ML22074A190

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March 16, 2022 Title Slides Advanced Reactor Stakeholder Public Meeting
ML22074A190
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Issue date: 03/15/2022
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Advanced Reactor Stakeholder Public Meeting March 16, 2022 Microsoft Teams Meeting Bridgeline: 301-576-2978 Conference ID: 556 455 490#

Slide 1

Time Agenda Speaker 10:00 - 10:20 am Opening Remarks / Adv. Rx Integrated Schedule / Source Term Public Website NRC 10:20 - 10:45 am Update on NRC TRISO Project Involving a CNSC-NRC Joint Interim Report (Tim Drzewiecki and Kelly Conlon)

NRC/CNSC 10:45 - 11:30 am Trial Use Reg Guide (TRG) 1.247, Acceptability of PRA results for non-LWR Risk Informed Activities (Donna Williams)

NRC 11:30 - 11:50 am Advanced Reactor Content of Application Project (ARCAP) and Technology Inclusive Content of Application Project (TICAP) Guidance Development Status (Joseph Sebrosky)

NRC 11:50 am - 12:50 pm Lunch Break All 12:50 - 1:20 pm Part 53: Traditional, Risk-Informed Option (Bill Jessup)

NRC 1:20 - 2:00 pm Part 53: Perspective on PRA, Process, Concerns, and Going Forward (Cyril Draffin)

USNIC 2:00 - 3:00 pm Development of Guidance for Evaluating Changes to Facilities Utilizing NEI 18-04 (Mike Tschiltz)

Southern Co.

3:00 - 3:05 pm Future Meeting Planning and Concluding Remarks NRC Slide 2

Advanced Reactor Integrated Schedule of Activities The updated Advanced Reactor Integrated Schedule is publicly available on NRC Advanced Reactors website at:

https://www.nrc.gov/reactors/new-reactors/advanced/details#advSumISRA Slide 3

Advanced Reactor Integrated Schedule of Activities https://www.nrc.gov/reactors/new-reactors/advanced/details#advSumISRA Slide 4

Advanced Reactor Integrated Schedule of Activities https://www.nrc.gov/reactors/new-reactors/advanced/details#advSumISRA UPDATES:

Strategy 2, Computer Codes and Review Tools:

Reference plant model for Molten-Salt-Cooled Pebble Bed Reactor - Version 1 complete; Version 2 completion in April 2022 Reference plant model for Monolith-type Micro-Reactor - completion Sep. 2022 Reference plant model for Gas-Cooled Pebble Bed Reactor - completion Sep. 2022 Reference SCALE/MELCOR plant model for Molten Salt Fueled Reactor - Marked complete MACCS radionuclide screening analysis - Marked complete Code Assessment Report Volume 4 (Licensing and Siting Dose Assessments) - Two new items - Phase 2 (Effluent Code Consolidation) current target completion April 2023 and Phase 3 (Habitability Code Consolidation) current target completion FY24 Strategy 3, Guidance:

Develop Advanced Reactor Content of Application Project (ARCAP) Regulatory Guidance - Added Federal Register Publication in April, public comment period and a public meeting in May 2022, concurrence in July, ACRS SC/FC in August and September 2022, concurrence in October and November 2022, and final issuance in December 2022.

Slide 5

Advanced Reactor Integrated Schedule of Activities https://www.nrc.gov/reactors/new-reactors/advanced/details#advSumISRA UPDATES (contd.):

Strategy 3, Guidance (contd.):

Develop Advanced Reactor Inspection and Oversight Framework Document - Final Draft of framework document submitted to NRC in March 2022 Develop MC&A guidance for Cat II facilities (NUREG-2159) - Issue final by March 2022 Final MSR Fuel Qualification guidance - Currently with staff for review Strategy 4, Consensus Codes and Standards:

Develop Regulatory Guide for endorsement of the non-LWR Probabilistic Risk Assessment Standard-TRG and FRN to be issued by March 31, 2022 Strategy 5, Policy and Key Technical Issues:

Annual Fees for Non-Light Water Reactors and Microreactors - Added concurrence period from June to August 2022 and Commission review period from September to November 2022 Slide 6

Nuclear Power Reactor Source Term Public Web Page The web page contains discussion and listing of documents that could be relevant to the development of non-LWR accident source terms for licensing The web page is a dedicated location for reasonably finding information useful in the development of a power reactor source term Applicants are solely responsible for providing to the NRC for approval, their specific reactor design source term associated with the analysis and evaluation of the performance of structures, systems, and components of the facility with the objective of assessing the risk to public health and safety resulting from operation of the proposed nuclear power reactor facility The Power Reactor Source Term Web Page IS IS NOT A tool that provides information from a collection of source term relevant documents The web page discussion text itself IS NOT Regulatory Guidance Slide 7

Nuclear Power Reactor Source Term Public Web Page Public access to the web page is available through the Advanced Reactors (non-LWR Designs) web page at: Related Documents, Related Information or Nuclear Power Reactor Source Term

  • The NRC staff is open to stakeholder feedback and will maintain the web page updated as needed Examples of the web page listed information includes the following:

Regulatory Guides NUREGs SRM and SECY Papers National Labs and Other Reports Technical Presentations NRC Workshops and Videos Topics on the web page:

  • History and evolution of Light Water Reactor (LWR) source term
  • NRC analytical tools and past studies
  • SMRs and non-LWRs
  • Accident consequence related regulation activities
  • Guidance and information for developing advanced reactor source term Slide 8

First Interim Report Advanced Reactor Stakeholders Meeting Kelly Conlon, Canadian Nuclear Safety Commission (CNSC)

Tim Drzewiecki, U.S. Nuclear Regulatory Commission (NRC)

Slide 9

Memorandum of Cooperation (MOC)

  • Generic Tristructural Isotropic (TRISO) qualification assessment is supportive of NRC/CNSC MOC (ML19275D578), Item 2 Area of Cooperation TRISO Assessment Development of shared advanced reactor and SMR [small modular reactor] technical review approaches that facilitate resolution of common technical questions to facilitate regulatory reviews that address each Participants national regulations Exercise the fuel qualification framework developed in Nuclear Energy Agency (NEA) report, Regulatory Perspectives on Nuclear Fuel Qualification for Advanced Reactors, (ML22018A099) and NUREG-2246, Fuel Qualification for Advanced Reactors (ML22063A131)

Collaboration on pre-application activities to ensure mutual preparedness to efficiently review advanced reactor and SMR designs Several proposed advanced reactor designs use TRISO fuel and reference the testing performed as part of the Advanced Reactor Fuel (AGR) program as documented in topical report EPRI-AR-1(NP)-A Collaboration on research, training, and in the development of regulatory approaches to address unique and novel technical considerations for ensuring the safety of advanced reactors and SMRs Final report will (1) provide evidentiary basis to support regulatory findings for items that are generically applicable to TRISO, (2) identify items that are design dependent, and (3) highlight areas where additional information and/or testing is needed Slide 10

Assessment Team and Schedule Task A, Project Planning Timeline: Fourth Quarter 2021 End Product: Initial project plan finalized with resources in place (PNNL contract awarded)

Task B, Draft Fuel TRISO Fuel Assessment Report Timeline: Fourth Quarter 2021 through Fourth Quarter 2022 End Product: Four interim draft reports. The final draft will be a comprehensive draft report addressing the goals within the fuel qualification framework from NEA report, Regulatory Perspectives on Nuclear Fuel Qualification for Advanced Reactors, and NUREG-2246.

Task C, Finalize Report Timeline: Fourth Quarter 2022 to Second Quarter 2023 End Product: The final report will be a joint NRC/CNSC report providing a generic assessment of TRISO fuel

  • Joint report from CNSC and US NRC
  • UK regulator, Office for Nuclear Regulation (ONR) involved as an observer
  • Technical support provided by Pacific Northwest National Laboratory (PNNL)
  • Work plan:

Input Framework ML22018A099 ML22063A131 ML21175A152 TECDOC-1645 ML20336A052 Interim Report ML22030A000 Slide 12

Assessment Framework

  • For illustrative purposes only. See Fig A-1 of NUREG-2246 for legible figure.

Slide 13

Focus of First Interim Report Slide 14

Focus of First Interim Report Slide 15

Contents

  • Technologies considered (partially addresses G2.1.1, Fuel performance envelope is defined)
  • Regulatory basis in the US and Canada
  • Degradation mechanisms and failure modes for TRISO (partially addresses EM G1.3, Evaluation model is capable of modelling the physics relevant to fuel performance

Technologies Considered

  • Other parameters being considered (e.g., power density)
  • Performance envelope is specific to UCO-TRISO
  • Currently reviewing manufacturing parameters:
  • Table 5-5 of EPRI-AR-1
  • Fuel kernel composition (e.g., carbon-to-oxygen ratio)
  • Fuel kernel size and porosity
  • Fuel compact packing fraction (overcoating thickness)

Coolant Structural Form Time Averaged Volume-Averaged Temperature*

Peak Burnup*

Peak Fast Fluence*

Helium Air or dry-nitrogen FLiBe (molten salt)

Pebble Bed Prismatic 955 - 1296 19.6 percent fissions per initial metal atom (FIMA) 4.3 x 1025n/m (E > 0.18 MeV)

Slide 17

Degradation Mechanisms and Failure Modes

  • Partially addressed EM G1.3, Evaluation model is capable of modeling the physics relevant to fuel performance
  • Identified through past experience, legacy data, and expert panels (PIRTs)
  • Some degradation mechanisms and failure modes have been addressed by the development of UCO-TRISO (i.e., can be addressed through controlled manufacturing) or have not been observed in testing
  • 10 failure mode identified:

Pressure vessel failure of standard (intact) particles Pressure vessel failure of particles with defective or missing coatings Irradiation induced IPyC cracking failure SiC thermal decomposition failure Debonding between IPyC and SiC layers failure Kernel migration failure Fission product attack failure Non-retentive SiC failure Creep failure of PyC Kernel-coating mechanical interaction failure Slide 18

Transient Conditions

  • The specification of a performance envelope, G2.1.1, includes the identification of representative transient conditions
  • Rapid reactivity insertions, sufficient to make the reactor prompt-critical, may not be considered credible for designs that use UCO-TRISO.

Vrain (ML100820279)

  • Technology Inclusive and Risk-Informed Reviews for Advanced Reactors (ML21225A101)
  • Previous studies, using fresh UO2 kernels, were investigated Slide 19

Reactivity Initiated Accident (RIA) Testing Reactor Kernel Type Energy Deposition Pulse Width Fuel Failure Nuclear Safety Research Reactor (NSRR - Japan)

(Fukeda)

UO2 Compact and loose particles 500-2,300 J/g-UO2 5 ms

> 1,400 J/g NSRR (Umeda)

UO2 Loose particles 500-1,700 J/g-UO2 5 ms

> 1,400 J/g HYDRA (Russia)

UO2 Compact and loose particles 100-1,700 J/g-UO2 1-2 ms

> 1,300 J/g Impulse Graphite Reactor (IGR - Kazakstan)

UO2 Pebble

> 10,000 J/g-UO2 700-30,000 ms Matrix failure Slide 20

RIA Testing

  • Particle failure correlates well with kernel melting
  • Open questions:
  • How much lower is UCO melting (do we expect a lower failure threshold because of melting)?
  • Is data applicable to UCO TRISO?

Failure mechanisms and thresholds likely different for UCO TRISO are higher burnups

  • Is this type of RIA (i.e., millisecond pulse widths) credible?

Slide 21

RIA Testing Slide 22

Questions?

(Questions for CNSC should be directed to mediarelations-relationsmedias@cnsc-ccsn.gc.ca or by phone at 613-996-6860)

Slide 23

Non-LWR PRA Acceptability Trial Regulatory Guide 1.247 March 16, 2022 Slide 24

Agenda

Background

Comments Received Changes to Regulatory Guide Next Steps Slide 25

=

Background===

Preliminary Trial Regulatory Guide (TRG) made public in September 2021 ACRS meetings - Subcommittee September 20, 2021; Full Committee October 5, 2021.

Staff reviewed all exceptions and clarifications Public meeting November 3, 2021 Team revised TRG to address self-assessment findings and comments Slide 26

Comments received ACRS FC meeting October 5, 2021 Letter recd October 26, 2021 (ML21288A018). Staff response to recommendations (ML21316A000)

Public meeting November 3, 2021 JCNRM, NEI presentations (comments also submitted formally)

Comments received via letters and emails Process - no formal comment period required prior to publication of a trial RG. Comment resolution will not be included with Trial RG 73 specific comments provided Slide 27

Categories of Comments

Requested clarification on the motivation for Regulatory Positions

Regulatory positions regarding PRA scope and the specification of methods or analytical approaches would be better placed within application-specific guidance.

The NRC noted several areas where the NLWR standard could be improved. Such changes should be submitted to the JCNRM for further review.

Too much how to

Comments on specific exceptions Slide 28

Addressing Comments Staff considered each comment submitted Some comments addressed in trial RG (or no change made if staff didnt agree)

Some will be deferred to the trial use period Some will be provided to JCNRM in next revision of standard Some deferred to other efforts (i.e. ARCAP)

Slide 29

Staff assessment of RG Reviewed all the exceptions with the aim of achieving a consistent and clear voice for every exception we plan to take.

Many exceptions deleted (including exceptions related to non-mandatory appendices)

Some exceptions rewritten to reflect that exceptions are anchored in a regulatory concern or are in terms of something that the NRC would need for a decision making.

Slide 30

Changes from draft version 86 exceptions deleted (146 in pre-decisional draft and 60 in Trial RG 1.247)

Significantly fewer number of overall exceptions then in RG 1.200 for the Level 1/LERF LWR PRA standard Editorial changes as result of technical edit review Changes to address stakeholder and ACRS comments Changes resulting from self assessment Slide 31

Next Steps Trial RG to be issued by March 31, 2022 Federal Register notice will include a 60-day comment period Submit comments at http://www.regulations.gov Staff to address public comments June 2022 Public comment period will be followed by a 2-year trial use period. At any time during the trial use period, a member of the public may submit suggestions to the NRC Suggestions will be considered in future updates Slide 32

Status of Advanced Reactor Content of Application Project (ARCAP) and Technology Inclusive Content of Application Project (TICAP) Guidance Documents March 16, 2022 Slide 33

ARCAP/TICAP Status

Purpose:

To provide current status of ARCAP and TICAP guidance documents and to inform stakeholders of planned next steps in the process Key messages:

o On March 1, 2022, NEI submitted NEI 21-07, Revision 1, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Utilizing NEI 18-04 Methodology, ADAMS Accession No. ML22060A190 o

Draft White Paper ARCAP and TICAP guidance documents as well as NEI 21-07 Revision 1 are available on NRC ARCAP/TICAP public webpage (see:

https://www.nrc.gov/reactors/new-reactors/advanced/details.html#advRxContentAppProj) o Staff is in the process of developing draft ARCAP and TICAP guidance documents for formal public comment

Target date for Federal Register Notification for these documents is late April early May 2022 o

As noted on the ARCAP/TICAP public webpage robust public stakeholder interactions have been held for over 2 years to aid in the development of ARCAP and TICAP guidance.

Slide 34

ARCAP and Technology Inclusive Content of Application Project (TICAP) - Nexus Outline Safety Analysis Report (SAR) -

Based on TICAP Guidance

1. General Plant Information, Site Description, and Overview of the Safety Case
2. Methodologies and Analyses
3. Licensing Basis Event (LBE) Analysis
4. Integrated Evaluations
5. Safety Functions, Design Criteria, and SSC Safety Classification
6. Safety Related SSC Criteria and Capabilities
7. Non-safety related with special treatment SSC Criteria and Capabilities
8. Plant Programs Additional Portions of Application
  • Technical Specifications
  • Technical Requirements Manual
  • Quality Assurance Plan (design)
  • Quality Assurance Plan (construction and operations)
  • Physical Security Plan
  • SNM material control and accounting plan
  • Radiation Protection Program
  • Inservice inspection/Inservice testing (ISI/IST) Program
  • Environmental Report
  • Site Redress Plan
  • Exemptions, Departures, and Variances
  • Facility Safety Program (under consideration for Part 53 applications)

Audit/inspection of Applicant Records Calculations Analyses P&IDs System Descriptions Design Drawings Design Specs Procurement Specs Probabilistic Risk Assessment Safety Analysis Report (SAR) structure based on clean sheet approach Additional SAR Content -Outside the Scope of TICAP

9. Control of Routine Plant Radioactive Effluents, Plant Contamination, and Solid Waste
10. Control of Occupational Doses
11. Organization and Human-System Considerations
12. Post-construction Inspection, Testing and Analysis Programs
  • Additional contents of application outside of SAR are still under discussion. The above list is draft and for illustration purposes only.

Slide 35

ARCAP/TICAP

Background

  • Status of ARCAP Interim Staff Guidance Draft White Papers ARCAP ISG Title Date Accession No.

Review of Risk-Informed, Technology-Inclusive Advanced Reactor Applications - Roadmap Dec 2, 2021 ML21336A702 Chapter 2, Site Information July 6, 2021 ML21189A031 Chapter 9, Control of Routine Plant Radioactive Effluents, Plant Contamination and Solid Waste July 6, 2021 ML21189A033 Chapter 10, Control of Occupational Doses July 6, 2021 ML21189A035 Chapter 11, Organization and Human-System Consideration Nov 5, 2021 ML21309A020 Chapter 12, Post Construction Inspection, Testing and Analysis Program Oct 21, 2021 ML21294A266 Licensing Modernization Project-based Approach for Developing Technical Specifications May 10, 2021 ML21133A490 Risk-Informed, Performance-Based Fire Protection Program (for Operations)

Sept 10, 2021 ML21253A134 Risk-Informed ISI/IST Programs Aug 4, 2021 ML21216A051 Slide 36

ARCAP/TICAP

Background

  • Status of TICAP Guidance Documents TICAP Title Date Accession No.

NEI 21-07, Revision 1, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Utilizing NEI 18-04 Methodology March 1, 2022 ML22060A190 Regulatory Guide Draft White Paper, Guidance for a Technology-Inclusive Content of Application Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Advanced Reactors Dec 2, 2021 ML21336A697 NEI 21-07, Revision 0, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Utilizing NEI 18-04 Methodology August 30, 2021 ML21250A378 Slide 37

ARCAP Status Staff in the process of addressing internal comments on the nine ARCAP interim staff guidance (ISG) documents Current plan is to provide separate Federal Register Notifications (FRNs) to solicit public comment on these documents o

Allows for easier binning and addressing of comments received in response to the FRN.

The staff intends to issue the nine ARCAP ISG FRNs and the TICAP Draft Regulatory Guide FRN on the same day o

Targeting late April early May for issuance of FRNs 45-day comment period o

Staff intends to hold a public meeting during the public comment period to provide an overview of the documents and to address stakeholder questions before the public comment period closes.

Slide 38

TICAP Status Staff is updating the TICAP Draft Regulatory Guide to reference NEI 21-07, Revision 1 and to address internal comments on the draft document.

Staff considering the following changes:

o Appendix A regarding construction permit guidance will be kept

Appendix will be updated to address issues highlighted in the December version of the TICAP draft regulatory guide white paper.

Staff addressing previous comments (as appropriate) received by industry in April and December of 2021 related to TICAP construction permit guidance

Guidance related to the source term to be used for evaluating radiological consequences for non-LWRs will likely be updated and moved to the main body of the guidance document Guidance involves the scope of events to be considered in developing the source term to be used to meet the requirements found in 10 CFR 50.34(a)(1)(ii)(D) or 10 CFR 52.79(a)(1)(vi) for designs following an LMP-based approach Traditionally, the source terms used in evaluating radiological consequences for LWRs have been representative of the source terms that result from a "major accident.

Slide 39

TICAP Status (continued)

Changes (continued):

o Appendix B of the draft white paper TICAP guidance (proposed exceptions, clarification, and additions) to be removed The final set of exceptions, clarifications and additions (based on NEI 21-07, revision 1) will be incorporated into applicable chapter guidance in the main body of the TICAP draft regulatory guide As noted in a previous slide, staff plans to issue a FRN requesting public comment on the TICAP draft regulatory guide in the late April early May time frame concurrent with the FRNs for the nine ARCAP interim staff guidance documents Slide 40

Next Steps - Milestones ARCAP/TICAP Near-Term Milestones Target Date Issue Federal Register Notice Seeking public comment on 9 ARCAP ISGs and TICAP Draft Regulatory Guide Late April May 2022 Public Meeting to Facilitate Stakeholder Comment Development May/June 2022 Advisory Committee on Reactor Safeguards (ACRS) Future Plant Designs Subcommittee Meeting Fall 2022 ACRS Full Committee Meeting Fall 2022 Issuance of Final TICAP RG and Final ARCAP interim staff guidance documents Late Calendar year 2022 Slide 41

Break Meeting will resume at 12:50 pm EST Microsoft Teams Meeting Bridgeline: 301-576-2978 Conference ID: 556 455 490#

Advanced Reactor Stakeholder Public Meeting Slide 42

A Traditional, Technology-Inclusive, and Risk-Informed Framework Option in Part 53 Slide 43

  • Part 53 stakeholder feedback included requests to consider international approaches and flexibility in the use of PRA
  • Previously released preliminary proposed rule text (Part 5X) outlined technology-inclusive, risk-informed alternatives for using the traditional technical requirements in Parts 50 and 52
  • Inclusion of a traditional, technology-inclusive, and risk-informed regulatory framework in Part 53 minimizes potential impact on existing requirements and centralizes alternatives for new commercial reactors
  • Dedicated staff to develop the traditional licensing framework are integrated with existing Part 53 team
  • Aligned with the established Part 53 rulemaking schedule

Background

Slide 44

  • Subpart B - Safety Requirements
  • Subpart C - Design Requirements
  • Subpart D - Siting
  • Subpart E - Construction
  • Subpart F - Operations
  • Subpart G - Decommissioning
  • Subpart H - Licensing Processes
  • Subpart I - License Maintenance
  • Subpart J - Reporting
  • Subpart K - Quality Assurance Part 53 Licensing Framework Subpart A - General Provisions Part 53 Slide 45
  • Subpart B - Safety Requirements
  • Subpart C - Design Requirements
  • Subpart D - Siting
  • Subpart E - Construction
  • Subpart F - Operations
  • Subpart G - Decommissioning
  • Subpart H - Licensing Processes
  • Subpart I - License Maintenance
  • Subpart J - Reporting
  • Subpart K - Quality Assurance Part 53 Licensing Frameworks
  • Subpart B1 - Purpose/Definitions
  • Subpart B2 - Siting
  • Subpart B3 - Construction
  • Subpart B4 - Operations
  • Subpart B5 - Decommissioning
  • Subpart B6 - Licensing Processes
  • Subpart B7 - License Maintenance
  • Subpart B8 - Reporting
  • Subpart B9 - Quality Assurance Alternate Evaluation for Risk Insights Framework B Framework A Subpart A - General Provisions 10 CFR 53.015 - Subparts Part 53 Slide 46

Slide 47

Comprehensive search for initiators Applicant elects enhanced use of PRA Comprehensive definition of event sequences Select licensing events Perform consequence analyses Identify the bounding event Alternative Evaluation for Risk Insights

1. Develop demonstrably conservative risk estimate
2. Develop risk insights
3. Search for severe accident vulnerabilities Conservative risk estimate

> QHOs?

Select licensing events Compare to QHOs A

K M

N S

N Y

Applicant elects traditional use of PRA Select LBEs Select DBAs Classify SSCs Compare to QHOs O

P Q

R ENHANCED USE OF PRA TRADITIONAL USE OF PRA ALTERNATIVE TO PRA C

D E

F H

I N

Y Y

N Develop PRA Comprehensive search for initiators Comprehensive definition of event sequences START Develop PRA Comprehensive search for initiators Comprehensive definition of event sequences CONTINUE LICENSING B

J PRA in complementary/supporting role CONTINUE LICENSING CONTINUE LICENSING Use of PRA in Part 53 Framework B Framework A Slide 48

Working to integrate an alternative to PRA for gaining risk insights in Framework B Cannot presume there is a PRA

  • Examples: Risk-informed inservice inspection, etc.
  • Possible resolutions: Use alternative approach to achieve the same level of safety Preliminary Proposed Rule Text Development Guidance #1: Technology-inclusive identification of licensing events (yellow boxes)
  • Search for initiators and delineate event sequences without preconceptions or predefined lists (i.e.,

start with a blank sheet of paper) - Boxes B, J, M, and N

  • Group initiators and event sequences into a set of licensing events - Boxes I, O, P, and Q Guidance #2: Implementing the alternative to PRA (gray boxes)
  • Entry conditions - Box H
  • Alternative Evaluation for Risk Insights - Box R
  • Off-ramp - Box S Supporting Guidance Development Alternative to PRA for Gaining Risk Insights Slide 49

Quantitative Risk Information Bounding Approaches Traditional Use of PRA Risk-Informed Continuum Slide 50

Next Steps Align with established Part 53 rulemaking schedule for publication of proposed rule Release preliminary proposed rule language (tentative May 2022)

Part 53 public meeting presentation (tentative late May)

Discuss with Advisory Committee on Reactor Safeguards Subcommittee: June 21-22, 2022 Full Committee: July 6-9, 2022 Slide 51

Additional Information Additional information on the 10 CFR Part 53 rulemaking is available at https://www.nrc.gov/reactors/new-reactors/advanced/rulemaking-and-guidance/part-53.html For information on how to submit comments go to https://www.regulations.gov and search for Docket ID NRC-2019-0062 For further information, contact Robert Beall, Office of Nuclear Material Safety and Safeguards, telephone: 301-415-3874; email:

Robert.Beall@nrc.gov Slide 52

Part 53:

Perspective on PRA, Process, Concerns, and Going Forward Cyril Draffin, Senior Fellow, Advanced Nuclear, U.S. Nuclear Industry Council NRC Advanced Reactor Stakeholder Meeting 16 March 2022 Slide 53

Roles of Probabilistic Risk Assessment (PRA) in Risk-Informed Approach

  • We support enhanced use of PRA and NRCs efforts to incorporate alternative approaches
  • Allowing traditional, risk-informed framework in rule and providing guidance in a graded approach is appropriate
  • Fully developed Level 3 PRA at beginning of licensing process not possible for Construction Permit, may be too burdensome for Operating License / Combined License, and well beyond requirements for Part 50/52
  • Part 53 must allow for appropriate use of PRA as important tool (for insight)
  • Appropriate for rule to allow risk-informed spectrum of enhanced PRA and traditional - with specific guidance for alternative approaches/frameworks (2021 industry suggestion)
  • Part 53 should not have multiple separate complex parallel frameworks in rule language (e.g. (a) Enhanced use of PRA for licensing (similar to TICAP), (b) Traditional use of PRA (similar to approaches previously licensed under Part 52), and (c) MCA approach or alternative PRA approach) (this was not requested by industry)

Slide 54

Process Seeking Stakeholder Comments

  • USNIC supports the development of performance-based risk-informed rule that is useful and efficient
  • USNIC appreciates the work being undertaken by NRC on Part 53
  • USNIC concerned with very limited transparency regarding NRCs reaction to alternatives suggested by industry and other stakeholders
  • NRC staff listens but provides very limited responses
  • Part 53 comment review process could be improved by:
  • Seeking more two way interactive dialog
  • Employing similar workshop approach used for developing Regulatory Guide 1.206 (Applications for Nuclear Power Plants) that was more interactive and more productive than current Part 53 process
  • Providing a clearer roadmap of what NRC is attempting to accomplish in the rule
  • An overarching framework has not been provided
  • Providing a list of industry-raised issues/concerns (besides PRA) under consideration by NRC staff, and a schedule when they will be addressed Slide 55

Process of Preparing Language Matching NEIMA Intent

  • USNIC concerned that, so far, Commission staff appear to be creating Part 53 in contradiction to NEIMA and Congressional intent-- by adding regulatory burden, making process less efficient, and not streamlining deployment of these technologies
  • Would be helpful to know how NRC staff plans to use 9-month extension to bridge gaps/inconsistencies between staffs current position and NEIMA Slide 56

Ongoing Concerns

  • ALARA - Our members recognize ALARA (as low as reasonably achievable) is a good practice, but Part 20 should be referenced, rather than putting new provisions in rule that affect design
  • QHOs - Not clear how Quantitative Health Objectives will be met in the rule
  • Currently, there is no guidance on how to implement QHOs and we believe, as proposed by the staff, this is unnecessary expansion of regulatory requirements
  • Subpart F - Some programs (e.g. Facility Safety program (53.890) and Integrity Assessment Program (53.850)) are redundant, new, and probably unnecessary
  • Defense in Depth
  • We appreciate DID is an important design philosophy. We suggest that the rule allow sufficient flexibility for applicants to demonstrate how DID is provided (e.g. allow use of programmatic controls as an alternative to additional equipment).

Other specific concerns regarding preliminary language provided in 5 Nov. 2021 112-page document Slide 57

More Recent Concerns (increased Regulatory Burden & not risk-informed)

(From February 2022 NRC Part 53 Consolidated text)

Safety Criteria for LBEs other than DBAs (53.220)

  • Wording has changed from the Safety Goals, which focused on deaths (not health effects), to much broader term of "health effects" Functional Design Criteria for Occupational Dose ALARA (53.430)
  • Significant expansion of current operational ALARA requirements into design space Special Treatments and QA (53.460)
  • Seems to say no graded QA for safety-related SSCs. This is highly undesirable, and seems to be change from what is permitted by NEI 18-04 Earthquake Engineering (53.480)
  • Seems all non-safety-related but safety significant (NSRSS) SSCs must be seismic. Not sure why staff singled out earthquakes for more rigorous treatment that goes beyond NEI 18-04 Fire Protection Requirements (53.440)

Deterministic approach, not risk-informed Slide 58

Going Forward

  • Staff should seek early resolution from Commission of policy issues
  • Staff could offer alternative text for key issues (ALARA, PRA, QHO, DID, programs, etc.)

for Commission/stakeholder review in Q2

  • Staff could provide proposed rule framework that encapsulates alternative positions provided by industry besides the staff recommendation
  • Higher level standards and simplicity could benefit the process. Need reasonable balance between predictability and flexibility-guidance helps.
  • Rule should enable deployment of advanced technologies and not impose burdens currently beyond Part 50 and 52
  • NRC should demonstrate why new requirements are required
  • NRC staff should not use this rulemaking to incorporate requirements in Part 53 that were previously part of guidance documents
  • Change future public meetings from one-way NRC listening sessions to open two-way dialog leading to resolution of topical issues (multiple topics including Role of PRA in risk-informed approach; in April and May)

Slide 59

Possible Next Steps NRC Could Consider Taking

  • Consider process improvements in dealing with stakeholders
  • Increase transparency regarding NRCs reaction to alternatives suggested by industry and other stakeholders
  • Increase two-way dialog through workshop approach for addressing key Part 53 issues
  • Provide NRC reaction to stakeholder Part 53 comments at next Stakeholders meeting
  • Continue evolving Part 53 language
  • High level language regarding PRA in rule, with detailed guidance for different approaches/frameworks
  • Provide response to stakeholder comments regarding following concerns:
  • Subpart F
  • Defense in Depth
  • Reconsider language based on 5 November 2021 detailed industry comments, and Most Recent Concerns slide Slide 60

Appendix: Example USNIC Input on Part 53

  • Suggested update to Part 53 Subpart B preliminary language

Comments on stakeholder engagement, USNIC Part 53 survey results, lack of roadmap and clarity on safety expectations, rule development, ALARA, QHOs, Quality Assurance, Subpart F, Decommissioning, Defense in Depth, Two Tiers, Reasonable Assurance of Adequate Protection

  • With three detailed attachments (112 pages)

Comments on QHO, PRA, ALARA, safety standards/AEA, BDBE in design basis, redundant programs, regulatory efficiency NEI/USNIC Part 53 slides 681-754; transcript of NEI/USNIC Part 53 remarks start at 400 Slide 61

1 March 16, 2022 Mike Tschiltz Consultant to Southern Company Evaluation of Changes to Facilities Utilizing NEI 18-04 Methodology NRC Advanced Reactor Stakeholder Meeting Slide 62

Develop guidance for evaluating changes to the facility for ANLWRs The objectives of this guidance are to:

Provide regulatory confidence that the basis for the LMP-based safety case will be effectively monitored and any changes will be efficiently managed Minimize the unnecessary burden to the regulator and owners/operators for determining if changes require a license amendment Establish a clear understanding of how the 50.59 criteria for making facility changes without prior NRC approval may be met Applicable to ANLWR designs that utilize NEI 18-04 and 10 CFR Part 50 or 52 Builds upon the work accomplished by LMP (NEI 18-04) and TICAP (NEI 21-07)

Project Description Slide 63

Project Description (cont)

  • Southern led team with support from Dept of Energy and the Idaho National Laboratory (DOE/INL) (cost share)

Team members: Southern Company employees, NEI, advanced reactor designers, INL and consultants

  • Schedule:

Guidance is expected to be needed by ARDP applicants within next three years Draft guidance to be developed as a Southern document by late summer Convert to NEI guidance and submit to NRC for formal review and endorsement (September 22)

Support NRC review and endorsement (FY 2023)

  • Details on following slides Slide 64

NRC COMMENTS/FEEDBACK

  • Does this approach present any significant challenges from NRC perspective?
  • Does NRC anticipate challenges with the evaluation of facility changes under 50.59 using risk-informed criteria?

Slide 65

Project Plan

  • Preliminary High Level Schedule (NRC interactions highlighted)

Identify Key Issues associated with developing guidance for a change evaluation process for designs licensed utilizing NEI 18-04 safety case (status: complete)

Develop papers that address key issues associated with the scope of the changes to be addressed in the guidance and the screening and evaluation of changes (status: internal comment resolution ongoing)

Develop a white paper that describes the proposed applicability determination and change evaluation process. (NRC meetings to discuss progress targets: 3rd week in April, 3rd week May)

NRC Review of white paper that describes the proposed applicability determination and change evaluation process (proposed NRC review 5/5-5/19)

Develop tabletop exercise objectives and guidelines and identify advanced reactor tabletop participants. NRC review and comment (NRC Meeting target: 3rd week in April)

NRC Review of white paper that describes the proposed applicability determination and change evaluation process and evaluation guidance (NRC observation, June)

Slide 66

Project Plan(cont)

  • Preliminary High Level Schedule (NRC interactions highlighted)

Conduct two ANLWR design tabletop exercises that apply different parts of the screening (NRC Observation: June 7-20)

Develop annotated outline for the guidance document. NRC review and comment.

(NRC Meeting target: 2nd week in June)

Develop Guidance Document based on topics included in the Annotated Outline (July -

August) (NRC Meeting targets: mid-July and mid-August)

Tabletop Lessons Learned (NRC Meeting target: July)

NRC review of draft guidance (Southern Company document) (mid-August)

Convert to NEI guidance and submit for formal NRC review and endorsement (end of Sept)

NRC formal review and endorsement in FY23 Slide 67

Questions

  • Questions ?

Slide 68

Future Meeting Planning

  • The next periodic stakeholder meeting is scheduled for May 11, 2022.
  • If you have suggested topics, please reach out to Steve Lynch at Steven.Lynch@nrc.gov Slide 69
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