ML24115A087
| ML24115A087 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/2024 |
| From: | Gerond George Licensing Processes Branch |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML24115A087 (11) | |
Text
NRC Staff Perspectives on Hydrogen Production at Nuclear Power Plants Gerond A George Branch Chief Licensing Projects Branch Office of Nuclear Reactor Regulation
- The purpose of the MOU is to coordinate DOE and NRC technical readiness and sharing of technical expertise and knowledge on advanced nuclear reactor technologies and nuclear energy innovation.
- NRCs Role for this discussion
- Provide current information on licensing and regulatory reviews of emerging technologies to prioritize regulatory needs 2
LWRS MOU NRC/DOE ML21124A125
- The NRC is currently monitoring H2 generation implementation activities and reviewing information shared through the MOU.
- Specifically, for the H2 generation activities, NRC staff from different NRC offices have been meeting frequently to determine if any licensing and oversight impacts will appear from these emerging technologies.
3 Current Activities for H2 generation
- Existing NRC regulatory framework adequately supports installation and operations associated with hydrogen production and storage.
- Need for a License Amendment Request (LAR) prior to installation and operation will be determined by site specific license basis considerations.
- Topical Reports can be used as a basis for LARs to alleviate potential licensing uncertainties within the general aspects of designs.
- Those changes to facilities that do not need LARs could potentially be reviewed during the NRC oversight activities.
4 NRC Regulatory Framework
- Changes governed by 10 CFR 50.59
- Technical Specifications changes will require a LAR
- Facilities and Procedures described in Updated Final Safety Analysis Reports must be evaluated against guidance approved in RG 1.187
- Other License Basis Changes
- Quality Assurance Plan
- Fire Protection Plan
- Emergency Plan / Emergency Response Facilities
- Security Plan / Target Set
- Independent Spent Fuel Storage Installations (ISFSIs) 5 Licensing Basis and Facility/Procedure Changes
Hydrogen production and storage at a site has the potential to impact accidents, transients, and other discussions in the Updated Final Safety Analysis Report (UFSAR):
- Excess Steam Flow
- Loss of Load / Load Rejection
- ATWS considerations (HTEF only)
- High-Energy Line Break (HTEF only)
- Turbine-Generator Trip
- Impact to Accident Indications
- Control Room and Plant Operations
- LIST IS NOT ALL INCLUSIVE 6
Updated Final Safety Analysis Report Potential Impacts
Changes that impact onsite fires and explosions are governed by site specific fire protection program license conditions.
Focus is on maintaining provisions of General Design Criterion (GDC) 3, Fire Protection, of Appendix A to Part 50, General Design Criteria for Nuclear Power Plants.
NRC guidance found in:
- RG 1.189, Revision 5 Fire Protection for Nuclear Power Plants (ADAMS Accession No. ML23214A287)
- RG 1.205, Revision 2, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants (ADAMS Accession No. ML21048A448) 7 Fire Protection Considerations
Changes to emergency plans are governed by 10 CFR 50.54, Conditions of licenses (specifically 10 CFR 50.54(q))
Changes to a licensees emergency plan that reduce the effectiveness of the plan may not be implemented without prior approval by the NRC.
NRC guidance found in RG 1.219, Revision 1 Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors (ADAMS Accession No. ML16061A104)
As an example, consider impacts to Emergency Response Facilities and Emergency Action Levels 8
Emergency Plan Considerations
Changes to that impact the safety / security interface are governed by 10 CFR 73.58, Safety / security interface requirements for nuclear power reactors Licensees shall assess and manage the potential for adverse effects on safety and security before implementing changes.
NRC guidance found in RG 5.74, Revision 1 Managing the Safety / Security Interface (ADAMS Accession No. ML14323A549)
As an example, consider impacts to target sets, staging areas, response times and locations, and barriers.
9 Security Plan Considerations
Changes that can impact ISFSIs are governed by 10 CFR 72.48, Changes, tests, and experiments, and 10 CFR 72.212, Conditions of general license issued under
§72.210.
10 CFR 72.48 discusses when a LAR is needed prior to making changes.
NRC guidance found in RG 3.72, Revision 1 Guidance for Implementation of 10 CFR 72.48, Changes, Tests, and Experiments (ADAMS Accession No. ML20220A185)
As an example, consider impacts to facility / cask designs which may differ from safety-related SSCs.
10 ISFSI Considerations
Questions?