M211209: Slides - Briefing on 10 CFR Part 53 Licensing and Regulation of Advanced Nuclear Reactors - E Lyman SlidesML21337A138 |
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12/03/2021 |
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ML21301A174 |
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M211209 |
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Category:Commission Meeting Slides
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UCS Perspectives on Part 53 Dr. Edwin Lyman Director of Nuclear Power Safety Climate and Energy Program Union of Concerned Scientists December 9, 2021
The foundation of a new reactor licensing rule
- A new reactor licensing rule should
- Clearly provide for levels of safety, security, and environmental protection at least equivalent to the operating fleet
- Or preferably, greater levels than the operating fleet
- Employ risk-informed provisions only to the extent that state-of-the-art risk assessment methods allow
- Maintain robust defense-in-depth
- Contain clear requirements for prototype testing
- Reject provisions that could result in disproportionate outcomes to disadvantaged communities 2
The Part 53 process is broken
- Although UCS appreciates the greater degree of public engagement for developing the draft rule language required in SRM-SECY-0020-0032, the intermittent and iterative process has been ineffective and inefficient, and the high degree of industry involvement threatens to compromise the NRCs regulatory independence
- What was intended to be a flexible, technology-inclusive approach has split into at least three alternatives
- Following the next release of draft language, UCS recommends that a more conventional notice-and-comment rulemaking process be restored, and that the NRC consider developing a regulatory basis document 3
Part 53 should be scrapped
- Development of a technology-inclusive rule does not require starting from scratch and rewriting the entire rule book
- The population of new reactor designs that the NRC is likely to receive for review for many years to come is not actually that diverse
- Coolants: liquid-metal, gas, molten salt
- Fuels: metal, TRISO, molten salt
- Size: very small (<20 MWe), small (<300 MWe); medium (<600 MWe)
- The accident spectrum is fairly well-characterized for many of these design categories 4
Alternative approach
- Rather than a new part, NEIMAs intent can be addressed through a series of appendices to Parts 50/52
- Coolant-specific, size-specific, and fuel specific
- All regulations in Parts 50/52 that are not applicable
- Design-specific alternatives for inapplicable requirements that correspond to a safety or security function (e.g. 50.46)
- Anticipated operational occurrences, design-basis accidents, and severe accidents determined through a structured process such as the Licensing Modernization Project, with sufficient error bars on frequency estimates to adequately encompass uncertainties
- Should be complemented with a requirement to conduct systematic searches for hazards, initiating events, and accident scenarios, as recommended by ACRS 5
Core safety approach
- To ensure a clear correspondence with requirements for the operating fleet, fundamental defense-in-depth principles for AOOs and DBAs should be maintained on an equivalent level, including safety-related SSCs and the single-failure criterion
- Severe accident risks should not be greater than those for the operating fleet (more on this later) 6
Alternative approach
- Part 53 will duplicateor may even be inconsistent withother rulemakings taking place for new reactors
- Limited-scope security
- EP requirements
- The risk-informed licensing approach should focus first and foremost on the design and construction of the plant
- Requirements covered by other parts of the regulations should remain where they are
- risk-informed voluntary alternatives should be available once designs have been approved (or demonstrated)
- A structured approach is needed for application of analytical safety margins to operating flexibilities to ensure sufficient layers of defense-in-depth are maintained 7
Severe accidents and the use of PRA
- There is no credible way to risk-inform licensing without a PRA other than providing defense-in-depth measures with unquantified risk benefitsi.e. a deterministic approach
- There is no plausible way to define a maximum credible accident without a PRA (maximum credible implies a likelihood threshold) 8
Role of Quantitative Health Objectives in licensing
- The QHOs are not adequate metrics for incorporation as regulatory requirements
- Magnitude is too high
- Do not include societal risks (land contamination)
- Are based on population-averaged radiological risks that are insensitive to the disproportionate effects of ionizing radiation on disadvantaged populations such as Black people 9
Conclusion
- The 9-month extension in the Part 53 schedule should provide some room for the NRC to reconsider the direction of the rulemaking
- UCS recommends a more modest approach that preserves the foundational principles underlying the current rules, while providing for design-specific 10
Acronyms
- CDF: Core Damage Frequency
- DBA: Design-Basis Accident
- QHOs: Quantitative Health Objectives
- SSCs: Structures, Systems, and Components