ML22203A156

7/28/2022 - NRC Public Meeting Presentation on Part 53 Framework B, Subparts N-U, Including the Alternative Evaluation for Risk Insights

ML22203A156
Person / Time
Issue date:	07/28/2022
From:	Robert Beall NRC/NMSS/DREFS/RRPB
To:
Beall, Robert
References
10 CFR Part 53, NRC-2019-0062, RIN 3150-AK31
Download: ML22203A156 (50)

Text

J u l y 2 8, 2 0 2 2 Public Stakeholder Meeting Part 53 Framework B

Agenda 2

Time Topic Lead Participant 10:00 AM - 10:15 AM Introductory Remarks NRC/External Stakeholders 10:15 AM - 10:30 AM Part 53 Introduction NRC 10:30 AM - 10:45 AM Framework B Introduction NRC 10:45 AM - 11:45 AM Open Discussion:

Subparts N - Definitions Subpart O - Construction/Manufacturing Subpart P - Operations Subpart Q - Decommissioning NRC/External Stakeholders 11:45 AM - 12:45 PM Lunch Break NRC/External Stakeholders 12:45 - 2:00 PM Open Discussion:

Subpart R - Application Requirements Subpart S - Licensing Maintenance Subpart T - Reporting Subpart U - Quality Assurance NRC/External Stakeholders 2:00 - 3:00 PM AERI Introduction and Open Discussion NRC/External Stakeholders 3:00 - 3:15 PM Break NRC/External Stakeholders 3:15 - 4:50 PM Open Discussion on Part 53 NRC/External Stakeholders 4:50 - 5:00 PM Concluding Remarks NRC/External Stakeholders

Meeting Format and Facilitation 3

Part 53 Introduction

Nuclear Energy Innovation and Modernization Act

• NEIMA requires the NRC to complete a rulemaking to establish a technology-inclusive, regulatory framework for optional use for commercial advanced nuclear reactors.

• The term technology-inclusive regulatory framework means a regulatory framework developed using methods of evaluation that are flexible and practicable for application to a variety of reactor technologies, including, where appropriate, the use of risk-informed and performance-based techniques and other tools and methods.

5

January 2019 NEIMA signed into law NEIMA Reports 2019, 2021 April - October 2020 Rulemaking Plan and Schedule SECY-20-0032 SRM SRM Response October - November 2021 Extension to:

• Enhance flexibility

• Enable further engagement on preliminary proposed rule text iterations January - June 2022

• Development of Framework B

• Additional iterations of preliminary proposed rule text released for Framework A Preliminary Proposed Rule Text Present

• Continued stakeholder engagement

• Integration of Framework A and B 6

NEIMA and Part 53 Development Stakeholder engagement on regulatory infrastructure for new commercial nuclear reactors Stakeholder engagement on Part 53 Example Initiatives Vision and Strategy LMP Fuel Qualification Codes and Standards TICAP/ARCAP X

X X

X X

X X

X X

X X

X X

X Stakeholder Engagement 22 Public Meetings since September 2020 X

X X

X X

X X

X X

Part 53 Rulemaking Process 7

Part 53 Rulemaking Schedule 8

Part 53 Licensing Frameworks Framework A o PRA-led approach o Functional design criteria o Top-down approach for meeting high-level safety criteria and defining key safety functions Framework B o Traditional use of risk insights o Principal design criteria o Bottom-up approach based on well-established safety functions o Includes an Alternative Evaluation for Risk Insights (AERI) approach Subpart A - General Provisions Subpart B - Safety Requirements Subpart C - Design Requirements Subpart D - Siting Subpart E - Construction/Manufacturing Subpart F - Operations Subpart G - Decommissioning Subpart H - Application Requirements Subpart I - License Maintenance Subpart J - Reporting Subpart K - Quality Assurance Subpart N - Definitions Subpart O - Construction/Manufacturing Subpart P - Operations Subpart Q - Decommissioning Subpart R - Application Requirements Subpart S - License Maintenance Subpart T - Reporting Subpart U - Quality Assurance 9

Quantitative Risk Information Bounding Approaches Traditional Use of PRA Risk-Informed Continuum Part 53 Licensing Frameworks 10

Part 53 Framework B Introduction

• Part 53 stakeholder feedback included consideration of international licensing approaches and flexibility in the use of probabilistic risk assessment (PRA)

• Previously released preliminary proposed rule text (Part 5X) outlined technology-inclusive, risk-informed alternatives for using the traditional technical requirements in Parts 50 and 52

• Including a traditional, technology-inclusive framework in Part 53 minimizes potential impact on existing requirements and centralizes alternatives for new commercial nuclear reactors

Background

12

Part 53 Subpart Comparison Subpart Title Framework A Subpart Framework B Subpart General Provisions Subpart A (Common)

Technology-Inclusive Safety Requirements Subpart B (Subpart R)

Design and Analysis Requirements Subpart C Siting Requirements Subpart D (Part 100)

Definitions Subpart N Construction and Manufacturing Requirements Subpart E Subpart O Requirements for Operation Subpart F Subpart P Decommissioning Requirements Subpart G Subpart Q Licenses, Certifications, and Approvals Subpart H Subpart R Maintaining and Revising Licensing Basis Information Subpart I Subpart S Reporting and Other Administrative Requirements Subpart J Subpart T Quality Assurance Criteria Subpart K Subpart U 13

Framework B Development Approach 14

Framework B Guidance Development Many Framework A and B guidance development activities are linked May involve updates or supplements to existing guidance covering existing regulatory frameworks Guidance for technical content of application requirements now part of Advanced Reactor Content of Application Project effort 15

Areas of Focus Integration of Frameworks A and B Ensure consistency between parallel provisions

• Siting

• Seismic Design Criteria

• Requirements for Operation Evaluate other provisions for potential alignment

• Definitions

• General Provisions Commonalities in Subpart A Continue consideration of stakeholder feedback 16

Part 53 Framework B Open Discussion

Subpart N - Definitions Subpart N contains terms that are specific to Framework B Common definitions remain in Subpart A (§ 53.020) 18

Subpart N - Definitions

• Discussion of Stakeholder Feedback Received

• Stakeholder Open Discussion 19

Subpart O - Construction and Manufacturing Requirements Parallel structure and content to Framework A Subpart E Variations largely limited to conforming changes needed to adapt Framework A provisions to Framework B 20

Subpart O - Construction and Manufacturing Requirements

• Discussion of Stakeholder Feedback Received

• Stakeholder Open Discussion 21

Subpart P - Requirements for Operation

• Structured similar to Subpart F in Framework A

• Programmatic requirements for security, emergency preparedness, and radiation protection aligned with those in Framework A

• Provisions for staffing, training, personnel qualifications, and human factors are largely equivalent between frameworks with the exception of GLROs

• Other requirements for operation informed by existing requirements applicable to applicants and licensees under Parts 50 and 52

• Maintenance, repair, and inspection programs

• Technical specifications

• Fire protection

• Primary containment leakage

• Environmental qualification of electrical equipment 22

Subpart P - Requirements for Operation

§ 53.4210 Maintenance, repair, and inspection programs.

§ 53.4213 Technical specifications.

§§ 53.4220 - 53.4299 General staffing, training, personnel qualifications, and human factors requirements.

§ 53.4300 Programs.

§ 53.4310 Programs: Radiation protection.

§ 53.4320 Programs: Emergency preparedness.

§ 53.4330 Programs: Security programs.

§ 53.4340 Programs: Quality assurance.

§ 53.4350 Programs: Fire protection.

§ 53.4360 Programs: Inservice inspection/inservice testing.

§ 53.4380 Programs: Environmental qualification of electric equipment

§ 53.4390 Programs: Procedures and guidelines.

§ 53.4400 Programs: Integrity assessment program.

§ 53.4410 Programs: Primary containment leakage rate testing program.

23

Subpart P - Requirements for Operation

• Discussion of Stakeholder Feedback Received

• Stakeholder Open Discussion 24

Subpart Q - Decommissioning Requirements Parallel structure and content to Framework A Subpart G Variations largely limited to conforming changes needed to adapt Framework A provisions to Framework B 25

Subpart Q - Decommissioning Requirements

• Discussion of Stakeholder Feedback Received

• Stakeholder Open Discussion 26

• Structured similar to Subpart H in Framework A

• Process-related requirements in Subpart R are identical between the frameworks

• Technical requirements informed by existing regulatory frameworks

• Requirements captured in content of application sections

• Technical content of application requirements consolidated in § 53.4730

• Many requirements from Parts 50 and 52 translated to Framework B with select updates and modifications for technology-inclusiveness

• Initiating event and accident analyses requirements evolved from initial Part 5X effort

• Requirements in § 53.4730(a)(5) cover AOOs, DBAs, BDBEs, severe accidents and chemical hazards

• Generally aligned with current requirements and, as appropriate, incorporates international concepts on DID

• Requirements for containment address the need for functional containment alternatives that may be employed by non-LWRs Subpart R - Licenses, Certifications, and Approvals 27

Subpart R - Licenses, Certifications, and Approvals

§ 53.4700 General Provisions.

§ 53.4725 Standards for review.

§ 53.4730 General technical requirements.

§ 53.4731 Risk-informed classification of structures, systems, and components.

§ 53.4740 Limited work authorizations.

§ 53.4750 Early site permits.

§ 53.4800 Standard design approvals

§ 53.4830 Standard design certifications.

§ 53.4870 Manufacturing licenses.

§ 53.4900 Construction permits.

§ 53.4960 Operating licenses.

§ 53.5010 Combined licenses.

28

• Technical content of application requirements consolidated in § 53.4730 o Reduces rule length o Minimizes the potential for requirements to diverge between application types Subpart R - Licenses, Certifications, and Approvals

§ 53.4730: General Technical Requirements COL OL CP ML DC SDA ESP (1)

X X

X X

X X

X (2)

X X

X X

X X

X (3)

X X

X X

X

(37)

X X

X X

X X

X Application Type

§ 53.4730(a)

Requirement 29

Subpart R - Licenses, Certifications, and Approvals

• Discussion of Stakeholder Feedback Received

• Stakeholder Open Discussion 30

Subpart S -

Maintaining and Revising Licensing Basis Information

• Parallel structure and content to Framework A Subpart I

• Notable differentials o § 53.6010, Application for amendment of license o § 53.6040, Updating licensing basis information and determining the need for NRC approval o § 53.6045, Updating final safety analysis reports o § 53.6050, Evaluating changes to facility as described in final safety analysis reports o § 53.6052, Maintenance of risk evaluations

• Remaining variations largely limited to conforming changes to adapt Framework A provisions to Framework B 31

Subpart S - Maintaining and Revising Licensing Basis Information

• Discussion of Stakeholder Feedback Received

• Stakeholder Open Discussion 32

Subpart T - Reporting and Other Administrative Requirements

• Parallel structure and content to Framework A Subpart J

• Notable differentials o § 53.6320(e) added to align with state-of-practice policy initiative on reporting requirement for fee purposes o § 53.6330, Immediate notification requirements for operating commercial nuclear plants, aligned with § 50.72 o § 53.6340, Licensee event report system, aligned with § 50.73

• Remaining variations largely limited to conforming changes to adapt Framework A provisions to Framework B 33

Subpart T - Reporting and Other Administrative Requirements

• Discussion of Stakeholder Feedback Received

• Stakeholder Open Discussion 34

Subpart U - Quality Assurance

• Subpart U parallels structure and content of Framework A Subpart K

• Closely aligned with 10 CFR Part 50 Appendix B (18 criteria)

• Exception: § 53.6635, Control of Purchased Material, Equipment and Services (10 CFR Part 50 Appendix B Criterion VII) o Commercial nuclear plant used in lieu of nuclear power plant o Ensures consistency with terminology throughout Part 53 35

Subpart U - Quality Assurance

• Discussion of Stakeholder Feedback Received

• Stakeholder Open Discussion 36

Part 53 Framework B Alternative Evaluation for Risk Insights (AERI)

• Evolution of the AERI approach is an example of modern risk-informed regulation:

• Achieves the underlying purposes of Commission policy statements:

• Policy Statement on the Regulation of Advanced Reactors (73 FR 60612; October 14, 2008)

• Safety Goals for the Operation of Nuclear Power Plants (51 FR 28044; August 4, 1986 as corrected and republished at 51 FR 30028; August 21, 1986)

• Severe Reactor Accidents Regarding Future Designs and Existing Plants (50 FR 32138; August 8, 1985)

• Use of Probabilistic Risk Assessment Methods in Nuclear Regulatory Activities (60 FR 42622; August 16, 1995)

• Provides sufficient risk information to inform licensing decisions

• Right-sizes the effort required to evaluate risk

• Two pre-decisional draft regulatory guides (PDGs) have been developed to:

• Clarify for potential applicants the logic and the expectations of the NRC staff

• Address related ACRS recommendations to start with a blank sheet of paper (10/7/2019, 10/21/2020, 5/30/2021, and 10/26/2021)

Evolution of the AERI Alternative Approach Uses risk insights to enhance regulatory efficiency.

38

Risk insights support or complement deterministic analyses, consistent with traditional approach Includes requirement to provide a description of the plant-specific PRA and its results translated to Framework B

§ 52.79(a)(44) § 53.4730(a)(34)(i)

Optional alternate risk evaluation for applicants that meet the criteria in § 53.4730(a)(34)(ii) o No PRA required o Implicitly demonstrates that quantitative health objectives (QHOs) are met, searches for severe accident vulnerabilities, and provides risk insights without a requirement for a PRA o Inherently addresses the mitigation of beyond-design-basis events requirements when AERI entry criteria are met o Cannot implement risk-informed applications if AERI approach is used Risk evaluations (PRA or AERI) must be maintained consistent with requirements in Subpart S

(§ 53.6052, informed by § 50.71(h))

Assessing Risk in Framework B 39

40 40 Perform transient and accident analyses Perform design basis accident radiological consequences analyses Identify and analyze the bounding event Finish PRA development Select LBEs Select DBAs Classify SSCs Continue design and licensing activities Evaluate defense-in-depth Comprehensive and systematic initiator search and event sequence delineation without preconceptions or reliance on predefined lists Select licensing events Select licensing framework Perform transient and accident analyses Perform design basis accident radiological consequences analyses Elect to develop PRA Finish PRA development Continue design and licensing activities Continue design and licensing activities A

Parts 50 and 52 with LMP Part 53 Framework A Parts 50 and 52 without LMP Part 53 Framework B B

C D

E F

G H

I J

K L

M N

O yes no Applicant decision PDG-1413, Technology-Inclusive Identification of Licensing Events for Commercial Nuclear Plants PDG-1414, Alternative Evaluation for Risk Insights (AERI) Framework Licensing Modernization Project (LMP) guidance - NEI 18-04, Rev. 1, as endorsed in RG 1.233 AERI entry condition met?

P yes no Q

Licensing Frameworks - Risk Evaluation Perspective Alternative Evaluation for Risk Insights Notes:

1)

Each step builds on all of the preceding steps (considers all information available at that point) 2)

Feedback loops (e.g., the impact of design revisions) are not shown AERI Q1 Develop demonstrably conservative risk estimate using the bounding event Q2 Search all event sequences for severe accident vulnerabilities Q3 Develop risk insights by reviewing all event sequences Q4 Assess defense-in-depth adequacy by reviewing all event sequences ONLY for Part 53 Framework B 40

Proposed AERI Entry Condition 53.4730(a)(34) Description of risk evaluation.

A description of the risk evaluation developed for the commercial nuclear plant and its results. The risk evaluation must be based on:

(i) A PRA, or (ii) An AERI, provided that the dose from a postulated bounding event to an individual located 100 meters (328 feet) away from the commercial nuclear plant does not exceed 1 rem total effective dose equivalent (TEDE) over the first four days following a release, an additional 2 rem TEDE in the first year, and 0.5 rem TEDE per year in the second and subsequent years.

41 The AERI entry condition is not a safety or siting criterion!!!

42 reference point is the exclusive area boundary (EAB) reference point = 100 meters QHO = 2E-6 If the reference point is the EAB, then need to credit accident frequency when EAB radius > 100 meters Premise: It is feasible to identify a bounding event such that the consequence of any event sequence is less than or equal to the consequence of the bounding event.

Implication: Risk is less than or equal to the product of the sum of event sequence frequencies and the consequence of the bounding event.

Note: It is only necessary to estimate the sum of the event sequence frequencies; it is not necessary to estimate each individual event sequence frequency using a PRA.

Development of the AERI Entry Condition

Technology-Inclusive Identification of Licensing Events for Commercial Nuclear Plants (PDG-1413)

• Formatted like a regulatory guide; currently a pre-decisional draft regulatory guide

• Section A: Applies to LWRs and non-LWRs licensed under Parts 50, 52, and 53 (Frameworks A and B)

• Section B (Discussion):

o Identifies licensing events for each licensing framework o Provides historical perspectives (early licensing, development of the standard review plan (SRP))

o Addresses ACRS recommendations to start with a blank sheet of paper (10/7/2019, 10/21/2020, 5/30/2021, and 10/26/2021)

• Section C (Staff Guidance) provides an integrated approach for:

o Conducting a systematic and comprehensive search for initiating events o Delineating a systematic and comprehensive sets of event sequences o Grouping the lists of initiating events and event sequences into licensing events

• Appendix A (Comprehensive Search for Initiating Events):

o Reviews techniques for searching for initiating events and points the user to helpful references o Does not endorse or recommend any specific technique 43

Alternative Evaluation for Risk Insights (AERI) Framework (PDG-1414)

• Formatted like a regulatory guide; currently a pre-decisional draft regulatory guide

• Section A (Introduction): Only applies to LWRs and non-LWRs licensed under Part 53 Framework B

• Sections B (Discussion) & C (Staff Guidance) - Components of the AERI approach:

o Identification and characterization of the bounding event Definition of a bounding event Multiple events may need to be considered as bounding events o Determination of a consequence estimate for the bounding event to confirm that the reactor design meets the AERI entry condition o Determination of a demonstrably conservative risk estimate for the bounding event to demonstrate that the QHOs are met Assumed frequency of 1/yr consistent with frequency of all event sequences for LWRs Applicant may use a lower frequency with justification o Search for severe accident vulnerabilities for the entire set of licensing events Definitions of severe accident and severe accident vulnerability o Identification of risk insights for the entire set of licensing events o Assessment of defense-in-depth adequacy for the entire set of licensing events 44

Alternative Evaluation for Risk Insights (AERI)

• Discussion of Stakeholder Feedback Received

• Stakeholder Open Discussion 45

Open Discussion 46

• Discussion of Other Stakeholder Feedback

• Stakeholder Open Discussion

Concluding Remarks 47

Additional Information Additional information on the 10 CFR Part 53 rulemaking is available at https://www.nrc.gov/reactors/new-reactors/advanced/rulemaking-and-guidance/part-53.html For information on how to submit comments go to https://www.regulations.gov and search for Docket ID NRC-2019-0062 For further information, contact Robert Beall, Office of Nuclear Material Safety and Safeguards, telephone: 301-415-3874; email:

Robert.Beall@nrc.gov 48

ACRS Advisory Committee on Reactor Safeguards AEC Atomic Energy Commission AERI Alternative evaluation for risk insights AOO Anticipated operational occurrence ARCAP Advanced Reactor Content of Application Project ATWS Anticipated transient without scram BDBE Beyond design basis event BE Bounding event CFR Code of Federal Regulations COL Combined license CP Construction permit DANU Division of Advanced Reactors and Non-Power Production and Utilization Facilities Acronyms EAB Exclusion area boundary DBA Design basis accident DBE Design basis event DC Design certification DG Draft regulatory guide DRA Division of Risk Assessment ESP Early site permit FR Federal Register GLRO Generally licensed reactor operator HFE Human factors engineering IAEA International Atomic Energy Agency IEFR Individual early fatality risk ILCFR Individual latent cancer fatality risk LBE Licensing basis event 49

LCO Limiting condition for operation LMP Licensing Modernization Project LNT Linear no-threshold LWR Light water reactor ML Manufacturing license NEI Nuclear Energy Institute NEIMA Nuclear Energy Innovation and Modernization Act NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation NUREG U.S. Nuclear Regulatory Commission technical report designation OL Operating license PDG Pre-decisional draft regulatory guide PRA Probabilistic risk assessment Acronyms QA Quality assurance RO Reactor operator QHO Quantitative health objective RES Office of Nuclear Regulatory Research RG Regulatory guide SBO Station black out SDA Standard design approval SRO Senior reactor operator SRP Standard review plan SSCs Structures, systems, and components STA Shift technical advisor TEDE Total effective dose equivalent TICAP Technology Inclusive Content of Application Project 50