ML25070A004

IAEA Presentation for 2025 Psr Workshop- D.Hardesty-USNRC

ML25070A004
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Issue date:	03/11/2025
From:	Duane Hardesty Office of Nuclear Reactor Regulation
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The U.S. and Periodic Safety Assessments Duane Hardesty U.S. Nuclear Regulatory Commission March 11, 2025 NRC: An Independent Regulator

Topics 2

• U.S. Non-power Production and Utilization Facilities (NPUFs)

• U.S. Alternative to PSR

• Example Comparisons U.S. Approach to PSR Safety Factors

• Summary of U.S. Position

NPUF Categories

• The NRC licenses production and utilization facilities under authority of the Atomic Energy Act of 1954, as amended

• Two classes of licenses under the AEA:

• Commercial (Section 103)

• Medical Therapy and Research and Development (Section 104)

• Subcategories of NPUFs:

• Research Reactors

• Testing Facilities

• Medical Therapy

• Medical Isotope Facilities

4 36 regulated non-power production and utilization facilities 29 operating reactors in 21 States 2 reactors permanently shut down and in decommissioning 5 construction permits U.S. Regulated NPUFs

5 Section 104 Medical Therapy and Research and Development Commission directed to impose minimum amount of regulation on class 104 needed to promote the common defense and security; protect the health and safety of the public; and permit:

(a) the widest amount of effective medical therapy possible, and (c) the conduct of widespread and diverse research and development The NRC licenses NPUFs pursuant to the regulations provided in Title 10 of the Code of Federal Regulations, Part 50, Domestic Licensing of Production and Utilization Facilities

6 The U.S. regulatory approach provides a continuum of assessment and review that ensures public health and safety and protection of the environment throughout the period of facility operation that affords comparable level of safety to the PSR process.

U.S. Alternative

7 U.S. Approach to Safety

• Maintain Safety throughout life of facility

• Consistent with AEA; goal is to prevent degradation of acceptable licensing basis not continuous improvement

• In the U.S., facility safety is improved by a combination of the:

- ongoing NRC regulatory process, including required record keeping and reporting

- oversight of the current licensing basis

- broad-based evaluations

- licensing actions

- licensee initiatives

77 How We Regulate

1414 Regulatory Framework 9

11

• Rulemaking Develop New Rules

- Update Existing Rules

• Guidance Development Regulatory Guides Standard Review Plans Inspection Manual

• Generic Communications

• Consensus Standards

- ANS/ANSI

- ASME

- IEEE Regulations and Guidance

11 Licensing, Decommissioning and Certification

• Licensing

- New Licenses

- License Renewals*

- Licensing Actions (Amendments, Exemptions, Orders etc.)

• Decommissioning

• Certification

- Spent Fuel Casks

- Transportation Packages

• In addition to meeting 10 CFR Part 50 requirements, NPUFs must also consider:

Part 20, Protection Against Radiation Part 30, Licensing of Byproduct Material Part 51, Environmental Protection Regulations for Domestic Licensing Part 55, Operators Licenses Part 73, Physical Protection of Plants and Materials

• Test reactors must also meet 10 CFR Part 100 accident dose acceptance criteria 13 Applicable Regulatory Requirements

16 Oversight

• Reactor Oversight

- Inspection

- Operator Examination

• Enforcement

• Allegations

• Investigations

• Incident response

17

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Yearly ~65 hours on average at each facility Safety Inspections:

< 2 MWth One visit/yr per facility Avg. 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />s/yr per facility Safeguards Inspections:

Cat 2:

One week visit Every 2 years

> 2 MWth Two visits/yr per facility Avg. 80 hour9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />s/yr per facility Cat 3:

One week visit Every 3 years Non-Routine Inspections:

Management visits, special and reactive inspections Avg. 2-3 per yr for fleet One week each Inspection Activities

Operational Experience OLCs - require routine operating reports:

initial startup routine annual operating reports special occurrences Event Notification - Each licensee must send information on "reportable events" Preliminary Notification is required not later than the following working day Final written report that describes the circumstances of the event within 14 days Significant OpE is communicated to all licensees via generic communications (e.g., Bulletins or Info Notices)

NRC maintains an OpE database and shares operating experience via IRSRR (maintained by IAEA)

16 Support for Decisions

• Research Activities

• Advisory Activities

• Adjudication

17 Strengths of U.S. Approach NRC participated in PSR development, and stays actively engaged in international activities NRCs continuous oversight ensures safety throughout the life of the facilities NRCs comprehensive activities incorporate the intent of all PSR safety factors Interactions between NRC, TRTR, and licensees provide coordinated approach to technical issues throughout community The U.S. approach affords comparable level of safety to the PSR process

21 PSR Safety Factors

• Plant Design

• Actual Condition of SSCs

• Equipment Qualification

• Aging

• Deterministic Safety Analysis

• Probabilistic Safety Assessment

• Hazard Analysis

• Safety Performance

• Use of Experience from Other Plants

• Organization, Management and Safety Culture

• Procedures

• Human Factors

• Emergency Planning

• Radiological Impact on Environment

19 Example of U.S.

Alternatives to PSR IAEA PSR Safety Factor Summary of NRC Program Elements that Accomplish the Safety Factor Objectives Plant Design - The objective of the review is to determine the adequacy of the design and its documentation against current international standards and practice.

RTR plant design is maintained through the controls in 10CFR 50.59 which allows licensees to make changes following a safety review process.

RTR TSs typically include requirements to invoke higher management level reviews for changes to equipment considered important to safety.

Inspection Manual Chapter 2545 Research and Test Reactor Inspection Program IP (IP) 69005 - Evaluation of Changes, Test, or Experiments IP 69006 - Research and Test Reactors Organization and Operations and Maintenance Activities IP 69007-Research and Test Reactor Review and Audit and Design Change Functions IP 69008-Research and Test Reactor Procedures IP 69009-Research and Test Reactor Fuel Movement IP 69010- Research and Test Reactor Surveillance IP 69011-Research and Test Reactor Emergency Preparedness IP 69012-Research and Test Reactors Radiation Protection Actual Conditions of Structures, Systems, and Components (SSCs) - The objective of the review is to determine the actual condition of SSCs Important to Safety (ITS) and whether it is adequate to meet their design requirements and confirm the condition of SSCs is properly documented Initial application and license renewal review evaluate potential accidents and determine adequacy of proposed equipment important to safety to be included in TSs.

Thorough review and approval by licensing PM of any licensing amendments and changes Routine In-depth inspections by assigned facility inspectors IP 69005 - Evaluation of Changes, Test, or Experiments IP 69007 - Research and Test Reactor Review and Audit and Design Change Functions IP 69008 - Research and Test Reactor Procedures IP 69010- Research and Test Reactor Surveillance

20 U.S. Position on PSRs U.S. program elements are an alternative arrangement to PSRs.

PSRs are not consistent with the NRCs regulatory framework in which U.S. reactors are subject to ongoing licensing, inspection, audits, and oversight.

PSRs are not consistent with RTR minimum regulation of Atomic Energy Act.

The U.S. approach is arguably safer than the PSR process, since the U.S. paradigm is for the regulator to not wait until a scheduled PSR to take action against specific licensees.

U.S. and IRRS Mission 27

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• The U.S. 2010 IRRS Mission concluded that the NRC programs are intended to ensure that the goals of the PSR are met.

• The NRC continues to evaluate findings of PSRs conducted across the world to ensure lessons learned are incorporated in the NRCs assessment processes.

• As of today, no major gaps have been identified.

28 Summary of U.S Position

• The U.S. regulatory approach provides a continuum of assessment and review that ensures public health and safety and protection of the environment throughout the period of facility operation.

• The U.S. approach meets or exceeds the intent of PSR Safety Factors.

23 QUESTIONS