ANSI-NISTNuclear 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• 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• 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 ApplicationsUnder Review – Large LWRs+

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ABWR

AP1000

EPR

ESBWR

USAPWR

+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

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• 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

Pre-ConstructionConstruction Verification

Early Site Permit

Standard Design Certification

Combined License Review, Hearing,

and Decision

Verification of Regulations with ITAAC

ReactorOperationDecision

OptionalPre-Application

Review

LWA

Lessons Learned in COL Reviews

First implementation of NRC’s 10 CFR Part 52 processes to issue COLs

• 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

Tier 1 Tier 2 Tier 2*

COL FSAR

E Plans QA

SecurityOp Programs

FFD

ESP SSAR(Vogtle Only)

E Plans Seismic

Hydrology

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.) 10

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 REVIEW1 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

13OFFICIAL USE ONLY

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

15OFFICIAL USE ONLY