ML22063A012
| ML22063A012 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/2022 |
| From: | Renee Taylor Office of Nuclear Reactor Regulation |
| To: | Rempe J Advisory Committee on Reactor Safeguards |
| Beall, Robert | |
| Shared Package | |
| ML22053A092 | List: |
| References | |
| 10 CFR Part 53, LTR-22-0045, NRC-2019-0062, RIN 3150-AK31 | |
| Download: ML22063A012 (4) | |
Text
March 30, 2022 Joy L. Rempe, Chairman Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
RESPONSE TO THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS LETTER ON PRELIMINARY RULE LANGUAGE FOR 10 CFR PART 53, SUBPART F, REQUIREMENTS FOR OPERATIONS, INTERIM REPORT
Dear Chairman Rempe:
On behalf of the U.S. Nuclear Regulatory Commission (NRC) staff, I would like to thank you for the letter from the Advisory Committee on Reactor Safeguards (ACRS or the Committee), dated February 17, 2022 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML22040A361), regarding the ACRS review of the staffs approach to human-system considerations for advanced reactors and proposed, preliminary requirements for Title 10 of the Code of Federal Regulations (10 CFR) Part 53, Subpart F, Requirements for Operations, within the specific areas of staffing, training, personnel qualifications, and human factors. I appreciate the time and effort that the ACRS has devoted to this subject, as reflected in meetings held with the ACRS Future Plant Designs subcommittee on May 20, 2021; September 23, 2021; November 18, 2021; and December 16, 2021; and with the ACRS Full Committee on February 2, 2022.
In its letter, the ACRS recognized that the staff is methodically working through the delicate balance of flexibility and predictability in regulations for operator staffing. The ACRS letter also included the following recommendations:
- 1. The staff should consider the suggestions identified in this letter to ensure the 10 CFR Part 53 approach yields equivalent safety to current regulatory approaches.
Staff Response: The staff agrees with the ACRS recommendation and will draft a rule that, as a minimum, provides at least the same degree of protection of the public and the environment that is required for the current generation of light water reactors.
- 2. The staff should approach the concept of not having a Shift Technical Advisor (STA) by having the applicant justify why the STA is not needed rather than a blanket elimination of this position. This is particularly important for the expected wide application of first-of-a-kind technologies that may be licensed under this rule.
Staff Response: In light of the wide variety of new technologies and first-of-a-kind plant designs, the staff agrees that a blanket elimination of STA-level capabilities on shift is not prudent. Elimination of the STA position or any requirement for engineering expertise for such facilities would be counter to the intent of the Commission Policy Statement on Engineering Expertise on Shift, published on October 28, 1985 (50 FR 43621). As described in the policy statement, the function of the STA is to provide engineering and accident assessment advice to the Shift Supervisor in the event of abnormal or accident conditions. Therefore, the staff intends to add a performance-based requirement in the preliminary proposed 10 CFR Part 53 rule language for adequate engineering expertise to be available to operating personnel, consistent with the Commission policy statement. Such an approach is consistent with NRCs approval of the NuScale Topical Report NuScale Control Room Staffing Plan TR-0430-69456, NuScale Control Room Staffing Plan (ADAMS Accession No. ML21012A363). The staff will present the revised preliminary proposed rule language to the ACRS subcommittee in the summer of 2022.
- 3. The concept of non-licensed, certified operators should not be pursued. Staff should focus on adapting the existing approach to the NRC operator licensing process to produce training, qualification, and licensing requirements based on the degree of safety reliance attributed to operator actions for the specific plant design. This should take advantage of inherent and passive safety features of the nuclear power plant.
Staff Response: In the development of a risk-informed, performance-based, and technology-inclusive regulatory framework, the staff is considering improvements in nuclear power technology and relying on expert engineering and scientific judgment to determine the requirements applicable to operators of new reactors. As such, the staff continues to evaluate a range of options and criteria to determine appropriate operator qualification, training, and licensing. Of note, on March 1 - 2, 2022, the staff hosted a workshop on the exchange of licensing and certification testing practices to gather information on certification and licensing processes for personnel in other fields that require safety significant responsibilities, such as pilots, air traffic controllers and rail transportation personnel.
The proposal to provide options for scaling the requirements for operators and facility personnel to the scope of job tasks anticipated in new technologies within the preliminary Part 53 framework is not final, and the staff continues with the process of developing rule language. The staff plans to present its proposed resolution for this comment to the ACRS subcommittee in the summer of 2022.
- 4. Staff should develop guidance for judging the acceptability of limited scope simulators.
Staff Response: The staff agrees with the ACRS recommendation.
The staff appreciates the ACRS review and looks forward to future interactions with the Committee.
Sincerely,
/RA/
Robert M. Taylor Deputy Office Director for New Reactors Office of Nuclear Reactor Regulation cc: Chairman Hanson Commissioner Baran Commissioner Wright SECY
- via e-mail NRR-106 OFFICE NRR/REFS/RRPB: PM*
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NAME RBeall JDougherty GLappert LNist DATE 03/07/2022 03/07/2022 03/07/2022 03/16/2022 OFFICE NRR/REFS/RRPB: BC* NRR/DANU/IOLB: BC*
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NAME IBerrios SLynch JTappert CMiller DATE 03/17/2022 03/17/2022 03/17/2022 03/17/2022 OFFICE NRR/DANU: DD*
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NAME MShams MSpencer RTaylor DATE 03/17/2022 03/17/2022 03/30/2022