ML23130A064
| 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 ClearPath Mission: Develop and advance policies that accelerate innovations to reduce and remove global energy emissions.
2 Key technologies and policy areas
Power Federal R&D (basic and applied)
Demonstration Nuclear Storage Natural Gas Programs
Deployment Incentives Carbon CaptureHydro Geothermal Ecosystem Industrial e.g. Regulatory Modernization
Technology Export Concrete Metals Hydrogen and Finance 3
Two Questions for the NRC Commissioners
Can reactors licensed under the existing regulatory frameworks transition to Part 53?
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?
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
4 Flexibility vs Predictability How to Recreate the Rule
Current Draft Rule Licensing Review Process Recreating the Draft Rule
The Licensing Modernization The current approach tries to This different philosophical approach can address Project (LMP) is already approved create predictability in rule text staff, industry, and stakeholder concerns for Part 50 and Part 52, so it does itself this has made the draft not need to form the basis for rule unworkable If the rule is performance-based, then it will be easier Framework A to be risk-informed and technology inclusive A change in approach can allow Framework B seemingly offers the staff to incorporate current Frameworks A and B should be guidance that meet few bene"ts over Part 50/52 and future review experience performance-based requirements and feedback more easily
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 Consequences on the NRC staff when they are making their safety findings of inaction Part 53 will not meet the Nuclear Energy Innovation and Modernization Act (NEIMA)
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 Leverage A performance-based rule, with Frameworks A and B as regulatory guidance, what exists can also address major technical concerns on the draft proposed rule
Clarify and communicate what a successful Part 53 looks like The Consider the implementation of Part 53 holistically Commission Send the rule back to the staff with detailed, clear instructions should: and expectations 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 Nicholas McMurray Managing Director, Public Policy mcmurray@clearpath.org
8