ML23130A062

M230516: Slides/Supporting Presentation Material - D. True - Update on 10 C.F.R. Part 53 Licensing and Regulation of Advanced Nuclear Reactors

ML23130A062
Person / Time
Issue date:	05/16/2023
From:	NRC/OCM
To:
Shared Package
ML23067A030	List: ML23130A062 ML23130A063 ML23130A064 ML23130A065 ML23130A066 ML23130A097 ML23130A100 ML23142A113
References
M230516, 10 CFR Part 53, NRC-2019-0062, RIN 3150-AK31
Download: ML23130A062 (8)

Text

Part 53:

A Generational Opportunity Presented to:

U.S. Nuclear Regulatory Commission May 16, 2023

©2023 Nuclear Energy Institute

©2023 Nuclear Energy Institute l 1

Main Points Draft proposed Part 53:

1. Too complex

2. Overly burdensome

3. Fails to meet the moment Industrys Key Issues Unchanged From 18 Months Ago

©2023 Nuclear Energy Institute 2

Too Complex 1,300 pages Including guidance level detail in the rule Two frameworks - prescribing methods

• QHOs and specific uses of PRA in the rule New terminology/programs

• e.g., replacing reasonable assurance of adequate protection with new legal standards

©2023 Nuclear Energy Institute 3

Overly Burdensome Some, but relatively little modernization

• Technology inclusive safety characteristics (Framework A)

• Some performance-based approaches for security and fitness for duty Aggregated Regulatory Analysis hides regulatory burdens Unjustified additional burden

• Facility Safety Program

• ALARA in Design

• Design for the Beyond Design Basis

©2023 Nuclear Energy Institute 4

Key Issues Unchanged No Need for Two Frameworks Remove QHOs as Performance Criteria in Rule Remove ALARA as a Design Requirement Remove Requirements to Design to Protect Against and Withstand BDBEs Remove Facility Safety Program Reconcile New Programs and Terminology November 2021 Letter: ML21309A578 August 2022 Letter: ML22243A257 ©2023 Nuclear Energy Institute 5

Fails to Meet the Moment NEI/USNIC survey of industry

• 18 of 21 do not plan to use rule in current form Efficiency must become a priority Significant areas did not receive updates

• Siting

• Manufacturing licenses (removed in proposed rule)

• Improvements to process efficiencies

©2023 Nuclear Energy Institute 6

Path Forward Issuing proposed rule as-is for comment not efficient

• NRC has the information it needs to resolve stakeholder concerns Industry committed to a successful Part 53

• NEI will continue to remain fully engaged

• Member interest has waned due to frustrations Re-Direction Needed

©2023 Nuclear Energy Institute 7

Acronyms ALARA - As Low As Reasonably Achievable BDBE - Beyond Design Basis Event NEI - Nuclear Energy Institute PRA - Probabilistic Risk Assessment QHO - Quantitative Health Objective USNIC - United States Nuclear Industry Council

©2023 Nuclear Energy Institute 8