ML22342B223

NRC Presentation on Regulatory Framework for Advanced Reactors for the International Atomic Energy Agency Consultancy Meeting on Safety of Liquid Metal Fast Reactors

ML22342B223
Person / Time
Issue date:	12/07/2022
From:	William Kennedy NRC/NRR/DANU/UARP
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Download: ML22342B223 (1)

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NRC Regulatory Framework for Advanced Reactors IAEA Consultancy Meeting on the Development of a Technical Document on the Safety of Liquid Metal Cooled Fast Reactors December 7 - 9, 2022 William Kennedy Reed Anzalone U.S. Nuclear Regulatory Commission

U.S. Nuclear Regulatory Commission The NRC's mission is 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.

The Office of Nuclear Reactor Regulation (NRR) is responsible for accomplishing key components of the NRC's nuclear reactor safety mission, including activities that encompass licensing, oversight, siting, rulemaking, and incident response for civilian nuclear reactors.

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NRC is preparing for a Variety of Advanced Nuclear Technologies EVOLVING LANDSCAPE A number of current and potential applications Research and Test Reactors Molten Salt Reactors Small Modular Reactors High-Temperature Gas-Cooled Reactors Liquid Metal Cooled Fast Reactors Many different reactor technologies Range of sizes from < 10 MWt to 600 MWt Multiple reactors on a single site Hazards vary with power level and radionuclide inventory Micro-Reactors 3

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LMFR Landscape

• Preapplication Safety Evaluation Report for the Power Reactor Innovative Small Module (PRISM) Liquid-Metal Reactor, 1994

• TerraPower-GEH Natrium sodium fast reactor

• ARC-100 sodium fast reactor

• Westinghouse lead-cooled fast reactor 5

Vision & Strategy Nuclear Energy Innovation and Modernization Act (NEIMA; Public Law 115-439), dated January 2019, requires the NRC to complete a rulemaking to establish a technology-inclusive, regulatory framework for optional use for commercial advanced nuclear reactors no later than December 2027 6

Modernizing the Regulatory Framework Environmental Review Functional Containment Physical Security Emergency Preparedness Siting Content of Application Licensing Modernization Project (LMP) 10 CFR Part 53 Technology-Inclusive, Risk-Informed, and Performance-Based Regulatory Framework Fuel Qualification 7

10 CFR = Title 10 of the Code of Federal Regulations NRC Website on advanced reactors

10 CFR Part 53 is being developed Optional rule; 10 CFR Parts 50 and 52 remain for use Promote regulatory stability, predictability, and clarity Reduce requests for exemptions from the current requirements in 10 CFR Parts 50 and 52 Establish new requirements to address advanced reactor technologies Recognize technological advancements in reactor design Credit the response of advanced nuclear reactors to postulated event sequences, including slower response times and relatively small and slow release of fission products Enables operational flexibility In September, the NRC staff released the draft proposed Part 53 rulemaking package NRC Website on 10 CFR Part 53 rulemaking 10 CFR Part 53, Risk-Informed, Technology Inclusive Regulatory Framework for Advanced Reactors 8

Frequency & Consequence-Oriented Requirements Technology-Inclusive Explicit Consideration of Defense-In-Depth Expanded Use of Graded Performance Requirements Part 53 Risk-Informed Approach Prescriptive Requirements Optimized for Specific Technology Augmented for Operating Experience Conservative Assumptions &

Analyses Parts 50/52 vs 10 CFR Part 53 would evolve existing requirements into a modern, risk-informed, performance-based approach

10 Part 53 rulemaking addresses plant lifecycle with appropriate flexibilities and safety focus 17

10 CFR Part 53 Subpart B - Technology-Inclusive Safety Requirements 11 (B) Safety Criteria (B) Safety Functions (C) Design Features (and Human Actions)

(C) Functional Design Criteria (Personnel; Concept of Operations)

What function(s)

(e.g., a barrier, cooling) are needed to satisfy safety criteria What design features (e.g., a structure, system) are provided to fulfill the safety function(s)

What design criteria (e.g., leak rate, cooling capacity) are needed for design feature

• Safety Objectives

• Safety Criteria

• Safety Functions

• Licensing Basis Events

• Defense-in-Depth (DID)

• Normal Operations and Protection of Plant Workers

Regulatory Guide (RG) 1.233 12 Technology-inclusive, risk-informed, and performance-based methodology to inform licensing basis and content of application for licenses, certifications, and approvals of non-LWRs Endorses Nuclear Energy Institute (NEI) 18-04 with clarifications

NEI 18-04 13 Risk-informed performance-based guidance for non-LWR licensing basis development Known as the Licensing Modernization Project (LMP)

Technology-inclusive methodology for:

• Selecting licensing basis events

• Classifying structures, systems, and components (SSCs), and associated risk-informed special treatments

• Determining the defense-in-depth (DID) adequacy

14 NEI 18-04 Methodology

NEI 18-04: The Frequency-Consequence Target 15

NEI 18-04: SSC Safety Categories 16

Pre-Application Engagement Draft White Paper - Preapplication Engagement to Optimize Advanced Reactors Application Reviews Encourages pre-application interactions with advanced reactor developers to provide stability and predictability in the licensing process through early identification and resolution of technical and policy issues that would affect licensing.

- Principal Design Criteria for non-light water reactors

- Process for selection of licensing basis events and classification and treatment of structures, systems, and components

- Fuel qualification plan and associated methodologies

- Source term methodology

- Quality Assurance Program description

- Plan for protection of safeguards information

- Safety and accident analysis methodologies

- Others based on specific design or licensing approach 17

RG 1.232 Guidance on how the General Design Criteria (GDCs) in Appendix A of 10 CFR Part 50 may be adapted for non-LWR designs.

Guidance for developing Principal Design Criteria (PDCs) for non-LWR designs as required by applicable regulations.

- Appendix A: the technology-inclusive Advanced Reactor Design Criteria (ARDCs)

- Appendix B: Design criteria for sodium-cooled fast reactors (SFR-DCs)

- Appendix C: Design criteria for modular high temperature gas reactors (MHTGR-DCs) 18

RG 1.232 Appendix B: Design criteria for sodium-cooled fast reactors:

- I. Overall Requirements

- II. Multiple Barriers

- III. Reactivity Control

- IV. Fluid Systems

- V. Reactor Containment

- VI. Fuel and Reactivity Control

- VII. Additional SFR-Design Criteria 19

RG 1.247

• Acceptability of probabilistic risk assessment (PRA) for non-LWR risk-informed activities

• Endorses, with staff exceptions, a consensus PRA standard (ASME/ANS RA-S-1.4-2021)

• Endorses NEI 20-09 on non-LWR PRAs 20

DG-1413

• Technology-Inclusive Identification of Licensing Events for Commercial Nuclear Plants

• Guidance on identifying licensing events used to inform the design basis, licensing basis, and content of applications for commercial nuclear plants 21

DG-1414

• Alternative Evaluation for Risk Insights (AERI) framework to inform the content of applications and licensing basis for light-water reactors (LWRs) and non-LWRs

• AERI entry conditions in preliminary proposed 10 CFR 53.4730(a)(34) (still under development) must be met:

- Bounding event less than 1 Rem TEDE at 100 meters during 4 days

- No active safety features and no passive safety that require actuation or operator action 22

Other Guidance Developments 23 Instrumentation and Controls

• Technology-inclusive, risk-informed, and performance-based

• Top-down, streamlined approach

• Design Review Guide for non-LWR Instrumentation and Controls Reviews published Fuel qualification

• To establish a performance-based fuel qualification assessment framework that would satisfy regulatory requirements

• NUREG-2246 published

• Developing guidance for liquid-fueled molten salt reactors Reliability and Integrity Management (RIM)

• American Society of Mechanical Engineers (ASME) SECTION XI, DIVISION 2

• A program to ensure that passive component reliability and integrity are properly managed

• Based on achieving an acceptable level of reliability

• Implement strategies to ensure that Reliability Targets for SSCs are defined, achieved, and maintained

• RG 1.246 published in October 2022 Code of construction for high temperature reactors

• ASME SECTION III, DIVISION 5

• To publish RG 1.87, Revision 2 and NUREG-2245

Acronyms and Abbreviations DID Defense-in-depth EAB Exclusion area boundary ESP Early site permit F-C Frequency-consequence GDC General Design Criterion GEH GE Hitachi Nuclear Energy GEIS Generic Environmental Impact Statement GIV Generation IV HTGR High-temperature gas-cooled reactor IAEA International Atomic Energy Agency ISI/IST Inservice inspection/inservice testing LBE Licensing basis event LMFR Liquid metal fast reactor LMP Licensing Modernization Project LWR Light-water reactor 24 ACU Abilene Christian University ADAMS Agencywide Documents Access and Management System AEA Atomic Energy Act AOO Anticipated operational occurrence ARCAP Advanced reactor content of application project ARDC Advanced Reactor Design Criterion ASME American Society of Mechanical Engineers BDBE Beyond design basis event CFR Code of Federal Regulations COL Combined license CP Construction permit DBA Design basis accident DBE Design basis event DC Design certification DG Draft Regulatory Guide

Acronyms and Abbreviations 25 MCFR Molten chloride fast reactor MHTGR-DC Modular high-temperature gas-cooled reactor design criteria MIT Massachusetts Institute of Technology ML Manufacturing license MSR Molten salt reactor MWt Megawatt thermal NEI Nuclear Energy Institute NEIMA Nuclear Energy Innovation and Modernization Act NRC U.S. Nuclear Regulatory Commission OL Operating license P&ID Piping and instrumentation diagram PDC Principal design criterion PRA Probabilistic risk assessment QHO Quantitative health objective RG Regulatory Guide RIM Reliability and Integrity Management RIPB Risk-informed performance-based RTR Research and test reactor SAR Safety analysis report SDA Standard design approval SFR-DC Sodium-cooled fast reactor design criteria SRM Staff Requirements Memorandum SSC Structure, system, and component TICAP Technology-inclusive content of application project

References 1.

10 CFR Part 50, Domestic licensing of production and utilization facilities 2.

10 CFR Part 52, Domestic licensing of production and utilization facilities 3.

ASME/ANS RA-S-1.4-2021, Probabilistic Risk Assessment Standard for Advanced Non-Light Water Reactor Nuclear Power Plants 4.

ASME Boiler & Pressure Vessel Code,Section III, Division 5 - High Temperature Reactors 5.

ASME Boiler & Pressure Vessel Code,Section XI - Rules for Inservice Inspection of Nuclear Power Plant Components, Division 2, Requirements for Reliability and Integrity Management (RIM) Programs for Nuclear Power Plants 6.

NEI 18-04, Revision 1, Risk-Informed Performance-Based Guidance for Non-Light Water Reactor Licensing Basis Development, August 19, 2019. (ADAMS Accession No. ML19241A472).

7.

NEI 21-07, Revision 0, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Utilizing NEI 18-04 Methodology, August 2, 2021. (ADAMS Accession No. ML21250A378).

8.

NRC, SECY-18-0096, Functional Containment Performance Criteria for Non-Light-Water Reactors, Washington, DC, September 28, 2018. (ADAMS Accession No. ML18114A546).

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NRC, SRM-SECY-18-0096, SECY-18-0096 - Functional Containment Performance Criteria for Non-Light-Water-Reactors, December 4, 2018. (ADAMS Accession No. ML18338A502).

10.

Nuclear Energy Innovation and Modernization Act (NEIMA; Public Law 115-439), January 2019.

11.

RG 1.232, Revision 0, Guidance for Developing Principal Design Criteria for Non-Light Water Reactors, April 2018. (ADAMS Accession No. 17325A611).

12.

RG 1.233, Revision 0, Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light Water Reactors, June 2020. (ADAMS Accession No. ML20091L698).

13.

RG 1.247, Acceptability of Probabilistic Risk Assessment Results for Non-Light Water Reactor Risk-Informed Activities, March 2022. (ADAMS Accession No. ML21235A008).

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Backup Slides 27

Rulemaking Schedule 28

10 CFR Part 53 Traditional Approach Consideration of stakeholder requests for an option for a more traditional, deterministic licensing framework for advanced reactors Provides technology-inclusive alternatives to LWR-centric requirements in 10 CFR Parts 50 and 52 Aligns with international standards (i.e., International Atomic Energy Agency)

Guidance for systematic searches for hazards, initiating events, and event sequences 29

Other rulemaking activities Physical Security

- Establish alternative, consequence-oriented physical security requirements for advanced reactors

- The rule and guidance under development Emergency Preparedness

- Provide alternative, consequence-oriented emergency preparedness requirements for SMRs and other new technologies

- The proposed rule is with the Commission (SECY-22-0001)

- DG-1350 provides a technology-inclusive, RIPB approach to radiological dose assessment Generic Environmental Impact Statement

- Streamline the environmental review process

- Technology-neutral plant parameter envelope and site parameter envelope approach

- The draft proposed rule was provided to the Commission (SECY-21-0098) 30

Content of Application Guidance To develop technology-inclusive, risk-informed and performance-based application guidance In support of 10 CFR Parts 50, Part 52, and Part 53 applications TICAP (Industry-led): Guidance to develop the content for LMP-based portions of the safety analysis report ARCAP (NRC-led): Guidance that describes the contents for an entire application Guidance will be revised in accordance with the 10 CFR Part 53 rulemaking underway NRC Website on ARCAP/TICAP ARCAP: Advanced Reactor Content of Application Project TICAP: Technology Inclusive Content of Application Project (TICAP) 31

ARCAP/TICAP - Nexus Outline Safety Analysis Report (SAR) -

Based on TICAP Guidance

1. General Plant Information, Site Description, and Overview of the Safety Case

2. Methodologies and Analyses

3. Licensing Basis Event Analysis

4. Integrated Evaluations

5. Safety Functions, Design Criteria, and SSC Safety Classification

6. Safety-Related SSC Criteria and Capabilities

7. Non-Safety-Related with Special Treatment SSC Criteria and Capabilities

8. Plant Programs Additional Portions of Application

• Technical Specifications

• Technical Requirements Manual

• Quality Assurance Plan (design)

• Fire Protection Program (design)

• Quality Assurance Plan (construction and operations)

• Emergency Plan

• Physical Security Plan

• SNM physical protection program

• SNM material control and accounting plan

• Cyber Security Plan

• Fire Protection Program (operational)

• Radiation Protection Program

• Offsite Dose Calculation Manual

• Inservice inspection/Inservice testing Program

• Environmental Report

• Site Redress Plan

• Exemptions, Departures, and Variances

• Facility Safety Program (under consideration for 10 CFR Part 53 applications)

Audit/inspection of Applicant Records Calculations Analyses System Descriptions Design Drawings Design Specifications Procurement Specifications Probabilistic Risk Assessment SAR structure based on clean sheet approach Additional SAR Content - Outside the Scope of TICAP

9. Control of Routine Plant Radioactive Effluents, Plant Contamination, and Solid Waste

10. Control of Occupational Doses

11. Organization and Human-System Considerations

12. Post-construction Inspection, Testing and Analysis Programs

• Additional contents of application outside of SAR are still under discussion. The above list is draft and for illustration purposes only.

Developing a Regulatory Guide for TICAP guidance

• NEI 21-07, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Utilizing NEI 18-04 Methodology

• Chapters 1 - 8 of the safety analysis report based on RG 1.233/NEI 18-04

• To issue a Regulatory Guide to endorse it with clarifications 33

Functional Containment Methodology for establishing functional containment performance criteria for non-LWRs Focused on ability of multiple fission product barriers to retain radionuclides (i.e., technology-inclusive, risk-informed, and performance-based requirement) rather than a leak-tight containment building (i.e.,

prescriptive requirement)

Commission approved the staff proposal in SECY-18-0096 34 Source: SECY-18-0096, Enclosure 2