1

IAEA & GIF-RSWG

Regulatory Experience & Progress in US

Jim Kinsey

Idaho National Laboratory

Office of Nuclear Energy

U.S. Department of Energy

December, 2019

2

NRC Regulatory Readiness

• NRC has a near term focus on establishing or improving advanced reactor “regulatory readiness”

• Establish a more flexible, risk-informed, performance-based, non-LWR regulatory review process within the bounds of existing regulations, including the use of conceptual design reviews and staged-review processes.

• Contributing Activities• Establish the criteria necessary to reach a safety, security, or

environmental finding for non-LWR technologies

• Determine appropriate licensing bases and accident sets for non-LWR technologies

• Identify and resolve gaps in current regulatory framework

3

NRC Vision and Strategy

4

4

Strategy 1

Knowledge, Skills

and Capability

Strategy 2

Computer Codes

& Review Tools

Strategy 3

Flexible Review

Processes

Strategy 5

Policy and Key

Technical Issues

Strategy 6

Communication

Strategy 4

Consensus Codes

and Standards

ONRL Molten Salt

Reactor Training

Knowledge

Management

Competency

Modeling

Regulatory

Roadmap

Prototype

Guidance

Non-LWR Design

Criteria

ASME BPVC

Section III

Division 5

ANS Standards

20.1, 20.2

30.2, 54.1

Non-LWR

PRA Standard

Siting near

densely populated

areas

Insurance and

Liability

Consequence

Based Security

(SECY-18-0076)

NRC DOE

Workshops

Periodic

Stakeholder

Meetings

NRC/DOE GAIN

MOU

Identification &

Assessment of

Available Codes

WGSAR

Licensing

Modernization

Project (LMP)

Functional

Containment

(SECY-18-0096)

EP for SMRs

and ONTs

(SECY-18-0103)

Environmental

Review ISG

Fast Reactor

Training

Micro Reactor

Policy issues

HTGR TrainingCode

Development/V&V

Environmental

policy issues

Technology Inclusive Content

Applications Project (TICAP)

NRC DOE DOD

Micro Reactor

MOU

NRC/DOE NEICA

MOU

Memorandum of

Cooperation

with CNSC

Licensing Project Plans

NRC Near Term Plan

5

Advanced Reactor Design Criteria Development

Joint Initiative

U.S. Department of Energy &

Nuclear Regulatory Commission

6

Joint DOE-NRC Initiative: Background

Adapt LWR-Based Regulatory Requirements

• Characteristics of current set of regulatory requirements

• Each has an underlying safety basis that ultimately helps to assure protection of public health and safety

• Language frequently prescribes an approach for satisfying the safety basis for large LWR designs (either PWR or BWR) with active systems

• Most efficient path forward is to adapt existing requirements to meet the underlying safety bases in a “technology inclusive” manner for advanced reactors

• A key to this adaption is the establishment of a structured “performance based” approach

• Focus on “what” must be accomplished to satisfy the underlying safety basis

• Avoid descriptive discussion of “how” requirement is to be accomplished

• The joint DOE-NRC initiative on General Design Criteria was a first step in this area

7

The Advanced Reactor Design Criteria (ARDC) are intended to be applicable to:• Sodium Fast Reactors (SFRs)

• Modular High Temperature Gas-Cooled Reactors (mHTGRs)

• Fluoride High Temperature Reactors (FHRs)

• Molten Salt Reactors (MSRs)

• Gas Cooled Fast Reactors (GFRs)

• Lead Fast Reactors (LFRs)

Advanced Reactor Design Criteria Applicability

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Modular HTGR Design Criteria – Key Results

NRC Regulatory Guide 1.232 has accepted a number of significant updates that are applicable to modular HTGRs, based on DOE/industry proposals:

• Offsite and onsite power requirements much less prescriptive

• Specified acceptable radionuclide release design limit concept added

• Functional containment concept confirmed • A barrier, or set of barriers taken together, that effectively limit the physical transport and

release of radionuclides to the environment across a full range of normal operating conditions, AOOs, and accident conditions.

• Passive heat removal requirements refined and clarified

• New functional requirements established for Reactor Building to:• Ensure the geometry for passive heat removal

• Permit neutron absorber insertion for reactor shutdown

• Provides a pathway for reactor helium release

9

NRC Final Report

• Guidance for Developing Principal Design Criteria For Non-Light Water Reactors

• Final report issued April 2018

• NRC Accession # ML17325A611

10

10

Strategy 1

Knowledge, Skills

and Capability

Strategy 2

Computer Codes

& Review Tools

Strategy 3

Flexible Review

Processes

Strategy 5

Policy and Key

Technical Issues

Strategy 6

Communication

Strategy 4

Consensus Codes

and Standards

ONRL Molten Salt

Reactor Training

Knowledge

Management

Competency

Modeling

Regulatory

Roadmap

Prototype

Guidance

Non-LWR Design

Criteria

ASME BPVC

Section III

Division 5

ANS Standards

20.1, 20.2

30.2, 54.1

Non-LWR

PRA Standard

Siting near

densely populated

areas

Insurance and

Liability

Consequence

Based Security

(SECY-18-0076)

NRC DOE

Workshops

Periodic

Stakeholder

Meetings

NRC/DOE GAIN

MOU

Identification &

Assessment of

Available Codes

WGSAR

Licensing

Modernization

Project (LMP)

Functional

Containment

(SECY-18-0096)

EP for SMRs

and ONTs

(SECY-18-0103)

Environmental

Review ISG

Fast Reactor

Training

Micro Reactor

Policy issues

HTGR TrainingCode

Development/V&V

Environmental

policy issues

Technology Inclusive Content

Applications Project (TICAP)

NRC DOE DOD

Micro Reactor

MOU

NRC/DOE NEICA

MOU

Memorandum of

Cooperation

with CNSC

Licensing Project Plans

NRC Near Term Plan

11

Industry-Led Licensing Modernization Project

(LMP)

(“Approach 1” Effort in U.S.)

12

Licensing Modernization Project

• Industry-led Licensing Modernization Project (LMP) was established to address policy and key licensing technical requirements issues with NRC

• Advanced non-LWR technology inclusive

• Multiple reactor developer and end-user contributors

• NRC interactions on LMP approach and pending licensing framework proposals commenced in December, 2016

• Public NRC working meetings held every 6 weeks

• The LMP process is very closely aligned with IAEA CRP “Approach 1”

• The LMP effort also aligns with US Congress direction to the NRC, through the Nuclear Energy Innovation and Modernization Act, to increase the use of risk-informed, performance-based licensing evaluation techniques

13

LMP Areas of Focus

14

Sequence of LMP Review by NRC

15

U.S. Documents Addressing “Approach 1”

• The detailed description of the approach proposed by industry is contained in NEI 18-04, “Risk-Informed Performance-Based Guidance for Non-Light Water Reactor Licensing Basis Development”

• The results of NRC’s review of the industry proposal, and their current plans to endorse the approach for industry use, are reflected in:

• DG-1353, “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.” and an associated Commission paper (SECY-19-0117)

16

Summary of NRC Review Results

The NRC Staff is making the following recommendation to the Commission:

• The staff recommends that the Commission approve the use of the technology-inclusive, risk-informed, and performance-based approach described in the paper (consistent with NEI 18-04 and DG-1353) for identifying LBEs, classifying SSCs, and assessing the adequacy of defense in depth. These key aspects of the proposed approach will also be used to inform the appropriate scope and level of detail for information to be included in applications to the NRC for licenses, certifications, and approvals for non-LWRs.

17

ACRS Review and Feedback (excerpt)

The Commission’s independent review committee, the Advisory Committee on Reactor Safeguards (ACRS), has provided its recommendation (March, 2019) to the NRC Chairman (excerpts below):

1. The draft …paper proposes the next evolution of a licensing approach that has been developed over the past thirty years.

2. The paper proposes an approach to accomplish three objectives: to select licensing basis events; to classify structures, systems, and components; and to assess the adequacy of defense-in-depth for new designs. The approach has matured to the point of being ready for application.

3. We recommend that the Commission adopt the approach proposed by the staff for and performance-based methodology for informing the licensing basis and content of applications for non-light-water reactors.

18

18

Strategy 1

Knowledge, Skills

and Capability

Strategy 2

Computer Codes

& Review Tools

Strategy 3

Flexible Review

Processes

Strategy 5

Policy and Key

Technical Issues

Strategy 6

Communication

Strategy 4

Consensus Codes

and Standards

ONRL Molten Salt

Reactor Training

Knowledge

Management

Competency

Modeling

Regulatory

Roadmap

Prototype

Guidance

Non-LWR Design

Criteria

ASME BPVC

Section III

Division 5

ANS Standards

20.1, 20.2

30.2, 54.1

Non-LWR

PRA Standard

Siting near

densely populated

areas

Insurance and

Liability

Consequence

Based Security

(SECY-18-0076)

NRC DOE

Workshops

Periodic

Stakeholder

Meetings

NRC/DOE GAIN

MOU

Identification &

Assessment of

Available Codes

WGSAR

Licensing

Modernization

Project (LMP)

Functional

Containment

(SECY-18-0096)

EP for SMRs

and ONTs

(SECY-18-0103)

Environmental

Review ISG

Fast Reactor

Training

Micro Reactor

Policy issues

HTGR TrainingCode

Development/V&V

Environmental

policy issues

Technology Inclusive Content

Applications Project (TICAP)

NRC DOE DOD

Micro Reactor

MOU

NRC/DOE NEICA

MOU

Memorandum of

Cooperation

with CNSC

Licensing Project Plans

NRC Near Term Plan

19

TICAP

US industry stakeholders have now initiated the Technology Inclusive

Content of Application Project (TICAP) and have started a planned series of

public meetings with the NRC

The industry-led TICAP has the following attributes:

• Uses the LMP (“Approach 1”) methodology to “right-size” the content of

license applications

• Is advanced reactor technology-inclusive

• Is intended to improve the overall efficiency of NRC application reviews

20

20

Strategy 1

Knowledge, Skills

and Capability

Strategy 2

Computer Codes

& Review Tools

Strategy 3

Flexible Review

Processes

Strategy 5

Policy and Key

Technical Issues

Strategy 6

Communication

Strategy 4

Consensus Codes

and Standards

ONRL Molten Salt

Reactor Training

Knowledge

Management

Competency

Modeling

Regulatory

Roadmap

Prototype

Guidance

Non-LWR Design

Criteria

ASME BPVC

Section III

Division 5

ANS Standards

20.1, 20.2

30.2, 54.1

Non-LWR

PRA Standard

Siting near

densely populated

areas

Insurance and

Liability

Consequence

Based Security

(SECY-18-0076)

NRC DOE

Workshops

Periodic

Stakeholder

Meetings

NRC/DOE GAIN

MOU

Identification &

Assessment of

Available Codes

WGSAR

Licensing

Modernization

Project (LMP)

Functional

Containment

(SECY-18-0096)

EP for SMRs

and ONTs

(SECY-18-0103)

Environmental

Review ISG

Fast Reactor

Training

Micro Reactor

Policy issues

HTGR TrainingCode

Development/V&V

Environmental

policy issues

Technology Inclusive Content

Applications Project (TICAP)

NRC DOE DOD

Micro Reactor

MOU

NRC/DOE NEICA

MOU

Memorandum of

Cooperation

with CNSC

Licensing Project Plans

NRC Near Term Plan