ML21243A564

NRC Use of Codes and Standards - Fall 2021 Week 2 Engr 2125 (Part 2)

ML21243A564
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Issue date:	09/07/2021
From:	Robert Roche-Rivera NRC/RES/DE/RGDB
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NRC Use of Codes and Standards Robert Roche-Rivera, NRC/RES Presented to: ME/ENGR 2125 Introduction to Nuclear Codes & Standards and Regulatory Endorsement September 7, 2021 1

Disclaimer This presentation was prepared as an account of work sponsored by an agency of the U.S. Government. Neither the U.S. Government nor any agency thereof, nor any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third partys use, or the results of such use, of any information, apparatus, product, or process disclosed in this presentation, or represents that its use by such third party would not infringe privately owned rights. The views expressed in this presentation are not necessarily those of the U.S. Nuclear Regulatory Commission.

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Who We Are

• The Energy Reorganization Act of 1974 created the U.S. Nuclear Regulatory Commission from a portion of the former Atomic Energy Commission to independently regulate commercial uses of nuclear material; other duties of the former Atomic Energy Commission were assigned to the Department of Energy.

• The NRC is headed by four Commissioners and a Chairman, all appointed by the President and confirmed by the Senate for staggered five-year terms. No more than three can be from the same political party.

• The NRC has about 3,000 staff members, at headquarters, 4 regional offices, and at power plant 3 sites.

Our Mission 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.

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Some Nuclear Facts

• Currently 93 nuclear power reactors supply about 19 percent of the electricity in the U.S.

• Nuclear materials are used in medicine for cancer treatment and diagnosis.

• Nuclear materials are widely used in industry, such as in density gauges, flow measurement devices, radiography devices and irradiators.

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The NRC Regulates:

• Nuclear reactors - commercial power reactors, research and test reactors;

• Nuclear materials - nuclear reactor fuel, radioactive materials for medical, industrial and academic use;

• Nuclear waste - transportation, storage and disposal of nuclear material and waste, decommissioning of nuclear facilities; and

• Nuclear security - physical security and cyber security of nuclear facilities and materials from sabotage, theft, diversion, and other malicious acts.

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NRC Primary Functions

• Develop regulations and guidance

• License or certify applicants

• Oversee licensee operations and facilities

• Evaluate operational experience

• Conduct research 7

NRC Defense in Depth Concept

• Multiple independent and redundant layers of defense to compensate for hazards, failures or errors so that no layer is exclusively relied upon

• Protection, mitigation and emergency preparedness

1. Protection against internal, external & security-related events

2. Mitigation - hardened safety systems

• Robust containment structure

• Post 9/11 requirements

• Post Fukushima requirements

3. Emergency preparedness

• Evacuation plans

• Sheltering

• Potassium Iodide (KI) 8

NRCs Policy on Consensus Standards

• Involve all interested stakeholders in the NRCs regulatory development processes

• Participate in the development of consensus standards that support the NRCs mission

• Use consensus standards developed by voluntary consensus standards bodies consistent with the provisions of Federal law 9

NTTAA, OMB Circular A-119, and NRC MD 6.5

• National Technology Transfer and Advancement Act (1995) (Pub. L. 104-113)

- Established policy for Government to participate in development and adoption of consensus standards

- Government must consider consensus standards in lieu of Government-unique standards

• OMB Circular A-119 provides guidance for implementing NTTAA

- Agencies report annually to the National Institute of Standards and Technology (NIST), to Congress

• NRC Management Directive (MD) 6.5

- Provides direction to the NRC staff for implementing the NTTAA and OMB Circular A-119.

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Nuclear Energy Innovation and Modernization Act (NEIMA)

• Nuclear Energy Innovation and Modernization Act (Public Law 115-439)

- Directs the NRC to collaborate with standards-setting organizations to:

(1) identify specific technical areas for which new or updated standards are needed to support the commercial advanced nuclear reactor licensing process and (2) incorporate the respective consensus-based codes and standards into the regulatory 11 framework.

The Consensus Standards Process

• Administered by American National Standards Institute (ANSI)

• Implemented by Standards Development Organizations (SDOs), such as ASME, ANS, IEEE

• Consensus: Due process + substantial agreement

- Not strictly = unanimity

• Due process (for ANSI accreditation) - any party with a direct and material interest has a right to participate by:

- expressing a position and its basis

- having that position considered

- having the right to appeal 12

How NRC uses Codes and Standards - Rulemaking

• NRC establishes rules and regulations that have to be satisfied to receive and maintain a license.

• NRC regulations are contained in Title 10 -

Energy, of the Code of Federal Regulations (CFR), Chapter I - Nuclear Regulatory Commission, Volume 1 (Parts 1 - 50) and Volume 2 (Parts 51 - 199).

• Standards may be incorporated by reference into NRC regulations.

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How NRC uses Codes and Standards - Guidance

• Methods of satisfying NRC regulations are explained in NRC Regulatory Guides (RGs)

• Standard Review Plans explain how NRC reviews applications for licenses and license amendments

• Both widely reference Codes and Standards 14

Endorsement through Rulemaking

• Most formal of NRC endorsement processes

• Standards endorsed in rulemaking process become licensee requirements

• Backfit Rule considered

• Includes ACRS, CRGR, and public/stakeholder comment reviews

• Takes 2-3 years to complete

• About 1% of cited standards

• Rulemaking process improvements under way 15

Special Rulemaking: 10 CFR 50.55a

• Incorporates by reference and mandates use of ASME B&PV Code, Sections III (design) and XI (inspection of operating components), and ASME Operation and Maintenance Code

• Imposes NRC conditions

• Incorporates by reference three Regulatory Guides that endorse the use of selected ASME Code Cases

• Incorporates by reference two IEEE Standards:

- Standard 279 - Criteria for Protection Systems for Nuclear Power Generating Stations

- Standard 603 - Standard Criteria for Safety Systems for Nuclear Power Generating Stations 16

Reactor Vessel Before Installation -

ASME Section III 17

In-service Inspection of Reactor Vessel Welds - ASME Section XI 18

Endorsement through Regulatory Guides

• Describe methods that the staff considers acceptable for use in implementing specific parts of the agencys regulations

• Not substitutes for regulations; compliance with RGs is not required

• Best repository of the current staff position

• Include ACRS, CRGR and public comment reviews

• Take 1 - 11/2 years to complete

• Receive periodic review every 10 years 19

Endorsement in Standard Review Plans

• Guidance to staff, but publicly available

• Explain how NRC will review applications for licenses and license amendments

• Endorsed standards are not requirements

• Includes ACRS, CRGR and public comment reviews 20

Endorsement in other documents

• Examples

- Inspection Procedures & Manuals

- Standard Design Certifications

- Individual Licenses

- NUREGs, white papers, basis documents 21

Some recent or current activities related to endorsement of C & S

• NFPA

• ASME

• ASME/ANS PRA

• AISC

• ASCE

• IEEE

• Standards for New and Advanced Reactors 22

National Fire Protection Association (NFPA) Standard

• 10 CFR 50.48(c) was added to allow use of performance-based approach

- as a substitute for 10 CFR 50.48(b), Appendix R

- 50.48(c) has additional limitations on NFPA 805

- 50.48(a) requirements remain in place 23

ASME Standards 24

ASME/ANS Standards 25

AISC Standard 26

ASCE Standard 27

IEEE Standards 28

Standards for New and Advanced Reactors (e.g., SMRs, Non-LWRs)

• ORNL/SR-2017/520 (September 2017),

Assessment of Applicability of Standards Endorsed by Regulatory Guides to Sodium Fast Reactors (SFRs)

• NRC/ANS Advanced Non-Light Water Reactor Workshop (May 2018; ML18152B668)

• ANS Special Report - Setting the Right Bar:

How Consensus Standards Help Advanced Reactor Development (November 2019)

• NEI 19-03, Advanced Reactor Codes and Standards Needs Assessment (March 2020)

• NEI/ANS Advanced Reactors Codes &

Standards Workshop (June 2020) 29

NRC Standards Forum Usually held once a year in the fall NRC-led collaborative effort between standards development organizations, government, industry, and academia

Purpose:

-Facilitate discussions on codes and standards needs.

-Collaborate to accelerate the development of codes and standards and the NRC's endorsement of them in its regulations and regulatory guides.

2020 Standards Forum

- Held on October 13, 2020.

- Marked the fourth NRC Standards Forum and first all-virtual Standards Forum.

- Attended by close to 300 participants.

- Focused in part on codes and standards for advanced reactors.

- Next Forum is scheduled for September 15, 2021.

To register for the 2021 NRC Standards Forum, please visit the NRC webpage at the following link:

https://www.nrc.gov/pmns/mtg?do=details&Code=20211034 (in the webpage, please access the Webinar ink) 30

NRC Review and Endorsement of ASME Sec III, Div 5, High Temperature Reactors

• Draft Guide - 1380, and NUREG-2245

- Issued for public comments on August 20, 2021 (86 FR 46888)

• Staff supported by:

- PNNL (ML20269A145),

- ANL (ML21090A033),

- ORNL (ML20269A125),

- NUMARK/EMC2 (ML20349A003, ML20358A145, and ML20349A002) 31

Standards for Advanced Manufacturing

• ASTM E08/F42 Symposiums on Fatigue and Fracture of AM Materials & Components and Structural Integrity of AM Materials and Parts

• ASME special committee on AM

• NRC public workshop Additive Manufacturing for Reactor Materials and Components, Nov. 2017

- Scope included standardization activities, AM research and applications in nuclear and other industry, AM processes and capabilities, technical and regulatory challenges

- Proceedings: NUREG/CP-0310 (7/2019; ML19214A205)

• NRC public workshop on Advanced Manufacturing Technologies for Nuclear Applications, Dec. 2020

- Scope included nuclear industry implementations plans, codes and standards activities, research findings, and regulatory approaches in other industries 32

International Standards Developers

• Developers

- International Atomic Energy Agency (IAEA) Safety Standards, Safety Guides, Codes of Conduct

- International Standards Organization (ISO)

Standards

- International Electrotechnical Commission (IEC)

- International Committee on Radiation Protection (ICRP) recommendations

• NRC participates in the development work of these & other organizations

• Investigating ways to use international standards 33

NRC Response to Fukushima Event (11 March 2011)

• Incident Response Center entered Monitoring Mode

• Japan site team was dispatched to support U.S. Ambassador and Japanese regulatory counterparts

• Near Term Task Force conducted a methodical and systematic review

• Near term actions included conducting additional inspections regarding coping measures for extensive damage mitigation 34 IEEE Spectrum

NRC Response to Fukushima Event

• Recommendations for Enhancing Reactor Safety in the 21st Century, July 2011 (ML111861807)

• Near Term Task Force Conclusions

- No imminent risk from continued operation and continued licensing activities

- Similar sequence of events in the U.S. is unlikely

- Mitigation measures could reduce the likelihood of core damage and radiological releases

- NRCs regulatory framework could be enhanced

• NRC Rule: Mitigation of Beyond Design Basis Events, effective 9/9/2019 35

Fukushima Cooperative Efforts

• SDO Task Group on Design Basis and Response to Severe Accidents

- Oversight Team: ASME, ANS, JSME, NEI, NRC

- Coordinating with NEI, INPO, EPRI, IEEE

• NRC & other U.S. stakeholders worked with other IAEA member states to address related issues in Safety Standards and Safety Guides

- Review/comment on Draft IAEA Commission on Safety Standards-Secretariat Plan for the Review of the IAEA Safety Standards

- Nuclear Safety Standards Committee (NUSSC) 36

Conclusions (1/2)

• NRC makes extensive and effective use of C&S as part of its regulatory process

• Regulatory vehicles include regulations, regulatory guides, standard review plans

• C&S written by numerous standards bodies, e.g., ANS, ASME, ASCE, AISC, IEEE

• NRC staff participate in writing C&S and have influence in setting the priorities of C&S bodies 37

Conclusions (2/2)

• Proper endorsement of codes & standards creates durable regulatory guidance that is key to improved safety performance

• Coordination and collaboration between standards development and endorsement activities will further improve process effectiveness 38