ML23130A063
| ML23130A063 | |
| Person / Time | |
|---|---|
| Issue date: | 05/16/2023 |
| From: | NRC/OCM |
| To: | |
| Shared Package | |
| ML23067A030 | List: |
| References | |
| M230516, 10 CFR Part 53, NRC-2019-0062, RIN 3150-AK31 | |
| Download: ML23130A063 (10) | |
Text
UCS Perspectives on Part 53 Dr. Edwin Lyman Director of Nuclear Power Safety Climate and Energy Program Union of Concerned Scientists May 16, 2023
General perspectives
- The NRC staff has done a good job of being responsive to the many industry complaints about proposed Part 53 language without straying from its fundamental principles
- But not responsive to UCS concerns
- Scope is too broad
- Extending applicability to any commercial nuclear plant instead of limiting to those with significant improvements consistent with the letter and intent of NEIMA
- Incorporating operational programs (physical protection, access authorization, fitness for duty, operator licensing, etc) instead of limiting to reactor design and safety analysis
- Safety margins may be significantly decreased based on unrealistic and potentially unverifiable expectations of safety system performance 2
Maintaining the current level of safety
- The complexity of the draft Part 53 and its incorporation of programs where risk cannot be quantified makes it extremely difficult to judge whether current levels of safety and security would be maintained
- UCS continues to be concerned about the cumulative effect of an across-the-board weakening of standards, facilitating the licensing and deployment of experimental reactors that could pose undue public health and safety risks 3
4 A.J. Nosek, MACCS Consequence Analysis Demonstration Calculations for an Example Heat Pipe Reactor Source Term, US. NRC, March 2023 2 MW-electric heat pipe microreactor.
Unrealistically assumes large reactor building that reduces release to environment by 1000.
Revising the QHOs In previous remarks, UCS has called for an updating of the Safety Goals to better reflect experience (Fukushima) and to better address current values (such as environmental justice concerns)
SECY-23-0021 does not discuss the merits of revising the Safety Goals/QHOs but simply says it would be a significant regulatory challenge and take too long To maintain a level of safety comparable to the operating fleet, if the current QHOs are to be used, then there also must be a defense-in-depth requirement in Part 53 to ensure a comparable margin for new plants (factor of 100 or more) 5
- UCS strongly supports the staffs position on retaining ALARA requirements both in the design stage and during operation to ensure all reasonable, cost-effective steps are taken
- to protect workers and the public during normal operation
- to ensure conformity with long-held international radiation protection standards (ICRP and IAEA) 6
Facility Safety Program
- UCS believes that the Facility Safety Program in the proposed draft rule is an essential component of risk-informed regulation by ensuring that the safety implications of PRA updates that could affect the original plant licensing basis are promptly and thoroughly addressed
- Will help to address concerns about how plant safety may change over time due to effects such as aging and climate change 7
Generally licensed reactor operators
- A category of operator for a type of facility (self-reliant-mitigation) that probably will never exist
- More efficient to be handled by exemption given it most likely will be of very limited applicability
- And will DBT-initiated events be included in the determination of whether a facility qualifies for GLROs? Such facilities would likely also seek exemptions from the DBT under §53.860(a)(2)(i) 8
Location and control of PRA information
- The draft proposed rule requests comment on where detailed PRA information (as compared to a summary) should be located and how it should be controlled
- In our view, given the elevation of importance of the PRA in Part 53 Framework A compared to Part 52including the determination of design-basis accidentsfar more PRA detail than a mere summary should be included in the FSAR and subject to stringent change control requirements 9
10 Acronyms
- ALARA: As Low as Reasonably Achievable
- GLRO: Generally Licensed Reactor Operator
- IAEA: International Atomic Energy Agency
- ICRP: International Commission on Radiological Protection
- QHOs: Quantitative Health Objectives