ANSI-NIST
Nuclear Energy Standards Coordination
Collaborative
Larry Burkhart, Chief, AP1000 Projects Branch (LB4)
Division of New Reactor Licensing
NRC’s Office of New Reactors
November 7, 2013
Agenda and Background
Agenda
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New Reactor Designs/applications in the USA
Quick construction status – Vogtle and Summer AP1000s
10 CFR Part 52 - combined licenses and certified designs
Lessons learned from a regulatory perspective
Background
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Combined license – NRC authorization to construct and operate a nuclear power plant
in accordance with applicable laws, regulations, and conditions
Latest version of Westinghouse’s AP1000 standard design certified in December 2011
SNC, et al, received combined licenses for Vogtle Units 3 and 4 on February 10, 2012
SCE&G, et al, received combined licenses for Summer Units 2 and 3 on March 30, 2012
First Nuclear Concrete (FNC) for Summer Unit 2 poured 9 – 11 March 2013 (4
November for Unit 3)
FNC for Vogtle Unit 3 poured 12 – 14 March 2013
Continuing civil works, module fabrication and shipping, and large component deliveries
4 AP1000s under construction in China (Sanmen and Haiyang sites commenced in
2008) – cooperation with China bilaterally and multilaterally
AP1000 design reviewed/under review in Canada, China, and the U.K. (MDEP)
AP1000 being marketed in Czech Republic, India and other countries
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New Reactor Applications
Under Review – Large LWRs+
ABWR
AP1000
ESBWR
EPR
USAPWR
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+Large
LWRs-- Large Light-Water Reactors, generally of the order of 1000 MW(e) or more
Construction Status Vogtle
Vogtle Unit 3
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Construction Status Vogtle
Vogtle Unit 3
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Part 52 - Fitting the Pieces Together
Pre-Construction
Early Site Permit
LWA
Combined License
Review, Hearing,
and Decision
Optional
Pre-Application
Review
Construction Verification
Verification of
Regulations
with ITAAC
Reactor
Operation
Decision
Standard Design
Certification
• Licensing decisions finalized before major construction begins
• Inspections w/ITAAC (Inspections, Tests, Analyses, and Acceptance Criteria) to verify construction
• Limited work may be authorized before COL issuance
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Lessons Learned in COL Reviews
First implementation of NRC’s 10 CFR Part 52 processes to issue COLs
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Bipartisan Policy Center Report (April 6, 2010)
• Thorough and timely evaluation of license applications…however, there were
expected problems in navigating the new processes
• The Commission should ensure the lessons learned are rigorously applied to
make the processing of subsequent applications more efficient
NRC’s Lessons Learned Review Report – April 213
• High quality applications with sufficient detail
• Timely development and maintenance of regulatory guidance
• Strong design standardization
• Early identification and timely resolution of complex issues
• Improve system of requests for additional information
• Concurrent reviews of design certifications and combined license applications
• Update to regulations incorporating lessons learned
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Terminology - Current Licensing Basis
Definition of Licensing Basis (10 CFR 54.3)
• Obligations (Regulations, License Conditions, Technical
Specifications, Environmental Protection Plan,
and ITAAC)
• Mandated Licensing Basis Documents (FSAR, QA, EP,
Security Plan, etc.)
Vogtle/Summer-FSAR:
• Summer — COL FSAR +Plant Specific DCD
• Vogtle — ESP SSAR + COL FSAR + Plant Specific DCD
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FSAR
Plant –Specific DCD
COL
FSAR
ESP
SSAR
(Vogtle Only)
E Plans
QA
Tier 1
Tier 2
Tier 2*
Security
Op Programs
E Plans
Seismic
Hydrology
FFD
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Design Certification – AP1000 and COLs That
Reference the AP1000
Design is Certified, i.e., incorporated into NRC regulations as 10 CFR Part 52 Appendix D
• Design is fixed at the detail of the Design Control Document
• Standard and process for imposing and seeking changes is high
• Rulemaking and the associated process is necessary to change
• Issues covered by the design certification are resolved issues and are not subject to
contentions during the COL hearing process
• COL may depart from the certified design but must follow the change process identified
in App. D
• Tier 1 information
• High level description of systems and drawings focused on safety aspects
• Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC)
• For a COL to change – Exemption to Appendix D and amendment to COL needed
• Tier 2 information
• More detailed description of systems, structures, and components of the entire
facility
• COL licensee may depart from Tier 2 but must evaluate in accordance with the
change process (50.59 process). An LAR may or may not be required
• Tier 2* information
• Subset of Tier 2 information that, if desired to be changed, must be requested in a
License Amendment Request (LAR) in accordance with the change process.
• Construction details (rebar design, etc.)
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Experience post-COL Issuance
First implementation of Part 52 processes (licensing basis maintenance)
• License amendment (LARs), and exemptions, and ASME code relief requests
• LARs are expected as design evolves and due to in-situ conditions
• Design changes to rebar (shear reinforcement details)
• Turbine building bracing
• Additional electrical penetration assemblies in the containment
• Inconsistencies between Tier 1 and Tier 2
• Other
• Preliminary Amendment Request (PAR) Process
• Codified in license as an option for the licensee (following ISG-25)
• Flexibility in making physical changes while licensing basis change is udner
review
• Tied to an LAR
• Obligation to construct in accordance with the licensing basis
• NRO is performing a self assessment of the experience during the first year of
licensing Part 52 plants (with input from licensees, vendors, public, staff)
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NRC SELF ASSESSMENT REVIEW
1 YEAR POST-COL ISSUANCE
Highlights of July 2013 Report ML13196A403
• Clarity of design control document (DCD) Tier 2* information could be enhanced
• Better Communications between regulator and licensee can enhance better
decision making
• More effective interfaces on ITAAC Closure Notices
• NEI 08-01 (endorsed by NRC regulatory guide 1.215)
• Nexus of the construction Reactor Oversight Process (cROP) with the vendor
oversight program
• Monitor the current licensing basis change process to identify where additional
process enhancements may be warranted
• NEI 96-07, Appendix C (not yet endorsed by the NRC)
• Preliminary Amendment Request (PAR) Process provides some flexibility
• Codified in license as an option for the licensee (following ISG-25)
• Flexibility in making physical changes while licensing basis change is
under review
• Tied to an LAR
• Obligation to construct in accordance with the licensing basis
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Summary
•First implementation of Part 52 regulations to issue COLs and for post-licensing
processes
•Vogtle and Summer licenses issued and construction ongoing
•Experience gained in licensing pre and post COL issuance
•A learning experience for regulator and licensee
•Improvements can be made
•Assessments to inform improvements
•Philosophy of Part 52 – Standardization
•Importance of maintaining current licensing basis
•Managing changes appropriately
•Proper change processes
•Safety benefits
•ITAAC completion
•Safe operation
OFFICIAL USE ONLY
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10 CFR Part 52
QUESTIONS?
www.nrc.gov/new-reactors/col-holder/html
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ACRONYMS
•CLB – current licensing basis
•COL – combined license
•DCD – design control document
•EP – emergency plan
•ESP – early site permit
•FFD – fitness for duty
•ITAAC – inspections, tests, analyses, and acceptance criteria
•LAR – license amendment request
•LWA – limited work authorization
•LWR – light water reactors
•SMR – small modular reactor
•SSAR – site safety analysis report
•UFSAR – updated final safety analysis report
OFFICIAL USE ONLY
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