ML23130A064: Difference between revisions
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{{#Wiki_filter:NRC Commission Hearing: | {{#Wiki_filter:NRC Commission Hearing: | ||
Update on 10 C.F.R. Part 53 Licensing and Regulation of Advanced Nuclear Reactors | Update on 10 C.F.R. Part 53 Licensing and Regulation of Advanced Nuclear Reactors May 16, 2023 | ||
2 ClearPath Mission: Develop and advance policies that accelerate innovations to reduce and remove global energy emissions. | |||
3 Federal R&D (basic and applied) | |||
Demonstration Programs Deployment Incentives Ecosystem e.g. Regulatory Modernization Key technologies and policy areas Power Industrial Concrete Metals Hydrogen Nuclear Storage Natural Gas Carbon Capture Hydro Geothermal Technology Export and Finance | |||
Two Questions for the NRC Commissioners Can reactors licensed under the existing regulatory frameworks transition to Part 53? | |||
4 Expanded interest in clean energy and energy security have increased the demand for new nuclear Multiple new reactor designs with unique safety cases as well as dozens of applications per design are expected Part 53 should not add unnecessary regulatory burden onto industry or onto the NRC staff Due to recent policies, there will be multiple initial applications using Part 50 or Part 52 Part 53 needs to provide a better, long-term regulatory framework, or developers will continue to use Part 50 or Part 52 Speed should not take priority over a thoughtful rulemaking - Chairman Hanson Can Part 53 efficiently and effectively handle a large volume of applications? | |||
Flexibility vs Predictability How to Recreate the Rule Licensing Review Process The current approach tries to create predictability in rule text itself this has made the draft rule unworkable A change in approach can allow the staff to incorporate current and future review experience and feedback more easily Current Draft Rule The Licensing Modernization Project (LMP) is already approved for Part 50 and Part 52, so it does not need to form the basis for Framework A Framework B seemingly offers few bene"ts over Part 50/52 Recreating the Draft Rule This different philosophical approach can address staff, industry, and stakeholder concerns If the rule is performance-based, then it will be easier to be risk-informed and technology inclusive Frameworks A and B should be guidance that meet performance-based requirements 5 | |||
The Commissioners Responsibility Locking in overly complex language today will be harder to untangle tomorrow By not considering how to fully implement the rule, it will create an additional burden on the NRC staff when they are making their safety findings Part 53 will not meet the Nuclear Energy Innovation and Modernization Act (NEIMA) | |||
Consequences of inaction There is significant, detailed stakeholder feedback on how to craft the rule Existing and future licensing reviews will provide valuable feedback on implementing Part 53 A performance-based rule, with Frameworks A and B as regulatory guidance, can also address major technical concerns on the draft proposed rule The Commission should: | |||
Clarify and communicate what a successful Part 53 looks like Consider the implementation of Part 53 holistically Send the rule back to the staff with detailed, clear instructions and expectations Leverage what exists 6 | |||
Technology | References ClearPath, A Simpler, Dedicated Pathway for Advanced Nuclear Reactor Licensing, https://clearpath.org/our-take/a-simpler-dedicated-pathway-for-advanced-nuclear-reactor-licensing/, | ||
October 7, 2020 ClearPath Comments on Proposed Rule, Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors, ML21187A250, July 2, 2021 Joint Comment: The Breakthrough Institute, ClearPath, Good Energy Collective, Nuclear Innovation Alliance, and Third Way, ML21207A223, July 23, 2021 ClearPath Presentation, Nuclear Regulatory Commission Public Meeting on Part 53, ML22038A179, February 8, 2022 ClearPath, New Nuclear Energy Needs New Licensing Process, https://clearpath.org/our-take/new-nuclear-energy-needs-new-licensing-process/, March 16, 2023 7 | |||
Managing Director, Public Policy mcmurray@clearpath.org Nicholas McMurray 8}} | |||
8}} | |||
Latest revision as of 04:53, 27 November 2024
| ML23130A064 | |
| Person / Time | |
|---|---|
| Issue date: | 05/16/2023 |
| From: | NRC/OCM |
| To: | |
| Shared Package | |
| ML23067A030 | List: |
| References | |
| M230516, 10 CFR Part 53, NRC-2019-0062, RIN 3150-AK31 | |
| Download: ML23130A064 (8) | |
Text
NRC Commission Hearing:
Update on 10 C.F.R. Part 53 Licensing and Regulation of Advanced Nuclear Reactors May 16, 2023
2 ClearPath Mission: Develop and advance policies that accelerate innovations to reduce and remove global energy emissions.
3 Federal R&D (basic and applied)
Demonstration Programs Deployment Incentives Ecosystem e.g. Regulatory Modernization Key technologies and policy areas Power Industrial Concrete Metals Hydrogen Nuclear Storage Natural Gas Carbon Capture Hydro Geothermal Technology Export and Finance
Two Questions for the NRC Commissioners Can reactors licensed under the existing regulatory frameworks transition to Part 53?
4 Expanded interest in clean energy and energy security have increased the demand for new nuclear Multiple new reactor designs with unique safety cases as well as dozens of applications per design are expected Part 53 should not add unnecessary regulatory burden onto industry or onto the NRC staff Due to recent policies, there will be multiple initial applications using Part 50 or Part 52 Part 53 needs to provide a better, long-term regulatory framework, or developers will continue to use Part 50 or Part 52 Speed should not take priority over a thoughtful rulemaking - Chairman Hanson Can Part 53 efficiently and effectively handle a large volume of applications?
Flexibility vs Predictability How to Recreate the Rule Licensing Review Process The current approach tries to create predictability in rule text itself this has made the draft rule unworkable A change in approach can allow the staff to incorporate current and future review experience and feedback more easily Current Draft Rule The Licensing Modernization Project (LMP) is already approved for Part 50 and Part 52, so it does not need to form the basis for Framework A Framework B seemingly offers few bene"ts over Part 50/52 Recreating the Draft Rule This different philosophical approach can address staff, industry, and stakeholder concerns If the rule is performance-based, then it will be easier to be risk-informed and technology inclusive Frameworks A and B should be guidance that meet performance-based requirements 5
The Commissioners Responsibility Locking in overly complex language today will be harder to untangle tomorrow By not considering how to fully implement the rule, it will create an additional burden on the NRC staff when they are making their safety findings Part 53 will not meet the Nuclear Energy Innovation and Modernization Act (NEIMA)
Consequences of inaction There is significant, detailed stakeholder feedback on how to craft the rule Existing and future licensing reviews will provide valuable feedback on implementing Part 53 A performance-based rule, with Frameworks A and B as regulatory guidance, can also address major technical concerns on the draft proposed rule The Commission should:
Clarify and communicate what a successful Part 53 looks like Consider the implementation of Part 53 holistically Send the rule back to the staff with detailed, clear instructions and expectations Leverage what exists 6
References ClearPath, A Simpler, Dedicated Pathway for Advanced Nuclear Reactor Licensing, https://clearpath.org/our-take/a-simpler-dedicated-pathway-for-advanced-nuclear-reactor-licensing/,
October 7, 2020 ClearPath Comments on Proposed Rule, Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors, ML21187A250, July 2, 2021 Joint Comment: The Breakthrough Institute, ClearPath, Good Energy Collective, Nuclear Innovation Alliance, and Third Way, ML21207A223, July 23, 2021 ClearPath Presentation, Nuclear Regulatory Commission Public Meeting on Part 53, ML22038A179, February 8, 2022 ClearPath, New Nuclear Energy Needs New Licensing Process, https://clearpath.org/our-take/new-nuclear-energy-needs-new-licensing-process/, March 16, 2023 7
Managing Director, Public Policy mcmurray@clearpath.org Nicholas McMurray 8