ML21012A167

From kanterella
Jump to navigation Jump to search
NRC Staff Presentation Slides to Support ACRS Future Plant Subcommittee Meeting - 10 CFR Part 53 Licensing and Regulation of Advanced Nuclear Reactors - Subparts B and F (Facility Safety Program Only) Preliminary Proposed Rule Language
ML21012A167
Person / Time
Issue date: 01/14/2021
From: Robert Beall
NRC/NMSS/DREFS/RRPB
To:
Beall, Robert
References
10 CFR Part 53, NRC-2019-0062, RIN 3150-AK31
Download: ML21012A167 (41)
v • d • e


Text

ACRS Future Plant Designs Subcommittee 10 CFR Part 53 Licensing and Regulation of Advanced Nuclear Reactors Subparts B and F Preliminary Proposed Rule Language January 14, 2021 1

Agenda 9:30-9:40 am Opening Remarks/Speaker Introductions 9:40-11:00 am Background and Part 53 Rulemaking Strategy

& Schedule 11:00 am - 1:00 pm Subpart B - Technology-Inclusive Safety Requirements 1:00-2:00 pm BREAK 2:00-3:00 pm Subpart B - Technology-Inclusive Safety Requirements 3:00-4:30 pm Subpart F - Requirements for Operation (Facility Safety Program) 4:30-6:00 pm Discussion 2

Background

  • Nuclear Energy Innovation and Modernization Act (NEIMA; Public Law 115-439) signed into law in January 2019 requires the NRC to complete a rulemaking to establish a technology-inclusive, regulatory framework for optional use for commercial advanced nuclear reactors no later than December 2027 o (1) ADVANCED NUCLEAR REACTORThe term advanced nuclear reactor means a nuclear fission or fusion reactor, including a prototype plant with significant improvements compared to commercial nuclear reactors under construction as of the date of enactment of this Act, 3

SECY-20-0032 Rulemaking Plan

  • In SECY-20-0032, Rulemaking Plan on Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors, (ADAMS ML19340A056), dated April 13, 2020, NRC staff proposed:

o Developing a new 10 CFR part that could address performance requirements, design features, and programmatic controls for a wide variety of advanced nuclear reactors throughout the life of a facility o Focusing the rulemaking on risk-informed functional requirements, building on existing NRC requirements, Commission policy statements, and recent activities o Building upon activities such as those described in SECY-19-0117, Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light-Water Reactors, dated December 2, 2019 (ADAMS Accession No. ML18311A264), to develop the associated performance criteria.

o Seeking extensive interactions with external stakeholders and the Advisory Committee on Reactor Safeguards (ACRS) on the content of the rule 4

Staff Requirements Memorandum (SRM) -

SECY-20-0032, Rulemaking Plan

o Approved the staffs proposed approach for the rulemaking o Directed the staff to provide:

a schedule with milestones and resource requirements to achieve publication of the final Part 53 rule by October 2024 key uncertainties impacting publication of the final rule by that date options for Commission consideration on licensing and regulating fusion energy systems o Directed the staff to develop and release preliminary proposed rule language intermittently, followed by public outreach and dialogue 5

30-Day Commission Memo

  • On November 2, 2020, staff submitted a Commission memorandum responding to the SRM direction to provide a schedule with milestones and resources to complete the final rule by October 2024 (ADAMS ML20288A251).
  • The memorandum included a discussion of key uncertainties that could impact publication of the final rule by that date.

6

30-Day Commission Memo Milestone Schedule Major Rulemaking Activities/Milestones Schedule Public Outreach, ACRS Interactions and October 2020 to April 2022 Generation of Proposed Rule Package (19 months)

Submit Draft Proposed Rule Package to May 2022 Commission Publish Proposed Rule and Draft Key Guidance October 2022 Public Comment Period - 60 days November and December 2022 Public Outreach and Generation of Final Rule January 2023 to February 2024 Package (14 months)

Submit Draft Final Rule Package to Commission March 2024 Office of Management and Budget and Office of July 2024 to September 2024 the Federal Register Processing Publish Final Rule and Key Guidance October 2024 7

30-Day Commission Memo

  • Key uncertainties in meeting the Commission directed rulemaking schedule:

o NRC-stakeholder alignment on the scope of the rulemaking o Engagement on key issues within the NRC and communication with external stakeholders and ACRS o Timing of guidance document development o Ability of the public to review the proposed rule within the proposed 60-day public comment period o Ability to include the regulatory framework and requirements for fusion facilities 8

NRC Staff Plan to Develop Part 53 Subpart B Subpart C Subpart D Subpart E Subpart F Subpart G Project Life Cycle Design and Siting Construction Operation Retirement Analysis Requirements Facility Safety Definition System External Construction/ Program

  • Fundamental Safety & Component Hazards Manufacturing Design Surveillance Functions Site Ensuring Maintenance
  • Prevention, Mitigation, Analysis Characteristics Capabilities/

Performance Criteria Requirements Configuration (e.g., F-C Targets) Reliabilities Environmental Control

  • Normal Operations Safety Change Control (e.g., effluents) Considerations Categorization Design
  • Other & Special Environmental Changes Treatment Considerations Staffing &

Programs Plant/Site (Design, Construction, Configuration Control)

Clarify Controls Analyses (Prevention, Mitigation, Compare to Criteria) and Distinctions Between Plant Documents (Systems, Procedures, etc.)

LB Documents (Applications, SAR, TS, etc.) Subparts H & I 9

NRC Staff Engagement Plan Stakeholder Interactions Framework Safety Criteria Design Siting Construction Operations Decommissioning Licensing General/Admin Nov 20 Dec 20 Jan 21 Feb 21 Mar 21 Apr 21 May 21 Jun 21 Jul 21 Consolidated Technical Sections Aug 21 Sep 21 Oct 21 Nov 21 Consolidated Rulemaking Package Dec 21 Jan 22 ACRS Full Committee Feb 22 Mar 22 Apr 22 May 22 Draft Proposed Rulemaking Package to the Commission Jun 22 Jul 22 Aug 22 Sept 22 Oct 22 Concept Discussion Closure 10

NRC Staff Engagement Plan ACRS Interactions Framework Criteria Design Siting Construct Operation Decom Licensing Gen/Adm Subpart B Subpart C Subpart D Subpart E Subpart F Subpart G Subparts H, I Subparts A, J Nov 20 Dec 20 Jan 21 Feb 21 Mar 21 Apr 21 May 21 Jun 21 Jul 21 Aug 21 Sept 21 Oct 21 Nov 21 Consolidated Rulemaking Package Dec 21 Jan 22 ACRS Full Committee Feb 22 Mar 22 Apr 22 May 22 Draft Proposed Rulemaking Package to the Commission Jun 22 Jul 22 Aug 22 Sept 22 Oct 22 Concept 11 Discussion

Advanced Reactor Concepts

  • Light-Water Small Modular Reactors
  • Non-Light-Water Reactors
  • Liquid Metal Cooled Fast Reactors
  • Gas Cooled Reactors
  • Molten Salt Cooled Reactors
  • Molten Salt Fueled Reactors
  • Heat Pipe Reactors o Microreactors
  • Accelerator Driven Systems
  • Fusion Reactors
  • Note that fusion energy systems to be subject of separate paper with specific ACRS interactions 12

Non-LWR Landscape 13

First Principles See: SECY-18-0096, Functional Containment Performance Criteria for Non-Light-Water-Reactors, and INL/EXT-20-58717, Technology-Inclusive Determination of Mechanistic Source Terms for Offsite Dose-Related Assessments for Advanced Nuclear Reactor Facilities 14

Integrated Approach (Background)

Bow-Tie Risk Management Figure 15

Integrated Approach (NRC Activities)

Note that a goal of the current effort is to build from the Licensing Modernization Project and have that guidance (NEI 18-04, RG 1.233) be one acceptable way of meeting the requirements to be developed and incorporated into Part 53 16

Licensing Modernization Project Licensing Basis Events Event Sequences

  • Design Basis Events
  • Beyond Design Basis Events Design Basis Accidents (relying on safety-related structures, systems, and components)

See: NEI-18-04 (NRC ADAMS ML19241A336) and Regulatory Guide 1.233 (NRC ADAMS ML20091L698) 17

Licensing Modernization Project Classification & Defense in Depth

  • Safety Classification and Performance Criteria
  • Safety Related (based on needed capabilities and reliabilities)
  • Non-Safety Related With Special Treatment
  • Non-Safety Related With No Special Treatment

Part 53 General Layout

  • Subpart A, General Provisions
  • Subpart B, Technology-Inclusive Safety Requirements
  • Subpart C, Design Requirements
  • Subpart D, Siting
  • Subpart E, Construction and Manufacturing Requirements
  • Subpart F, Requirements for Operation
  • Facility Safety Program
  • Subpart G, Decommissioning Requirements
  • Subpart H, Applications for Licenses, Certifications and Approvals
  • Subpart I, Maintaining and Revising Licensing Basis Information
  • Subpart J, Reporting and Administrative Requirements 19

10 CFR Part 53 Subpart B Layout

  • § 53.200 - Safety Objectives
  • § 53.210 - Safety Functions
  • § 53.220 - First Tier Safety Criteria
  • § 53.230 - Second Tier Safety Criteria
  • § 53.240 - Licensing Basis Events
  • § 53.250 - Defense in Depth
  • § 53.260 - Protection of Plant Workers 20

Subpart B Flowchart ATOMIC ENERGY ACT Safety Objectives Adequate Protection (Sec. 182) and Minimize Danger (Sec. 161)

First Tier Second Tier Two Tiers § 20.1301 - Normal Ops ALARA for Normal Ops

§ 50.34/52.79 - Unplanned NRC Safety Goals for unplanned of Safety Criteria Events events Retention of radionuclides (1) Retention of radionuclides (2)

Safety Functions - Control heat generation - Control heat generation

- Control heat removal - Control heat removal

- Control chemical interactions - Control chemical interactions Design Features and Safety Classification Special Treatment Programmatic Tech Specs Licensee Programs Controls Chapter 15 21

§§ 53.200 & 53.220/53.230 Objectives and Criteria

  • Safety Objectives o Reasonable assurance of adequate protection of the public health and safety and the common defense and security o Additional measures to minimize danger to life and property, when considering various factors
  • Safety Criteria o Two-Tiered structure 22

§ 53.220 - First Tier Safety Criteria (Adequate Protection)

  • Normal operations (§ 20.1301) o Contribution to total effective dose equivalent (TEDE) to individual members of the public from normal plant operation does not exceed 0.1 rem (1 mSv) in a year o Contribution to dose in any unrestricted area does not exceed 0.002 rem (0.02 millisievert) in any one hour
  • Licensing basis events (§§ 50.34(a)(1)(ii)(D) & 52.79(a)(1)(vi))

o Upper bound frequency > once per 10,000 years o An individual located at exclusion area boundary for any 2-hour period following the onset of release would not receive a radiation dose in excess of 25 rem (250 mSv) TEDE o An individual located at outer boundary of the low population zone exposed to the radioactive cloud resulting from the postulated fission product release (during the entire period of its passage) would not receive a radiation dose in excess of 25 rem (250 mSv) TEDE

  • Additional requirements established by the NRC for reasonable assurance of adequate protection 23

§ 53.230 - Second Tier Safety Criteria (Substantial Additional Protection)

  • Estimated TEDE to the public from effluents during normal plant operation are as low as reasonably achievable (ALARA) o Performance objectives for liquid and gaseous effluents (10 CFR Part 50, Appendix I)
  • Design features and programmatic controls must:

o Ensure plant structures, systems, and components (SSCs), personnel, and programs provide necessary capabilities & reliabilities to address licensing basis events o Provide measures for defense-in-depth o Maintain overall cumulative plant risk from licensing basis events within NRC safety goals 24

§ 53.210 - Safety Functions

  • Safety Functions o Primary safety function is to limit the release of radioactive materials from the facility o Additional functions supporting the retention of radioactive materials must be defined o Design features and programmatic controls fulfill the safety functions 25

Safety Functions Concept NGNP Concept 26

§ 53.240 - Licensing Basis Events

  • Licensing basis events must address combinations of malfunctions of plant SSCs, human errors, and the effects of external hazards
  • Licensing basis events must be used to o Confirm the adequacy of design features and programmatic controls needed to satisfy first and second tier safety criteria o Establish related functional requirements for plant SSCs, personnel, and programs 27

§ 53.250 - Defense in Depth

  • Measures must be taken to ensure appropriate defense in depth is provided to compensate for uncertainties
  • Measures can include increased safety margins and provide alternate means to accomplish safety functions
  • No single design or operational feature should be exclusively relied upon 28

§ 53.260 - Protection of Plant Workers

  • Ensure radiological dose to plant workers does not exceed occupational dose limits from 10 CFR Part 20
  • Use procedures and engineering controls to keep occupational dose levels ALARA 29

Additional Discussion Topics

  • Consideration of unmitigated consequences from event scenarios to support Part 53 o Department of Energy Orders & American Nuclear Society Standard 2.26 (Seismic design)
  • Embedded mechanisms to apply analytical safety margins to gain operational flexibilities o Example is alternative offsite dose thresholds being considered for emergency planning zones and siting o Look ahead to associated Section in Subpart C, Design and Analysis Requirements 30

Integrated Approach Siting near densely populated Functional areas EP for SMRs Containment and ONTs Licensing Modernization Project Insurance and Liability Environmental Reviews Consequence Based Security 31

Key Public Comments on Subpart B, Technology-Inclusive Safety Objectives

  • Adequate protection standard o Avoid regulations that are not needed to provide reasonable assurance of adequate protection of health and safety o Could we add some text to the rule language to help clarify exactly what reasonable assurance of adequate protection means?
  • Safety case o Flexibility is important for applicants to use different approaches to define their safety case (dont require a PRA)
  • Numerical probabilities in rule vs. guidance o Consider replacing with qualitative probability
  • Licensing basis event categories o Clarify how rule addresses specific event categories such as beyond design basis events 32

Key Public Comments on Subpart B, Technology-Inclusive Safety Objectives

  • Requirements for beyond design basis events o Should approach focus on mitigation, like § 50.155?

o Is inclusion of the QHOs necessary? Are there other options to address cumulative risk?

QHOs don't specify the dose value for prompt fatalities and latent health effects

  • Additional requirements for adequate protection o Is § 53.220(c) necessary and, if so, in the right subpart?
  • The two-tier concept is complex and difficult to understand. Is there a more efficient way to organize it?
  • Do you really need a requirement to maintain doses ALARA to meet adequate protection or to minimize danger to the public in Part 53?

33

Key Public Comments on Subpart B, Technology-Inclusive Safety Objectives

  • A requirement for limitations on effluent releases during normal operations may not be needed.
  • Defense-in-depth requirement should allow more flexibility o Concerns with its deterministic nature
  • Avoid uses of the term "high confidence" in the rule language
  • Remove requirements for occupational dose from safety criteria o Consider moving to radiation protection program 34

Part 53 General Layout

  • Subpart A, General Provisions
  • Subpart B, Technology-Inclusive Safety Requirements
  • Subpart C, Design and Analysis
  • Subpart D, Siting
  • Subpart E, Construction and Manufacturing Requirements
  • Subpart F, Requirements for Operation
  • Facility Safety Program
  • Subpart G, Decommissioning Requirements
  • Subpart H, Applications for Licenses, Certifications and Approvals
  • Subpart I, Maintaining and Revising Licensing Basis Information
  • Subpart J, Reporting and Administrative Requirements 35

10 CFR Part 53 Subpart F Layout -

Facility Safety Program

  • § 53.800 - Facility Safety Program
  • § 53.810 - Facility Safety Program Performance Criteria
  • § 53.820 - Facility Safety Program Plan
  • § 53.830 - Review, Approval, and Retention of Facility Safety Program Plans 36

§ 53.800 - Facility Safety Program

  • Establish a facility safety program (FSP) using a risk-informed, performance-based process to proactively identify new or revised hazards and performance issues
  • Routinely evaluate potential hazards, operating experience, human actions, and programmatic controls
  • Consider measures to mitigate or eliminate the resulting risks 37

§ 53.810 - Facility Safety Program Performance Criteria

  • Take measures to protect public health and minimize danger to life or property as may be reasonably achieved when considering costs o Assess risk reduction measures related to radionuclide release during normal operation o Assess risk reduction measures for contributors to the overall cumulative risk from unplanned events
  • Need to integrate with licensing and recordkeeping processes (e.g., updating safety analysis reports) 38

§ 53.820 - Facility Safety Program Plan

  • FSP must use written plan and address:

o Scope of facilities covered o How FSP will be implemented o How personnel will be trained in FSP o Risk-informed hazard management program o Technology assessment program o Internal facility safety program assessment 39

§ 53.830 - Review, Approval, and Retention of FSP

  • FSP plan is part of the application
  • NRC to review/approve FSP plan
  • Will define staff process for reviewing FSP plan changes and amendments 40

Part 53 Rulemaking 41

Retrieved from "https://kanterella.com/w/index.php?title=ML21012A167&oldid=3182829"