Post on 30-Jul-2018
Emergency Preparedness Rulemaking on Transition to Decommissioning and
Small Modular Reactors and Other New Technologies
Robert Kahler, Chief
Policy and Oversight Branch
Division of Preparedness and Response
Office of Nuclear Security and Incident Response
National Radiological Emergency Preparedness Conference April 17, 2018
• Current Emergency Preparedness (EP)
Regulatory Framework
• Operating Power Reactor
• 10 CFR 50.47
• 10 CFR 50.54(q), (s), and (t)
• 10 CFR Part 50, Appendix E
• Independent Spent Fuel Storage Installation
(ISFSI) and Monitored retrievable (pool)
storage (MRS)
• 10 CFR 72.32
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• Current EP Regulatory Framework
• EP regulations for operating reactors • Do not address risk for permanently shutdown and
defueled reactors
• Exemptions from regulations provide
regulatory relief on a case-by-case basis • Requires multiple filings on the licensees docket
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Current and Future Sites
Ft. Calhoun
Oct 24, 2016
Indian Point
Unit 2 April 2020
Unit 3 April 2021
Palisades Spring 2022
Pilgrim May 2019
Oyster Creek Oct 2018
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Commission-Directed Rulemaking
• SRM SECY-14-0118 • Crystal River Exemption Request Approval
• Graded Approach to EP • Commensurate with reductions in
radiological risk
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Proposed Rulemaking Areas
Emergency
Preparedness Physical Security Fitness for Duty
Training Requirements
for Certified Fuel
Handlers
Current Regulatory
Approach for
Decommissioning
Application of
Backfitting Protection
Decommissioning
Trust Funds
Offsite and Onsite
Liability Protection
General Questions
(e.g., Cumulative
Effects of Regulation)
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EP Regulatory Documents
• RIN Number: 3150-AJ59 • www.Regulations.Gov • Docket ID NRC–2015–0070 • Appendix A – Emergency Preparedness
• ADAMS No. ML17018A040 • EP Research Study
• ADAMS No. ML16110A416 o Analysis of Mitigative Actions o Spent Fuel Decay Time o Dose Rate of Accidental Radiological Release from
Spent Fuel Pool
• Decommissioning Regulatory Basis • ADAMS No. ML17215A010
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Level 1
Post Shutdown
Emergency Plan
(PSEP)
~ 10 - 16
months
Level 2
Permanently
Defueled
Emergency Plan
(PDEP)
Level 3
ISFSI Only
Emergency
Plan
(IOEP)
~ 5 years
Level 4
Cessation of
Power Operations and
Permanently Defueled
Power
Operations
Permanent
or Interim
Waste
Storage
Available
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Proposed Concept for EP
Decommissioning Regulations
• Implementation of a graded approach to EP • Maintain reasonable assurance commensurate
with radiological risk • Offsite Radiological Emergency Preparedness
• FEMA assessment • Change processes to minimize licensing actions
• Transitioning to Levels • Changes within Levels • Changes in EAL Classifications and Scheme(s)
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April 17, 2018
Decommissioning Rule Schedule
• November 2017
– Regulatory Basis issued (ADAMS No.ML17215A010)
• December 2018
– Proposed Rule issued for public comment
– Public Comment period 75 days
– Draft guidance will accompany the proposed rule
• September 2019
– Target: Provide Final Rule/Final Regulatory Guidance to the Commission
• December 2019
– Issue Final Rule/Final Regulatory Guidance
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EP Rulemaking for SMR/ONT
• Current Regulatory Basis is the same EP for Large LWR
– Appendix E to Title 10 of Part 50 footnote states:
• NRC will evaluate EPZ size on a Case-by-Case basis if < 250MwT or Gas-cooled Rx
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Commission Directed Rulemaking
• SRM SECY-15-0077
– Options for EP for SMR and ONT
– Approval for Rulemaking
• SRM SECY-16-0069
– Rulemaking Plan Schedule
• Graded Approach to EP
– Commensurate with the radiological risk
National Radiological Emergency Preparedness Conference April 17, 2018
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• Develop a clear set of rules and guidance for SMRs and ONT
Principle of dose-at-distance and consequence-oriented approach to determine EPZ size
Risk-Informed, Performance Based
Technology Neutral or Inclusive
EP Rulemaking for SMRs and ONT
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• Regulatory Basis provides
– policy and legal issues
– stakeholder interactions
– lessons learned from recent licensing of large light water reactors
– next steps in the rulemaking process
– the elements for reasonable assurance determination of adequate protection of public health and safety
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EP Rulemaking for SMRs and ONT
• 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
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EP Rulemaking for SMRs and ONT
Emergency Preparedness Rulemaking for SMR/ONT
• Proposed Rule would:
– Allow for smaller EPZ sizes than those for existing nuclear power reactors
– Require analysis of accident spectrum and consequences
– Require the use of performance indicators to monitor E-plan performance and trends
– NOT change the EPZs or EP requirements for existing nuclear power reactors
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• Proposed Performance Measures: • Event mitigation • Protective actions • Communications • Command and control • Staffing • Radiological assessment
• Proposed Guidance:
• General information (non-design specific)
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Emergency Preparedness Rulemaking for SMR/ONT
National Radiological Emergency Preparedness Conference April 17, 2018
EP SMR/ONT Rulemaking Schedule
• Regulatory Basis issued (ADAMS No.ML17206A265)
– November 2017
• Proposed Rule/Draft Regulatory Guidance
– Comment period 60 days –to be issued in January 2019
– Draft guidance will accompany the proposed rule
• Final Rule/Final Regulatory Guidance
– Target: Provide to the Commission February 2020
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EP Rulemaking Documents for SMR/ONT
• Rulemaking information • RIN Number: 3150-AJ68 • www.Regulations.Gov • Docket ID NRC–2015–0225 • Regulatory Basis ADAMS No. ML17206A265
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Questions?
Contact Information:
Robert Kahler
Branch Chief
U.S. NRC
robert.kahler@nrc.gov
(301) 287-3756
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