | |||
-Assessment (FSA) | Discussion Topics | ||
*Alert and Notification System (ANS) and Integrated Public Alert and Warning System (IPAWS) | * Guidance Documents | ||
*EP Rulemaking Activities | * Licensee Interactions | ||
*Risk Perception vs Risk Reality | * EP Significance Determination Process (EP SDP) | ||
*Provide technical basis for assumptions used by NRC to model | Focused Self-Assessment (FSA) | ||
* Alert and Notification System (ANS) and Integrated Public Alert and Warning System (IPAWS) | |||
*Major or minor | * EP Rulemaking Activities | ||
* Risk Perception vs Risk Reality 4 | |||
*Discussions on specific licensee actions need to be coordinated through Office of Nuclear Reactor Regulation (NRR) Project | |||
-16*Pre-submittal conference call/meeting | EP Guidance Documents | ||
*Conference call to discuss proposed (draft) requests for additional information (RAIs) | * NUREG/CR-7248, Capabilities and Practices of Offsite Response Organizations for Protective Actions in the Intermediate Phase of a Radiological Emergency Response." | ||
*Follow-up | * Enhance NRC understanding of ORO practices and capabilities | ||
*State consultation (license amendment request)FEMA consultation: Does change impact offsite plans? | * Provide technical basis for assumptions used by NRC to model protective actions in consequence studies and regulatory analyses | ||
7 | * Published June 19, 2018, ADAMS ML18170A043 5 | ||
*RIS 2016-10, | |||
-05 (On-Shift Staffing Analysis)Staff evaluation using NUREG | EP Guidance Documents | ||
-0654/FEMA-REP-1, Rev 1*Proposed Revision 2 to NUREG-0654/FEMA-REP- | * NUREG-0654/FEMA-REP-1, Revision 2 | ||
-June 12, | * Reflects changes to NRC/FEMA regulations, guidance, and policies | ||
*Table B-1 (functions/augmentation times) is intended to provide a | * Consolidates numerous supplemental documents and addenda | ||
* Modernizes guidance technological advances and best practices | |||
* | * Office of Management and Budget (OMB) | ||
*ADAMS Accession No. ML17354A094). | * Major or minor rule determination 6 | ||
*February 7, 2018, NRC responded via letter | |||
* | Licensee Interactions (A, B, Cs) | ||
*(ADAMS Accession No.ML18024A427). | * Discussions on specific licensee actions need to be coordinated through Office of Nuclear Reactor Regulation (NRR) Project Manager Forecast of planned licensing submittals: Regulatory Issue Summary (RIS) 2015-16 | ||
* | * Pre-submittal conference call/meeting | ||
*During 2018, NRC HQ and Regional staff conducted an FSA | * Conference call to discuss proposed (draft) requests for additional information (RAIs) | ||
*procedural reviews, EP Inspector surveys, and review of external | * Follow-up discussions If unsure, ask for clarification | ||
*Public Meetings | * State consultation (license amendment request) | ||
*June 25, 2018, introduced FSA intent and purpose | FEMA consultation: Does change impact offsite plans? | ||
*January 10, 2019, provide tentative results and project plan 10 EP Significance Determination Process (SDP)Focused Self Assessment (FSA) 11 | 7 | ||
-Plan Changes.05 | |||
-Hostile Action (HA) Event . | Operating Reactor Licensing (ERO Staffing / Augmentation) | ||
-Scenario Review | * RIS 2016-10, License Amendment Requests for Changes to ERO Staffing and Augmentation (ADAMS ML16124A002) | ||
*Drill and Exercise Performance (DEP) | Clarifies use of NEI 10-05 (On-Shift Staffing Analysis) | ||
*Emergency Response Organization Drill Participation (ERO)*Alert and Notification System Performance (ANS) | Staff evaluation using NUREG-0654/FEMA-REP-1, Rev 1 | ||
*The EP | * Proposed Revision 2 to NUREG-0654/FEMA-REP-1 Letter to NEI, Entergy, NextEra - June 12, 2018 Table B-1 and Technical Basis (ADAMS ML16117A427) 8 | ||
*These enhancement opportunities are to be considered | |||
Operating Reactor Licensing (ERO Staffing / Augmentation) | |||
*The EP | * Table B-1 (functions/augmentation times) is intended to provide a model to consider in developing a site-specific emergency plan. | ||
*These enhancement opportunities are to be considered | * Emergency plan should describe the minimum ERO staffing plan Supporting EPIPs can describe any other staff response desired, as long as this staff is not critical to effective emergency plan implementation. | ||
9 | |||
*Outlook E-mail account for knowledge management | |||
*In Progress:2/3 staff qualified,remaining staff member will be | EP Significance Determination Process (SDP) | ||
-learned and other EP issues relevant to the ROP and SDP*COMPLETED | Focused Self Assessment (FSA) | ||
*Consideration of other Reactor Safety Cornerstones when | * December 12, 2017, Nuclear Energy Institute (NEI) submitted letter | ||
*Only these can be Greater than Green | * Recommendations for Improving the Emergency Preparedness Significance Determination Process | ||
*Only these would require a formal 10 CFR 50.54(q) change review, and subsequent requirement for NRC prior approval*Replace ANS PI with ERF Readiness PI | * ADAMS Accession No. ML17354A094). | ||
*Add EP ROP PIs to support 24 | * February 7, 2018, NRC responded via letter | ||
-month 10 CFR 50.54(t) | * Receipt of Nuclear Energy Institute Recommendations for Improving the Emergency Preparedness Significance Determination Process | ||
*Revise and consolidate EP Baseline Inspection Procedures*Provide guidance to better risk inform: EALs, dose assessment modeling, 10 CFR | * (ADAMS Accession No. ML18024A427). | ||
*Enhance guidance for evaluating meteorology and SCBA (joint EP and RP issue)*Revise EP Training | * take a fresh look at the EP SDP and to convene an expert team to evaluate the EP SDP based on the NRCs experience with the EP SDP as well as inputs from external stakeholders. | ||
*NRC Licensees are required to demonstrate reasonable assurance and adequate protection through the use of a viable Alert and Notification Systems (ANS | * During 2018, NRC HQ and Regional staff conducted an FSA | ||
* procedural reviews, EP Inspector surveys, and review of external stakeholder comments and/or suggestions. | |||
*Appendix E | * Public Meetings | ||
* June 25, 2018, introduced FSA intent and purpose | |||
*Licensees should | * January 10, 2019, provide tentative results and project plan 10 | ||
*NRC has final decision authority on Alert and Notification System | |||
EP Significance Determination Process (SDP) | |||
-out by individual users | Focused Self Assessment (FSA) 11 | ||
*Power Reactors Transition to Decommissioning | EP Significance Determination Process (SDP) | ||
*Small Modular Reactors and Other New Technologies (SMR/ONT) | Focused Self Assessment (FSA) | ||
*Mitigation of Beyond Design Basis Events(MBDBE)*10 CFR 50 and 52 Alignment 24 | Safety Cornerstones Baseline Inspection Performance Indicator Results Results Significance Significance Determination Process (SDP) Threshold Action Matrix Special Inspections Regulatory Response 12 | ||
*NUREG-1738, | |||
*NUREG-2161, | EP Significance Determination Process (SDP) | ||
-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor | Focused Self Assessment (FSA) | ||
*Supporting Research Studies (ADAMS ML16110A416) | BASELINE INSPECTION PROCEDURES | ||
*Analysis of | .01 Exercise Evaluation (biennial exercise) | ||
*Dose Rate of Accidental Radiological Release | .02 Alert and Notification System Evaluation | ||
*Although made public on May | .03 ERO Staffing and Augmentation System | ||
*The Commission will vote on the rulemaking and provide a Staff Requirements Memorandum (SRM) with direction on how to proceed. | .04 Emergency Action Level And E-Plan Changes | ||
*As such, the rule language and accompanying guidance may change and should not be considered final. | .05 Maintenance of Emergency Preparedness | ||
.06 Drill Evaluation (resident inspector) | |||
*PSEP may start after NRC dockets | .07 Exercise Evaluation - Hostile Action (HA) Event | ||
*PSEP is a transition period | .08 Exercise Evaluation - Scenario Review 13 | ||
-May only last 10 months (BWR) to 16 months (PWR) | |||
-Significant changes to plan not anticipated | EP Significance Determination Process (SDP) | ||
-No changes to regulations for offsite emergency plan | Focused Self Assessment (FSA) | ||
*10 CFR 50.200(a) | EP Performance Indicators (PIs) | ||
*Proposed Rule provides for: | * Drill and Exercise Performance (DEP) | ||
-Reduced ERO staffing | * Emergency Response Organization Drill Participation (ERO) | ||
-Revisions to EALs | * Alert and Notification System Performance (ANS) 14 | ||
-ETE updates no longer required | |||
-Annual dissemination of information to the public | EP Significance Determination Process (SDP) | ||
-future plant status | Focused Self Assessment (FSA) | ||
-Revised exercise schedule (drill cycle maintained) | Green Very low safety significance (licensee response band) | ||
*10 CFR 50.200(b) and (c) | White Low to moderate safety significance (increased regulatory response band) | ||
*Proposed Rule provides for: | Yellow Substantial safety significance (required regulatory response band) | ||
-Reduced ERO staffing | Red High safety significance (unacceptable performance band) 15 | ||
-Classification and Notification timeliness commensurate to risk and accident timing | |||
-Events classified as NOUE or Alert | EP Significance Determination Process (SDP) | ||
-No offsite (REP) planning requirements | Focused Self Assessment (FSA) | ||
*Proposed Rule provides for: | * FSA Conclusion | ||
-Revisions to EALs | * The EP SDP is sound | ||
-Emergency response facilities (TSC, OSC, EOF) may be combined | * However, there are several areas where the NRC should consider enhancement opportunities. | ||
-Biennial exercise within 2 years of entering into decommissioning (drill cycle maintained) | * These enhancement opportunities are to be considered preliminary, not a final NRC position, and subject to change. | ||
-No hostile action requirements (security EALs maintained) | 16 | ||
*10 CFR 50.47(f) | |||
EP Significance Determination Process (SDP) | |||
Focused Self Assessment (FSA) | |||
* FSA Conclusion | |||
* The EP SDP is sound | |||
*IOEP may start after all spent fuel is in dry cask storage | * However, there are several areas where the NRC should consider enhancement opportunities. | ||
*IOEP utilizes established EP planning standards for ISFSIs contained in 10 CFR 72.32(a) | * These enhancement opportunities are to be considered preliminary, not a final NRC position, and subject to change. | ||
*Part 50 and Part 52 licensees are granted a general Part 72 license*Application for a specific Part 72 license would require | 17 | ||
-Transition to Levels | |||
-Changes within Levels | EP Significance Determination Process (SDP) | ||
-Changes in Final Safety Analysis Report (FSAR) | Focused Self Assessment (FSA) | ||
-Changes in Emergency Action Levels (EALs) Classifications and Scheme(s) | Enhancement Opportunities | ||
*10 CFR 50.54(q)(7) | * Outlook E-mail account for knowledge management and drive consistency and awareness between NRC Regions and HQs | ||
* COMPLETED | |||
*10 CFR 50.54(q)(8) | * SharePoint tools to document and track issues. | ||
* COMPLETED | |||
*Transition between levels is not an RIE if changes comply with standards. | * SharePoint tools to coordinate NRC Regional and HQ resources. | ||
*Changes to e | * COMPLETED | ||
-plan are not RIEs if supported by Final Safety Analysis Report (FSAR) for Safety Systems and Components (SSCs) out of service. | * Qualify HQ EP staff as EP Inspectors. | ||
*Changes to EAL not RIE if physically unattainable. | * In Progress: 2/3 staff qualified, remaining staff member will be qualified in 2019 | ||
*Draft EP Regulatory Guide to accompany proposed rule | * Annual EP Operating Experience Report to capture lessons-learned and other EP issues relevant to the ROP and SDP | ||
*DG-1346, | * COMPLETED 18 | ||
*Final Regulatory Basis | |||
-November 2017, ML17215A012 | EP Significance Determination Process (SDP) | ||
*Proposed Rule/Draft Regulatory Guidance | Focused Self Assessment (FSA) | ||
-Provided to Commission May 7, 2018 | Enhancement Opportunities | ||
-Public May 22, 2018, ADAMS Package ML18012A019 | * Consideration of other Reactor Safety Cornerstones when determining significance of an EP issue | ||
*Public Comment Period (current estimate) | * Planning Standards 10 CFR 50.47(b)(2) (4) (5) (8) (9) (10 offsite) | ||
-April 30, 2019 | * Only these can be Greater than Green | ||
*Final Rule/Final Regulatory Guidance | * Only these would require a formal 10 CFR 50.54(q) change review, and subsequent requirement for NRC prior approval | ||
-Oct 7,2019, Provide to Commission | * Replace ANS PI with ERF Readiness PI | ||
-Dec 30, 2019, Issue FInal*Regulations.gov Docket ID NRC | * Add EP ROP PIs to support 24-month 10 CFR 50.54(t) review frequency. | ||
-2015-0070 | * Revise and consolidate EP Baseline Inspection Procedures | ||
39 | * Provide guidance to better risk inform: EALs, dose assessment modeling, 10 CFR 50.54(q), Fission Barrier Matrix, and Radiation Monitoring Instrumentation | ||
-oriented approach | * Enhance guidance for evaluating meteorology and SCBA (joint EP and RP issue) 19 | ||
*Proposed Rule and Guidance: | * Revise EP Training | ||
-based, risk | ANS and IPAWS | ||
-informed | * NRC Licensees are required to demonstrate reasonable assurance and adequate protection through the use of a viable Alert and Notification Systems (ANS) | ||
* 10 CFR 50.47(b)(5) means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established. | |||
-oriented, graded | * Appendix E licensee shall demonstrate that administrative and physical means have been established 20 | ||
-approach | |||
-inclusive, but does not alter existing nuclear power reactor EP requirements | ANS and IPAWS | ||
* There are no nuclear regulatory requirements for sirens to be the primary method an ANS | |||
*Proposed Performance Measures: | * Licensees should use 10 CFR 50.54 (q) change process for changes to its ANS | ||
* Some alert and notification requirements are included as specific licensing conditions for certain licensees | |||
* Licensee decision to implement IPAWS in lieu of sirens may require prior NRC approval or License Amendment Request (LAR) | |||
* NRC has final decision authority on Alert and Notification System 21 | |||
*Proposed Guidance: | |||
ANS and IPAWS Improvements and Innovation in 2019 | |||
-design specific) 42 | * FCC has required that IPAWS systems allow state and local governments to draw octagonal area for notifications. | ||
*Regulatory Basis issued (ADAMS No.ML17206A265) | * Accuracy of the drawing will be at 1/10 of mile of the area covered | ||
-November 2017 | * The FCC is completing development of a fourth WEA message to supplement the current three WEA messages in IPAWS | ||
*Draft | * Fourth WEA message will be Testing | ||
*August 3, 2018, Publicly Available (ADAMS No. ML18213A264) | * Fourth WEA message mode has potential to be used to evaluate drills and exercises | ||
*August 22, 2018, Advisory Committee on Reactor Safeguards Subcommittee | * Current three message types are: Presidential, Amber, and Imminent Threats | ||
*October 12, 2018, Provided to Commission | * Testing, Amber and Imminent Threat alerts can be opted-out by individual users | ||
*Public Comment Period (current estimate)*April 30, 2019*Final Rule/Final Regulatory Guidance | * Presidential alerts cannot be opted-out by individual user | ||
-Feb 14, 2020, Provide to Commission | * Increase the number of characters to be displayed in a message; | ||
-April 30, 2020, Issue Final | * Ability to insert internet links, pictures and videos. | ||
*Rulemaking information | 22 | ||
*RIN Number: 3150 | |||
-AJ68*www.Regulations.Gov | ANS and IPAWS | ||
*Docket ID NRC | * Licensees should use 10 CFR 50.54 (q) change process for changes to its ANS | ||
-2015-0225 43 | * If the design of the primary ANS includes specific requirements that were established as part of a licensees licensing basis, then the licensee will need to use the 10 CFR 50.90 license amendment request process 23 | ||
*EP items that were determined by Commission to be addressed at the regulatory guidance level and were removed from the final rule*Sufficient staffing to support implementation of the capabilities required by the rule | |||
*Sufficient communications capability, both onsite and offsite to support implementation of the strategies required by the rule | EP Rulemaking Activities | ||
*Drills or exercises to demonstrate a capability to use the strategies and guidelines required by the rule | * Power Reactors Transition to Decommissioning | ||
*Licensees have previously committed to have in place and maintain these items via the 50.54(f) letters that were issued on March 12, 2012. | * Small Modular Reactors and Other New Technologies (SMR/ONT) | ||
*These items have been inspected using TI | * Mitigation of Beyond Design Basis Events (MBDBE) | ||
-2515/191 and NRC will determine the continuing inspection process for these items going forward. | * 10 CFR 50 and 52 Alignment 24 | ||
-Emergency Planning and Preparedness for Production and Utilization Facilities | EP Decommissioning Rulemaking 25 | ||
*This appendix has been revised to eliminate the pointer to | |||
§50.54(hh)(2) in IV.F.2.j.and now points to the | EP Decommissioning Rulemaking Research to Support Rulemaking | ||
§50.155(b)(2) | * NUREG-1738, Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants | ||
* NUREG-2161, Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. | |||
)the Commission approved development of a regulatory basis to revise the regulations in 10 CFR Part 50 for new power reactor applications to more closely align with requirements in 10 CFR Part 52*Commission also approved revision of 10 CFR Part 52 and supporting regulations to reflect lessons learned from recent new reactor licensing activities | Mark I Boiling Water Reactor | ||
*The staff is considering what items should be included in the scope of that rulemaking. | * Supporting Research Studies (ADAMS ML16110A416) | ||
* Analysis of Mitigative Actions | |||
*Atomic Energy Act of 1954, amended in | * Spent Fuel Decay Time | ||
* Dose Rate of Accidental Radiological Release from Spent Fuel Pool 26 | |||
*Federal lead role in evaluating offsite emergency planning and preparedness activities was transferred from the NRC to FEMA after the accident at TMI U2*Assignment aligned with | |||
*If NRC determines the need for offsite radiological emergency plans, they are evaluated by FEMA for adequacy; findings and determinations are reported to the NRC *FEMA established its REP Program to manage its responsibility in areas around nuclear power plants | EP Decommissioning Rulemaking | ||
*NRC maintains responsibility for onsite emergency preparedness and overall finding of reasonable assurance (and continuing maintenance of reasonable assurance) considering FEMA input | * The following contains information that was provided to the Commission on May 7th to support the Draft Proposed Transition to Decommissioning Rulemaking. | ||
*Plume exposure pathway | * Although made public on May 22nd, the rulemaking has not been issued for public comment. | ||
*Ingestion pathway | * The Commission will vote on the rulemaking and provide a Staff Requirements Memorandum (SRM) with direction on how to proceed. | ||
*Exact size and shape of each EPZ is a result of detailed planning which includes consideration of the specific conditions at each site, unique geographical features of the area, and demographic information | * As such, the rule language and accompanying guidance may change and should not be considered final. | ||
*Preplanned strategy for an EPZ provides a substantial basis to support activity beyond the planning zone in the extremely unlikely event it would be needed | 27 | ||
*NRC evaluates onsite emergency planning and preparedness and, considering | |||
EP Decommissioning Rulemaking Graded Approach Level 1 Permanent cessation of operations and all fuel in spent fuel pool Level 2 Spent fuel has sufficiently decayed (10 hour adiabatic heatup time) | |||
-informing NRC regulatory activities | Level 3 All fuel is in dry cask storage Level 4 All fuel removed from site 28 | ||
*SMRs and other new reactor designs are expected to pose risks orders of magnitude lower than already very low risk posed by current large commercial reactors | |||
*EPZ size and other REP capabilities should be proportional to risk without undue regulatory burden on licensees*Rulemaking for SMRs and other new technologies includes performance | EP Decommissioning Rulemaking Decommissioning EP Levels Power Level 1 Level 2 Level 3 Level 4 Operations Post Permanently ISFSI Only No Spent Shutdown Defueled Emergency Fuel Onsite Emergency Emergency Plan Plan (IOEP) | ||
-based EP and scalable EPZ size commensurate with risk | Plan (PDEP) | ||
*EPZ size can be site boundary to some specified distance off | (PSEP) | ||
-site*Ingestion planning capabilities rather than defined zone | Cessation of Power 10 months (BWR) >5 Operations and Defueled 16 months (PWR) years 29 | ||
-water reactors (LWRs) | |||
EP Decommissioning Rulemaking Post-Shutdown EP (PSEP) | |||
*Any nuclear power plant | * PSEP may start after NRC dockets licensees certifications of certifications of permanent cessation of operations and permanent removal of all fuel from the reactor vessel. | ||
*But if an accident occurs, what is needed to protect public health and safety? | * PSEP is a transition period | ||
*Implementation of protective measures such as evacuation/sheltering | - May only last 10 months (BWR) to 16 months (PWR) | ||
*Numerous examples of successful evacuations in response to | - Significant changes to plan not anticipated | ||
-threatening non | - No changes to regulations for offsite emergency plan 30 | ||
-nuclear events | |||
*Evacuations from hazards that are immediately dangerous to life and health occur routinely and most typically without extensive preplanning | EP Decommissioning Rulemaking Post-Shutdown EP (PSEP) | ||
*Freight train derailments (trains carrying haz-mat)*Mississauga, Ontario train derailment >200,000 people promptly evacuated (in the absence of emergency planning) due to toxic gas releases,*Wildfires*California wildfires impact hundreds of thousands of people with very short notification times under life threatening and rapidly changing conditions. | * 10 CFR 50.200(a) | ||
*Flash Floods | * Proposed Rule provides for: | ||
*September 2018 | - Reduced ERO staffing | ||
*PEMA stated evacuations were reported in a number of counties, but no injuries were reported. | - Revisions to EALs | ||
*July 2018 | - ETE updates no longer required | ||
*Nothing unique is required for evacuations/shelter | - Annual dissemination of information to the public | ||
-in-place as a result of nuclear power plant accidents | - future plant status | ||
*NRC has high confidence in the ability of offsite response organizations to implement appropriate response actions when necessary | - Revised exercise schedule (drill cycle maintained) 31 | ||
*Confidence is strengthened by | |||
*For NRC-licensed facilities where radiological hazards present a very low offsite hazard, the risk posed by the low | EP Decommissioning Rulemaking Permanently Defueled EP (PDEP) | ||
-level hazard can be addressed by all | * 10 CFR 50.200(b) and (c) | ||
-hazards planning | * Proposed Rule provides for: | ||
*Risks can be reduced but not eliminated; society must balance the benefits of enabling technologies against risks that cannot be completely eliminated without rendering the technologies infeasible | - Reduced ERO staffing | ||
*By focusing on Safety Goals, the NRC keeps the risk associated with radioactive materials very small compared to other risks to which members of the public are exposed, while still enabling use of such materials consistent with National policy as reflected in the Atomic Energy Act | - Classification and Notification timeliness commensurate to risk and accident timing | ||
* | - Events classified as NOUE or Alert | ||
- No offsite (REP) planning requirements o No defined EPZs beyond the site boundary o No demonstration of capability for prompt public alerting o No pre-determined Protective Actions 32 | |||
EP Decommissioning Rulemaking Permanently Defueled EP (PDEP) | |||
* Proposed Rule provides for: | |||
- Revisions to EALs | |||
- Emergency response facilities (TSC, OSC, EOF) may be combined | |||
- Biennial exercise within 2 years of entering into decommissioning (drill cycle maintained) | |||
- No hostile action requirements (security EALs maintained) 33 | |||
EP Decommissioning Rulemaking Permanently Defueled EP (PDEP) | |||
* 10 CFR 50.47(f) Planning standards do not apply to offsite EP if EPZ does not extend beyond the site boundary. | |||
10 CFR 50.54(s)(3) Clarifies how NRC will make findings and determinations of reasonable assurance when planning standards do not apply to offsite. | |||
(s)(3)If the planning standards for radiological emergency preparedness apply to offsite radiological emergency response plans, the NRC will base its finding on a review of the FEMA findings and determinations as to whether State and local emergency plans are adequate and capable of being implemented, and on the NRC assessment as to whether the licensee's emergency plans are adequate and capable of being implemented. | |||
10 CFR 50.54(t) EP program element review at 2 year intervals until all fuel in dry cask storage. | |||
34 | |||
EP Decommissioning Rulemaking ISFSI Only EP (IOEP) | |||
* IOEP may start after all spent fuel is in dry cask storage | |||
* IOEP utilizes established EP planning standards for ISFSIs contained in 10 CFR 72.32(a) | |||
* Part 50 and Part 52 licensees are granted a general Part 72 license | |||
* Application for a specific Part 72 license would require NRC approval of emergency plan 35 | |||
EP Decommissioning Rulemaking | |||
*Emergency Plan Change Process | |||
- Transition to Levels | |||
- Changes within Levels | |||
- Changes in Final Safety Analysis Report (FSAR) | |||
- Changes in Emergency Action Levels (EALs) Classifications and Scheme(s) | |||
* 10 CFR 50.54(q)(7) Licensee may elect to follow and maintain a Level standard when conditions are met. | |||
* 10 CFR 50.54(q)(8) Clarifies Reduction in Effectiveness (RIE) | |||
* Transition between levels is not an RIE if changes comply with standards. | |||
* Changes to e-plan are not RIEs if supported by Final Safety Analysis Report (FSAR) for Safety Systems and Components (SSCs) out of service. | |||
* Changes to EAL not RIE if physically unattainable. | |||
* Draft EP Regulatory Guide to accompany proposed rule | |||
* DG-1346, Emergency Planning for Decommissioning Nuclear Power Reactors (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17311B018) 36 | |||
EP Decommissioning Rulemaking YOU ARE HERE 37 | |||
EP Decommissioning Rulemaking Decommissioning Rule Schedule | |||
* Final Regulatory Basis | |||
- November 2017, ML17215A012 | |||
* Proposed Rule/Draft Regulatory Guidance | |||
- Provided to Commission May 7, 2018 | |||
- Public May 22, 2018, ADAMS Package ML18012A019 | |||
* Public Comment Period (current estimate) | |||
- April 30, 2019 | |||
* Final Rule/Final Regulatory Guidance | |||
- Oct 7,2019, Provide to Commission | |||
- Dec 30, 2019, Issue FInal | |||
* Regulations.gov Docket ID NRC-2015-0070 38 | |||
EP SMR/ONT Rulemaking Draft Proposed EP SMR/ONT Rulemaking This draft document was released to support the August 22, 2018 Advisory Committee on Reactor Safeguards Sub-Committee public meeting. This draft document has not been subject to Commission, NRC management, and legal reviews and approvals, and its contents should not be interpreted as official agency positions. Following the public meeting, the NRC staff plans to continue working on this document as well as other documents related to this rulemaking. | |||
39 | |||
SMR/ONT Rulemaking Develop a clear set of rules and guidance for SMRs and ONT Technology Neutral or Inclusive Risk-Informed, Performance Based Principle of dose-at-distance and consequence-oriented approach to determine EPZ size 40 | |||
SMR/ONT Rulemaking | |||
* Proposed Rule and Guidance: | |||
Performance-based, risk-informed Some capability based planning standards Consequence-oriented, graded-approach Technology-inclusive, but does not alter existing nuclear power reactor EP requirements Recognizes offsite response & preparedness 41 | |||
SMR/ONT Rulemaking | |||
* Proposed Performance Measures: | |||
Event mitigation Protective actions, Communications, Command and control, Staffing, and Radiological assessment | |||
* Proposed Guidance: | |||
General information (non-design specific) 42 | |||
SMR/ONT Rulemaking | |||
* Regulatory Basis issued (ADAMS No.ML17206A265) | |||
- November 2017 | |||
* Draft Proposed Rule/Regulatory Guidance Package | |||
* August 3, 2018, Publicly Available (ADAMS No. ML18213A264) | |||
* August 22, 2018, Advisory Committee on Reactor Safeguards Subcommittee | |||
* October 12, 2018, Provided to Commission | |||
* Public Comment Period (current estimate) | |||
* April 30, 2019 | |||
* Final Rule/Final Regulatory Guidance | |||
- Feb 14, 2020, Provide to Commission | |||
- April 30, 2020, Issue Final | |||
* Rulemaking information | |||
* RIN Number: 3150-AJ68 | |||
* www.Regulations.Gov | |||
* Docket ID NRC-2015-0225 43 | |||
MBDBE Rulemaking | |||
* Multi Source Dose Assessment capability was removed as a requirement in the rule prior to the final rule affirmation by the Commission. | |||
* EP items that were determined by Commission to be addressed at the regulatory guidance level and were removed from the final rule | |||
* Sufficient staffing to support implementation of the capabilities required by the rule | |||
* Sufficient communications capability, both onsite and offsite to support implementation of the strategies required by the rule | |||
* Drills or exercises to demonstrate a capability to use the strategies and guidelines required by the rule 44 | |||
MBDBE Rulemaking | |||
* Addressed at the regulatory guidance level and the Commission concluded that the requirements imposed by the Orders (NRC Order EA-12-049 and NRC Order EA-12-051) are sufficient to provide reasonable assurance of adequate protection of public health and safety. | |||
* Licensees have previously committed to have in place and maintain these items via the 50.54(f) letters that were issued on March 12, 2012. | |||
* These items have been inspected using TI-2515/191 and NRC will determine the continuing inspection process for these items going forward. | |||
45 | |||
MBDBE Rulemaking | |||
* Appendix E to Part 50 - Emergency Planning and Preparedness for Production and Utilization Facilities | |||
* This appendix has been revised to eliminate the pointer to §50.54(hh)(2) in IV.F.2.j.and now points to the implementation of strategies, procedures, and guidance under | |||
§50.155(b)(2) 46 | |||
10 CFR 50/52 Rulemaking | |||
* In SRM-SECY-15-0002 (ML13277A420) the Commission approved development of a regulatory basis to revise the regulations in 10 CFR Part 50 for new power reactor applications to more closely align with requirements in 10 CFR Part 52 | |||
* Commission also approved revision of 10 CFR Part 52 and supporting regulations to reflect lessons learned from recent new reactor licensing activities | |||
* The staff is considering what items should be included in the scope of that rulemaking. | |||
47 | |||
Risk Perception vs Risk Reality 48 | |||
Risk Perception vs Risk Reality NRC Authorities | |||
* Atomic Energy Act of 1954, amended in 1974 empowered the NRC to establish by rule or order, and to enforce, such standards to govern these uses as "the Commission may deem necessary or desirable in order to protect health and safety and minimize danger to life or property." | |||
* U.S. Supreme Court has expressly held that, while states retain authority over questions of need, reliability, cost, and other related State concerns, federal preemption under the Atomic Energy Act (AEA) prevents states from regulating nuclear power for the purposes of radiological safety. | |||
* Helps ensure regulatory stability and predictability in the licensing process 49 | |||
NRC Authorities | |||
* The NRC establishes regulatory standards for offsite REP | |||
* Regulatory requirements for offsite radiological emergency planning/response and the REP Program are not synonymous; the licensee maintains agreements with local emergency responders that are outside of the REP program such as EMT and fire response | |||
* Federal lead role in evaluating offsite emergency planning and preparedness activities was transferred from the NRC to FEMA after the accident at TMI U2 | |||
* Assignment aligned with FEMAs statutory role in promoting, funding, coordinating, and providing technical assistance for disaster preparedness | |||
* If NRC determines the need for offsite radiological emergency plans, they are evaluated by FEMA for adequacy; findings and determinations are reported to the NRC | |||
* FEMA established its REP Program to manage its responsibility in areas around nuclear power plants | |||
* NRC maintains responsibility for onsite emergency preparedness and overall finding of reasonable assurance (and continuing maintenance of reasonable assurance) considering FEMA input 50 | |||
Emergency Planning Zones | |||
* Two EPZs around each currently licensed nuclear power plant to facilitate preplanned strategies for protective actions during an emergency | |||
* Plume exposure pathway | |||
* Ingestion pathway | |||
* Exact size and shape of each EPZ is a result of detailed planning which includes consideration of the specific conditions at each site, unique geographical features of the area, and demographic information | |||
* Preplanned strategy for an EPZ provides a substantial basis to support activity beyond the planning zone in the extremely unlikely event it would be needed 51 | |||
Reasonable Assurance/ | |||
Adequate Protection | |||
* Reasonable Assurance: a determination that NRC licensee or applicant onsite plans and state, local, tribal government, and utility offsite plans and preparedness are adequate to protect public health and safety in the emergency planning areas of a commercial nuclear power plant FEMA evaluates offsite planning and preparedness and reports findings/determination to NRC | |||
* NRC evaluates onsite emergency planning and preparedness and, considering FEMAs evaluation, makes the overall decision of reasonable assurance. Once determined, assumed to remain in place unless demonstrated otherwise 52 | |||
What Has Changed? Why? | |||
* Commission has maintained a continuing focus on risk-informing NRC regulatory activities | |||
* SMRs and other new reactor designs are expected to pose risks orders of magnitude lower than already very low risk posed by current large commercial reactors | |||
* EPZ size and other REP capabilities should be proportional to risk without undue regulatory burden on licensees | |||
* Rulemaking for SMRs and other new technologies includes performance-based EP and scalable EPZ size commensurate with risk | |||
* EPZ size can be site boundary to some specified distance off-site | |||
* Ingestion planning capabilities rather than defined zone 53 | |||
Commission Policy on Advanced Reactors The Commission expects, as a minimum, at least the same degree of protection of the environment and public health and safety and the common defense and security that is required for current generation light-water reactors (LWRs) the Commission expects that advanced reactors will provide enhanced margins of safety and/or use simplified, inherent, passive, or other innovative means to accomplish their safety and security functions. | |||
54 | |||
What If? | |||
* Concerns that an event could happen that could lead to doses in excess of the EPA Protective Action Guidelines offsite in a community with no formal Federally mandated REP | |||
* Any nuclear power plant licensed with a site boundary EPZ will present very low risk of offsite health impacts (acute or stochastic) as the result of an accident | |||
* But if an accident occurs, what is needed to protect public health and safety? | |||
* Implementation of protective measures such as evacuation/sheltering | |||
* Numerous examples of successful evacuations in response to no notice life-threatening non-nuclear events 55 | |||
What If? | |||
* Urgent protective measures include evacuation/sheltering | |||
* Evacuations from hazards that are immediately dangerous to life and health occur routinely and most typically without extensive preplanning | |||
* Freight train derailments (trains carrying haz-mat) | |||
* Mississauga, Ontario train derailment >200,000 people promptly evacuated (in the absence of emergency planning) due to toxic gas releases, | |||
* Wildfires | |||
* California wildfires impact hundreds of thousands of people with very short notification times under life threatening and rapidly changing conditions. | |||
* Flash Floods | |||
* September 2018 Pennsylvania Flash Flooding Triggers Evacuations, Prompts Disaster Declarations | |||
* PEMA stated evacuations were reported in a number of counties, but no injuries were reported. | |||
* July 2018 Heavy downpours are soaking parts of central Pennsylvania, causing evacuations and forcing an amusement park to close for the second time this week | |||
* Nothing unique is required for evacuations/shelter-in-place as a result of nuclear power plant accidents 56 | |||
What If? | |||
* State and local governments are responsible for the protection of public health and safety for all types of events, both natural and those related to human activities | |||
* NRC has high confidence in the ability of offsite response organizations to implement appropriate response actions when necessary | |||
* Confidence is strengthened by NRCs recognition of national-level efforts, in which the NRC participates, to enhance the state of emergency planning at all levels of government and within the whole community | |||
* For NRC-licensed facilities where radiological hazards present a very low offsite hazard, the risk posed by the low-level hazard can be addressed by all-hazards planning 57 | |||
Risk Trade Offs | |||
* Use of technologies involves some risk | |||
* Risks can be reduced but not eliminated; society must balance the benefits of enabling technologies against risks that cannot be completely eliminated without rendering the technologies infeasible | |||
* By focusing on Safety Goals, the NRC keeps the risk associated with radioactive materials very small compared to other risks to which members of the public are exposed, while still enabling use of such materials consistent with National policy as reflected in the Atomic Energy Act | |||
* NRCs safety mission is achieved once Safety Goals are met for an acceptable level of risk; thus, not imposing undue burden on licensees 58 | |||
Risk Perception vs Risk Reality Changes? | |||
* Reactor technology is changing, | |||
* EP is evolving, | |||
* NRCs mission to protect the health and safety of the public remains unchanged 59 | |||
For More Information Bob Kahler, Policy & Oversight Branch Chief 301-287-3756 Robert.Kahler@nrc.gov Joe Anderson, Reactor Licensing Branch Chief 301-287-9300 Joseph.Anderson@nrc.gov Bill Gott, Coordination Branch Chief 301-287-9256 Bill.Gott@nrc.gov Silas Kennedy, Operations Branch Chief 301-287-0756 Silas.Kennedy@nrc.gov 60}} |
Latest revision as of 02:00, 20 October 2019
ML19044A691 | |
Person / Time | |
---|---|
Issue date: | 02/06/2019 |
From: | Robert Kahler Office of Nuclear Security and Incident Response |
To: | |
Kelly Grimes | |
References | |
Download: ML19044A691 (60) | |
Text
U.S. NRC Headquarters Update 2019 TOP Workshop February 6, 2019 Robert Kahler, Chief Policy and Oversight Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 1
2 NRC Commissioners The Commission Kristine L. Svinicki, Chairman Jeff Baran Stephen G. Burns Annie Caputo David Wright Began Serving: March 2008 Began Serving: October 2014 Began Serving: November 2014 Confirmed: May 2018 Confirmed: May 2018 Term ending: June 2022 Term Ending: June 2023 Term Ending: June 2019 Term Ending: June 2021 Term Ending: June 2020 3
Discussion Topics
- Guidance Documents
- Licensee Interactions
Focused Self-Assessment (FSA)
- Alert and Notification System (ANS) and Integrated Public Alert and Warning System (IPAWS)
- EP Rulemaking Activities
- Risk Perception vs Risk Reality 4
EP Guidance Documents
- NUREG/CR-7248, Capabilities and Practices of Offsite Response Organizations for Protective Actions in the Intermediate Phase of a Radiological Emergency Response."
- Enhance NRC understanding of ORO practices and capabilities
- Provide technical basis for assumptions used by NRC to model protective actions in consequence studies and regulatory analyses
- Published June 19, 2018, ADAMS ML18170A043 5
EP Guidance Documents
- NUREG-0654/FEMA-REP-1, Revision 2
- Reflects changes to NRC/FEMA regulations, guidance, and policies
- Consolidates numerous supplemental documents and addenda
- Modernizes guidance technological advances and best practices
- Office of Management and Budget (OMB)
- Major or minor rule determination 6
Licensee Interactions (A, B, Cs)
- Discussions on specific licensee actions need to be coordinated through Office of Nuclear Reactor Regulation (NRR) Project Manager Forecast of planned licensing submittals: Regulatory Issue Summary (RIS) 2015-16
- Pre-submittal conference call/meeting
- Conference call to discuss proposed (draft) requests for additional information (RAIs)
- Follow-up discussions If unsure, ask for clarification
- State consultation (license amendment request)
FEMA consultation: Does change impact offsite plans?
7
Operating Reactor Licensing (ERO Staffing / Augmentation)
- RIS 2016-10, License Amendment Requests for Changes to ERO Staffing and Augmentation (ADAMS ML16124A002)
Clarifies use of NEI 10-05 (On-Shift Staffing Analysis)
Staff evaluation using NUREG-0654/FEMA-REP-1, Rev 1
- Proposed Revision 2 to NUREG-0654/FEMA-REP-1 Letter to NEI, Entergy, NextEra - June 12, 2018 Table B-1 and Technical Basis (ADAMS ML16117A427) 8
Operating Reactor Licensing (ERO Staffing / Augmentation)
- Table B-1 (functions/augmentation times) is intended to provide a model to consider in developing a site-specific emergency plan.
- Emergency plan should describe the minimum ERO staffing plan Supporting EPIPs can describe any other staff response desired, as long as this staff is not critical to effective emergency plan implementation.
9
EP Significance Determination Process (SDP)
Focused Self Assessment (FSA)
- December 12, 2017, Nuclear Energy Institute (NEI) submitted letter
- Recommendations for Improving the Emergency Preparedness Significance Determination Process
- ADAMS Accession No. ML17354A094).
- February 7, 2018, NRC responded via letter
- Receipt of Nuclear Energy Institute Recommendations for Improving the Emergency Preparedness Significance Determination Process
- (ADAMS Accession No. ML18024A427).
- take a fresh look at the EP SDP and to convene an expert team to evaluate the EP SDP based on the NRCs experience with the EP SDP as well as inputs from external stakeholders.
- During 2018, NRC HQ and Regional staff conducted an FSA
- procedural reviews, EP Inspector surveys, and review of external stakeholder comments and/or suggestions.
- Public Meetings
- June 25, 2018, introduced FSA intent and purpose
- January 10, 2019, provide tentative results and project plan 10
EP Significance Determination Process (SDP)
Focused Self Assessment (FSA) 11
EP Significance Determination Process (SDP)
Focused Self Assessment (FSA)
Safety Cornerstones Baseline Inspection Performance Indicator Results Results Significance Significance Determination Process (SDP) Threshold Action Matrix Special Inspections Regulatory Response 12
EP Significance Determination Process (SDP)
Focused Self Assessment (FSA)
BASELINE INSPECTION PROCEDURES
.01 Exercise Evaluation (biennial exercise)
.02 Alert and Notification System Evaluation
.03 ERO Staffing and Augmentation System
.04 Emergency Action Level And E-Plan Changes
.05 Maintenance of Emergency Preparedness
.06 Drill Evaluation (resident inspector)
.07 Exercise Evaluation - Hostile Action (HA) Event
.08 Exercise Evaluation - Scenario Review 13
EP Significance Determination Process (SDP)
Focused Self Assessment (FSA)
EP Performance Indicators (PIs)
- Drill and Exercise Performance (DEP)
- Emergency Response Organization Drill Participation (ERO)
- Alert and Notification System Performance (ANS) 14
EP Significance Determination Process (SDP)
Focused Self Assessment (FSA)
Green Very low safety significance (licensee response band)
White Low to moderate safety significance (increased regulatory response band)
Yellow Substantial safety significance (required regulatory response band)
Red High safety significance (unacceptable performance band) 15
EP Significance Determination Process (SDP)
Focused Self Assessment (FSA)
- FSA Conclusion
- However, there are several areas where the NRC should consider enhancement opportunities.
- These enhancement opportunities are to be considered preliminary, not a final NRC position, and subject to change.
16
EP Significance Determination Process (SDP)
Focused Self Assessment (FSA)
- FSA Conclusion
- However, there are several areas where the NRC should consider enhancement opportunities.
- These enhancement opportunities are to be considered preliminary, not a final NRC position, and subject to change.
17
EP Significance Determination Process (SDP)
Focused Self Assessment (FSA)
Enhancement Opportunities
- Outlook E-mail account for knowledge management and drive consistency and awareness between NRC Regions and HQs
- COMPLETED
- SharePoint tools to document and track issues.
- COMPLETED
- SharePoint tools to coordinate NRC Regional and HQ resources.
- COMPLETED
- In Progress: 2/3 staff qualified, remaining staff member will be qualified in 2019
- Annual EP Operating Experience Report to capture lessons-learned and other EP issues relevant to the ROP and SDP
- COMPLETED 18
EP Significance Determination Process (SDP)
Focused Self Assessment (FSA)
Enhancement Opportunities
- Consideration of other Reactor Safety Cornerstones when determining significance of an EP issue
- Planning Standards 10 CFR 50.47(b)(2) (4) (5) (8) (9) (10 offsite)
- Only these can be Greater than Green
- Only these would require a formal 10 CFR 50.54(q) change review, and subsequent requirement for NRC prior approval
- Add EP ROP PIs to support 24-month 10 CFR 50.54(t) review frequency.
- Revise and consolidate EP Baseline Inspection Procedures
- Provide guidance to better risk inform: EALs, dose assessment modeling, 10 CFR 50.54(q), Fission Barrier Matrix, and Radiation Monitoring Instrumentation
- Revise EP Training
- NRC Licensees are required to demonstrate reasonable assurance and adequate protection through the use of a viable Alert and Notification Systems (ANS)
- 10 CFR 50.47(b)(5) means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.
- Appendix E licensee shall demonstrate that administrative and physical means have been established 20
- Licensees should use 10 CFR 50.54 (q) change process for changes to its ANS
- Some alert and notification requirements are included as specific licensing conditions for certain licensees
- Licensee decision to implement IPAWS in lieu of sirens may require prior NRC approval or License Amendment Request (LAR)
- NRC has final decision authority on Alert and Notification System 21
ANS and IPAWS Improvements and Innovation in 2019
- FCC has required that IPAWS systems allow state and local governments to draw octagonal area for notifications.
- Accuracy of the drawing will be at 1/10 of mile of the area covered
- The FCC is completing development of a fourth WEA message to supplement the current three WEA messages in IPAWS
- Fourth WEA message will be Testing
- Fourth WEA message mode has potential to be used to evaluate drills and exercises
- Current three message types are: Presidential, Amber, and Imminent Threats
- Testing, Amber and Imminent Threat alerts can be opted-out by individual users
- Presidential alerts cannot be opted-out by individual user
- Increase the number of characters to be displayed in a message;
- Ability to insert internet links, pictures and videos.
22
- Licensees should use 10 CFR 50.54 (q) change process for changes to its ANS
- If the design of the primary ANS includes specific requirements that were established as part of a licensees licensing basis, then the licensee will need to use the 10 CFR 50.90 license amendment request process 23
EP Rulemaking Activities
- Power Reactors Transition to Decommissioning
- Small Modular Reactors and Other New Technologies (SMR/ONT)
- Mitigation of Beyond Design Basis Events (MBDBE)
- 10 CFR 50 and 52 Alignment 24
EP Decommissioning Rulemaking 25
EP Decommissioning Rulemaking Research to Support Rulemaking
- NUREG-1738, Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants
- NUREG-2161, Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S.
Mark I Boiling Water Reactor
- Supporting Research Studies (ADAMS ML16110A416)
- Analysis of Mitigative Actions
- Spent Fuel Decay Time
- Dose Rate of Accidental Radiological Release from Spent Fuel Pool 26
EP Decommissioning Rulemaking
- The following contains information that was provided to the Commission on May 7th to support the Draft Proposed Transition to Decommissioning Rulemaking.
- Although made public on May 22nd, the rulemaking has not been issued for public comment.
- The Commission will vote on the rulemaking and provide a Staff Requirements Memorandum (SRM) with direction on how to proceed.
- As such, the rule language and accompanying guidance may change and should not be considered final.
27
EP Decommissioning Rulemaking Graded Approach Level 1 Permanent cessation of operations and all fuel in spent fuel pool Level 2 Spent fuel has sufficiently decayed (10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> adiabatic heatup time)
Level 3 All fuel is in dry cask storage Level 4 All fuel removed from site 28
EP Decommissioning Rulemaking Decommissioning EP Levels Power Level 1 Level 2 Level 3 Level 4 Operations Post Permanently ISFSI Only No Spent Shutdown Defueled Emergency Fuel Onsite Emergency Emergency Plan Plan (IOEP)
Plan (PDEP)
(PSEP)
Cessation of Power 10 months (BWR) >5 Operations and Defueled 16 months (PWR) years 29
EP Decommissioning Rulemaking Post-Shutdown EP (PSEP)
- PSEP may start after NRC dockets licensees certifications of certifications of permanent cessation of operations and permanent removal of all fuel from the reactor vessel.
- PSEP is a transition period
- May only last 10 months (BWR) to 16 months (PWR)
- Significant changes to plan not anticipated
- No changes to regulations for offsite emergency plan 30
EP Decommissioning Rulemaking Post-Shutdown EP (PSEP)
- Proposed Rule provides for:
- Reduced ERO staffing
- Revisions to EALs
- ETE updates no longer required
- Annual dissemination of information to the public
- future plant status
- Revised exercise schedule (drill cycle maintained) 31
EP Decommissioning Rulemaking Permanently Defueled EP (PDEP)
- 10 CFR 50.200(b) and (c)
- Proposed Rule provides for:
- Reduced ERO staffing
- Classification and Notification timeliness commensurate to risk and accident timing
- Events classified as NOUE or Alert
- No offsite (REP) planning requirements o No defined EPZs beyond the site boundary o No demonstration of capability for prompt public alerting o No pre-determined Protective Actions 32
EP Decommissioning Rulemaking Permanently Defueled EP (PDEP)
- Proposed Rule provides for:
- Revisions to EALs
- Emergency response facilities (TSC, OSC, EOF) may be combined
- Biennial exercise within 2 years of entering into decommissioning (drill cycle maintained)
- No hostile action requirements (security EALs maintained) 33
EP Decommissioning Rulemaking Permanently Defueled EP (PDEP)
- 10 CFR 50.47(f) Planning standards do not apply to offsite EP if EPZ does not extend beyond the site boundary.
10 CFR 50.54(s)(3) Clarifies how NRC will make findings and determinations of reasonable assurance when planning standards do not apply to offsite.
(s)(3)If the planning standards for radiological emergency preparedness apply to offsite radiological emergency response plans, the NRC will base its finding on a review of the FEMA findings and determinations as to whether State and local emergency plans are adequate and capable of being implemented, and on the NRC assessment as to whether the licensee's emergency plans are adequate and capable of being implemented.
10 CFR 50.54(t) EP program element review at 2 year intervals until all fuel in dry cask storage.
34
EP Decommissioning Rulemaking ISFSI Only EP (IOEP)
- IOEP may start after all spent fuel is in dry cask storage
- IOEP utilizes established EP planning standards for ISFSIs contained in 10 CFR 72.32(a)
- Part 50 and Part 52 licensees are granted a general Part 72 license
- Application for a specific Part 72 license would require NRC approval of emergency plan 35
EP Decommissioning Rulemaking
- Emergency Plan Change Process
- Transition to Levels
- Changes within Levels
- Changes in Final Safety Analysis Report (FSAR)
- Changes in Emergency Action Levels (EALs) Classifications and Scheme(s)
- 10 CFR 50.54(q)(7) Licensee may elect to follow and maintain a Level standard when conditions are met.
- 10 CFR 50.54(q)(8) Clarifies Reduction in Effectiveness (RIE)
- Transition between levels is not an RIE if changes comply with standards.
- Changes to e-plan are not RIEs if supported by Final Safety Analysis Report (FSAR) for Safety Systems and Components (SSCs) out of service.
- Changes to EAL not RIE if physically unattainable.
- Draft EP Regulatory Guide to accompany proposed rule
- DG-1346, Emergency Planning for Decommissioning Nuclear Power Reactors (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17311B018) 36
EP Decommissioning Rulemaking YOU ARE HERE 37
EP Decommissioning Rulemaking Decommissioning Rule Schedule
- Final Regulatory Basis
- November 2017, ML17215A012
- Proposed Rule/Draft Regulatory Guidance
- Provided to Commission May 7, 2018
- Public May 22, 2018, ADAMS Package ML18012A019
- Public Comment Period (current estimate)
- April 30, 2019
- Final Rule/Final Regulatory Guidance
- Oct 7,2019, Provide to Commission
- Dec 30, 2019, Issue FInal
- Regulations.gov Docket ID NRC-2015-0070 38
EP SMR/ONT Rulemaking Draft Proposed EP SMR/ONT Rulemaking This draft document was released to support the August 22, 2018 Advisory Committee on Reactor Safeguards Sub-Committee public meeting. This draft document has not been subject to Commission, NRC management, and legal reviews and approvals, and its contents should not be interpreted as official agency positions. Following the public meeting, the NRC staff plans to continue working on this document as well as other documents related to this rulemaking.
39
SMR/ONT Rulemaking Develop a clear set of rules and guidance for SMRs and ONT Technology Neutral or Inclusive Risk-Informed, Performance Based Principle of dose-at-distance and consequence-oriented approach to determine EPZ size 40
SMR/ONT Rulemaking
- Proposed Rule and Guidance:
Performance-based, risk-informed Some capability based planning standards Consequence-oriented, graded-approach Technology-inclusive, but does not alter existing nuclear power reactor EP requirements Recognizes offsite response & preparedness 41
SMR/ONT Rulemaking
- Proposed Performance Measures:
Event mitigation Protective actions, Communications, Command and control, Staffing, and Radiological assessment
- Proposed Guidance:
General information (non-design specific) 42
SMR/ONT Rulemaking
- Regulatory Basis issued (ADAMS No.ML17206A265)
- November 2017
- Draft Proposed Rule/Regulatory Guidance Package
- August 3, 2018, Publicly Available (ADAMS No. ML18213A264)
- August 22, 2018, Advisory Committee on Reactor Safeguards Subcommittee
- October 12, 2018, Provided to Commission
- Public Comment Period (current estimate)
- April 30, 2019
- Final Rule/Final Regulatory Guidance
- Feb 14, 2020, Provide to Commission
- April 30, 2020, Issue Final
- Rulemaking information
- RIN Number: 3150-AJ68
- www.Regulations.Gov
- Docket ID NRC-2015-0225 43
MBDBE Rulemaking
- Multi Source Dose Assessment capability was removed as a requirement in the rule prior to the final rule affirmation by the Commission.
- EP items that were determined by Commission to be addressed at the regulatory guidance level and were removed from the final rule
- Sufficient staffing to support implementation of the capabilities required by the rule
- Sufficient communications capability, both onsite and offsite to support implementation of the strategies required by the rule
- Drills or exercises to demonstrate a capability to use the strategies and guidelines required by the rule 44
MBDBE Rulemaking
- Addressed at the regulatory guidance level and the Commission concluded that the requirements imposed by the Orders (NRC Order EA-12-049 and NRC Order EA-12-051) are sufficient to provide reasonable assurance of adequate protection of public health and safety.
- Licensees have previously committed to have in place and maintain these items via the 50.54(f) letters that were issued on March 12, 2012.
- These items have been inspected using TI-2515/191 and NRC will determine the continuing inspection process for these items going forward.
45
MBDBE Rulemaking
- Appendix E to Part 50 - Emergency Planning and Preparedness for Production and Utilization Facilities
- This appendix has been revised to eliminate the pointer to §50.54(hh)(2) in IV.F.2.j.and now points to the implementation of strategies, procedures, and guidance under
§50.155(b)(2) 46
10 CFR 50/52 Rulemaking
- In SRM-SECY-15-0002 (ML13277A420) the Commission approved development of a regulatory basis to revise the regulations in 10 CFR Part 50 for new power reactor applications to more closely align with requirements in 10 CFR Part 52
- Commission also approved revision of 10 CFR Part 52 and supporting regulations to reflect lessons learned from recent new reactor licensing activities
- The staff is considering what items should be included in the scope of that rulemaking.
47
Risk Perception vs Risk Reality 48
Risk Perception vs Risk Reality NRC Authorities
- Atomic Energy Act of 1954, amended in 1974 empowered the NRC to establish by rule or order, and to enforce, such standards to govern these uses as "the Commission may deem necessary or desirable in order to protect health and safety and minimize danger to life or property."
- U.S. Supreme Court has expressly held that, while states retain authority over questions of need, reliability, cost, and other related State concerns, federal preemption under the Atomic Energy Act (AEA) prevents states from regulating nuclear power for the purposes of radiological safety.
- Helps ensure regulatory stability and predictability in the licensing process 49
NRC Authorities
- The NRC establishes regulatory standards for offsite REP
- Regulatory requirements for offsite radiological emergency planning/response and the REP Program are not synonymous; the licensee maintains agreements with local emergency responders that are outside of the REP program such as EMT and fire response
- Federal lead role in evaluating offsite emergency planning and preparedness activities was transferred from the NRC to FEMA after the accident at TMI U2
- Assignment aligned with FEMAs statutory role in promoting, funding, coordinating, and providing technical assistance for disaster preparedness
- If NRC determines the need for offsite radiological emergency plans, they are evaluated by FEMA for adequacy; findings and determinations are reported to the NRC
- NRC maintains responsibility for onsite emergency preparedness and overall finding of reasonable assurance (and continuing maintenance of reasonable assurance) considering FEMA input 50
Emergency Planning Zones
- Two EPZs around each currently licensed nuclear power plant to facilitate preplanned strategies for protective actions during an emergency
- Plume exposure pathway
- Ingestion pathway
- Exact size and shape of each EPZ is a result of detailed planning which includes consideration of the specific conditions at each site, unique geographical features of the area, and demographic information
- Preplanned strategy for an EPZ provides a substantial basis to support activity beyond the planning zone in the extremely unlikely event it would be needed 51
Reasonable Assurance/
Adequate Protection
- Reasonable Assurance: a determination that NRC licensee or applicant onsite plans and state, local, tribal government, and utility offsite plans and preparedness are adequate to protect public health and safety in the emergency planning areas of a commercial nuclear power plant FEMA evaluates offsite planning and preparedness and reports findings/determination to NRC
- NRC evaluates onsite emergency planning and preparedness and, considering FEMAs evaluation, makes the overall decision of reasonable assurance. Once determined, assumed to remain in place unless demonstrated otherwise 52
What Has Changed? Why?
- Commission has maintained a continuing focus on risk-informing NRC regulatory activities
- SMRs and other new reactor designs are expected to pose risks orders of magnitude lower than already very low risk posed by current large commercial reactors
- EPZ size and other REP capabilities should be proportional to risk without undue regulatory burden on licensees
- Rulemaking for SMRs and other new technologies includes performance-based EP and scalable EPZ size commensurate with risk
- EPZ size can be site boundary to some specified distance off-site
- Ingestion planning capabilities rather than defined zone 53
Commission Policy on Advanced Reactors The Commission expects, as a minimum, at least the same degree of protection of the environment and public health and safety and the common defense and security that is required for current generation light-water reactors (LWRs) the Commission expects that advanced reactors will provide enhanced margins of safety and/or use simplified, inherent, passive, or other innovative means to accomplish their safety and security functions.
54
What If?
- Concerns that an event could happen that could lead to doses in excess of the EPA Protective Action Guidelines offsite in a community with no formal Federally mandated REP
- Any nuclear power plant licensed with a site boundary EPZ will present very low risk of offsite health impacts (acute or stochastic) as the result of an accident
- But if an accident occurs, what is needed to protect public health and safety?
- Implementation of protective measures such as evacuation/sheltering
- Numerous examples of successful evacuations in response to no notice life-threatening non-nuclear events 55
What If?
- Urgent protective measures include evacuation/sheltering
- Evacuations from hazards that are immediately dangerous to life and health occur routinely and most typically without extensive preplanning
- Freight train derailments (trains carrying haz-mat)
- Mississauga, Ontario train derailment >200,000 people promptly evacuated (in the absence of emergency planning) due to toxic gas releases,
- Wildfires
- California wildfires impact hundreds of thousands of people with very short notification times under life threatening and rapidly changing conditions.
- Flash Floods
- September 2018 Pennsylvania Flash Flooding Triggers Evacuations, Prompts Disaster Declarations
- PEMA stated evacuations were reported in a number of counties, but no injuries were reported.
- July 2018 Heavy downpours are soaking parts of central Pennsylvania, causing evacuations and forcing an amusement park to close for the second time this week
- Nothing unique is required for evacuations/shelter-in-place as a result of nuclear power plant accidents 56
What If?
- State and local governments are responsible for the protection of public health and safety for all types of events, both natural and those related to human activities
- NRC has high confidence in the ability of offsite response organizations to implement appropriate response actions when necessary
- Confidence is strengthened by NRCs recognition of national-level efforts, in which the NRC participates, to enhance the state of emergency planning at all levels of government and within the whole community
- For NRC-licensed facilities where radiological hazards present a very low offsite hazard, the risk posed by the low-level hazard can be addressed by all-hazards planning 57
Risk Trade Offs
- Use of technologies involves some risk
- Risks can be reduced but not eliminated; society must balance the benefits of enabling technologies against risks that cannot be completely eliminated without rendering the technologies infeasible
- By focusing on Safety Goals, the NRC keeps the risk associated with radioactive materials very small compared to other risks to which members of the public are exposed, while still enabling use of such materials consistent with National policy as reflected in the Atomic Energy Act
- NRCs safety mission is achieved once Safety Goals are met for an acceptable level of risk; thus, not imposing undue burden on licensees 58
Risk Perception vs Risk Reality Changes?
- Reactor technology is changing,
- EP is evolving,
- NRCs mission to protect the health and safety of the public remains unchanged 59
For More Information Bob Kahler, Policy & Oversight Branch Chief 301-287-3756 Robert.Kahler@nrc.gov Joe Anderson, Reactor Licensing Branch Chief 301-287-9300 Joseph.Anderson@nrc.gov Bill Gott, Coordination Branch Chief 301-287-9256 Bill.Gott@nrc.gov Silas Kennedy, Operations Branch Chief 301-287-0756 Silas.Kennedy@nrc.gov 60