ML23130A097
| ML23130A097 | |
| 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: ML23130A097 (26) | |
Text
Scott Morris Deputy Executive Director for Reactor and Preparedness Programs 2
Andrea Veil, Delivering on the Requirements of the Nuclear Energy Innovation and Modernization Act Mohamed Shams, Overview of Draft Proposed Rule Development and Addressing Stakeholder Comments Nanette Valliere, Draft Proposed Rule Structure and Key Topics Martin Stutzke, Development of Innovative Risk Assessment Methodology for Part 53 Tara Inverso, Leveraging Innovation in the Rulemaking Process 3
Andrea Veil Director, Office of Nuclear Reactor Regulation 4
o On target to complete the rulemaking in advance of the NEIMA schedule o
Risk-informed, performance-based, and technology-inclusive o
Achieves an equivalent level of safety to existing regulations 5
Addressing applicant use of Licensing Modernization Project concepts Incorporating licensing efficiencies in guidance 08 07 06 05 Leveraging innovative approaches under 10 CFR Parts 50 and 52 Making improvements in NRC processes Trial use guidance on PRA acceptability for non-light-water reactors ASME Code Sections on High Temperature Reactors & Reliability and Integrity Management 01 02 03 04 Rulemakings on emergency preparedness, physical security, and environmental impacts Guidance on fuel qualification for advanced reactors 6
Stakeholder input Expected, planned for, and actively sought Draft proposed rule Considered feedback and evolved the draft proposed rule Continuing Engagement Engagement to continue during public comment period 7
Mohamed Shams Director, Division of Advanced Reactors and Non-Power Production and Utilization Facilities, Office of Nuclear Reactor Regulation 8
o Reflects internal collaboration and stakeholder feedback o Incorporates technology-inclusive, performance-based approaches o Embodies Commission policy decisions 9
Technology-inclusive traditional framework Subpart A - General Provisions o Responsive to stakeholder feedback o Flexible licensing alternatives o Technology-inclusive approaches 10 AERI Framework B Technology-inclusive traditional framework Framework A PRA-led approach
Balances level of detail For effective and consistent implementation with prescriptive methods in guidance Enables flexibility Performance-based approaches and broadening code and standard accessibility Embraces adaptability Optimal combination of programs, design features, and human actions to demonstrate safety 11
Nanette Valliere Senior Project Manager, Division of Advanced Reactors and Non-Power Production and Utilization Facilities, Office of Nuclear Reactor Regulation 12 to SECY-23-0021 Discusses these topics and provides the rationale for the NRC staffs recommendations Outlines possible implications of adopting alternative approaches for each topic 13
Tied to Existing Regulatory Framework
Inclusion in licensing bases dates back decades
Regulatory justification for rules played role in labeling
BDBEs affected plant designs Beyond-design-basis events (BDBEs)
Generally consistent with current NRC requirements
Allows flexibility to combine design attributes & programmatic elements
Includes a technology-inclusive performance goal
Is supported by performance-based guidance ALARA in Part 53 14
Part 53 Innovations Generally Licensed Reactor Operators Addresses whether reactor operators have a role in maintaining and fulfilling safety functions Incorporates greater operational flexibility Facility Safety Program Allows licensees to continue to leverage PRA insights during operation Assesses potential changes to plant hazards and considers risk reduction measures, when appropriate 15
Martin Stutzke Senior Technical Advisor for Probabilistic Risk Assessment, Division of Advanced Reactors and Non-Power Production and Utilization Facilities, Office of Nuclear Reactor Regulation 16
Framework A is consistent with the principles of risk-informed integrated decision making described in RG 1.174 Ensuring a Comparable Level of Safety 17 Integrated Decision Making
- 1. Change meets current regulations unless it is specifically related to a requested exemption.
- 3. Maintain sufficient safety margins.
Overall Framework A (crosswalks, existing standards)
Design Requirements
§ 53.210, § 53.440 Defense-in-Depth Provisions
§ 53.250, § 53.450 Risk Metrics
§ 53.220, § 53.450 (QHOs or surrogates)
Performance Monitoring Subparts F, I RG 1.174 Risk-Informed Integrated Decision Making
- 5. Use performance-measurement strategies to monitor changes.
- 4. Proposed changes in risk are small and are consistent with the Commissions Safety Goal Policy Statement.
- 2. Change is consistent with defense-in-depth philosophy.
17
o Defines an acceptable level of radiological risk, i.e.,
how safe is safe enough o Implements Commission policies o Consistent with guidance for performance-based regulation in NUREG/BR-0303 o Applies to all reactor technologies 18 o Provides one element of the safety criteria o Consistent with SRM-SECY-98-144 concerning risk-informed and performance-based regulation
19 o Provides alternative to PRA o Achieves underlying purposes of Commission policies o May be used by plants with small fission product inventories and straightforward designs o AERI entry conditions are not safety or siting criteria
Tara Inverso Director, Division of Security Operations, Office of Nuclear Security and Incident Response 20
o Frequent meetings with NRC Steering and Advisory Committees o Close coordination with ACRS on key topics of interest o Developed core team of SMEs across the agency Result: Shorter overall rulemaking schedule 21
22 Pre-Rule Phase Steps Enhanced Part 53 Approach Less frequent release of rule language (if any) 20+ iterations of draft rule language released Less frequent engagement with stakeholders and ACRS 24 public meetings held 16 ACRS meetings conducted 126 letters received Result: Demonstrated the flexibility and scalability of NRCs rulemaking process to achieve positive outcomes.
Addressing challenges:
Aligning on rulemaking scope Engaging on key issues Developing supporting guidance o Reviewing the proposed rule within a 60-day public comment period 23
o Conduct a multiday public meeting during the proposed rule public comment period o Provide a formal response to public comments o Engage with ACRS 24
25 Scott Morris Deputy Executive Director for Reactor and Preparedness Programs
26
- AERI - Alternative Evaluation for Risk Insights
- ALARA - As Low As is Reasonably Achievable
- ASME - American Society of Mechanical Engineers
- BDBEs - Beyond-Design-Basis Events
- CFR - Code of Federal Regulations
- NUREG - U.S. NRC technical report designation
- NUREG/BR - NUREG brochure
- RG - Regulatory Guide
- SMEs - Subject Matter Experts
- SRM - Staff requirements memorandum
- QHOs - Quantitative Health Objectives