ML22196A033

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M220721: Slides - Briefing on 10 CFR Part 53 Licensing and Regulation of Advanced Nuclear Reactors - GEH Slides
ML22196A033
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Issue date: 07/21/2022
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GEH Perspective on Part 53 Licensing Dennis Henneke; Consulting Engineer, Advanced Reactors July 21, 2022

GEH Advanced Reactors GE Hitachi is supportive of development of a risk-informed, performance-based licensing process.

GE Hitachi is currently supporting two reactor designs being proposed under a 10 CFR Part 50 licensing process. Both plants utilize passive and inherent safety features extensively.

The two designs would currently be processed under different Part 53 Frameworks:

  • Supporting TerraPower and the Natrium Sodium-Cooled Fast Reactor, which is utilizing the Licensing Modernization Project (LMP) process, and would be under Framework A.
  • The BWRX-300 LWR is being developed utilizing a risk-informed IAEA approach (utilizing IAEA SSR-2/1) due to being initially licensed at the Darlington site in Canada.

This is currently listed under Framework B.

Neither would likely utilize the Part 53 licensing as currently proposed, due to the increased burden under Part 53, and minimal benefit to transition from Part 50.

We are proposing several improvements below, followed by some clarification details on the frameworks and the supporting safety analysis (safety case).

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© 2022, GE Hitachi Nuclear Energy. All rights reserved

Part 53 Recommendations

1. A PRA-forward approach, such as a Risk-Informed(RI)-IAEA approach, which has the same basic attributes as LMP, should be included in Framework A since there is little difference between the results/outcome (see the following slides) a) This goal should also support the international effort on harmonization of licensing requirements for advanced reactors and SMRs.
2. Very few of the sub-parts of Part 53 are risk-informed. The NRC should reconsider the current requirements, with a specific goal of utilizing a RI process. Consider the following question:

a) If a reactor has a very small risk contribution for Attribute X (fill in the blank Fire, combustible gas control, EQ, operator actions, etc.), are the requirements for the Attribute different in comparison to a reactor such as the current operating fleet?

b) Our review currently indicates none of the sub-parts can answer yes to the above.

c) One goal of Part 53 should be to result in overall reduction in burden over part 50 for low-risk Advanced Reactors.

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© 2022, GE Hitachi Nuclear Energy. All rights reserved

Safety Analysis - LMP Approach (currently Framework A)

Arrow Keys Initial Basis LBEs (Postulated PRA/LMP Deterministic Initiating Events Analysis Safety Analysis

- PIEs)

Confirmation Inform Basis Must Agree SSC Classification BDB/DEC DID Adequacy Analysis*

  • Also gets input from LBEs/PIEs Key Points:
1) An LMP Approach still requires a DSA, which must be consistent with the LMP output.
2) If the PRA/LMP basis were removed from the results; the analysis could be processed under existing deterministic rules.

© 2022, GE Hitachi Nuclear Energy. All rights reserved

Safety Analysis - using an IAEA Approach (Currently Framework B)

Arrow Keys Initial Basis LBEs (Postulated Deterministic PRA Initiating Events Safety Analysis

- PIEs)

Confirmation Inform Basis SSC Classification BDB/DEC DID Adequacy Analysis*

Key Points:

1) The IAEA guidance includes use of PRA/PSA to inform or confirm the results from the deterministic analysis. DID adequacy is more rigorous (5 defense levels) than the LMP process.
2) The results of the IAEA and LMP approaches would be similar, with the IAEA approach being slightly more conservative for SSC classification.

© 2022, GE Hitachi Nuclear Energy. All rights reserved

Framework A and B Safety Analysis Comparison LMP Approach (currently Framework A) Risk-Informed IAEA Approach LBEs LBEs Determinist Determinist PRA/LMP (Postulated (Postulated Initiating ic Safety PRA Initiating ic Safety Analysis Events - PIEs) Analysis Events - PIEs) Analysis Must Agree SSC SSC Classification Classification DID BDB/DEC DID BDB/DEC Adequacy Analysis

  • Adequacy Analysis
  • Key Point:
1) The outcome of the two processes above are similar - and can be generalized as a deterministic safety analysis that is harmonized with the PRA/PSA, with a detailed DID evaluation.

© 2022, GE Hitachi Nuclear Energy. All rights reserved

Acronym List BDB -Beyond Design Basis DEC - Design Extension Condition DID - Defense In Depth DSA - Deterministic Safety Analysis IAEA - International Atomic Energy Association LBE - Licensing Basis Event LMP - Licensing Modernization Project (see NEI 18-04)

PIE - Postulated Initiating Event PRA/PSA - Probabilistic Risk Assessment/Safety Assessment RI - Risk-informed SSC - Systems, Structures and Components 7

© 2022, GE Hitachi Nuclear Energy. All rights reserved

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