Text

Adv_Rx_Stakeholders_Meeting_Presentation_6-30-22
	ML22180A095
Person / Time
Issue date:	06/30/2022
From:	; Office of Nuclear Reactor Regulation
To:	;
References
	10 CFR Part 53, NRC-2019-0062, RIN 3150-AK31
	Download: ML22180A095 (74)
	v • d • e

Advanced Reactor Stakeholder Public Meeting June 30, 2022 Microsoft Teams Meeting Bridgeline: 301-576-2978 Conference ID: 625 515 774#

1

Time Agenda Speaker 10:00 - 10:15 am Opening Remarks/ Adv. Rx Integrated Schedule NRC (Shelley Pitter - Logistics, Steve Lynch) 10:15 - 10:30 am Expanding and Internationalizing the EPRI Advanced Reactor Owner- EPRI Operator Requirements Guide (ORG) (Marc Albert) 10:30 - 12:00 pm Part 53 Rulemaking Process Part 53 - Stakeholder Perspectives on Framework B, Framework A, Stakeholders and NRC Stakeholder Engagement Process (Steve Lynch)

(Cyril Draffin, USNIC/Marc Nichol, NEI) 12:00 - 1:00 pm Lunch Break All 1:00 - 1:45 pm Part 53 - Stakeholder Perspectives on Framework B, Framework A, Stakeholders and NRC Stakeholder Engagement Process (Rani Franovich, BTI/ Steve Nesbit, ANS) 1:45 - 2:30 pm Regulatory Priorities for New and Advanced Reactors (Kati Augsten) NEI 2:30 - 2:40 pm Break All 2:40 - 4:35 pm Part 53 Subpart F Staffing Requirements (Jesse Seymour) NRC 4:35 - 4:55 pm U.S.-NRC-CNSC Memorandum of Cooperation: Joint Report, TRISO Fuel NRC Qualification Assessment (Jeffrey Schmidt) 4:55 - 5:00 pm Future Meeting Planning and Concluding Remarks NRC 2

https://www.nrc.gov/reactors/new-reactors/advanced/integrated-review-schedule.html 3

Expanding and Internationalizing the EPRI Advanced Reactor Owner-Operator Requirements Guide (ORG)

(Marc Albert) 4

Internationalization of the EPRI Advanced Reactor Owner-Operator Requirements Guide An Opportunity for Harmonization and Collaboration Andrew Sowder, Ph.D., CHP Advanced Nuclear Technology Program Jeremy Shook, PmP Advanced Nuclear Technology Program Marc Albert, PE Advanced Nuclear Technology Program June 30, 2022 www.epri.com © 2022 Electric Power Research Institute, Inc. All rights reserved. 5

Current Status of EPRI Owner-Operator Requirements Guidance

EPRI Utility Requirements Document (URD)

Key element of EPRI-led Advanced Light Water Reactor (ALWR) program to revive prospects for new nuclear deployment for

- Capturing 1000s of reactor-years of experience

- Realizing significant safety improvements

- Stabilizing regulatory basis

- Regulatory optimization

- Promote standardization

- Reduce capital and O&M costs

- Restore investor confidence

Last update (Rev. 13) in 2014*

Incorporates requirements for small modular LWRs (smLWRs) and Fukushima lessons learned

Advanced Nuclear Technology: Advanced Light Water Reactor Utility Requirements Document, Revision 13. EPRI, Palo Alto, CA: December 2014. 3002003129.

https://www.epri.com/research/products/000000003002003129 7

EPRI Advanced Reactor Owner-Operator Requirements Guide What does the customer want? What will the future energy market need?

Policies Owner-Operator Requirements Guide & Goals (ORG) for Advanced Reactors PURPOSE: Provide a common framework to align AR design attributes with customer needs:

Flexible and living document

Technology and mission inclusive VALUE: Inform and support commercial development and adoption of ARs for potentially greater impact than the Advanced Light Water Reactor program and Customer -

URD Developer Interface GLOBAL RELEVANCE: Nonprescriptive approach applicable by international stakeholders at all stages of commercial maturity STATUS: Revision 1 published June 2019 (Report 3002015751)

Scoping study for Revision 2 completed May 2022 8

EPRI URD vs. ORG (and planned ORG revision) 1990 (Rev 0) 2014 (Rev 13) 2016 (Scoping) 2023 (Rev 2)

Utility Requirements Document (URD) Owner-Operator Requirements Guide (ORG)

Retrospective, proven technology Prospective, new technologies One customer and mission Multiple customers, missions Advanced LWRs (& lwSMRs)

Advanced (non-LWR) Reactors Fukushima Lessons Learned light water small modular expanded coverage of microreactors reactors (lwSMRs) non-electric missions Planned ORG Rev. 2 Expansion in 2023 9

Currently a unique opportunity exists for international coordination and harmonization of end-user requirements for new (advanced) reactors.

A New Hierarchy to Support Harmonization while Preserving IP and Honoring Commercial Relationships Framework and High-Level (Consensus?) Policies and Facilitates publicly coordination and available Mission Requirements harmonization Supports adaptation to Technology-Specific Requirements national, regional, or organizational approaches Vendor/Design-Specific Requirements Protects propriety information and commercial relationships 11

Revisiting EPRIs Requirements Guidance Structure CURRENT EPRI GUIDANCE PROPOSED NEW EPRI FRAMEWORK Policies, Goals, URD ORG New ORG and Mission Requirements All Reactors ALWRs non-LWRs Technology- +

Specific smLWRs ...

smLWR Requirements ALWRs HTGRs s

Design-Specific Requirements Vendor/ Vendor/ ...

Design #1 Design #2 12

Project Development and Execution Paradigm EPRI Guidance Owner-Operator Owner-Operator EPRI Siting Mission Technology Specific Guide Requirements Requirements New Plant Project Development Select Process Planning: Location Define Define Design NEED NEW Define Mission Technology Requirements GENERATIO Requirements Requirements (bid specs.)

N Select Technology EPRI Technology Assessment Guide EPRI Guidance

To g e t h e r S h a p i n g t h e F u t u r e o f E n e r g y Part 53 - Stakeholder Perspectives on Framework B, Framework A, and NRC Stakeholder Engagement Process (Cyril Draffin, USNIC/ Marc Nichol) 15

Part 53 Rulemaking:

General Part 53 Comments (part of joint USNIC/NEI presentation)

NRC Advanced Reactor Stakeholder Meeting 30 June 2022 Cyril W. Draffin, Jr.

Senior Fellow, Advanced Nuclear U.S. Nuclear Industry Council Cyril.Draffin@usnic.org Powered by

Part 53 General Comments - Part 53 Not efficient

Industry unanimous in wanting rule that is useful, efficient & technology inclusive

Concerned that (absent change) Part 53 will result in rule that few applicants wish to utilize-- applicants likely to seek exemptions to Part 50 and 52, which provides more predictable outcome without new requirements

Potential interest in using Part 53 is directly related to whether Part 53 will be more efficient than Parts 50 and 52 in achieving same level of safety 17

Part 53 General Comments - Nuclear Energy Innovation and Modernization Act (NEIMA)

The purpose of this Act is to allow the innovation and commercialization of advanced nuclear reactors (Sec. 2)

Prescriptive language in Part 53 limits a designers' ability to be innovative, because they are locked into certain requirements regardless of variations in design considerations

Based on recent stakeholder input (USNIC/NEI survey) on the rule by those responsible for innovation/commercialization, not clear how the existing rule text supports innovation/commercialization

Staged licensing--For the purpose of predictable, efficient, and timely reviews (Sec. 103. a (1)) and improving the efficiency, timeliness, and cost-effectiveness of licensing reviews of commercial advanced nuclear reactors (Sec. 103. b (4))

Not clear how Part 53 allows more efficient application preparation and review

Concerned that while well intended, current Part 53 framework is contrary to Congressional intent--

by adding regulatory burden, making process less efficient, and not streamlining deployment of these technologies

Commission shall develop .strategies for the increased use of risk-informed, performance- based licensing evaluation techniques and guidance for commercial advanced nuclear reactors (Sec 103 a (2)) and the Commission shall complete a rulemaking to establish a technology-inclusive, regulatory framework for optional use by commercial advanced nuclear reactor applicants for new reactor license applications. (Sec 103 a (4))

Many parts of Framework A and B are overly prescriptive 18

Part 53 General Comments - Lengthy & Complex

397 page Part 53 Framework A + 304 page Framework B = ~700 pages

+ other regulatory documents (e.g. Part 20)

Doubt that Congress, Industry, and the Public will think that more detailed regulations requiring hundreds of pages to present (more than current Part 50 and 52) adds clarity

We have not had enough time to conduct a detailed review the new

>300 page Framework B

Some believe a single consolidated framework that utilizes guidance for details for different approaches would be more appropriate

We question whether long, detailed, prescriptive regulations is the "modernized" approach to regulations that the Commission is seeking?

Guidance documents (likely to be hundreds of pages, including 26 page Alternative Evaluation for Risk Insights (AERI)) will add to complexity 19

Part 53 General Comments - Need RIPB language & clarity Many prescriptive requirements in Framework A & B- many parts of Part 53 not risk-informed and performance-based (RIPB)

Where requirements are identical with Part 50 or 52- just reference them to avoid misalignment and adding unnecessary bulk in Part 53

If QA closely aligned with 10 CFR Part 50 Appendix B, why not reference Part 50 Appendix B and list any necessary changes (and separately for clarity show changes in redline version and explain why changes made)

Part 53 approach and language may not reflect how licensing applications and analyses are done (using PRA as a tool and involving deterministic analysis)

Too much separation in preliminary Part 53 language into different unconnected frameworks (e.g. Framework A, and multiple parts in Framework B) vs. allowing a continuous spectrum of probabilistic and risk-analysis approaches depending on the type of technology Powered by 20

Part 53 General Comments - Which innovations NRC not pursuing would greatly enhance value of Part 53?

(score 0 to 5, with 5 being the most beneficial) (Q9 from April 2022 Industry Survey)

Most (4 Least (0 Dont Part 53 Content or 5) or 1) Know Streamlining of licensing reviews and regulatory approvals 79% (15) 0% (0) 5% (1)

Streamlining of program requirements 68% (13) 0% (0) 5% (1)

Treating ALARA as a Policy rather than requirements in the Rule 67% (14) 0% (0) 10% (2)

Streamlining of oversight and inspections 65% (13) 0% (0) 10% (2)

More performance-based and modern siting requirements 60% (12) 0% (0) 10% (2)

Integrating safety, security, emergency planning and siting 57% (12) 9% (2) 5% (1)

QA requirements that explicitly allow ISO-9001 for safety-related 52% (11) 0% (0) 10% (2) 21

Part 53 General Comments - ALARA, DID, QHO, Programs ALARA

- Our members recognize ALARA is a good practice, but Part 20 should be referenced, rather than putting new provisions in rule that affect design.

How would including this in Part 53 interact with the Backfit Rule?

Defense in Depth

- DID is an important design philosophy. We suggest that the rule allow sufficient flexibility for applicants to demonstrate how DID is provided QHOs (required in Framework A)

- 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 in Framework A) and Integrity Assessment Program (53.850)) are redundant, new, and unnecessary- and value has not been explained Other specific concerns in 5 Nov 2021 112-page NEI/USNIC document regarding Framework A 22

High Level Insights for Framework A (relevant to Framework B)

Based on comprehensive April 2022 Industry survey

12 owner/ operator responses and 10 designer/developer-only responses

Key active organizations provided responses-- 15 of 22 respondents submitted application to NRC, are in pre-application with NRC, or submitted RIS response to NRC

Ten Part 53 items create significant concerns -- expanding ALARA to be design requirement, proliferation of unnecessary programs, increased regulatory burden for non-safety SSCs, safety objectives different than in AEA, expansion of design basis to include Beyond Design Basis Events, lack of clarity in purpose of some requirements, lack of measurable goals for regulatory efficiency

Four Part 53 items have benefits -- increased use of performance-based approaches for security, technology-inclusive requirements, increased use of performance based approach for operators

Most do not want QHOs in the rule -- All plan to use PRA

Many goals for Part 53 are not met by current language: Improving regulatory efficiency, predictability, stability, clarity, and flexibility

Part 53 review is time-consuming process; only limited support for current language; many areas where improvements needed to address concerns 23

Part 53 Going Forward

In the past, Industry has given extensive input, but NRC staff usually has not been receptive to alternative approaches

- NRC should offer alternative text for key issues (ALARA, PRA, QHO, DID, programs, etc.) for stakeholder/Commission review-- that encapsulates alternative positions provided by industry.

Future Part 53 Public meetings could be changed from one-way NRC listening sessions to open two-way dialog leading to resolution of topical issues

Rule should enable deployment of advanced technologies and not impose burdens currently beyond Part 50 and 52

- NRC bears responsibility for demonstrating why new requirements are required. It should not be industry responsibility to demonstrate why new requirements should not be included.

- NRC staff should not use this rulemaking to incorporate requirements in Part 53 that were previously part of guidance documents

- Higher level standards and simplicity could benefit the process. Need reasonable balance between predictability and flexibility

- NRC should be trying to make Part 53 more efficient (but unfortunately added more burden) 24

Part 53 Rulemaking:

Framework B NRC Advanced Reactor Stakeholder Meeting June 30, 2022 Marc Nichol, NEI Senior Director, New Reactors

Context for Comments The following are initial thoughts based upon a cursory initial review of Part 53 Framework B. (ML22145A000)

More detailed comments based upon a thorough review are being developed.

Part 53 Framework B - General Observations (1/3)

The NRC Part 53 Framework B Development Process and Provisions White Paper is very useful in following the details in Framework B and in clearly identifying the provisions that come from Parts 50/52 and Framework A. Absent this document, sorting out the source for the requirements would be very challenging.

Framework B is more technology-inclusive than Parts 50 and 52. However, much of the framework still appears to be LWR specific. There are numerous requirements that are still technology specific and prescribe the methods rather than establish the performance criteria.

Rule text is very voluminous (over 300 pages). A streamlining of the rule text length will improve clarity, predictability and efficiency. Sources of this length appear to include 1) areas where rule language is duplicated with Parts 50/52 or Framework A, and 2) areas where requirement appears to have guidance level of detail (significantly more detail than equivalent types of requirements).

Part 53 Framework B - General Observations (2/3)

Industry is unsure whether Framework B is viable, due to insufficient time to understand the details. Industry is cautious because significant detail has been observed in Framework B, and Framework A includes more regulatory burden than Parts 50/52.

Some negative attributes of Framework A have been avoided in Framework B, such as not including a Facility Safety Program.

Some positive attributes of Framework A were not included in Framework B, but should be. For example, the technology-inclusive and performance-based requirements for safety functions. These do not depend on the method in which a PRA is used, which NRC also stated at a public meeting in January 2022. Prescriptive requirements for safety functions will increase confusion, limit innovation, and increase the likelihood of needing exemptions.

Some negative attributes of Framework A appear to be carried over, such as establishing requirements for the design to achieve ALARA, rather than an operational consideration as it is in Parts 50 and 52.

Industry still believes it is possible to have a single Part 53 framework by not moving details appropriate for guidance into the rule text, and making simple changes in Framework A. Detail in the rule text will limit flexibility and is not necessary for regulatory clarity in predictability, since guidance can provide details.

Part 53 Framework B - General Observations (3/3)

More effort is needed to develop an efficient rule through requirements that are performance-based and risk-informed.

Risk-informed and performance-based are independent concepts and the rule should have both.

Performance-based:* A regulatory approach that focuses on desired, measurable outcomes, rather than prescriptive processes, techniques, or procedures. Performance-based regulation leads to defined results without specific direction regarding how those results are to be obtained. At the NRC, performance-based regulatory actions focus on identifying performance measures that ensure an adequate safety margin and offer incentives for licensees to improve safety without formal regulatory intervention by the agency.

Industry believes that Part 53 (Frameworks A and B) needs significant work in order to achieve a reasonable level of performance-based.

Risk-informed:* An approach to regulation taken by the NRC, which incorporates an assessment of safety significance or relative risk. This approach ensures that the regulatory burden imposed by an individual regulation or process is appropriate to its importance in protecting the health and safety of the public and the environment.

Note that this does not mean that requirements must prescribe the methods for utilizing quantitative PRA results in the safety case. ©2022 Nuclear Energy Institute 29

Source: NRC Website

Part 53 Framework B - Specific Observations (1/4)

Draft Rule Text: 53.4972(a)(5) Mitigation of beyond-design-basis events. This applies equally to 53.5019(a)(5)

The requirement points to 50.155, 50.155(b)(1) and 50.155(c) which are LWR-centric.

While including the mitigation provision is positive, the language in 53.4972(a)(5) should be modified to reflect a technology-inclusive, performance-based approach to mitigation for non-LWRs.

NEI proposed language (adapted from NEI letter dated February 11, 2021)

Each applicant or licensee shall develop, implement, and maintain mitigation strategies and guidance for rare event sequences, which may include one or more reactor modules, and that are not expected to occur in the life of a nuclear power plant that are capable of being implemented site-wide and must include the following:

1. The capability to maintain or restore the required facility functions necessary to meet the criteria in 53.2.

2. The acquisition and use of offsite assistance and resources to support the functions required by paragraph (b)(1) of this section indefinitely, or until sufficient site functional capabilities can be maintained without the need for the mitigation strategies

3. Strategies and guidance to provide the capabilities in (b)(1) under the circumstances associated with loss of large areas of the plant impacted by the event, due to explosions or fire, to minimize radiological releases.

Recommendation: NRC consider including performance-based language similar to the proposed alternative

Part 53 Framework B - Specific Observations (2/4)

Draft Rule Text: 53.4370(a)(3) - ALARA Requirement

As required by Subpart B to 10 CFR part 20, a combination of design features and programmatic controls must, to the extent practical, be based upon sound radiation protection principles to achieve occupational doses that are as low as is reasonably achievable.

Current Regulation: Part 20 Subpart B requirement, 20.1101 Radiation Protection Programs

(b) The licensee shall use, to the extent practical, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses and doses to members of the public that are as low as is reasonably achievable (ALARA).

Problem: Part 53 is not consistent with Part 20.

Is not applicable to the design features of the facility, and as they apply to the licensing of a new facility, focus solely on programs; and even when engineering controls are specified they refer to those used in the programs, not the design of the facility.

This requirement reduces clarity and predictability since it requires something that is not required in Part 20.

Part 53 Framework B - Specific Observations (3/4)

Examples of requirements that are prescriptive and not performance-based:

The Fire Protection requirements in 53.4350:

Appears to be more detailed and prescriptive than 50.48

Part 50 App. R. 53.4350 should be revised to make it performance based, with the details left to guidance.

An optional link to 50.48 and Part 50, App. R could be incorporated for applicants that do not want to make use of a performance-based regulation.

The requirements in 53.4380 Environmental qualification of electric equipment important to safety for nuclear power plants:

Includes the detailed and prescriptive requirements from 50.49.

This language should be revised to make the requirement performance based, leaving the detailed requirements to guidance. ©2022 Nuclear Energy Institute 32

Part 53 Framework B - Specific Observations (4/4)

Subpart R - Operations Requirements

The option for a general license to the facility for operator training (released in latest Framework A Subpart F) should also be available for Framework B.

The general license for operator training should be optional, and not required.

Some may meet the entry criteria, but have other reasons that they would not want to use a General License approach.

Alternative Evaluation of Risk Insights Guidance (1/2)

Enabling an option to simplify the licensing-basis safety case by not requiring a PRA is a positive enhancement in Framework B.

Although this results in a more conservative safety case, this may be attractive to some developers. Not just for micro-reactors, but for any that would be able to meet the entry criteria.

The entry criteria of 1 rem at 100 meters appears to be overly conservative, and a more reasonable criteria could be established. This limit is influenced by the NRC assumptions for the event frequency and population density.

An event frequency of once per year to release 1 rem is overly conservative, and could be reduced to once in 100 years or less. The event frequency of higher consequence (1 rem) events are very rare, and the consequence of more frequent events will be much less than 1 rem. A more realistic consideration of frequencies and how they differ for different categories of events is needed to avoid excessive conservatism.

Population density will be site specific. The guidance should allow applicants to adjust the distance at which the 1 rem dose must be met based upon site specific factors.

The establishment of the bounding event is not clear and should be reasonable.

Alternative Evaluation of Risk Insights Guidance (2/2)

The distance should not be specified in the entry criteria, but should be at the site boundary.

Designs that use AERI are designs with very low potential consequences and will achieve an EPZ at the site boundary. Thus, whether the site boundary is 100 meters or 200 meters or something else, setting the 1 rem limit for AERI at the site boundary provides adequate protection of the public.

The benefits of the AERI approach should be well defined:

NRC does not need to consider the PRA results in their review or in considering the Safety Goal Policy

Applicant does not need to meet requirements for BDBE mitigation

There may be other benefits, not yet considered

NRC expressed that the AERI approach is not seen as lending itself to other risk-informed applications after initial licensing. This does not have to be the case, and options for future risk-informed applications should be explored. ©2022 Nuclear Energy Institute 35

Part 53 - Stakeholder Perspectives on Framework B, Framework A, and NRC Stakeholder Engagement Process (Rani Franovich, BTI/ Steve Nesbit, ANS) 36

Regulatory Priorities for New and Advanced Reactors (Kati Augsten) 37

New Reactor Regulatory Priorities Kati Austgen June 30, 2022

New Nuclear Demand TO ACHIEVE OUR CLIMATE, ENERGY, ENVIRONMENTAL, ECONOMIC, AND NATIONAL SECURITY GOALS

U.S. DOE Projection: >300 plants 2020-2050

NEI Member Survey Top-Level Results Nuclear powers potential role in meeting company decarbonization goals:

SLR >90% of fleet expects to operate to at least 80 years GW 90 GW of new nuclear opportunity by 2050s SMRs Translates to nearly 300 SMR-scale plants

NEI utility member companies produce less than half of all US electricity ©2022 Nuclear Energy Institute 41

Potential Application Volume New Reactor Applications 70 60 50 40 30 20 10 0

2025 2026 2027 2028 2029 2030 2035 2040 2045 2050 New Reactor Applications

Advanced Nuclear Deployment Plans Projects in planning or under consideration in U.S. and Canada >20; Globally >30 KEY State policies to support advanced nuclear in place State policies to support advanced nuclear under consideration Planned project Under construction Updated 6/16/2022 ©2022 Nuclear Energy Institute 43

Summary of Nuclear Demand to Support Decarbonization by the 2050s - Grid Only 400 GW SURVEY MODELING Number of 300MWe SMRs 1,200 SMRs Installed New Capacity 336 GW Nominal 300 GW 900 SMRs 219 GW Nominal 200 GW 162 GW Nominal 600 SMRs 133 GW High Cost 100 GW 300 SMRs 92 GW Nominal 60 GW Constrained 57 GW High Cost NEI NEI Survey VCE INL/DOE Member Scaled to Model Model Survey All of U.S. ©2022 Nuclear Energy Institute 44

Regulatory Priorities NEW AND ADVANCED REACTORS

Priority Topics (1/2)

1. NRC Review Efficiency

Timeliness

Content of Applications

2. Environmental Reviews

3. Physical Security

4. Emergency Preparedness

5. Near-Term Risk-Informed, Technology Inclusive Regulatory Guidance

6. Part 50/52 Lessons Learned Rulemaking

Priority Topics (2/2)

7. Part 53 Rulemaking

8. Annual Fees for Non-Light Water Reactors

9. Siting

10. Advanced Manufacturing Technologies

11. Fuel Qualification

12. Operations

Part 53 Subpart F Staffing Requirements (Jesse Seymour) 48

10 CFR Part 53 Subpart F Staffing, Personnel Qualifications, Training, and Human Factors (2nd Iteration)

June 30, 2022 49

Agenda 2:40pm - 4:00pm Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors:

2nd Iteration Overview 4:00pm - 4:35pm Questions 50

Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Presentation Topics

Overview of Key Changes to Subpart F under the 2nd Iteration

- Addition of Engineering Expertise Requirement

- Expansion of Load Following Allowances

- Removal of Simulator HFE Testbed Requirement

- Replacement of Certified Operator Framework

Generally Licensed Reactor Operators

Questions 51

Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Key Changes to Subpart F under the 2nd Iteration

2nd iteration of Subpart F retains majority of requirements developed for the 1st iteration

Some requirements have been relocated to more appropriate spots (e.g., grouping technical requirements)

Most changes made for the second iteration of Subpart F were also mirrored in the contents of Subpart P for Framework B

A summary of those major changes will be provided here 52

Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Overview of Key Changes (continued)

Expansion of load following allowances o53.725(b) and 53.740(e) - (f) requirements modified to expand load following to include process heat usage

Removal of simulator HFE testbed requirement

Specific change management for approved programs

Addition of engineering expertise requirement

Staffing plan requirements of 53.730(f) modified to include providing engineering expertise to operators

Certified operator provisions completely replaced with an all new generally licensed reactor operator framework 53

Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Engineering Expertise Staffing plans for § 53.730(f) must include a description of how engineering expertise will be available to support the on-shift operating personnel during all plant conditions

For all types of Part 53 plants, regardless of licensed operator category and common to Subparts F and P

Intended to assist the on-shift crew with uncertainties (i.e.,

situations not covered by training or procedures)

Must have both a qualifying degree (or a PE license) and familiarity with facility operation

Provides flexibility: could be met by someone filling a traditional STA role or by offsite engineering expertise 54

Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Generally Licensed Reactor Operators (GLROs)

Under 2nd iteration of subpart F operator licenses now consist of general licenses and specific licenses.

- A specific license is issued to a named person and is effective upon approval by the Commission of an application filed pursuant to the regulations in this part and issuance of licensing documents to the applicant. Specific licenses are issued to ROs and SROs.

- A general license is effective without the filing of an application with the Commission or the issuance of licensing documents to a particular person. The general licensing of GLROs is addressed by the requirements of §§ 53.800 through 53.830.

55

Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Generally Licensed Reactor Operators (continued)

What types of facilities would have GLROs?

oNo operator action is needed to mitigate plant events and achieve acceptable accident performance oDefense-in-depth independent of operator action oOperators not significant factor in safety outcomes

What role would GLROs fulfil?

Administrative functions historically done by an SRO; keeps facility in analyzed state within licensing basis

Conduct manual reactivity manipulations if needed

Supervise core alterations and refueling operations 56

Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Generally Licensed Reactor Operators (continued)

Only a single operator license level exists within the GLRO framework (analogous to the SRO level)

Plants meeting the criteria for using GLROs would have to use GLROs in lieu of ROs and SROs for staffing

Like ROs and SROs, the GLRO training program must also be derived from a systems approach to training

Prescriptive staffing and capabilities for GLROs:

oContinuous monitoring with continuity of responsibility oMonitor plant parameters, evaluate emergency conditions, initiate reactor shutdown, dispatch/direct ops & maintenance personnel, and implement E-plan 57

Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Generally Licensed Reactor Operators (continued)

53.800 defines new class of plants using the design criteria previously developed for certified operator use oEstablishing new class done to conform with AEA

53.805 establishes the responsibilities of facility licensees that use GLROs:

oMaintain GLROs qualifications for responsibilities oOnly GLROs may manipulate facility controls oDevelop/implement/maintain Commission approved programs for GLRO training, exams, & proficiency oEnsure GLROs meet Part 26 & 73 requirements oReport names of all GLROs to the NRC annually

53.810 is the general license; it is granted provided that qualifications are established and maintained subject to restrictions. GLROs are subject to enforcement action.

58

Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Generally Licensed Reactor Operators (continued)

53.815 covers GLO training, retraining, and proficiency provisions oTraining programs must be derived from SAT Includes performing reactivity manipulations oInitial examination on knowledge and abilities oContinuing training and requalification exams oRequirements for use of simulation facilities oRecords must be available for NRC inspection oMust establish a GLRO proficiency program oNo specific medical requirements for GLROs

53.830 covers expiration of the license for GLROs 59

Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Specific Licensing (RO/SRO) versus General Licensing (GLRO)

Comparison of key aspects of the SRO/RO and GLRO frameworks:

Framework Aspect RO / SRO GLRO Licensed operators with Yes Yes responsibility for administrative requirements Licensed operators with role in Yes No event mitigation NRC has legal authority to Yes Yes suspend or revoke license for violations NRC approval of training & Yes Yes exam programs required?

NRC approval needed for Yes No exams, medical, simulator, renewals, terminations, and waivers?

Flexibility for requalification No Yes training & exam periodicity?

60

Final Discussion and Questions 61

U.S.-NRC-CNSC Memorandum of Cooperation: Joint Report, TRISO Fuel Qualification Assessment (Jeffrey Schmidt) 62

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

Jeff Schmidt, U.S. Nuclear Regulatory Commission (NRC)

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 Exercise the fuel qualification framework developed in Nuclear modular reactor] technical review approaches that facilitate Energy Agency (NEA) report, Regulatory Perspectives on resolution of common technical questions to facilitate Nuclear Fuel Qualification for Advanced Reactors, regulatory reviews that address each Participants national (ML22018A099) and NUREG-2246, Fuel Qualification for regulations Advanced Reactors (ML22063A131)

Collaboration on pre-application activities to ensure mutual Several proposed advanced reactor designs use TRISO fuel and preparedness to efficiently review advanced reactor and SMR reference the testing performed as part of the Advanced Reactor designs Fuel (AGR) program as documented in topical report EPRI-AR-1(NP)-A Collaboration on research, training, and in the development of Final report will (1) provide evidentiary basis to support regulatory regulatory approaches to address unique and novel technical findings for items that are generically applicable to TRISO, (2) considerations for ensuring the safety of advanced reactors and identify items that are design dependent, and (3) highlight areas SMRs where additional information and/or testing is needed 64

Assessment Team and Schedule

Joint report from CNSC and US NRC Task A, Project Planning

Timeline: Fourth Quarter 2021

UK regulator, Office for Nuclear Regulation

End Product: Initial project plan finalized with (ONR) involved as an observer resources in place (PNNL contract awarded)

Technical support provided by Pacific Northwest National Laboratory (PNNL) Task B, Draft Fuel TRISO Fuel Assessment Report

Work plan:

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.

Available on NRC advanced reactor website https://www.nrc.gov/reactors/new-reactors/advanced/international- Task C, Finalize Report cooperation/collaboration-with-canada.html

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 65

Input Framework Interim Report ML21175A152 ML22018A099 TECDOC-1645 ML22063A131 ML22101A297 ML20336A052 66

Focus of Second Interim Report - NUREG-2246 Goals 67

Focus of Second Interim Report - NUREG-2246 Goals (cont) 68

Interim Report - Contents

Release paths from TRISO fuel identified

Safe state considerations including maintaining a coolable geometry and allowing for negative reactivity insertion when needed

Evaluation model and capabilities 69

Interim Report - TRISO Release Paths

Releases from fission of tramp uranium

Releases from fabrication-induced particle defects

Releases from particles that fail during normal operation

Releases from particles that fail because of the accident

Releases from the increase in permeability of the TRISO layers 70

Interim Report - Safe State

As described in Fuel Qualification for Advanced Reactors (NUREG-2246), fuel assemblies or fuel structures geometric stability can be important to retaining a coolable geometry and the ability to insert negative reactivity under accident conditions.

For most TRISO fueled designs, these requirements are achieved by maintaining pebble or compact integrity or are not dependent on the fuel design (e.g., control elements inserting into a graphite block).

Fuel pebble/compact integrity is material and environment dependent and hence typically addressed on a design dependent basis (e.g., molten salt coolant).

For compacts made consistent with the AGR program specification, operation in a noble gas environment up to 1800 C is acceptable.

Next interim will report planning to add information on acceptable pebble matrix material when operating in a noble gas environment.

71

Interim report - Evaluation Model and Capabilities

Evaluation models can be computer codes, hand calculations or experimental data

Evaluation models need to consider particle geometry and material properties changes with burnup and the thermofluid models used to determine compact/pebble boundary conditions

Evaluation models used to determine radionuclide release should be benchmarked to appropriate experimental data per NUREG-2246, Section 3.4

In-service intact releases and coatings failures are primarily driven by temperature, hence system/TRISO particle temperatures should be conservatively determined

Currently, evaluation models are expected to be design/applicant specific 72

Goals for Third Interim Report

Expand particle manufacturing section to include discussion of coating process and SiC microstructure attributes which ensure adequate fission product retention

Expand information on fuel element matrix material which has demonstrated the ability to maintain TRISO particle integrity and support maintaining a safe state

Continue work on the evaluation models used to predict radionuclide release

Begin drafting the experimental data assessment section (NUREG-2246, Section 3.4) 73

Questions?

(Questions for CNSC should be directed to mediarelations-relationsmedias@cnsc-ccsn.gc.ca or by phone at 613-996-6860) 74

ML22180A095

Text

Navigation menu

Search