ML22342B223

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NRC Presentation on Regulatory Framework for Advanced Reactors for the International Atomic Energy Agency Consultancy Meeting on Safety of Liquid Metal Fast Reactors
ML22342B223
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Issue date: 12/07/2022
From: William Kennedy
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NRC Regulatory Framework for Advanced Reactors IAEA Consultancy Meeting on the Development of a Technical Document on the Safety of Liquid Metal Cooled Fast Reactors December 7 - 9, 2022 William Kennedy Reed Anzalone U.S. Nuclear Regulatory Commission

U.S. Nuclear Regulatory Commission The NRC's mission is to license and regulate the Nation's civilian use of radioactive materials to provide reasonable assurance of adequate protection of public health and safety and to promote the common defense and security and to protect the environment.

The Office of Nuclear Reactor Regulation (NRR) is responsible for accomplishing key components of the NRC's nuclear reactor safety mission, including activities that encompass licensing, oversight, siting, rulemaking, and incident response for civilian nuclear reactors.

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NRC is preparing for a Variety of Advanced Nuclear Technologies Research Molten Salt Small and Test Reactors Modular Reactors Reactors A number of current and EVOLVING potential applications High-LANDSCAPE Temperature Liquid Metal Micro-Gas-Cooled Cooled Fast Reactors Reactors Reactors

  • Many different reactor technologies
  • Range of sizes from < 10 MWt to 600 MWt
  • Multiple reactors on a single site
  • Hazards vary with power level and radionuclide inventory 3

4 LMFR Landscape

  • Preapplication Safety Evaluation Report for the Power Reactor Innovative Small Module (PRISM) Liquid-Metal Reactor, 1994
  • TerraPower-GEH Natrium sodium fast reactor
  • Westinghouse lead-cooled fast reactor 5

Vision & Strategy Nuclear Energy Innovation and Modernization Act (NEIMA; Public Law 115-439), dated January 2019, requires the NRC to complete a rulemaking to establish a technology-inclusive, regulatory framework for optional use for commercial advanced nuclear reactors no later than December 2027 6

Modernizing the Regulatory Framework 10 CFR Part 53 Functional Emergency Containment Preparedness Physical Environmental Security Review Technology-Inclusive, Risk-Informed, and Performance-Based Regulatory Framework Licensing Fuel Modernization Qualification Project (LMP) Content of Siting Application 10 CFR = Title 10 of the Code of Federal Regulations 7 NRC Website on advanced reactors

10 CFR Part 53 is being developed

  • Promote regulatory stability, predictability, and clarity
  • Reduce requests for exemptions from the current requirements in 10 CFR Parts 50 and 52
  • Establish new requirements to address advanced reactor technologies
  • Recognize technological advancements in reactor design
  • Credit the response of advanced nuclear reactors to postulated event sequences, including slower response times and relatively small and slow release of fission products
  • Enables operational flexibility In September, the NRC staff released the draft proposed Part 53 rulemaking package NRC Website on 10 CFR Part 53 rulemaking 10 CFR Part 53, Risk-Informed, Technology Inclusive Regulatory Framework for Advanced Reactors 8

Part 53 Risk-Informed Parts 50/52 Approach

  • Frequency & Consequence-Oriented
  • Prescriptive Requirements Requirements
  • Optimized for Specific Technology Technology-Inclusive Explicit Consideration of Defense-In-vs
  • Augmented for Operating Experience Depth
  • Conservative Assumptions &
  • Expanded Use of Graded Performance Analyses Requirements 10 CFR Part 53 would evolve existing requirements into a modern, risk-informed, performance-based approach

Part 53 rulemaking addresses plant lifecycle with appropriate flexibilities and safety focus 10 17

10 CFR Part 53 Subpart B - Technology-Inclusive Safety Requirements

  • Safety Objectives (B) Safety Criteria What function(s)
  • Safety Criteria (e.g., a barrier, cooling) are needed to satisfy safety criteria
  • Safety Functions (B) Safety Functions
  • Licensing Basis Events What design features (e.g., a structure, system)
  • Defense-in-Depth are provided to fulfill the safety function(s)

(DID) (C) Design Features (and Human Actions)

  • Normal Operations What design criteria (e.g., leak rate, cooling and Protection of capacity) are needed for design feature Plant Workers (C) Functional Design Criteria (Personnel; Concept of Operations) 11

Technology-inclusive, risk-informed, and performance-based methodology to inform licensing basis and content of application for licenses, certifications, and approvals of non-Regulatory LWRs Guide (RG)

Endorses Nuclear Energy Institute 1.233 (NEI) 18-04 with clarifications 12

Risk-informed performance-based guidance for non-LWR licensing basis development NEI 18-04 Known as the Licensing Modernization Project (LMP)

Technology-inclusive methodology for:

  • Selecting licensing basis events
  • Classifying structures, systems, and components (SSCs), and associated risk-informed special treatments
  • Determining the defense-in-depth (DID) adequacy 13

NEI 18-04 Methodology 14

NEI 18-04: The Frequency-Consequence Target 15

NEI 18-04: SSC Safety Categories 16

Pre-Application Engagement

  • Draft White Paper - Preapplication Engagement to Optimize Advanced Reactors Application Reviews
  • Encourages pre-application interactions with advanced reactor developers to provide stability and predictability in the licensing process through early identification and resolution of technical and policy issues that would affect licensing.

- Principal Design Criteria for non-light water reactors

- Process for selection of licensing basis events and classification and treatment of structures, systems, and components

- Fuel qualification plan and associated methodologies

- Source term methodology

- Quality Assurance Program description

- Plan for protection of safeguards information

- Safety and accident analysis methodologies

- Others based on specific design or licensing approach 17

  • Guidance on how the General Design Criteria (GDCs) in Appendix A of 10 CFR Part 50 may be adapted for non-LWR designs.
  • Guidance for developing Principal Design Criteria (PDCs) for non-LWR designs as required by applicable regulations.

RG 1.232 - Appendix A: the technology-inclusive Advanced Reactor Design Criteria (ARDCs)

- Appendix B: Design criteria for sodium-cooled fast reactors (SFR-DCs)

- Appendix C: Design criteria for modular high temperature gas reactors (MHTGR-DCs) 18

  • Appendix B: Design criteria for sodium-cooled fast reactors:

- I. Overall Requirements

- II. Multiple Barriers

- III. Reactivity Control RG 1.232 - IV. Fluid Systems

- V. Reactor Containment

- VI. Fuel and Reactivity Control

- VII. Additional SFR-Design Criteria 19

  • Endorses, with staff exceptions, a consensus PRA standard (ASME/ANS RA-S-1.4-2021)
  • Technology-Inclusive Identification of Licensing Events for Commercial Nuclear Plants
  • Guidance on identifying DG-1413 licensing events used to inform the design basis, licensing basis, and content of applications for commercial nuclear plants 21
  • Alternative Evaluation for Risk Insights (AERI) framework to inform the content of applications and licensing basis for light-water reactors (LWRs) and non-LWRs

- Bounding event less than 1 Rem TEDE at 100 meters during 4 days

- No active safety features and no passive safety that require actuation or operator action 22

Other Guidance Developments Instrumentation and Controls

  • Technology-inclusive, risk-informed, and performance-based
  • Top-down, streamlined approach
  • Design Review Guide for non-LWR Instrumentation and Controls Reviews published Fuel qualification
  • To establish a performance-based fuel qualification assessment framework that would satisfy regulatory requirements
  • Developing guidance for liquid-fueled molten salt reactors Reliability and Integrity Management (RIM)
  • American Society of Mechanical Engineers (ASME) SECTION XI, DIVISION 2
  • A program to ensure that passive component reliability and integrity are properly managed
  • Based on achieving an acceptable level of reliability
  • Implement strategies to ensure that Reliability Targets for SSCs are defined, achieved, and maintained
  • RG 1.246 published in October 2022 Code of construction for high temperature reactors
  • ASME SECTION III, DIVISION 5

Acronyms and Abbreviations ACU Abilene Christian University DID Defense-in-depth Agencywide Documents Access and Management EAB Exclusion area boundary ADAMS System ESP Early site permit AEA Atomic Energy Act F-C Frequency-consequence AOO Anticipated operational occurrence GDC General Design Criterion ARCAP Advanced reactor content of application project GEH GE Hitachi Nuclear Energy ARDC Advanced Reactor Design Criterion GEIS Generic Environmental Impact Statement ASME American Society of Mechanical Engineers GIV Generation IV BDBE Beyond design basis event HTGR High-temperature gas-cooled reactor CFR Code of Federal Regulations IAEA International Atomic Energy Agency COL Combined license ISI/IST Inservice inspection/inservice testing CP Construction permit LBE Licensing basis event DBA Design basis accident LMFR Liquid metal fast reactor DBE Design basis event LMP Licensing Modernization Project DC Design certification LWR Light-water reactor DG Draft Regulatory Guide 24

Acronyms and Abbreviations MCFR Molten chloride fast reactor RG Regulatory Guide MHTGR- Modular high-temperature gas-cooled reactor RIM Reliability and Integrity Management DC design criteria RIPB Risk-informed performance-based MIT Massachusetts Institute of Technology RTR Research and test reactor ML Manufacturing license SAR Safety analysis report MSR Molten salt reactor SDA Standard design approval MWt Megawatt thermal SFR-DC Sodium-cooled fast reactor design criteria NEI Nuclear Energy Institute SRM Staff Requirements Memorandum NEIMA Nuclear Energy Innovation and Modernization Act SSC Structure, system, and component NRC U.S. Nuclear Regulatory Commission Technology-inclusive content of application TICAP OL Operating license project P&ID Piping and instrumentation diagram PDC Principal design criterion PRA Probabilistic risk assessment QHO Quantitative health objective 25

1.

References 10 CFR Part 50, Domestic licensing of production and utilization facilities

2. 10 CFR Part 52, Domestic licensing of production and utilization facilities
3. ASME/ANS RA-S-1.4-2021, Probabilistic Risk Assessment Standard for Advanced Non-Light Water Reactor Nuclear Power Plants
4. ASME Boiler & Pressure Vessel Code,Section III, Division 5 - High Temperature Reactors
5. ASME Boiler & Pressure Vessel Code,Section XI - Rules for Inservice Inspection of Nuclear Power Plant Components, Division 2, Requirements for Reliability and Integrity Management (RIM) Programs for Nuclear Power Plants
6. NEI 18-04, Revision 1, Risk-Informed Performance-Based Guidance for Non-Light Water Reactor Licensing Basis Development, August 19, 2019. (ADAMS Accession No. ML19241A472).
7. 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 2, 2021. (ADAMS Accession No. ML21250A378).
8. NRC, SECY-18-0096, Functional Containment Performance Criteria for Non-Light-Water Reactors, Washington, DC, September 28, 2018. (ADAMS Accession No. ML18114A546).
9. NRC, SRM-SECY-18-0096, SECY-18-0096 - Functional Containment Performance Criteria for Non-Light-Water-Reactors, December 4, 2018. (ADAMS Accession No. ML18338A502).
10. Nuclear Energy Innovation and Modernization Act (NEIMA; Public Law 115-439), January 2019.
11. RG 1.232, Revision 0, Guidance for Developing Principal Design Criteria for Non-Light Water Reactors, April 2018. (ADAMS Accession No. 17325A611).
12. RG 1.233, Revision 0, 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, June 2020. (ADAMS Accession No. ML20091L698).
13. RG 1.247, Acceptability of Probabilistic Risk Assessment Results for Non-Light Water Reactor Risk-Informed Activities, March 2022. (ADAMS Accession No. ML21235A008).

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Backup Slides 27

Rulemaking Schedule 28

  • Consideration of stakeholder requests for an option for a more traditional, deterministic licensing framework for advanced reactors
  • Aligns with international standards (i.e., International Atomic Energy Agency)
  • Guidance for systematic searches for hazards, initiating events, and event sequences 29

Other rulemaking activities

  • Physical Security

- Establish alternative, consequence-oriented physical security requirements for advanced reactors

- The rule and guidance under development

- Provide alternative, consequence-oriented emergency preparedness requirements for SMRs and other new technologies

- The proposed rule is with the Commission (SECY-22-0001)

- DG-1350 provides a technology-inclusive, RIPB approach to radiological dose assessment

  • Generic Environmental Impact Statement

- Streamline the environmental review process

- Technology-neutral plant parameter envelope and site parameter envelope approach

- The draft proposed rule was provided to the Commission (SECY-21-0098) 30

Content of Application Guidance

  • To develop technology-inclusive, risk-informed and performance-based application guidance
  • TICAP (Industry-led): Guidance to develop the content for LMP-based portions of the safety analysis report
  • ARCAP (NRC-led): Guidance that describes the contents for an entire application
  • Guidance will be revised in accordance with the 10 CFR Part 53 rulemaking underway NRC Website on ARCAP/TICAP ARCAP: Advanced Reactor Content of Application Project TICAP: Technology Inclusive Content of Application Project (TICAP) 31

ARCAP/TICAP - Nexus Outline Safety Analysis Report (SAR) - Additional Portions of Based on TICAP Guidance Application

1. General Plant Information, Site
  • Technical Specifications Description, and Overview of the
  • Technical Requirements Manual Safety Case
  • Quality Assurance Plan (design)
2. Methodologies and Analyses
3. Licensing Basis Event Analysis (design)
4. Integrated Evaluations
  • Quality Assurance Plan
5. Safety Functions, Design Criteria, and (construction and operations)

SSC Safety Classification Audit/inspection of Applicant

6. Safety-Related SSC Criteria and Records
  • Physical Security Plan Capabilities
  • Calculations
7. Non-Safety-Related with Special
  • Analyses program Treatment SSC Criteria and
  • System Descriptions
  • SNM material control and Capabilities
  • Design Drawings accounting plan
  • Design Specifications
8. Plant Programs
  • Procurement Specifications

Scope of TICAP

  • Radiation Protection Program
9. Control of Routine Plant Radioactive
  • Inservice inspection/Inservice Solid Waste testing Program
  • Environmental Report
10. Control of Occupational Doses
  • Site Redress Plan
11. Organization and Human-System
  • Exemptions, Departures, and Considerations Variances
12. Post-construction Inspection, Testing
  • Facility Safety Program (under and Analysis Programs consideration for 10 CFR Part 53 applications)
  • SAR structure based on clean sheet approach
  • Additional contents of application outside of SAR are still under discussion. The above list is draft and for illustration purposes only.
  • NEI 21-07, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Developing a Content for Applicants Utilizing NEI 18-04 Regulatory Methodology Guide for TICAP
  • Chapters 1 - 8 of the safety guidance analysis report based on RG 1.233/NEI 18-04
  • To issue a Regulatory Guide to endorse it with clarifications 33

Functional Containment

  • Methodology for establishing functional containment performance criteria for non-LWRs
  • Focused on ability of multiple fission product barriers to retain radionuclides (i.e., technology-inclusive, risk-informed, and performance-based requirement) rather than a leak-tight containment building (i.e.,

prescriptive requirement)

Source: SECY-18-0096, Enclosure 2

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