I am writing in support of the U.S. Nuclear Regulatory Commission's proposal to amend its regulations to include new alternative emergency preparedness approaches for light-water SMRs. I support the NRC’s movement towards performance-based, risk-informed, and consequence-oriented approaches to EP as described in the proposed rulemaking and draft Regulatory Guide (DG), DG-1350, “Performance-Based Emergency Preparedness for Small Modular Reactors, Non-Light-Water Reactors, and Non-power Production or Utilization Facilities.” However, I urge the NRC to continue to refine the regulations and guidance surrounding EP to ensure that it can effectively scale to the right-size given the inherent safety of advanced reactors. While the current rulemaking and guidance are applicable to light-water SMRs, the requirements do not fully recognize the inherent safety associated with microreactors. Though they are step in the right direction, I encourage additional adjustments to fully account for the very minor risk presented by some advanced reactors.
Scaleable emergency preparedness (EP) directly supports the NRC's primary mission to protect the public health and safety by ensuring that clean, emission-free power plants can be effectively evaluated and brought online. An appropriate regulatory framework surrounding EP supports a streamlined application process that allows for the rapid deployment of nuclear power plants. The reasons I support the effort to appropriately reform emergency preparedness to streamline the application process include:
1) Decisions concerning emergency planning activities and the size of emergency planning zones (EPZs) should be risk-informed, performance-based and consequence-oriented. SMRs and advanced reactors are designed to have inherent safety characteristics and smaller radioactive material inventories. Therefore a much smaller maximum potential release of radioactive material is theoretically possible. With that in mind, the EPZ needs to be able to match the risk associated with the facility and perhaps should be more comparable to that of an industrial facility with similar levels of risk. As the NRC has decades of regulatory experience with hundreds of small-scale reactors and no serious releases to date, it is well suited to make a right-sized assessment of SMRs and advanced reactors.
2) Advanced reactors that utilize a fast spectrum are the only effective tool in the world to both produce clean electricity as well as reduce radioactive waste. In fact, they are key to closing the fuel cycle and turning current hazards into valuable assets to the public.
3) As can be seen in the global impacts of air pollution and climate change, the greatest risk associated with nuclear reactors is not building them. Countries with abundant nuclear energy have fewer public health impacts from air pollution and contribute less per capita to climate change. Advanced reactors can also address historic environmental injustices by replacing fossil power plants that disproportionately pollute the air of poor and disadvantaged communities.
Given the above environmental and societal benefits, as well as the remarkably low risk associated with building and operating SMRs and advanced reactors, it is imperative these reactors not be subject to unnecessary burdens, especially considering the disproportionate economic burden they would place on smaller reactors. Simply taking a clear-eyed evidence based approach to assessing risk of radioactive release should allow these reactors to bring power to remote communities and more easily fight climate change and air pollution.
Thank you for continuing to ensure health and safety, in particular by enabling the deployment of clean, non-CO2-emitting power sources.