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DOE OSTI2021

Regulatory Treatment of Low Frequency External Events under a Risk-Informed Performance-Based Licensing Pathway

Significant efforts are underway to develop and implement a risk-informed performance-based licensing framework for advanced reactors built on the establishment of an affirmative safety case. Such approaches offer the benefits of increased flexibility regarding key design and licensing decisions based on a detailed assessment and understanding of plant risk. These methods include the comprehensive analysis of scenarios that have historically been addressed through conservative and deterministic licensing analysis approaches, such as the evaluation of event sequences at frequencies of occurrence beyond the design basis. While the detailed analysis of low frequency events provides insights that can help justify alternative treatments to past conservatism, the findings are dependent on the quality and confidence associated with the analyses. The assessment of external hazards presents a unique challenge, as their potential frequency of occurrence, especially of large magnitude events, is inherently uncertain given the long return periods in question. The current project seeks to further explore the regulatory treatment of low frequency external events as part of a risk-informed performance-based framework. The goals are to identify the benefits and challenges of such approaches for advanced reactor vendors and to aid in the development of consistent and appropriate methodologies. As part of this effort, the current report summarizes initial project findings, with a focus on the evaluation of the seismic hazard. This includes an exploration of the implementation of a risk-informed performance-based approach through an example analysis. Based on the identified challenges associated with the probabilistic treatment of low frequency event sequences, additional performance-based methods were explored as complementary tools for demonstrating regulatory compliance. The report highlights key challenges and opportunities associated with the methods and outlines recommendations and future activities to assist with their implementation.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗
DOE OSTI2024

Regulatory Treatment of Low Frequency External Events under a Risk-Informed Performance-Based Licensing Pathway: Safety Criteria Evaluation

There has been recent progress in the development of risk-informed performance-based (RIPB) design and licensing approaches, which leverage the insights gained from detailed risk assessments and utilize performance-based metrics to permit flexibility and innovation. The RIPB approaches have included the probabilistic treatment of external hazards, including low frequency events that are beyond the design basis. A preceding study conducted in FY21 noted that there are certain challenges to the probabilistic treatment of low frequency external events, which are primarily the result of uncertainty in the hazard curve and the associated plant response to rare, severe events. The current work expands on the previous study by examining the regulatory safety criteria contained within draft 10 CFR Part 53 and associated draft RIPB seismic design guidance. The evaluation identified potential challenges in demonstrating satisfaction of the safety criteria for low frequency external events, with specific difficulties associated with demonstrating compliance with cumulative safety criteria metrics, such as the quantitative health objectives (QHOs). Non-LWRs are expected to utilize the direct calculation of offsite consequence, rather than use surrogates, for comparison to the QHOs, which can be particularly challenging as the previously identified uncertainties are compounded by uncertainties in the response of the neighboring population. The current work details this evaluation and key findings. The central recommendation from this effort is that it is necessary to develop an approach for demonstrating compliance with the safety criteria in draft Part 53 that addresses the key challenges while providing flexibility to applicants.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗
DOE OSTI2024

Regulatory Treatment of Low Frequency External Events under a Risk-Informed Performance-Based Licensing Pathway: Enhanced SPRA-based Margins Assessment

Recently there has been development in the field of risk-informed performance-based (RIPB) design and licensing approaches, which leverage detailed risk assessments and performance-based metrics to allow flexibility and innovation. These RIPB approaches include the probabilistic treatment of external hazards, including low frequency events that are beyond the design basis. However, there are certain challenges that have been identified to the probabilistic treatment of low frequency external events, primarily due to uncertainty in the hazard curve and the associated plant response to rare, severe events. The NRC is currently developing 10 CFR Part 53 that would establish a technology-inclusive regulatory framework for use by applicants for new commercial advanced nuclear reactors. By examining the regulatory safety criteria contained within draft 10 CFR Part 53 and associated draft RIPB seismic design guidance, potential challenges were identified in demonstrating satisfaction of the safety criteria for low frequency external events, with specific difficulties associated with demonstrating compliance with the quantitative health objectives (QHOs). Non-LWRs are expected to utilize the direct calculation of offsite consequence, rather than use surrogates, for comparison to the QHOs, which can be particularly challenging as the previously identified uncertainties are compounded by uncertainties in the response of the neighboring population. The central recommendation from this effort is that it is necessary to develop an approach for demonstrating compliance with the safety criteria in draft Part 53 that addresses the key challenges while providing flexibility to applicants. This paper summarizes key findings, establishes a series of high-level goals, and reviews a newly developed approach to address the major challenges associated with assessing compliance with QHOs, with avenues to demonstrate compliance based on either the estimated consequence or the available margin to event occurrence, while also building on existing experience of seismic margins assessments. The paper also provides examples to demonstrate the application of the approach, as well as recommendations and potential future work.

external hazards↗
DOE OSTI2020

Modernization of Technical Requirements for Licensing of Advanced Non-Light Water Reactors: Risk-Informed and Performance-Based Evaluation of Defense-in-Depth Adequacy

This document supports the work contained in Nuclear Energy Institute (NEI) 18-04 “Risk-Informed Performance-Based Technology Inclusive Guidance for Advanced Reactor Licensing Basis Development” Revision 0. NEI 18-04 presents a modern, technology-inclusive, risk-informed, and performance-based (TI-RIPB) process for selection of Licensing Basis Events (LBEs); safety classification of structures, systems, and components (SSCs) and associated risk-informed special treatments; and determination of defense-in-depth (DID) adequacy for non-LWRs. The NEI guidance document provides one acceptable means for addressing the aforementioned topics as part of demonstrating a specific design provides reasonable assurance of adequate radiological protection. This report provides the framework and associated methodology guidelines and discussion for establishing, then evaluating, confirming, and documenting the adequacy of defense-in-depth (DID) for advanced non-light-water reactor technologies. It was developed as part of the Licensing Modernization Project led by Southern Company and cost-shared by the United States Department of Energy and has benefited from considerable NRC formal reviews and public workshops. The methodology converts the DID philosophy into a structured process that is implementable, embraces existing United States and international definitions and philosophies of DID that set the foundation for the process. It builds on the DID framework developed in the Department of Energy Next Generation Nuclear Plant Project and earlier works on this subject. The approach to establishing DID adequacy involves the incorporation of DID attributes into the plant capabilities and programmatic elements of DID. The integrated evaluation of DID adequacy includes both quantitative elements to incorporate risk-informed and performance-based (RIPB) considerations and qualitative elements that address uncertainties and limitations in the quantitative models and supporting data. Demonstration of DID adequacy ensures that there are multiple layers of defense for risk-significant challenges to the design and that the plant capabilities and programs that support each layer are provided in a manner that minimizes dependencies among these layers. The focus of this report is assurance of DID adequacy with respect to protection of the public from radiological exposures resulting from accidental releases of radioactive material. While other hazards are not specifically addressed, this methodology is expected to be beneficial for determining DID adequacy for them as well. Risk-informed evaluation of DID considers the integrated performance of all plant SSCs and associated programs to manage daily operational activities, transients, and accidents, including the evaluation of strategies for accident prevention and mitigation. The RIPB LBE scenario methodology used in this evaluation defines the challenges to the plant safety features included in the plant design basis and beyond, and the scope of all deterministic and probabilistic safety evaluations. By examining event sequences across the whole spectrum of LBEs, a systematic assessment of DID can be accomplished.

42 ENGINEERING↗
DOE OSTI2020

Model MC&A for Pebble Bed Reactors (Technical Direction No. 5 Task 2.6 Letter Report)

In preparation for non-light water reactor (non-LWR) activities, US Nuclear Regulatory Commission (NRC) staff are advancing risk-informed and performance-based licensing approaches and addressing key policy issues. One non-LWR reactor concept is a pebble bed reactor (PBR). This reactor design uses spherical fuel elements (pebbles) that are continually added to and removed from the reactor core. The free movement of the fuel in this design presents new challenges for material control and accounting (MC&A) programs. Therefore, an assessment of MC&A program features and measures for a PBR was performed to help NRC staff develop associated MC&A regulations or regulatory guides. The current regulatory framework for non-LWR fuel cycles excludes support for licensing reviews for MC&A programs for PBRs. Licensing reviews of an MC&A program for PBRs can be facilitated by (1) a model MC&A program for a PBR based on identification and assessment of MC&A program features and recommended measures for a reference PBR and (2) a methodology for assessing MC&A performance that can help assess different MC&A program features and measures. This report supports the NRC’s non-LWR Vision and Strategy Near-Term Implementation Action Plans.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗
DOE OSTI2022

Risk-Informed Initiating Events and Accident Response

Emerging nuclear technologies and advanced reactor developments have brought proposed changes to the regulatory framework which can be leveraged to improve safety implementation and regulatory oversight processes at existing operating nuclear power plants. Specifically, opportunities exist to make plants’ regulatory compliance processes more efficient. This can be done by decreasing reliance on purely deterministic and prescriptive approaches and expansion of the use of risk informed and performance-based approaches to demonstrate reactor safety while achieving economic gains and efficiencies. In this report, we researched possibilities of economic benefits potentially available from the application of concepts associated with a modernized regulatory framework developed for advanced reactors to the existing light water reactors. We used timing factors to demonstrate the complexity of the existing risk assessments and described how these complexities affect regulatory compliance activities at the plants. We also investigated regulatory framework for both existing and new reactors and provided an overview of potential improvements. Lastly, we evaluated various areas of existing plant operations where modernization of compliance activities can offer substantial benefits.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗
DOE OSTI2022

Regulatory Treatment of Non-Core Sources of Radioactivity for Advanced Reactor Designs

The recent resurgence in advance (non-light water) reactor development has been paralleled by the development of risk-informed performance-based (RIPB) licensing pathways. Specifically, the creation of the RIPB Licensing Modernization Project (LMP) approach and subsequent endorsement by the U.S. Nuclear Regulatory Commission (NRC) now provides advanced reactor vendors with a defined RIPB method to develop an affirmative safety case for licensing. In addition, the Technology Inclusive Content of Applications Project (TICAP) has published guidance on developing a license application based on the LMP approach. To support the utilization of risk information as part of advanced reactor design and licensing efforts, the American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) Joint Committee on Nuclear Risk Management (JCNRM) has developed a probabilistic risk assessment (PRA) standard for advanced reactors. The standard, which was formerly approved by the American National Standards Institute (ANSI) in 2021 and recently endorsed by the NRC in trial use Regulatory Guide (RG) 1.247, is an integral standard, covering from initiating events to offsite consequence. A major feature of the standard is that it permits the inclusion of any source of radioactivity material at the site within the plant PRA. Therefore, non-core sources of radioactivity, such as fuel storage, fuel processing, and purification systems, can be included within a single comprehensive plant PRA. For those advanced reactor vendors utilizing a RIPB licensing approach, there is an opportunity to include the non-core sources of radioactivity within the RIPB framework for licensing decision-making, such as the categorization of events, classification of structures, systems, and components (SSCs), and evaluation of the adequacy of defense-in-depth (DID). For advanced reactor designs that contain multiple non-core sources of radioactivity, or for monolithic plant sites that include associated fuel facilities, this approach could potentially simplify licensing applications through the use of a single, uniform, and consistent decision-making framework across all radioactive sources at the site. In addition, a RIPB approach could provide additional insights regarding plant behavior, flexibility regarding licensing decision-making, and potentially allow the use of risk information as part of the plant oversight process. Risk-informing these aspects of advanced reactor licensing would also be consistent with the NRC’s risk policy statement. However, there is diverse regulation and guidance regarding the licensing of non-core sources of radioactivity and generally limited experience using RIPB approaches for the evaluation as part of licensing.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗
DOE OSTI2020

Modernization of Technical Requirements for Licensing of Advanced Non-Light Water Reactors: Selection and Evaluation of Licensing Basis Events

This report, “Modernization of Technical Requirements for Licensing of Advanced Non-Light Water Reactors: Selection and Evaluation of Licensing Basis Events,” represents a key element in the development of a methodology for the efficient licensing of advanced non-light water reactors (non-LWRs). It is the result of a Licensing Modernization Project (LMP) led by Southern Company and cost-shared by the U.S. Department of Energy (DOE). The LMP will result in detailed proposals for establishing licensing technical requirements to facilitate risk-informed and performance-based design and licensing of advanced non-LWRs. Such a methodology acknowledges enhancements in safety achievable with advanced designs and reflects more recent states of knowledge regarding safety and design innovation, creating an opportunity for reduced regulatory complexity with increased levels of safety. The project builds on best practices as well as previous activities through DOE and industry-sponsored advanced reactor licensing initiatives.

42 ENGINEERING↗
DOE OSTI2020

Modernization of Technical Requirements for Licensing of Advanced Non-Light Water Reactors: Probabilistic Risk Assessment Approach

This report, “Modernization of Technical Requirements for Licensing of Advanced Non-Light Water Reactors: Probabilistic Risk Assessment Approach,” represents a key element in the development of a methodology for the efficient licensing of advanced non-light water reactors (non-LWRs). It is the result of a Licensing Modernization Project (LMP) led by Southern Company and cost-shared by the U.S. Department of Energy (DOE). The LMP has developed detailed proposals for establishing licensing technical requirements to facilitate risk-informed and performance-based design and licensing of advanced non-LWRs. Such a methodology acknowledges enhancements in safety achievable with advanced designs and reflects more recent states of knowledge regarding safety and design innovation, creating an opportunity for reduced regulatory complexity with increased levels of safety. The project builds on best practices, as well as previous activities through DOE and industry-sponsored advanced reactor licensing initiatives.

42 ENGINEERING↗
DOE OSTI2022

The Regulatory Treatment of Low Frequency External Events as Part of a Risk-Informed, Performance-Based Approach

To assist the developing advanced reactor industry in future licensing efforts, the U.S. Department of Energy Advanced Reactor Demonstration Program Regulatory Development area initiated a project at Argonne National Laboratory to examine the regulatory treatment of external hazards as part of a risk-informed performance-based (RIPB) licensing framework. A RIPB licensing framework for advanced reactors built on establishing an affirmative safety case offers the benefits of increased flexibility regarding key design and licensing decisions based on a detailed assessment and understanding of plant risk. Historically, reactor licensing addressed events of very low frequency primarily through the application of design margin and defense-in-depth philosophy. In contrast, RIPB approaches attempt to evaluate these scenarios at a level of detail commensurate with their risk, which often necessitates an explicit treatment of their frequency and associated consequence. While the detailed analysis of low frequency events provides insights that can help justify alternative treatments to past conservatism, the findings are dependent on the quality and confidence associated with the analyses. The assessment of external hazards presents a unique challenge, as their potential frequency of occurrence, especially of large magnitude events, is inherently uncertain given the long return periods in question. This project aims to identify the benefits and challenges of such approaches for advanced reactor vendors and aid in the development of consistent and appropriate analysis methodologies. The paper summarizes project findings and explores the application of various approaches for different external hazards. In addition, the current work also evaluates the application of the quantitative health objectives as a limit on external event risk, as they are a potential regulatory requirement under the current draft 10 CFR Part 53, which is a new technology-neutral reactor licensing pathway in the U.S.

Grabaskas, David↗
DOE OSTI2024

Towards Risk-Informed Performance-Based Emergency Planning: Review of Regulation, Guidance, and Methods

At a fundamental level, nuclear facility safety is built upon the concept of defense-in-depth (DID), which entails multiple, independent layers of protection for public health and safety. Within the DID structure, emergency preparedness (EP) is the last layer of defense and provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Over several decades, the EP regulatory framework has evolved in response to lessons learned from actual events, experience with maintaining and testing EP capabilities, and advances in a wide range of technologies. Furthering this evolution, recent developments in risk-informed performance-based (RIPB) design and licensing approaches provide an opportunity to leverage insights regarding the attributes of the specific facility and site to inform EP.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗
DOE OSTI2021

Modular High Temperature Gas-Cooled Reactor: Licensing Part I

NRC PRA Policy Statement motivates risk-informed, performance-based (RIPB) approach to modular High Temperature Gas-cooled Reactor (HTGR) licensing Complements traditional deterministic design approach to increase use of risk insights in design and licensing decisions Risk-informed approach: Explicit consideration to a broader set of challenges Logical prioritization of challenges Consideration of broader set of resources to defend against challenges Explicitly identifying and quantifying sources of uncertainty Better decision making by testing for sensitivity to key assumptions Performance-Based Approach: Measurable (or calculable) parameters for monitoring Objective criteria to assess performance

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗
DOE OSTI2025

Security Licensing Basis Framework Development

This report summarizes a technology-inclusive and performance-based method to determine the physical security licensing basis for a commercial nuclear reactor under the proposed 10 CFR 73.100 for Part 53 licensees. The method focuses on the identification of security functions, the contributing security systems and programs to meet those functions, the identification of security events that will provide the foundation for the security licensing basis and includes a risk-informed performance-based defense in depth adequacy method. The method can also be employed to justify performance-based alternative measures to traditional security requirements found in 10 CFR 73.55.

98 - NUCLEAR DISARMAMENT, SAFEGUARDS, AND PHYSICAL↗
DOE OSTI2024

ECAR-6440 Rev 2 MARVEL Hazard Evaluation

This hazard evaluation supports the Microreactor Applications Research, Validation, and Evaluation (MARVEL) Project’s design effort and the development of the preliminary documented safety analysis (PDSA) (addendum to safety analysis report [SAR]-420, “Transient Reactor Test [TREAT] Facility FSAR”) (SAR-420-ADD-1). The hazard evaluation process for the MARVEL project for compliance with the requirements in 10 CFR 830, “Nuclear Safety Management,” follows a process similar to the Licensing Modernization Project (LMP) as outlined in Nuclear Energy Institute (NEI)-18-04, “Risk-Informed Performance-Based Guidance for Non-Light Water Reactor Licensing Basis Development,” and supporting documents. The LMP process is adapted to fit Department of Energy (DOE) reactor regulatory requirements as applicable and appropriate using a graded approach based on the MARVEL microreactor design. This approach provides reasonable assurance of meeting the requirements of 10 CFR 830 for protection of the public, workers, and environment.

21 - SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLAN↗
DOE OSTI2021

Software Verification and Validation Guidelines for Non-Linear Soil-Structure Interaction Analysis

Seismic analysis of structures, systems, and components (SSCs), including the consideration of soil-structure interaction (SSI) effects, is an important and required step in the design and licensing of nuclear power plant SSCs important to safety. Historically, the SSI analysis of nuclear structures has been performed using equivalent linear methods. However, there has been considerable industry investment in alternative seismic design and analysis approaches to reduce the construction cost of new reactors. Toward that goal and in alignment with the Licensing Modernization Project (LMP) framework, the Nuclear Regulatory Commission (US NRC) has proposed a risk-informed, performance-based approach to seismic design that allows inelastic response in those nuclear plant structures not required for confinement. As a complementary effort, reactor designers are exploring nonlinear seismic analysis methods to optimize structural designs and reduce construction costs.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗
DOE OSTI2023

Novel Approaches and Technologies for Aging Management

As part of the application process for license renewal and subsequent license renewal, nuclear utilities must perform an evaluation to confirm that they have appropriately considered aging effects on plant structures, systems, components within the scope of the license renewal. This effort within the Light Water Reactor Sustainability program’s Risk-informed System Analysis pathway is focused on risk-informed and performance-based approaches for aging management of buried piping, specifically managing selective leaching degradation phenomena. Selective leaching is a commonly occurring aging and degradation mechanism in buried pipes at nuclear power plants. To better understand the extent of selective leaching and its effect on the health of buried components, the licensees currently rely on visual inspections and destructive examinations which require extraction of multiple buried components. This research explores technological solutions that may replace or supplement existing inefficient, costly, and labor-intensive methods used in aging management.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗
DOE OSTI2022

Utilization of the LMP Methodology in Support of the VTR Conceptual Safety Design Report

The Versatile Test Reactor (VTR) is a fast spectrum test reactor currently being developed in the United States under the direction of the US Department of Energy (DOE), Office of Nuclear Energy. The VTR is utilizing a risk-informed performance-based (RIPB) approach for design support and authorization by the DOE, derived from recent efforts by the US industry led Licensing Modernization Project (LMP). This document contains an overview of the implementation of the LMP approach in support of the VTR Conceptual Safety Design Report (CSDR). The work reported here is the result of studies supporting a VTR conceptual design, cost, and schedule estimate for DOE-NE to make a decision on procurement. As such, it is preliminary. The VTR RIPB authorization approach utilizes information from the probabilistic risk assessment (PRA), coupled with deterministic analyses, to aid in decision-making regarding the identification and categorization of safety basis events (SBEs), the classification of structures, systems, and components (SSCs), and the evaluation of defense-in-depth (DID) adequacy. As part of initial reactor design efforts, a VTR conceptual design PRA was developed to support the RIPB process, which focused on at-power internal events, with scoping analyses for seismic and sodium fire hazards. In addition to supporting numerous design studies, preliminary results from the RIPB approach and the VTR conceptual design PRA were utilized as the basis of the VTR CSDR. The initial identification and categorization of SBEs, SSC classification, and DID evaluation were contained within the CSDR, which was submitted to DOE in 2019 as part of the CD-1 submittal package. Following review, DOE approved the CSDR in April 2020 and the CD-1 package in late 2020. Valuable experience was gained through the implementation of the RIPB approach for design and authorization during the VTR conceptual design phase, which is summarized in this document. To the extent possible, this experience has been shared with the advanced reactor industry, through publications and participation in licensing tabletops, in addition to informing DOE:NE advanced reactor regulatory development efforts. Furthermore, the approval of the CSDR by the DOE as part of CD-1 represents a significant milestone in the use of RIPB approaches for advanced reactor licensing.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗
DOE OSTI2020

Structures, Systems, and Components Classification Criteria for the Versatile Test Reactor

The Versatile Test Reactor (VTR) is a fast spectrum test reactor currently being developed in the United States under the direction of the US Department of Energy (DOE), Office of Nuclear Energy. The VTR mission is to enable accelerated testing of advanced reactor fuels and materials required for advanced reactor technologies. The conceptual design of the 300 MWth sodium-cooled metallic-fueled pool-type fast reactor has been led by the U.S. National Laboratories in collaboration with General Electric-Hitachi and Bechtel National Inc. As part of the VTR authorization process by the DOE, it is necessary to identify the safety classification of structures, systems, and components (SSCs) to determine the proper design, surveillance, operation, and incident-reporting requirements. Since VTR is utilizing a risk-informed, performance-based authorization process based on the Licensing Modernization Project (LMP) described in NEI 18-04 [1], the criteria for SSC classification, which are reviewed here, includes both risk information from the probabilistic risk assessment (PRA) and prescriptive requirements.

Grabaskas, David↗