ML12139A046 - Station Blackout Advance Notice of Proposed Rule Making

7/31/2019 ML12139A046 - Station Blackout Advance Notice of Proposed Rule Making

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Station Blackout

Advance Notice of Proposed

Rulemaking

Category 3 Public Meeting

April 25, 2012


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Meeting Ground Rules

Limit interruptions (turn off cell phones, minimize side

conversations)

Speak one at a time

Be respectful of speakers/participants

If participating by webinar either use the chat function

to send questions or feel free to ask questions via the

phone line at the designated opportunities


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Meeting Purpose

Provide stakeholders with the NRC staffs preliminary

thoughts on station blackout (SBO) mitigation.

Afford stakeholders an opportunity to ask the NRC staffquestions to clarify the Advance Notice of Proposed

Rulemaking (ANPR).

Enable an exchan e of information on the ANPR and

SBO mitigation to facilitate more accurate and informedunderstanding of all parties.

The meeting is neither designed nor intended to solicit or

receive comments - use the guidance in the ANPR to

provide your written comment by May 4, 2012.


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ANPR Overview

An ANPR is a tool used to gather input to assemble a

regulatory basis for a potential regulatory action.

If new generic requirements are needed, the preferred

regulatory action is rulemaking.

A rulemaking on SBO is likely to incorporate the generic

as ects of the Miti atin Strate ies order re uirements

(ADAMS Accession ML12056A045). An ANPR is not rulemaking and the staff has greater

flexibility in considering input. Input will be considered

but not all comments will be formally dispositioned.


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Commission Direction

Commission directed that staff initiate rulemaking with an

ANPR (See SRM-SECY-11-0124)

The NRC published the SBO ANPR on March 20, 2012.

Commission directed that for beyond-design-basis

events, the staff should use a performance-based

regulatory approach similar to that used for the 2002

interim compensatory measures security order - sectionB.5.b requirements (now 10 CFR 50.54(hh)(2))

The Mitigation Strategies Order requirements follows a similar

performance-based approach.

The NRC staff is open to a similar approach being followed forSBO mitigation.


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ANPR Background

ANPR provides background relating to SBO.

10 CFR 50.63 focuses on improving reliability of

alternating current power: Requires licensees to cope with SBO for a specified duration on

a unit-specific basis.

The concern now is LOOPs and SBOs stemmin from

significant natural hazards (such as Fukushima)


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ANPR QuestionsOverview

The ANPR questions are intended to:

Solicit feedback that supports the staffs development of a

complete and adequate regulatory basis to support a possible

regulatory action - preferably a rulemaking for generic

.

Enable the staff to assemble a rule if supported (e.g., questionsto define scope, objectives, functional considerations).

Encourage broad feedback/while still focusing on the regulatory

matter at hand SBO mitigation.


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Rulemaking Scope

The NRC is seeking input from stakeholders to help

define the scope of regulatory framework for the

potential rulemaking. Pedigree of equipment to mitigate consequences of natural

phenomena

Design margins

Timing of mitigative strategy implementation/duration

Prolonged SBO assumptions (site-wide, multi-unit, specific

duration, loss of ALL alternating current, etc.)

Considerations for spent fuel pool cooling

Benefits and costs


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Rulemaking Objectives/

Success Criteria The NRC is seeking stakeholder views on specific

regulatory objectives and success criteria for the

potential rulemaking. Enhance safety by possibly reducing core damage frequency or large early

release frequency.

Safe shutdown condition end state

-

Staggered SBO mitigation requirements (low vs. high probability SBO events)

Near-Term Task Force recommendations

4.2 Mitigating strategies for beyond-design-basis events

5.1 Containment integrity

7.1 Spent fuel pool instrumentation

8.0 Strengthening and integration of emergency operating procedures, severe

accident management guidelines, and extensive damage mitigation guidelines


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SBO Mitigation Functions

The NRC is seeking input from stakeholders to help

Identify the functions that need to be performed under

SBO conditions. Requirements (design, inspection, testing, quality assurance,

corrective actions, etc.) for structures, systems, and components

needed to mitigate an SBO event

Requirements for supporting procedures, guidelines, and training Multi-unit SBO requirements

Benefits and costs


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Rulemaking Options

Approach 1 (Base Case Supplementary SBO

Requirements)

Leave current SBO requirements intact

Add new requirements as a new Part 50 section Example:

50.160 or 50.63a

Add reference to the new Part 50 section in 50.63 (and vice

Approach 2 (Unified SBO Requirements)

Integrate new SBO requirements into current 50.63

Similar to Approach 1 but integrated into a single Part 50 section

Example: Add new subsection 50.63(d) that details the new

SBO requirements


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Rulemaking Options, Cont.

Approach 3 (Superseding SBO Requirements)

New SBO requirements would entirely supersede/replace the

current 50.63 requirements

The revised rule might not differentiate between SBO ascurrently addressed by 50.63 versus an SBO stemming from

severe natural events

Would necessitate chan es to documents includin lant

procedures, plans, and the Final Safety Analysis Report


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ANPR IssuesFurther Discussion/Focus

If a rulemaking follows, stakeholders will have an

opportunity to comment on the proposed rule. If a proposed rule is issued draft supporting guidance

will be issued with the proposed rule (to support more

.

Consistent with Cumulative Effects of Regulations, the

NRC staff plans to make publicly available the regulatory

basis (or elements of it prior to, or coincident with,

issuance of a proposed rule).


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Wrap-up The staff hopes this was informative and helpful we

appreciate everyones participation.

Please submit written comments by the May 4, 2012comment deadline as described in the ANPR.

A copy of the meeting minutes and the meeting

transcript will be made publicly available in ADAMS andposted to regulations.gov, Docket ID: NRC-2011-0299.

Documents

ML12139A046 - Station Blackout Advance Notice of Proposed Rule Making