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Products & Policies | Ex-Im Bank Policies | Nuclear Guidelines

Nuclear Guidelines - Table 1

PROJECTS HAVING U.S. SOURCED OR LICENSED NSSS SYSTEMS

The guidelines outlined in this table are applicable to transactions covering Ex Im Bank support of services or equipment for commercial nuclear power plants in which the nuclear steam supply system (NSSS) is being (or has been) sourced or licensed from a U.S. supplier, whether or not the NSSS itself constitutes a part of the transaction for which Ex Im Bank support is being requested. Upgrades to existing nuclear power plants that have been previously operated and for which the NSSS was sourced from a U.S. supplier are also covered by this table. 

I. TRANSACTIONS FOR THE SUPPLY OF NSSS SYSTEMS (> 15 MWt) FROM THE U. S.
The "Unified Procedures Applicable to Major Federal Actions Relating to Nuclear Activities," issued pursuant to Executive Order 12114, shall be applied to new projects covering the supply of nuclear steam supply system (NSSS) equipment.

The Unified Procedures were established jointly by the Department of State, the Department of Energy, and the Export Import Bank. Projects covered include any NSSS for a plant capable of producing more than 15 MWt. Under these procedures the U.S. Government will prepare a Concise Environmental Review of the environmental issues involved with the project after consulting with the nation that is the proposed recipient of the export and international bodies or organizations of which the U.S. is a member, such as the International Atomic Energy Agency (IAEA). 

Documentation required by these Unified Procedures shall be submitted as soon as it becomes available. The documentation from the Unified Procedures will be evaluated with reference to the guidelines presented below.

II. GUIDELINES APPLICABLE TO PROJECTS USING U.S. SOURCED OR LICENSED NSSS 
The following guidelines apply to all projects utilizing U.S. sourced or licensed NSSS systems, whether or not the transaction is subject to the Unified Procedures noted above. Both new projects and upgrades to existing projects are addressed by these guidelines. 

A. Liability: The host country must have a regime acceptable to Ex-Im Bank governing liability for nuclear damage.

B. Nuclear Conventions and Treaties: The host country must provide a list of the applicable nuclear-related treaties and conventions, including the in-country status, to which the host country is a signatory. 

C. Local Regulatory Structure and Authority: The host country must have an established legal code addressing nuclear regulations and environmental protection. It must have an established nuclear regulatory authority capable of developing and implementing sound licensing and, as appropriate, re licensing procedures. 

The country's nuclear regulatory authority should have the independence and qualifications to oversee the siting, design, construction, commissioning, operation and decommissioning of the entire project to a level sufficient to ensure that all relevant safety measures and procedures are addressed and followed. Any IAEA reports on the status of the nuclear regulatory authority, such as an IRRT assessment, shall be used to evaluate the regulatory authority. Furthermore, the licensing process followed by the country's nuclear regulatory authority should follow the safety requirements set forth by the IAEA, such as IAEA Safety Standards No. GS-R-1 "Legal and Governmental Infrastructure for Nuclear, Radiation, Radioactive Waste and Transport Safety" and relevant supplemental Safety Guides GS-G-1.1 "Organization and Staffing of the Regulatory Body for Nuclear Facilities", GS-G-1.2 "Review and Assessment of Nuclear Facilities by the Regulatory Body", GS-G-1.3 "Regulatory Inspection of Nuclear Facilities and Enforcement by the Regulatory Body" and GS-G-1.4 "Documentation for Use in Regulating Nuclear Facilities".

D. Plant Design Criteria: 

  1. New Plants under Construction: The NSSS system and relevant plant systems shall be designed, supplied and installed in accordance with all applicable IAEA and local regulatory guidelines such as IAEA Safety Standards No. 110 "The Safety of Nuclear Installations", and No. NS-R-1 " Safety of Nuclear Power Plants: Design", fundamental principles, safety requirements and supplemental Safety Guides. All safety guidelines recommended by the host country regulatory authority and/or the IAEA shall be incorporated into the design of the project. If the plant consists of a standard reactor design that has been certified by the U.S. NRC, no further information about safety guidelines associated with its design will be required, except as needed to verify any major changes to the plant's design basis resulting from site specific conditions, as required by the local regulatory authority.
  2. Retrofits or Upgrades to Existing Plants: In the case of retrofits to plants which are operational (have received a permit to operate), it must be demonstrated that all safety guidelines recommended by the host country regulatory authority and/or the IAEA are incorporated into the design of the project, to the degree practical. 

E. Plant Design and Construction Procedures:

  1. New Plants under Construction: The construction and management of the plant must be in accordance with the fundamental principles set forth in IAEA documents. These include in particular the document issued by the IAEA Director General's International Nuclear Safety Advisory Group (INSAG), "Basic Safety Principles for Nuclear Power Plants, INSAG-12, and the recommendations and safety requirements adopted by the IAEA's Board of Governors. 

    Design procedures should include provisions for a Site Investigation Report or equivalent study such as outlined in IAEA Safety Standards No. NS-R-3 "Site Evaluation for Nuclear Installations" and the Safety Guides that supplement IAEA NS-R-3, and a Safety Analysis Report or equivalent study undertaken in accordance with IAEA guidelines applicable to the project and subject to the approval of the local regulatory authority. Information contained in these reports, including any completed sections of these reports or preliminary version, should be made available to Ex Im Bank upon request. 

    Quality Assurance (QA) and Quality Control (QC) measures and procedures shall be followed by suppliers of all applicable plant components, equipment and systems. All equipment and components shall adhere to applicable fabrication codes recommended by the IAEA Safety Standards No. 50 C/SG-Q "Quality Assurance for Safety in Nuclear Power Plants and Other Nuclear Installations, Codes and Safety Guides Q1-Q14" and the safety guides that supplement IAEA 50 C/SG-Q. The project must be subject to the approval of the host country's regulatory authority.
  2. Upgrades or Retrofits to Existing Plants: All modifications or upgrades to an existing plant shall be undertaken in accordance with the fundamental principles set forth in IAEA Safety Standards. These include the Safety Requirements issued by the IAEA, Safety Standards No. NS-R-1 and No. NS-R-2 and the supporting safety guides, in particular NS-G-1.2 "Safety Assessment and Verification for Nuclear Power Plants" and NS-G-2.3 "Modifications to Nuclear Power Plants". 

    All equipment and components for the retrofit or upgrade of the plant shall adhere to applicable fabrication codes recommended by the IAEA Safety Standards No. 50 C/SG-Q "Quality Assurance for Safety in Nuclear Power Plants and Other Nuclear Installations, Codes and Safety Guides Q1-Q14" and the safety guides that supplement IAEA 50 C/SG-Q and shall follow the QA/QC criteria established by the host country's regulatory authority. The retrofit or upgrade project must be subject to the approval of the host country's regulatory authority. 

F. Plant Operation Procedures: Operation of the plant will be subject to the issuance of an operating license by the host country's nuclear regulatory authority. There must be evidence that the project has adopted or will adopt sound operating plans, which address emergency procedures, evacuation programs and waste handling approved by the regulatory authority and in accordance with applicable IAEA guidelines such as IAEA Safety Standards No. NS-R-2, "Safety of Nuclear Power Plants: Operation," and that there is (or will be) an adequate number of trained and qualified personnel licensed by the regulatory authority to operate the plant in a safe manner in accordance with the operating plan of the project. The project should conform to the relevant supplemental documents including but not limited to, IAEA Safety Standards NS-G-2.8, "Recruitment, Qualification, and Training for Nuclear Power Plants." 

G. Environmental Monitoring Facility: An environmental monitoring facility shall be (or shall have been) installed at or near the project site, which will monitor the levels of radioactivity from the plant and the effects, if any, of the plant on the environment and ecology of the region around the plant. The facility shall submit regular reports, which show the results of its monitoring activities to the regulatory authority and to the environmental authority of the region. 

H. Environmental Impact Assessment (EIA):

  1. For all new or greenfield projects, an EIA with respect to the project shall be submitted to Ex Im Bank which addresses the environmental effects of the project in accordance with Annex C. The EIA shall address the impact of the project on the ecology of the region as well as any significant impact on the local population resulting from actions such as resettlement or major changes to the cultural or economic structure of the region. It also shall indicate the degree to which the international environmental guidelines listed below will be met, and list any measures taken to mitigate any adverse environmental effects of the project. 
  2. For projects involving retrofits or upgrades to existing plants, information shall be made available, to the extent available commensurate with the scope of the retrofit or upgrade, indicating the degree of compliance with applicable host country and relevant international environmental guidelines as set forth below.

I. Other International Guidelines:

EMISSIONS
Measures shall be established to ensure that the emission of any radioactive material from the plant be maintained as low as reasonably achievable. Radiation dose limits for all individuals shall be established for applicable radioactive elements that are analogous to the numerical limits set forth in the applicable IAEA recommendations. 

To the extent that the facility emits significant levels of non nuclear pollutants (particulates, SO2 and/or NOx) from various plant sources, those emission levels should comply with the more stringent of host country emission guidelines or those limits contained in the Pollution Prevention and Abatement Handbook (PPAH) of the World Bank. 

LIQUID EFFLUENTS
Measures shall be established to ensure that any radioactive material released in the discharge of the liquid effluent stream from the project be maintained as low as reasonably achievable. Limits for such radioactive material above background shall be established for the plant discharge that are analogous to the list of elements and numerical limits set forth in the applicable IAEA recommendations for plant discharge. 

In addition, process wastewater, plant cooling water, domestic sewage and contaminated stormwater should be treated before being discharged to surface water. Treatment levels should be to the more stringent of applicable host country guidelines or the limits set forth below that are also set forth in the PPAH. 

Pollutant Limit (mg/l)
pH  6 to 9
COD (Chemical Oxygen Demand) 250
BOD5 (Biochemical Oxygen Demand) 50
Total Suspended Solids 50
Oil and Grease 10
Total Residual Chlorine  0.2 (refer to PAPH) 
Metals, Total  5.0
Specific Metals, (as applicable):
  Cadmium 0.1
  Chromium, Total  0.5
  Copper 0.5
  Lead 0.1
  Mercury 0.01
  Nickel 1.5
  Zinc 1.0
  Arsenic 0.1
  Iron 1.0
Coliforms, Total <400 MPN/100 ml (MPN - Most Probable Number)
Temperature (edge of a designated mixing zone)  - Max 3oC > ambient temp of receiving water 
A mixing zone is a limited area or volume of water where initial dilution of a discharge takes place and beyond which applicable water quality criteria should not be exceeded. In the case of a thermal plume, a mixing zone is generally defined as occupying no more than 25% of the cross section of a waterway channel (river, stream, etc.) so as to allow passage of aquatic life and permit other uses of the water. In the case of an open body of water, the mixing zone will be defined on a case-by-case basis taking into account the existing ecology and in particular, the presence of coral reefs. Where zone is not defined, 100m from the point of discharge is used.

In the case of discharges potentially impacting groundwater resources, metal parameters will meet the levels listed under the liquid effluent limits. Measures should be taken to prevent potential groundwater contamination from discharges containing toxic hydrocarbons.

Reduction in the generation of effluents through process modifications and recycling is recommended. Chromates should not be used in the water treatment process. For projects potentially causing erosion and sedimentation impacts in receiving waters, a plan should be submitted incorporating measures to mitigate the impacts on water quality and aquatic life.

SOLID AND LIQUID WASTES 
To the extent that the facility produces solid or liquid waste, a waste management plan that incorporates environmentally safe waste management and disposal practices should be described and adopted. Recycling or reclamation of non hazardous materials is encouraged where possible. If recycling or reclamation is not practical, wastes must be disposed of in an environmentally safe manner in compliance with applicable local laws and regulations. The storage and handling of all hazardous materials must be undertaken appropriate to their hazard characteristics: reactivity, flammability, corrosivity, radioactivity, and toxicity, with fire prevention systems and secondary containment installed for storage facilities, where required, to prevent the release of hazardous materials to the environment. All hazardous wastes must be disposed of in a manner to prevent the contamination of soil, groundwater and surface waters. 

NOISE
The Project boundary or fence line is the commonly accepted location for evaluating Project related noise impacts, although the outer edge of a buffer zone or other uninhabited area may be appropriate in selected cases.

AMBIENT NOISE: Steady-state noise levels from the Project's operation, measured at noise receptors located outside the Project property boundary, should not exceed the following limits:

Location Category 

Limits in Decibels, dB(A)

Day Time  Night Time
Residential, Institutional, Educational 55 45
Commercial/Industrial 70 70

RESETTLEMENT, INDIGENOUS PEOPLES, CULTURAL PROPERTY (When Applicable)
Project site selection should take into account and minimize to the extent practical adverse impacts to indigenous and other vulnerable people within the project's area of influence resulting from involuntary resettlement, land use changes, population influx due to increased access caused by the project, or effects on culturally significant artifacts or sites.

Where large resettlement or relocation becomes unavoidable, a Resettlement Action Plan (RAP) must be developed and implemented in compliance with host-country laws and international guidelines such as those of the World Bank Group. (See Operational Safeguard Policies of the World Bank: OP 4.20, Indigenous Peoples; OP 4.11, Safeguarding Cultural Property and OD 4.30, Involuntary Resettlement). 

NATURAL HABITATS (When Applicable) 
Project site selection should take into account and minimize to the extent practical impacts to the ecology within the project's area of influence. Care to avoid/minimize impacts must be demonstrated, particularly in the case of important and critical natural habitats as defined in World Bank Operational Policy 4.04; Natural Habitats. For projects situated in sensitive locations, the EIA should address the risk of direct and indirect impacts on the environment of the project's area of influence as well as measures to mitigate these impacts. Guidance in protecting natural habitats is provided in OP 4.04. 

ENVIRONMENTAL MANAGEMENT AND MONITORING
For all projects requiring an EIA, an environmental management and monitoring plan (EMP), should be provided that sets forth: (a) the measures to be taken during the implementation and operation of a project to eliminate or offset adverse environmental impacts, or reduce them to acceptable levels; (b) the actions needed to implement these measures; and (c) actions required to assess the effectiveness of the mitigation measures employed. Specific requirements of the EMP will be made on a case-by-case basis according to the project's environmental sensitivities. The World Bank Operational Policy 4.01 provides guidance with respect to the preparation of an EMP. In addition, information should be provided in the EMP or in a separate document describing the Decommissioning Program for the project. 


Export-Import Bank of the United States
Revised : July 23, 2002
 
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