RIC 2022 T5 Technology Inclusive Risk Informed and Performance Based Regulatory Framework

our session will explore the development of a new regulatory framework for new reactors that will provide flexibility for a variety of novel licensing approaches my name is andrea vale i'm the director of the nrc's office of nuclear reactor regulation and i will be your chair for this session we're very excited to be here on this first day of rick 2022 and to have so many of you able to join us using this virtual platform our goal is to ensure that this session is informative and engaging and we welcome your participation to make that happen let me start by describing a few details about the session the session will follow a moderated panel discussion format after some brief opening remarks i'll lead a panel session on some key topics with our goal to bring you a broad range of perspectives on the development of the part 53 rulemaking during that discussion we'll also be using some live audience polling questions as a reminder you can access polls by clicking the word poll on the right side of the screen next to the q a your responses will feed into our discussion real time finally after the panel discussion we've allotted plenty of time to take audience questions so please first submit your questions via the q a box and we'll try to answer as many of your questions as we can the questions can be directed to me or to any of the panelists please submit your questions as early as you can there's no need to wait for the q a portion of the session to begin i would now like to kick things off with our first live polling question so we can really get a feel for the level of familiarity you have with the ongoing rulemaking i'll begin introducing the panelists ask the polling question is pulled up and give you a few minutes to answer again you can access polls by clicking the word poll on the right side of the screen next to q a now i'd like to introduce the panelists and i'm pleased to start with darren gale darin is the vice president and ardp program manager for commercial operations at x energy llc darin has been actively involved in the nuclear power industry for over 38 years with prior executive positions with framitone bwxt dan zimmerman and structural integrity x-energy was awarded funding by doe under the advanced reactor demonstration program to construct this xc100 high-temperature gas-cooled reactor near energy northwest columbia generating station nuclear plant and washington state dr david petty is a member of the nrc's advisory committee on reactor safeguards david was formerly the national technical director of does advance reactor program his work included numerous lead and chief scientist positions at the department of energy idaho national laboratory and the phoebus facility at the cotterash nuclear site in france he was recently elected to the national academy of engineering dr ed lyman is the director of the nuclear power safety at the union of concerned scientists dr lyman is an internationally recognized expert on nuclear proliferation and nuclear terrorism as well as nuclear power safety and security he is a member of the institute of nuclear materials management and has testified numerous times before congress and the nrc ed has been actively involved in stakeholder discussions on the part 53 rulemaking he earned a doctorate in physics from cornell university in 1992. dennis henneke is a consulting engineer at geh nuclear energy dennis is the technical lead for the pra supporting the bwrx 300 vtr and atrium reactors and was the principal investigator for the doe funded project for the prism reactor on development modernization of an advanced non-light water reactor probabilistic risk assessment dennis is also the ans chairman of the asme joint committee on nuclear risk management and has supported pra standard development since 1999 including non-lwr pra standard now let's take a look at the results from our first polling question before i begin introductory remarks so it looks like overwhelmingly about 48 say i've heard of part 53 um they're 16 that said what is part 53 so you're in the right place to learn about it i've attended a few meetings 19 and 17 i've attended most meetings and have read preliminary rule tax so with this wide variety of familiarity with part 53 i hope we can increase that level of familiarity today or fill in some of the gaps for those of you who are already familiar now i'll provide a brief discussion of the part 53 rulemaking to provide some explanatory background before we move to the panel discussion next slide please as required by the nuclear innovation and modernization act or nema the nrc staff is committed to developing a technology inclusive risk and form regulatory framework part 53 rule that provides at least the same degree of protection of public health and safety in the common defense and security for advanced reactors that is required for current generation like water reactors our goal is to develop an innovative predictable and appropriately flexible framework to enable a streamlined and efficient licensing process for advanced reactors the regulations will accommodate various advanced reactor technologies prioritizing risk and form and performance-based licensing approaches to protect public health and safety throughout the life of a facility the nrc staff has engaged in extensive stakeholder outreach during the rulemaking process and has received diverse and significant input the staff has been implementing a novel approach of releasing preliminary rule language to facilitate discussion i'm proud to say we've now completed the first draft of all preliminary real language the staff has considered stakeholder requests for a more traditional deterministic licensing framework for advanced reactors in addition the staff recognized that more time was needed to further engage stakeholders including the advisory committee on reactor safeguards and iterate on rule language before sending a proposed rule to the commission several organizations also noted support for a scheduled extension for the proposed rule during our public interactions to this end in october 2021 the staff requested a nine-month extension to the commission directed schedule for part 53 and the commission has approved the status request to fully develop this licensing alternative the staff is committed to developing an effective rule and following the nrc's principles of good regulation the nrc will continue to seek stakeholder input throughout the rulemaking process let's display live polling question number two now while that question is coming up i'll begin our panel discussion as we wait for the results to come up and we'll have plenty of time for you to input your answers now um just a note we're going to stop the discussion at about 2 p.m to allow plenty of time for q a so i'll first like to start with the first panel question how are we meeting the objectives outlined in nema and are we headed in the right direction and let's start with darren and then any other panelists who want to speak thank you andrea uh so x energy i think most of you will recognize you know as andrea pointed out the um as one of the awardees under ardp with the timing that the department of energy and congress had with ardp we have chosen to go the two-step process part 50 for the deployment of our reactor at the station here you know at the site near columbia generating station because of the timing for us it's we're not going to get through the 53 rule making in time for that but there clearly are our advantages to part 53 in subsequent subsequent deployments of our xe 100 plan so again the two things for us that are most important are the technology inclusive so we need to make sure that we're we're looking at all technologies here not just you know focused on on a select few but very technology inclusive and then the timeliness making sure that we have the efficiencies with this process that we maybe haven't to this point realized with part 52 i think we all thought with part 52 that we were going to create something that was going to save us some time but we haven't really learned how to do that yet and with part 53 i think we've really really got to do that so again those two things the technology inclusiveness and the timeliness the effectiveness of it those are the things that we're really you know that if we focus on those and continue to focus on those i think we're going to absolutely be doing the right thing so that's uh that's how i would answer that question thank you darren ed would you like to give your perspectives yes i would i appreciate that thank you um so in my view uh the direction of part 53 is going in a way which i think is less consistent with the intent and even the letter of nema and just to be uh clear on this uh and i was involved in many discussions on uh as nemo was being developed and i testified twice in legislative hearings on it my strong sense is that the purpose of that was to promote the development of advanced reactors and although the definition of advanced reactors you know is is up to the beholder and there is a definition in nema it just seems clear to me that it was meant to uh to promote uh reactors with advanced reactor characteristics additional safety features and the like and so the recent change to the scope of part 53 to refer to any commercial reactor which would also include light large light water reactors that have already been certified for example like the ap1000 i think is or even even reactors without the same passive safety features as the ap1000 i feel like that is is missing the intent of nema that um there's a there's a qualitative uh threshold for a reactor to be able to qualify for using a different approach than part 50 or 52 that would potentially provide an easier licensing path and to qualify for that i think there has to be a demonstrated threshold that this reactor actually is going to have credible there's a credible reason to believe that it will have enhanced safety or security features compared to the current fleet so although i understand the logic of opening up the scope to anything i do feel like it is um the nrc is missing an opportunity to use this as an incentive for new reactor applicants to follow through on claims of having inherent or advanced safety features and their designs and um so this um was also tied to the advanced reactor policy statement and the goal that um nemo over at part 53 shall not legislate uh safety that's greater than the operating fleet i do think that's also a missed opportunity in the part of the nrc and the commission to um uh to move the uh you know the commercial reactor fleet in this country in a direction of increased safety which i think would be appropriate if there's going to be greater deployment in the future so i i am concerned about that direction and also with regard to nema's performance-based uh licensing uh approach uh that that had arranged the nrc was given nema gave the nrc the authority to determine where that's appropriate and i i would caution the nrc that it should keep in mind that that the use of performance-based and risk-informed approaches is not always in not every instance and that they should look at that constraint instead of doing what um the staff is trying to do essentially rewriting the entire licensing framework for all new reactors in a way which may make it harder to understand where the risk and form approaches are more or less appropriate and maybe i went too long thank you i'll stop there no thank you ed uh dennis i see your hand is raised yeah thank you andrea andrea um yeah i'm gonna kind of talk more about the risk and form uh portion of it just to kind of give you a flavor how we think we're doing on in that portion i'm a pra guy doing risk and safety analysis for some 40 years and risk applications like risk important tech specs and um you know a lot of people have difficulty understanding what what truly risk informed and what truly risk performance-based applications are and i think overall we're pretty excited about part 53 to be able to uh transition to a much more risk-informed performance-based approach and there's been a lot of great progress in that area uh i agree with what that just talked about trying to apply this to advanced plants uh you know what we're proposing for advanced plants with passive and and inherent features are a factor of a hundred to a thousand times safer for a public safety standpoint than an existing fleet and when you look at that you know that it should bias quite a bit on the regulatory leeway on certain aspects of it that can be supported by risk assessment but i think the the progress is slow simply because a lot of the first words of the preliminary words that come out in the rule making um may appear on the surface to be a performance based or risk and form but they they end up having a deterministic underlying a set of requirements a good example of that is the seismic wording that came out just last month that talked about all um all components sscs that are safety related and non-safety with special treatment shall be cyclically qualified well that's not risk informed we you really only want to have those components that are required to safely shut down in case of a seismic event seismically qualified and you would have different qualifications for those that are safety related than those that are not safety with special treatment we made good progress on the operator side which could uh with the certification and you know requirements for operators because a lot of these op these plants are going to have no significant operator actions now so-called walk away safe although the industry doesn't like that term but uh you know there's uh passive and inherent features that operators really aren't needed uh to slightly shut down the plan unless multiple defense levels fail and so we're relaxing the requirements for operator certification but on the other hand the human factors engineering the hfe program requirements that underline the design the control room design of the plant are still very deterministic you still have to run scenarios on your on your simulator uh associated with for example station blackout when the station blackout may not be risked important at all so i think every time the words come out initially for the preliminary words for the rule making there's almost always a deterministic portion of it that maybe the nrc hasn't thought well about that they really should have thought it can i risk inform this better can i do a better job on that ask your pra guys and then when you've thought about that bring it to us because right now what we're having to do is the industry gets feedback this is a risk informed let's go ahead and and think about this better and then we go into discussion and the nrc been very good about modifying areas where they can find leeway to give but uh in the meantime it's just caught in his time and schedule in the overall process but back to the initial yeah we're overall happy with the direction of the rule and we just look forward to working with the nrc to improve the risk and form portion of the of the rule making a requirement thank you dennis and everyone for your perspectives on that question and the second question we touched on a bit but i want to get a little bit more granular here how can we start the appropriate balance between flexibility and predictability and i'll throw that out to whoever wants to address it first andre i'll start with that so i think what you know if you can clearly define at the beginning uh you know what are the what are the measurable safety objectives what what what are the functions what is the criteria that we're specifically you know managing and and what are the and the sources of uncertainty to that so i think if we can clearly identify all of those up front then it will be more easy for us to approach the you know our preparation of the applications preparation of the you know the technical papers that we put into the nrc for the reviews of these regulations and our approach to that then so the balance you know we'll be able to help provide that balance between the flexibility and you know and efficiency if you will but i think it's clearly defining all of those upfront what are the true objectives what are the true measures and then allowing the vendors and utilities the operators to then you know put put that approach together that that can create the balance thank you and i saw ed tan and then dennis yes thank you so i am concerned that i do think there is a tension between flexibility and regulatory uh it is certainty but uh maybe and assuredness danger is that if you go too far in the direction and i do uh fear that part 53 is going too far in this direction of not having a sufficient number of inspectable and clear regulatory criteria in the rule itself that that's not only going to make it more confusing uh for the public to understand what is actually being accomplished in licensing these reactors but i think it'll be harder for the actual review because i don't believe um these uh very complex safety and security issues that are going to come up in these reviews uh that that will have to be dealt with at some level and if it's not in the rule it's going to be in the guidance a request for additional information in the back and forth and if the staff is forced to have to clarify over and over what exactly it means and the applicants are going to have to explain uh you know in these um how to how they interpret these vague um rules um i feel like that could actually lead to less certainty because of this lack of clarity so i i i would i think it would benefit every stakeholder if the rule itself had some more specific uh performance and and in some cases where appropriate deterministic requirements to reduce that uncertainty okay i see dennis and then dave right i appreciate it um the um both the uh we were gah is working on both the x300 uh bwrx 300 reactor and the nitrogen reactor supporting terrapower both are currently uh proposing to go under the part 50 or 52 probably part 50 licensing approach uh simply for predictability predictably is is money right so it's if if we lose a year of schedule uh on a reactor it can make the difference between becoming profitable and not profitable and then and then and the other part is you know are we going to build a second or third plant in that in that reactor type so and we have a predictable approach under part 50 um and and the problem we see right now in part 53 really has to do with the additional requirements under part 53 many of which we've seen in in industry letters to the nrc that maybe haven't thought been fully thought out as far as a support for why those additional requirements are in in the rule such as alara uh and other other areas now there's no question that for advanced reactors as as that lyman has mentioned we are we are looking at much lower risk plants in general uh with advanced safety features so we expect to have some additional uh consideration beyond design basis accidents but but to have a safer plant and then now add in additional requirements not part under under 50 uh part 50 like alara it it does remove the predictability it does and so plants are going to continue to move until with part 50 until we can figure out if we can if that burden to go into part 53 is not that large so i i think rethinking the these extra portions of it some of which we expect there to be you know some advancements and some additional requirements but as long as that's not too overly burdensome the industry would uh really benefit from that predictability thanks thank you and dave yes um so before i begin i just want to let folks know that my opinions are my own those of the acrs those are found on the official website um i think this is an inherent problem given what the task at hand is to go across all the technologies that we're talking about there has to be more flexibility and you give up predictability as part of that it's a it's a fulcrum you know it's a balance what's flexible for one technology may not be for another and so um it's very hard to to write more prescriptive rules at higher at the higher level when they may not apply to all the technologies because the technologies are very different in when you get into into the details and the the the devil is going to be in guidance because there's just no way to stick that all in in the rule so i think it's important to understand that that's sort of inherent in in what what the staff is trying to do thanks thank you and before we look at the results of polling question two i'll ask one more question and this is specific to darren and dennis how important is part 53 to your business plans we heard about a little bit earlier from darren with the timing issue but if we could just flesh flesh that out a little bit more yeah andrea thank you so again your your point about the timing you know obviously with what we're doing out in washington state right now and the time of that we're moving forward with part 50 as dennis talked about some of the same reasons we're doing that at this point again the subsequent the subsequent plans that we would deploy uh would clearly set themselves up for a part 53 type process again any time you know at this point any first deployment without the predictability you know of a of a seasoned rule making uh you're going to go with what you've done before for that very reason you've got significant investment going on and and the the risk of going into uncharted waters with that people just aren't going to to take on so um once we have an operating plant once we've got a plant that is under regulatory approval then we'll have operating experience we'll have some other things that will probably help help get us through maybe an initial part 53 rule making process and then set itself up for subsequent ones uh you know after that so we clearly see that as we will definitely be looking at that type of approach down the road uh if again if we do get the efficiencies out of the out of the part 53 process we are certainly gearing up to to going that approach down the road so that's it so yes it to you the importance yes we see it as a key part of our business down the road thank you uh dennis would you like to comment yeah i think i'll keep it brief because i think i i agree with what darren said that you know it's um we're moving under part 50 uh initially for all the reactors but if you can see longer term than the you you make a safety case under your application and if the safety case for part 53 is is less burdensome to maintain and then the operation of land is less burdensome than than the second and third and fourth plants that we build will uh definitely move in that direction and that that's going to be key to make making sure the industry succeeds is to not have the expense of maintaining the license that we do under the current part 50. so i think for the initial license it's not part of our business case but for long-term survivability of what we're trying to do it's it's very important all right at this point i'd like to pull up the results of polling question two it's really relevant to our next discussion on stakeholder engagement it the engagement really has been a cornerstone you heard in the remarks i think by um certainly by the chairman and other commissioners how extensively we've been engaging with stakeholders and that was part of the reason for requesting um an extension so the engagement is very important to us and we want to kind of get an idea of whether or not it's about right too much too little so um as we're waiting for the poll questions to come up we can kind of start or the excuse me the results of poll question two we can kind of start the discussion um what do you think are the key lessons learned from stakeholder engagement so far andre i think one of the key ones we've learned is just an appreciation for how challenging it is to develop uh risk and form performance rule you know performance-based rules for a wide variety of technologies you've heard edwin you've heard dennis pointed out these are very different designs and key areas of their safety focus are maybe in completely different parts of the plant one may be a fuel based safety focus another one may be the operating systems based safety focus so it really it's difficult to you know to to be all-encompassing all at once and dave i really appreciate your comments and that you know what the what the nrc faces with how do you how do you make it efficient but make it good for every single design out there so i i think that's a lesson learned is just an appreciation for that and so it is difficult it's not something we can just turn turn out overnight um you know and have a panacea so i think that's that's one of the significant uh you know key lessons learned i think okay thank you i see ed and then dave yes thanks one of the uh my observations from this process and it is a different approach to rulemaking than uh than is typical uh with this much higher degree of involvement of various stakeholders which primarily means the the industry um it does not appear that it wasn't the most efficient way to move forward with this and it does raise difficult questions in my mind about the influence of the regulated parties on the nrc's development of rules and so i'm not sure it was really it's been superior to a more traditional process where uh the nrc is noticing rulemaking where every stakeholder including members of the public have uh have a clear but relatively limited role in development of the actual language and then there's a paper trail a very clear record of where the various uh parties comment on those rules uh where they disagree with the nrc and how the nrc resolves those so i am a bit concerned that this has led to an excessive degree of industry involvement and the thing is the industry is not monolithic and that's led to some confusion as well uh one other thing i i would say is i do think a regulatory uh basis is needed was also decided not to um take that step uh in this role making but i think it's sufficiently complex uh that that would really suit um uh it would be appropriate for again documenting why decisions were made as far as the particular rule text when it finally comes out and i i really feel it's important to have some sort of a crosswalk if this is going to be equivalent to the current level of safety that there has to be an understanding or everything has to be laid out every time there's a change to a current requirement explain what's the basis of that change and how it doesn't fundamentally change the level of safety of the current rules thank you ed and before we go to dave if we could get the results of polling question 2 um displayed and dave go right ahead okay um so i just wanted to expand upon this balance that the staff is trying to strike between predictability and flexibility when you look across the technology dennis is right what i like about 53 and particularly the risk-based approach is that it should help you focus very quickly on what are the really safety important things to worry about in design and they're going to be very different across the technologies but you're not going to waste a lot of time in terms of you know the review and being stuck on something because though that used to be an issue over here with technology x but it isn't an issue here with technology why it should help uh increase the focus and in fact we're seeing that today um with some of the plants that are coming in in pre-application um they're very different in their technologies and the issues just raised to rise to the top very quickly and they cause a focus and that i'm hoping will accelerate the the overall review process thank you dave and i know the next question i'll go ahead and start with dennis because i know he's going to want to speak on this one what should the role of a pra be in design licensing and operations for example enhanced traditional or none i appreciate the question and and stop me if i get too much into the pra nitty gritty but uh um the i think the the inner c in the industry i've had a lot of conversation on that and i think i think the conversation's been really good and just to simplify it down just a little bit i i guess the answer is it depends right so if if we're talking about a you know talked about a variety of advanced plants all the way from micro reactors all the way up to as i'd mentioned potentially a larger reactor but generally smrs right and most of them are quite safe um but there are there are reactors that are inherently safe from a public standpoint either through because they're such a small source term like a microreactor or because they have inherent features where the possibility of releases is very unlikely even given severe action conditions where fuel damage would normally occur uh from it for most reactors so this is the advanced fuel type of a reactor approach for these types of reactors you could make a qualitative argument that's still a risk assessment but it's qualitative and as a result a pra may not be needed now for most of the advanced reactors we still have to prove our safety cage right so we have for the natrium reactor for example the sodium reactor 300 megawatt um it's a very low risk reactor because it has a passive air cooling has passive features such as inherent reactivity feedback uh gravity rod drops and if you look at the overall risk it's quite quite low but still the pra is going to be important especially if we now start using the pra to do risk informed applications such as the determination of safety classification for the components um so i think there was a range i think the first attempt with the white paper from ndi and later the work from the nrc to look at a variety of approaches is is correct and but i think a lot of it has to do really with the inherent features and the relative risk of that plan from a public risk standpoint thanks thank you and i see dave's hand and then ed uh dave is your hand still up from before did you want to comment on this no i i wanted to comment but i can't oh there we go okay i just um wanted to say yeah to say that um beyond you know what we think of it as the traditional pra done done on large light water reactors i agree with dennis the answer really depends on on the system that you're looking at but that there are a number of risk tools in the risk toolbox that provide a lot of value without necessarily going all the way to fall trees and event trees and cup sets and all of that and they can be very important in design they're used heavily in other industries like the chemical industry to really get a better handle on what you think this system is like and how you think it actually behaves in an integrated manner and this is specifically true for systems that we've had no experience with where either the fuel the coolant the moderator any of them we've never used in in combination and so how it actually behaves is just not known well enough and these risk tools can be very very helpful without going to a full quote pra thank you dave and before we go to ed i just wanted to comment on the results of polling question two and the question was about how much engagement and it looks like overwhelmingly 41 percent said unsure 14 not enough of 32 is just about right and 13 says too much so ed you were next and then dan yeah just following up on dave um i have pretty strong concerns about a licensing approach for new reactors that depends too heavily on pra results that don't that haven't been validated uh with industry experience so um you know again this goes back to where it's appropriate and where it isn't to use risk-informed approaches that said i don't see much value in developing a part 53 that does incorporate let's let's hope that it'll incorporate pra where appropriate and respecting its limits in accordance with the pra policy statement and not going beyond the state of the art and taking uncertainties into account and requiring a defense in depth and where and deterministic requirements where pra use isn't appropriate uh and then once you have that framework then to come up with a deterministic alternative which is sort of like part 50 light uh so what i'm afraid is what's going on here and this relates to the earlier remark i made about applying uh to current uh generation reactors is that you may end up with a parallel licensing process that's mostly deterministic but not as stringent as the current process for uh you know under parts 50 or 52 and then it doesn't seem clear to me that that's necessary uh that um uh applicants who do not want to go the risk and form route with with a pra uh can simply uh stick to part 1552 right thank you i see darren's hand was up and then it went back yeah i i would just say that you know beyond what what all the other panels have said that the pra as a tool goes beyond just the regulatory side of it it's helped as a design tool for us when you go from the conceptual stage all through a final design informing yourself you know maybe eliminating some of the you know the hazards or as you're going along so the pra as a tool is helpful throughout the process now again in rule making in regulatory space is it the right thing to do you know i you know with with edward's comments about untested or unproven and with certain things clearly you know at this point in time where most of us are looking at both right we're looking at the deterministic values as compared to what the pra is giving us so at this point in time we have no clear only pra type approach that we're doing so we're getting some sense of how good the pra approaches are because right now we're looking a lot of the key safety areas with both so you know what's the best balance with part 53 again we'll have to continue to look and and i'll you know i'll defer to experts like dennis on that where we go to that because i'm certainly not one of them i'll admit that right now but again that you know it's more than just a regulatory tool at this point in time when we think of pra because it's how how it's helping us inform inform the the design throughout the process from conceptual to final well thank you darren and we'll do one more question before we move to the last polling question and then also to leave plenty of time for q's and a's so this question is are there any unique considerations that should be considered in part 53 with regard to non-traditional uses of nuclear energy such as process heat or industrial applications and new entities that have not owned or operated nuclear reactors before uh dennis i see your hand so great andre i appreciate it um let me um there are a lot of considerations there i i've been in uh a number of ieee um meetings where uh worldwide is quite interesting what uh what is being proposed if all the way from desalinization to you know uses that have already been in place other other places just as a just to provide heating and hot water to towns or industrial uses um i didn't want to focus on one aspect of it that um important from a regulatory standpoint is and that is we'll call it a decoupling process and the natrium reactor itself is use a molten salt uh core to heat up a molten sodium loop that goes to molten salt tanks that store up the energy um and allow the plant to um uh put out more power during the day when it's needed and the less power at night when it's not needed and the reactor just remains at the same power level and the hot tanks and the coal tanks uh go up and down depending on what power level is needed um and that decouple that we call it decoupling because regardless of what happens on the turbine generator side um the balance of plant side you can lose cooling water you could trip the turbine generator uh the the reactor itself doesn't isn't initially affected and you could depending on the level of the molten salt tanks continue to operate for some time or you could just reduce power down and and continue to operate um and then that i mean if you can show a decoupling on whatever the industrial use is whether it's a molten salt tank whatever whatever you happen to be as long as we can now take those traditional requirements that you might have had on the turbine generator and on the intake structure and all those things that just really don't affect nuclear safety and simplify those down to reduce those down to minimal that really is going to be helpful to these applications so we don't have anything in part 53 specifically on decoupling but the risk informed approach would allow us to move in that direction so just just something to think about on that thank you and i think i saw dave darren and ed in apologies if i got the wrong order so yeah i i was gonna make the same comment as dennis that this decoupling of the reactor from the application i think there are certain technologies and design solutions that work now a bad designer can design a reactor that's going to have a huge interaction if there's an upset in in terms of the end use of the energy but i think a good designer will look at ways to uncouple that and i think in the advanced technologies there's more than one technology that has these uh positive attributes so that you can not have to be as concerned about the impact of the end use of the energy on the reactors thank you uh ed and then or i'm sorry darren i think you're so working i i don't have anything different to say other than what dennis and dave just said but other than the fact that what we have seen uh globally is that the percentage of industrial applications uh are much more carbon based than when you think when you look at electricity based generation around the world so that in fact decarbonizing the planet on the industrial heat side is actually even more significant going to nuclear right is a much it's a bigger you know decarbonization footprint by utilizing nuclear on the industrial heat side so this is a very key and important part of part 53 is knowing and understanding that down the road the uses of nuclear power are going to be for companies that historically have not been in nuclear and have not you know have just been burning carbon based products to to create that higher temperature process heat that they need so it's something we clearly need to focus on in this rule making thank you and ed yes i think there are certain aspects where that decoupling you know may not be um possible and in particular if you're talking about process heat and the potential that you have a nuclear reactor close to uh you know chemical plant uh then you're going to have to worry about the external hazards posed by the plan on the reactor now that i think is already should be accommodated by by the rule uh but you it may need to be a little more explicit on how you know those those impacts would be assessed and then it goes the other way as well what about the impacts of reactor accidents on the safe operation of a hazardous facility so there are interactions and it may make sense uh for some specific um provisions to make sure those aren't those are fully addressed thank you and your answers were so crisp that we can actually do another question before we go to uh bowling question three and that is how do you see the role of prototype or test reactors in the deployment of advanced reactors and how should part 53 facilitate this approach and i see dan or dave's hand up so um i think that the prototypes are really important if a concept's never been built before so i'm not saying gas reactors i'm not saying sodium reactors many of those have been built but there are other technologies out there under consideration that have never seen neutrons and that's why i think a prototype would be useful um it's also in the broader engineering sense i i find it interesting to to hear comments about this the chemical industry use pilot plants for any new process that they develop when you've got this first of a kind the prototype really helps you in terms of scaling up the process from an engineering perspective you've got to write procedures and operational procedures if you've never done anything at any significant scale beforehand how does one do that now usually you start with components and you write procedures and you learn from the components you integrate them together you have some sort of a loop maybe a very small reactor and and from that you then develop the bigger reactor that's how reactive development has been done around the world um and it's not by accident it's good engineering practice and so i don't see us you know deviating from that um and i i think it should be part of 53 as an option right i think it was ed and then dennis yeah i would i would strongly agree with that i think that um and uh taking some issue with um with dennis um the the problem is that if you do have reactors that have not had you know they may have had some tester demonstration experience but not necessarily captured features of current designs that are critical for making that safety case that you do need a prototype testing to demonstrate some of these inherent safety features before you can have confidence that they can be licensed with uh you know what are called operational flexibilities or however you want to characterize it i would say a margin reduction uh so i i think prototyping has to be a critical part of that and the current language in 5043e i guess um regarding prototypes is is ambiguous it does i don't think it has clear criteria uh for determining uh when over at what point the nrc would decide the prototype is uh information is necessary which could impact schedules so i really would hope that part 53 would have more clarification of that and perhaps milestones uh decision making where applicants are are notified that they're going to need to build and demonstrate a prototype if they want a particular if they wanted a particularly regulatory relief to be able to take advantage of that so i i really would hope that those requirements for prototypes would be clarified in the rule and dennis yeah thanks andrea uh um i don't disagree with it with that said i think the uh you know prototypes for reactors we haven't uh operated it prior is going to be super important uh uh luckily in the sodium reactor space we've had a long history of sodium reactor operation um for example the ebr2 we ran for over 30 years and so we and it has the safety features that we're going to be utilizing in the current generation of sodium reactor fast reactors so um but you know molten salt reactors are going to be uh going to need that and i know kairos is moving in that direction and so it's really important the aspect that nobody else had covered yet though is let me talk about the testing uh currently the department of energy is proposing to test a lot of the advanced fuels and materials in the versatile test reactor vtr uh and unfortunately the funding on that has has dried up uh considerably and that is delayed um and as a result you know a lot of what we're gonna be building for some of these reactors will not have a lot of the testing we need for advanced materials especially in our advanced schools and so they'll move forward with what we know are the types of materials and fuels that we know and i think we can make a lot of progress in the area of safety if the vtr were completed so completing the vtr is super important for i think everybody's everybody's sake so thanks and darren yeah you know like what dennis said the you know the history behind high temperature gas cooled reactors goes back you know many decades not just many years many decades and we also at x energy will be you know are planning a series of helium loop testing that we'll do you know we'll be doing of components so we will not be obviously setting up a prototype reactor but we're certainly going to be doing some irradiation of our fuel compact the pebble and we're going to be setting up some some temp you know high temperature helium loop tests for the components so again we're we're pseudo setting up prototype testing in the reactor without actually doing a prototype reactor itself so i think clearly where you've got technologies that have never been used before setting it up in some type of prototype reactor is probably you know probably the the right thing to do from an engineering standpoint thank you darren and as we get ready to move into q's and a's can we get the last polling question question number three displayed and then i will start with the quest with the uh q's and a's so darren is on the screen and i believe the first no the first question is for dennis dennis what is your view with regard to the security risk and form and the role of security vulnerability assessment in the context of performance-based regulatory framework right uh that that's a great question um under the the jc and ram or drunkman nuclear risk management we we have a working group on risk and form uh physical and cyber security we have two working groups that are looking at that um hate to uh correct mr petty's uh wording uh he used the word risk based for us in the pra industry risk-based is kind of like a four-letter word you know we try not to use it uh what we're looking at is a risk-informed approach um and um and there are different different approaches but you know use use the risk assessment that you have typically a pra and then you know regardless of what the the results show you you always ensure you maintain a defense and depth and you ensure you have adequate safety margins um when the risk assessment can't uh cover that aspect then we then we move into a deterministic set of requirements so if you if you haven't done the risk assessment even under the light simulation project for example um you would default to a deterministic approach now security um is an interesting one we can't do a traditional pra because the the pra looks at both the consequences of you know what happens when something is damaged uh as well as the frequency and the frequency of the security event is the hardest thing to estimate all right you can't can't predict what um somebody may do to the plant uh for a variety of events whether whether it be an aircraft crash or just a security event overall security breach um the risk conformed security uh working group is working in that area to try to at least look at the relative frequencies and see if they can help but but i think the the longer term and uh i'm sure mr lyman would agree uh is i i don't think in the short term we're going to be able to risk informed security fully we can we can use risk information as the current fleet is using risk information regarding the target sets from the pra and in the level of damage it may be maybe seen for various events but with regard to um removing a lot of the deterministic criteria associated with physical security so it can we can get to it there to a certain extent and take credit for passive features inherent features of a reactor but i still think there will be a fairly large deterministic overlay on the requirements until we can do a little bit better job on estimating frequency of various events appreciate it hey thank you dennis now the next question is for me it says how has information from the canadian nuclear safety commission especially their smr testing at chalk river help support development of part 53 for addressing diverse safety and environmental points of view on licensing new and advanced reactors and this is not specific to chalk river but we have a memorandum of cooperation with cnsc and we've been coordinating for a while with them on various aspects including development of part 53 and one of the specific examples is um it actually came from feedback and meetings as well is to make sure what we're doing is not um impacting in a negative way international standards so as we're developing part 53 we're interacting with cnsc to make sure there's this global approach and we're also interacting with them on fusion as you heard the chairman mentioned we're in a learning phase of um giving options to the commission for their consideration and we will be submitting a paper to the commission with regard to fusion so the next question is for ed this question combines two questions we received and it says why would you exclude certain reactors from part 53 simply because of the kind of coolant they use and likewise what specifically is your concern with all reactors including non-passive plants using risk and form licensing wouldn't the process account for different types of technology yes and and to be clear i only singled out large light water reactors because that's what the current fleet consists of so we're essentially talking about anything new uh compared to the current fleet and um but the point the point is if um reactor design comes for if there's an application for reactor design that doesn't have a clear case for saying that it has significantly enhanced safety which means that maybe the nrc can take certain liberties with the existing licensing approach why should it have the benefit of being able to enter into this alternative approach and if and again it raises the the potential that that these new facilities may be licensed under a regime which is not comparable in safety and i know the goal is to make part 53 comparable but you know again there's some they're going to be a lot of i think uh lack there's going to be lack of clarity in a number of different areas that don't have to do with fundamental reactor design issues the operational programs like operation operator licensing requirements things like that these are already well established for the current fleet and i just feel like this is opening the door to a sort of parallel but weaker process potentially branding new applicant which could possibly lead to an overall decrease in safety of the fleet so that's my concern thank you and the next question is for me as well does this mean we would develop a new srp or standard review plan for advanced reactor reviews which would apply to all types of reactor designs uh no we're prioritizing the development of this technology inclusive regulatory guidance and consensus codes and standards we have very significant activities underway now for example developing the technology inclusive guidance for content of application to help applicants that are coming in to be clear on what they need to provide so the next question is for all panelists uh let's see the iterative rulemaking process with partial releases comment taking then reconsideration is inherently inefficient as ed notes it can result in a more widely accepted final product or not do you think use of this process for part 53 has helped or has it just caused additional frustration amongst all stakeholders because of the multiple rounds of engagement so let's start with i'm looking at dennis let's start with dennis to get your thoughts on that and then anybody else can um raise your hands if you want to comment i appreciate andre the the um i think i'd mention it earlier and i i wouldn't say it's so much frustration i um i think it's just takes extra time uh overall um and i think it's going to delay the the process it's not that the the overall process of engagement and discussion and then revision of the rule the directoral um i think it's very positive aspect of it because it's it's not just taking the industry comments uh it's taking mr lyman's comments whoever wants to comment on it and then the nrc weighs that as they should independently and then come up with the what they believe to be the best approach the the problem we're seeing is that the the amount of engagement is just too too high for me it's again back to that the the original wording that was released is just too too deterministic too much similar to the old wording um that requires a little bit too much engagement and if we can um somehow have the nrc think about the wording a little bit better before it comes out and in interface with their own pra people uh that would really reduce the amount of interaction required but what's really happening is the industry is is is focusing in on the things that they see right so that that's important to them but underlying that right we see you know the operator uh requirements for example operator training certification that all seemed to be very good but underlying that's the human factors engineering stuff i referred to earlier nobody's focusing on that because that's a smaller piece of the pie than we're worried about and eventually we'll have to talk about these these other things that we haven't yet had discussion on that may be underlying like the number of the fire brigade for on the fire protection program and the underlying deterministic fire protection requirements for uh suppression and detection and all that and how do you risk inform all that uh so i i think it's just you know we foresee further delays because of that amount of interaction this is all the only problem but the underlying process i think we have to go through it it's to get where we want to go i think we have thank you darren yeah so to dennis's point i would tell you that i i don't think it's the processes that make it slow it's just that this is hard what we're trying to do is hard and so it's not going to be just simple and quick that we get through this so the reason everyone is commenting on it because it is difficult and there's a lot of different things that we have to consider if you're going to make it technology inclusive you you have to have it very broadly based and and the flexibility to it so again yes it's it's going to make it longer than previously when the nrc was just you know focusing themselves on creating the language and then just letting us comment on the language but i i would tell you that i think it's just hard it's long because it's hard to do not that we've got the wrong process going that's what i would say and i don't see hands up so i would add here too that i think the value and doing this the way we've done it so early this is an unbiased opinion is that a lot of these um really difficult issues are put on the table early so you can iterate on the issues and there has been change there's been significant change that has come about because of this iterative process and just imagining having all of that and one uh you know um submittal and then trying to resolve all of those issues in a public comment period it would just kind of prolong it at that point while we're taking the time up front to really kind of dig into some of these issues i think it's the value and i see ed's panda yeah since i raised this in the first place i won't say too much but there were more than one occasion i saw a process where the staff came out with a proposal they were criticized by a number of industry stakeholders they went back and thought they changed it to accommodate what they heard and then the industry attacked it again and maybe even criticized why they were making the change in the first place even though they uh suggested it so uh it seems like there was some guy in circles at one point which is one thing in flag thank you uh let's see this question is for dennis risk and form is a blend of risk insights with deterministic insights isn't what you're talking about discarding deterministic requirements based um i'm not sure i use the word discarding deterministic criteria requirements but um the risk inform is of using risk results risk information um uh along with a deterministic overlay which includes defense and depth and and safety margin so uh irregardless of what your pra said you still have a safety analysis and you still have a safety case to be made uh and then when again you don't have risk information and risk results then you have determinants you go with a deterministic set of criteria um so we would never discard deterministic criteria we may um per se we may uh if we can demonstrate the risk is sufficiently low with margin and with adequate defense and net then we may remove requirements for example for components to be safety related they may be still present but not safety related um so hopefully that explains it but it depends on the application of risk and form as far as what you're doing but for risk and form licensing we still have deterministic requirements there in the area of defense

2022-04-14 01:35

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