ML22046A035
| ML22046A035 | |
| Person / Time | |
|---|---|
| Issue date: | 02/17/2022 |
| From: | O'Driscoll J NRC/NMSS/DREFS/RRPB |
| To: | |
| James O'DSriscoll | |
| References | |
| 10 CFR Part 50, 10 CFR Part 52, NRC-2009-0196, Part 50/52, RIN 3150-AI66 | |
| Download: ML22046A035 (36) | |
Text
ACRS Subcommittee Briefing:
Content of Proposed Rulemaking to Align Licensing Processes and Incorporate Lessons Learned from New Reactor Licensing 1
February 18, 2022 ADAMS Accession No. ML22046A035
2 Vicki Bier - Subcommittee Chairman Brian Smith - Director, Division of New and Renewed Licenses, Office of Nuclear Reactor Regulation OPENING REMARKS
3 Todays Meeting
- Provide an update on the effort since the last ACRS meeting on this rulemaking (meeting slides and materials: ADAMS Accession No. ML22020A000)
- Address in more depth ACRS members questions and comments provided during the last meeting
- Discuss specifics of proposed changes to guidance documents that support the draft proposed rule
- Provide an update on next steps and the rulemaking schedule
- Receive ACRS members perspectives
4 NRC STAFF PRESENTATION
5 NRC Staff Presenters Jim ODriscoll, NMSS Rulemaking Project Manager Omid Tabatabai, NRR Senior Project Manager
6 Topics for Further Discussion
- Entry conditions for part 50/52/53/53-T
- Cumulative effects of changes on the design when the plant is built
- Physical security of mobile reactors/assembled reactor cores shipped to a facility
- Flexibility for changes related to digital I&C
- Transfer of DC information to other vendors (NRCs role)
- Definition of essentially complete design
- Cutoff accident frequency for credible accidents
7 Entry Conditions for Licensing Processes
- There are no planned entry conditions for Part 50 or Part 52 (open to all technology)
- Part 53 will meet the provisions of NEIMA and provide risk-informed licensing pathways to applicants
- In addition, Part 53 will be technology inclusive
8 Cumulative Effects of Changes During Construction
- Part 50 and Part 52 remain distinct processes
- Part 52 is based on:
-Essentially complete nuclear plant design
-Final design information
-Resolution of all safety issues
-Finality for resolutions in subsequent proceedings
9 Physical Security of Mobile Reactors/
Assembled Reactor Cores
- The proposed changes in this rule do not affect this issue
- Mobile reactors are not being considered in rulemaking
- Requirements would be triggered by arrival of the fueled reactor
- Before arrival, access is controlled as it is currently for reactor construction sites
10 10 Review of Changes Related to Digital I&C
- Endorsement of NEI-96-07 Appendix D unaffected
- RG 1.187 unaffected
- Current interim staff guidance unaffected
- No changes to 10 CFR 50.55a(h) in this rulemaking
11 11 Review of Changes Related to Digital I&C (contd)
- Staff will ask for the level of detail necessary to meet a safety finding
- Design acceptance criteria is not needed
- Proposed change process for standard design approvals would use current methods
12 12 Transfer of DC Information to Other Vendors
- The proposed rule does not affect the responsibilities of vendors in this area
- Existing regulations and reviews ensure design errors are evaluated and reported, vendor qualifications are considered
- E.g., 10 CFR 50.46(a)(3)(i) through (iii),
Appendix B to Part 50, Part 21
- E.g., STP COL review considered alternate vendor qualifications
13 13 Definition of Essentially Complete Design
- Essentially complete is a unique term to Part 52 DCs
- CP level of detail must be sufficient to make 10 CFR 50.34(a) and 50.35 findings
- RG 1.70
- CP Interim Staff Guidance
- No intentional distinction between evolutionary and differs significantly designs within 10 CFR 52.41
14 14 Cutoff Accident Frequency for Credible Accidents
- A discrete cutoff accident frequency for credible accidents is not defined
- The changes to 10 CFR 50.59(c) would align the Part 50 change process with Part 52, with regard to consideration of severe accidents
- This rulemaking does not further define credible or what is substantial
15 15 Proposed Updates to Guidance Documents
- RG 1.206 (Applications)
- RG 1.187 (Changes, Tests, and Experiments)
- RG 4.7 (Site Suitability Criteria)
- SRP 13.3 (Emergency Planning)
16 16 RG 1.206 (Applications)
Purpose:
Unchangedprovide guidance on the format and content of applications for Part 52 nuclear power plants
- Rulemaking items driving changes:
- PRA
- Design scope and standardization
- Contents of applications
- Physical security
- Change process
17 17 RG 1.187 (Changes, Tests, and Experiments)
Purpose:
Unchangedprovide an acceptable method for use in complying with regulations related to changes, tests, and experiments
- Rulemaking item driving changes:
- Severe accident treatment requirements; new criteria 10 CFR 50.59(c)(2)(ix) and (x).
- Guidance applies to future Part 50 licensees
18 18 RG 1.200 (Acceptability of PRA Results)
Purpose:
Unchangedprovide an acceptable method to determine if a PRA is adequate to support an application
- Rulemaking item driving changes:
- Use of PRA in design
- Expands applicability to Part 50
- Guidance applies to future Part 50 applicants
19 19 RG 4.7 (Site Suitability Criteria)
Purpose:
Describe the major site characteristics related to public health and safety and environmental issues that NRC considers in determining the suitability of sites for light-water-cooled nuclear power stations
- Rulemaking item driving changes:
- Significant impediments to development of emergency plans
- Changes address siting criteria for ESP reviews conducted under 10 CFR 52.17(b)(1)
20 20 SRP 19.0 (PRA and Severe Accident Evaluation)
Purpose:
- Guides NRC staff review of PRA for a DC, ML, COL, CP, and OL application
- Guide staff in deterministic evaluation of severe accident design features
- Rulemaking items driving changes:
- Severe accident treatment requirements
- Use of PRA in design
- Guidance applies to future new reactor licensing reviews under Part 50
21 21 SRP 19.1 (Technical Adequacy of PRA Results)
Purpose:
Guides NRC staff review of the technical adequacy of PRA used to support a DC, ML, COL, CP, and OL application
- Rulemaking items driving changes:
-Severe accident treatment requirements
-Use of PRA in design
- Guidance applies to future new reactor licensing reviews under Part 50
22 22 SRP 13.3 (Emergency Planning)
Purpose:
Guides NRC staff review of the applicants emergency planning, as described in the safety analysis report associated with the CP, OL, or COL application
- Rulemaking items driving changes:
- Significant impediments to development of emergency plans
- Three Mile Island requirements
- Changes provide additional guidance on conducting a siting analysis and update references
23 Questions
24 24 Recap and Next Steps
- Complete concurrence on draft proposed rule
- Submit the proposed rule to the Commission
- Plan for additional public meeting(s) during the proposed rule phase
25 25 Rulemaking Schedule Issue final rule Issue final rule October 2024 Submit proposed rule to the Commission Submit proposed rule to the Commission May 2022
26 Jim ODriscoll, Project Manager Division of Rulemaking, Environmental, & Financial Support Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Email: James.ODriscoll@nrc.gov Phone: 301-415-1325 Omid Tabatabai, Senior Project Manager Division of New Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Email: Omid.Tabatabai@nrc.gov Phone: 301-415-6616 Contact Information
How to Stay Informed and Involved 27 Search regulations.gov on the docket ID NRC-2009-0196 Press the Subscribe button to receive alerts about updates to the docket
28 SUPPORTING INFORMATION
29 29 Abbreviations ACRS Advisory Committee on Reactor Safeguards ADAMS Agencywide Documents Access and Management System AEA Atomic Energy Act of 1954, as amended CFR Code of Federal Regulations COL Combined License CP Construction Permit DAC Design Acceptance Criteria DC Design Certification DG Draft Regulatory Guide ECCS Emergency Core Cooling System EP Emergency Planning ESP Early Site Permit FFD Fitness For Duty FRN Federal Register Notice FSAR Final Safety Analysis Report I&C Instrumentation and Controls ISG Interim Staff Guidance ITAAC Inspections, Tests, Analyses, and Acceptance Criteria LAR License Amendment Request LWR Light-Water Reactor ML Manufacturing License NEI Nuclear Energy Institute NEIMA Nuclear Energy Innovation and Modernization Act NMSS Office of Nuclear Material Safety and Safeguards NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation OL Operating License PRA Probabilistic Risk Assessment RG Regulatory Guide SDA Standard Design Approval SECY Office of the Secretary SRP Standard Review Plan SSC Structure, System, and Component STP South Texas Project TMI Three Mile Island
30 30 References Document Title ADAMS Accession Number/FR Citation Regulatory Guide 1.70, Revision 3, Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, dated November 1978 ML011340122 SECY-90-241, Level of Detail Required for Design Certification Under Part 52, dated July 11, 1990 ML003707877 IEEE Std. 603-1991, Standard Criteria for Safety Systems for Nuclear Power Generating Stations, dated December 31, 1991 https://ieeexplore.ieee.org/
document/159411 NEI 01-01/EPRI TR-102348, Revision 1, Guideline on Licensing Digital Upgrades, dated March 2002 ML020860169 NEI 00-04, Revision 0, 10 CFR 50.69 SSC Categorization Guideline, dated July 2005 ML052910035 Regulatory Guide 1.201, Revision 1, Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to Their Safety Significance, dated May 2006 ML061090627 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Chapter 13.3, Revision 3, Emergency Planning, dated March 2007 ML063410307 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Chapter 19.1, Revision 3, Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, dated September 2012 ML12193A107 Regulatory Guide 4.7, Revision 3, General Site Suitability Criteria for Nuclear Power Stations, dated March 2014 ML12188A053 NEI 96-07, Appendix C, Revision 0 - Corrected, Guideline for Implementation of Change Processes for New Nuclear Power Plants Licensed Under 10 CFR Part 52, dated March 2014 ML14091A739 Results of Periodic Review of Regulatory Guide (RG) 1.201, dated April 23, 2015 ML15091A788
31 31 References (contd)
Document Title ADAMS Accession Number/FR Citation Interim Staff Guidance COL-ISG-025, Changes During Construction Under 10 CFR Part 52, dated July 2015 ML15058A377 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Chapter 19.0, Revision 3, Probabilistic Risk Assessment and Severe Accident Evaluation for New Reactors, dated December 2015 ML15089A068 International Atomic Energy Agency, Specific Safety Requirements No. SSR 2/1, Revision 1, Safety of Nuclear Power Plants: Design, dated February 2016 https://www.iaea.org/
publications/8771/
safety-of-nuclear-power-plants-design NRC Letter to NEI Related to the Public Meeting of March 28, 2018, Regarding Avoiding Delays in Issuance of U.S. Nuclear Regulatory Commission Combined Licenses, dated May 9, 2018 ML18123A245 Regulatory Issue Summary (RIS) 2002-22, Supplement 1, Clarification on Endorsement of Nuclear Energy Institute Guidance in Designing Digital Upgrades in Instrumentation and Control Systems, dated May 31, 2018 ML18143B633 Regulatory Guide 1.206, Revision 1, Applications for Nuclear Power Plants, dated October 2018 ML18131A181 DI&C-ISG-06, Revision 2, Licensing Process, dated December 2, 2018 ML18269A259 NEI 18-04, Revision 1, Risk-Informed Performance-Based Technology Inclusive Guidance for Non Light Water Reactor Licensing Basis Development, dated August 2019 ML19241A472 NEI Letter to the NRC, Part 50/52 Lessons Learned Rulemaking, dated March 9, 2020 ML20108F543 NEI 96-07, Appendix D, Revision 1, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications, dated May 2020 ML20135H168
32 32 References (contd)
Document Title ADAMS Accession Number/FR Citation Public Meeting to Discuss the Status of Rulemaking to Align Licensing Processes and Apply Lessons Learned from New Reactor Licensing [NRC-2009-0196; RIN 3150-AI66] held April 29, 2020, dated May 26, 2020 ML20141L609 Regulatory Guide 1.233, Guidance for a 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 June 2020 ML20091L698 NRC Letter to NEI, Part 50/52 Lessons-Learned Rulemaking: U.S. Nuclear Regulatory Commission Transparency and Stakeholder Engagement, dated September 8, 2020 ML20156A308 Regulatory Guide 1.200, Revision 3, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, dated December 2020 ML20238B871 Regulatory Guide 1.237, Revision 0, Guidance for Changes During Construction for New Nuclear Power Plants Being Constructed Under a Combined License Referencing a Certified Design Under 10 CFR Part 52, dated February 2021 ML20349A335 Design Review Guide (DRG): Instrumentation and Controls for Non-Light-Water Reactor (Non-LWR)
Reviews, dated February 26, 2021 ML21011A140 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, last reviewed/updated March 9, 2021 https://www.nrc.gov/reading
-rm/doc-collections/nuregs/staff/sr08 00/index.html NEI, Industry Comments on the Regulatory Basis for Alignment of Licensing Processes and Lessons Learned from New Reactor Licensing (Docket ID: NRC-2009-0196), dated May 14, 2021 ML21144A164
33 33 References (contd)
Document Title ADAMS Accession Number/FR Citation Regulatory Guide 1.187, Revision 3, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated June 2021 ML21109A002 NUREG-1021, Revision 12, Operator Licensing Examination Standards for Power Reactors, dated September 2021 ML21256A276 Draft Interim Staff Guidance; Request for Comment, Safety Review of Light-Water Power-Reactor Construction Permit Applications, dated December 14, 2021 86 FR 71101 Draft FRN to Support ACRS Subcommittee Meeting - 10 CFR Part 50/52 Rulemaking to Align Licensing Processes and Lessons Learned from New Reactor Licensing, dated January 27, 2022 ML22020A002 ACRS Subcommittee Public Meeting - NRC Presentation for 10 CFR Part 50/52 Rulemaking to Align Licensing Processes and Lessons Learned from New Reactor Licensing, dated February 1, 2022 ML22020A001 Draft Guidance Documents to Support ACRS Subcommittee Meeting Regarding Part 50/52 Proposed Rulemaking, dated February 15, 2022 ML22040A074
34 34 Changes to Tier 1 Information Without Prior NRC Approval
- Industry desires more flexibility
- Additional process changes are not recommended due to experience with only one referenced DC
- Limited by the Atomic Energy Act
35 35 Operators Licensing NUREG-1021 Changes Permit the use of suitable alternatives in lieu of the plant walkthrough portion of the operating test while the facility is under construction Permit waivers for examination and test requirements for multiple unit sites of the same design
- Require actions that would ensure that an operator license applicants knowledge, skills, and abilities are maintained when there would be a significant amount of time between when the applicant successfully passes the licensing exam and completes the remaining requirements to be licensed
- Amend the definitions of plant-referenced simulator and reference plant to clarify that these terms are also applicable to simulators that model nuclear power plants that are under construction
36 36 Status of RG 1.201 Development of regulation and guidance:
10 CFR 50.69 issued in 2004 NEI 00-04 issued in final form in 2005 RG 1.201 issued for trial use in 2006 First application in 2014 Summary of issues in 2015 Many changes are needed to address use of the rule before construction