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Current U.S. Part 52, Title 10 Code of Federal Regulations (10CFR52) Process for Early Site Permits, Standard Design Certification and Combined Construction and Operating License International Nuclear Forum, Bulgarian Nuclear Energy – National, Regional, and World Energy Safety Varna, Bulgaria, May 27 – 29, 2009 Introduction and Overview 10CFRPart 50, Two Phases: Construction Permit, Operating License. 10CFR50 Process For New NPP: Large Expenditures Of Money/Time Well Before Key Environmental, Site Safety And Emergency Plan Issues Could Be Resolved (e.g., Shoreham NPP) Numerous Opportunities For Intervention, Public Hearings, And Consequential Delays USNRC Promulgated 10 CFR Part 52 In 1989 To Address Industry Concerns 10CFRPart 52 Established “One Step” Licensing Process “One Step” Licensing Process Affirmed By Congress - 1992 Energy Policy Act. Single Combined Construction and Operating License (COL) Designed To Improve Licensing Process Efficiency, Predictability Energy Policy Act of 2005 Provided “Kick-start” for Nuclear Introduction and Overview COL Granted Prior To Beginning Of Construction. Reduces Financial Risk – “Exit Ramps”, Incremental Decision Making Key Element Is Inspections, Tests, Analyses And Acceptance Criteria (ITAAC) May First Obtain An Early Site Permit (ESP) From the NRC. NRC Estimates 42 Months COLA Approval Process Part 52 Licensing Approach Allows Early Resolution Of Reactor Safety, And Environmental Issues. “FINALITY” - Regulatory Reviews Regarding Suitability Of Site or Design Of The Plant (Design Certification), Once Completed, Are Not Revisited Prior To Issuance Of The COL. COL Contains Same Information As 10CFR Part 50 Operating License Application. COL May be issued for multiple units Overview of Previous 10CFR50 “Two Step” Licensing Process Construction Permit Application* 10-30% of Design Complete Sequential process – overlapping regulatory reviews; Design effort proceeded throughout process; Regulatory standards evolved ad construction proceeded. Process was inefficient, unpredictable and invited intervention/abuse. Operating License Proceeding* Completed plant idle during proceeding Operating License Issued* Construction (design as you build) Operation * Opportunity for intervention, hearings and delay OL Issuance Jan-99 Jan-97 Jan-95 Jan-93 Jan-91 Jan-89 Avg = 5.6 yrs Jan-87 Jan-85 Jan-83 Jan-81 Jan-79 Jan-77 Jan-75 Jan-73 Jan-71 Jan-69 Duration of Construction Completion Times for the Current Fleet Avg = 11.1 yrs 25.0 20.0 15.0 10.0 5.0 0.0 Overview of the “One Step” 10CFR52 Licensing Process Early Site Permit (ESP)* Combined Construction And Operating License (COL)* Design >90% Complete Design Certification* In this process, all regulatory reviews (site, reactor design, construction/operating license) are completed before major capital investment at risk. Potential for delay is significantly reduced Construction ITAAC Met** Operation * Opportunity for public comment, intervention ** Opportunity for hearing; But, threshold very high 10 CFR Part 52 Part 52 — Licenses, Certifications, and Approvals for Nuclear Power Plants Subpart A — Early Site Permits (ESP) Subpart B — Standard Design Certifications (DC) Subpart C — Combined Licenses (COL) Other Subparts Cover Standard Design Approvals, Manufacturing Licenses, Enforcement 10 CFR Part 52, Subpart A Early Site Permit (ESP) ESP Addresses Site Safety Issues, Environmental Protection Issues and Emergency Plans ESP Separate from Construction/Operating License Application ESP can be “Banked” — 20 Years, 10 to 20 Years Renewal ESP Independent of Nuclear Power Plant Design Plant Parameter Envelope (PPE) Used for ESPs Surrogate Plant Approach Circa 200 Plant And Site Parameters Information To Support Safety & Environmental Reviews Select Best Reactor Technologies Available Encompasses Any Design Bounded By PPE Specific Reactor Technology Need Not Be Selected At Site Approval Phase ESP Application Includes: Administrative, Site Safety Analysis Report (RG 1.70, Ch. 2&3), Environmental Report (NUREG 1555), Emergency Plan, Redress Plan Three (3) Early Site Permits Approved: Clinton, North Anna, Grand Gulf Typical PPE Categories PPE Section Structures Normal Plant Heat Sink Ultimate Heat Sink Containment Heat Removal System Potable Water/Sanitary Waste Systems Demineralized Water System Fire Protection System Miscellaneous Drains/Discharges Unit Vent/Airborne Release Points Radwaste Systems – Liquid, Gaseous, Solid Spent Fuel Storage HVAC Systems Onsite/Offsite Electrical Power System Standby Power System Plant Characteristics Construction 1. Structure 1.1 Building Characteristics 1.1.1 Height 123 ft- 8 in (Does not include stack) 1.1.2 Foundation Embedment 66 ft-4 in to top of basement 1.2 Precipitation (for Roof Design) 1.2.1 Maximum Rainfall Rate 19.4 in/hr (6.2 in/5 min) 1.2.2 Snow Load 50 lb/sq ft 1.3 Safe Shutdown Earthquake (SSE) 1.3.1 Design Response Spectra Per RG 1.60 1.3.2 0.30 g at plant grade Peak Ground Acceleration 1.3.3 Time History Envelope SSE Response Spectra 1.3.4 Capable Tectonic Structures or Sources 1.4 Site Water Level (Allowable) 1.4.1 Maximum Flood (or Tsunami) 1 ft below grade 1.4.2 Maximum Ground Water 2 ft below plant grade Example - Reactor Technologies Included in Exelon ESP PPE Pebble bed modular reactor (PBMR) – 8 modules, 3200MWt Advanced boiling-water reactor (ABWR) – 1 unit, 3926 MWt Advanced pressurized-water reactor (AP1000) – 2 units, 6800 MWt Economic Simplified Boiling Water reactor (ESBWR) – 1 unit, 4000 MWt Gas turbine-modular helium reactor (GT-MHR) – 4 modules, 2400 MWt Advanced Canada Deuterium Uranium (CANDU) Reactor (ACR-700) – 2 units, 3966 MWt International Reactor Innovative and Secure (IRIS) – 3 units, 3000 MWt 10 CFR Part 52, Subpart B Standard Design Certifications NRC can certify a reactor design for 15 years through the Rulemaking Process, independent of a specific site Application for a DC must include information describing the design and proposed ITAAC Specific Reactor Design Control Document (DCD) follows RG 1.70 (FSAR) Tier 1 – Approved and Certified by Rulemaking Tier 2 – Approved Tier 1 based on Tier 2 Details. Changes to Tier 1 may lead to regulatory review, public comment, intervention and are avoided Multinational Design Approval Program (MDAP) leverages information reviewed by licensing authority of another country. ITAAC provides objective evidence and reasonable assurance that if ITAAC are performed and acceptance criteria met, a plant which references the design, is built and will operate in accordance with the Design Certification. Four Design Certified: Westinghouse AP600 and AP1000; GE ABWR; CE System 80+ New Licensing Process – 10 CFR Part 52 - Early Site Permit OR Equivalent Site Information Optional Pre-Application Review Pre-Construction Construction Verification Combined License Review, Hearing, and Decision Verification of Regulations with ITAAC Standard Design Certification OR Equivalent Design Information • Licensing decisions finalized before major construction begins • Inspections to verify construction • Limited work may be authorized before license is issued Reactor Operation Decision 10 CFR Part 52, Subpart C Combined Licenses COL applicant may reference ESP and/or a DCD, or neither one. COLA may be submitted for multiple units If ESP or DC is not referenced, applicant required to provide equivalent level of information in COLA If applicant does not reference an ESP, applicant must provide detailed siting information that would have been provided during ESP process. If DCD not referenced, COL applicant must provide complete design information and associated ITAAC for complete design (Very Risky) Application for COL must contain essentially same information required in an application for an operating license submitted under 10 CFR Part 50. Part 52 Final Rule Issued In September, 2007, clarifying/revising regulations applicable to licensing of nuclear plants (Parts 52, 50, 1, 2, 10, 19, 20, et al) Issues resolved in a prior proceeding generally not subject to further review at COL – HIGH THRESHOLD After COL granted, licensee must complete ITAAC established in the license 10 CFR Part 52, Sub Part C Combined Licenses (COL) - Continued NRC strong preference for Standard COLA and Certified Design (if not standard, you will always be at the end of the queue) Other applications to model COLAs after first COLA submitted (Change Site Conditions Only) COLA application includes: Administrative, FSAR, ER, EP, Tech Specs, DCD Exemptions/DCD Departures, Security Plan (withheld from public) May be submitted in 2 Parts (ER, FSAR), Not Preferred by NRC FSAR based on Certified Reactor Design Control Document (DCD) Reference to DCD with site specific deviations/exceptions Regulatory Guide 1.206 provides NRC guidance for COLAs Projected Locations of New Nuclear Power Reactors New Reactor Licensing Applications (Site and Technology Selected) An estimated schedule by Fiscal Year 2005 2006 2007 AP1000 Program Review Design Cert 2008 2009 2010 2011 2012 DC Amendment Hearing Hearing South Carolina E&G-Summer (2) Duke – Lee Station (SC) (2) Hearing Progress Energy - Harris (NC) (2) Hearing Hearing Southern – Vogtle (GA) (2) Hearing Progress Energy–Levy County (FL) (2) Hearing Florida P&L – Turkey Point (2) Hearing Legend: ESBWR Program Review North Anna ESP Grand Gulf ESP Design Certification Design Certification Hearing Hearing Early Site Permit Dominion - North Anna (VA) (1) Hearing Entergy – Grand Gulf (MS) (1) Hearing Entergy – River Bend (LA) (1) Hearing Exelon – Victoria Co. (TX) (2) EPR Program Review 2014 * Schedules depicted for future activities represent nominal assumed review durations based on submittal time frames in letters of intent from prospective applicants. Actual schedules will be determined when applications are docketed. TVA – Bellefonte (AL) (2) Vogtle ESP 2013 Hearing Design Certification UniStar-Calvert Cliffs (MD) (1) AmerenUE – Callaway (1) Hearing Hearing PPL Generation – Berwick (1) Combined License Hearing Post SER/EIS Hearing (other hearing activities occur during ESP/COL safety and environmental reviews) Number in ( ) next to COL name indicate number of units/site. Hearing Hearing Alternate Energy Holdings (ID) (1) Hearing UniStar-Nine Mile Pt (NY) (1) Hearing Amarillo Power (TX) (2) ABWR Program Review NRG Energy–South Texas Project (2) USAPWR Program Review Hearing DC – Mitsubishi USAPWR TXU Power –Comanche Peak (TX) (2) Hearing 1/02/08 Nuclear Plant Licensing: “Then and Now” Then Now (Anticipated Benefits) Dynamic Regulatory Environment: Changing Regulatory Standards and Requirements More stable/predictable process: NRC approves site and design, single license to build and operate, before construction begins and significant capital is placed “at risk” Multiple opportunities to intervene, resulting in delays Opportunities to intervene limited to welldefined points in process, and must be based on objective evidence that ITAAC have not or will not be met No Design Standardization Standard NRC-Certified Designs Inefficient Construction Practices – Piece by Piece Lessons learned from international projects incorporated, and modular construction practices Design as you build Plant designed before construction begins Separate application for each unit Single application for multiple units ESP/COLA Process Observations ESP Type Process (Equivalent Siting Information) with PPE Allows: Early Identification of Site Issues Prior to Major $$ Expenditures Site Selection Prior to Selection of Reactor Technology Later Final Construction Decision Leveraging Design Certifications/Compliance to EUR Standardization Standardization - Lump Sum vs. T&M, Parts, Training, Services, Fuel Previously Approved/Certified Standard FSAR with Deviations or Exceptions Helps Expedite Licensing Reviews Use of Existing Site Offers Many Advantages Site Characterization >2 Years Meteorological Data for Chi/Q, set EAB Geology, Geotechnical, Seismic Hydrology, Geography, Demography, Offsite Hazards, etc. ESP/COLA Process Observations Perform Gap Analysis – FSAR info vs. Current Existing Grid Connections/Stability Conditions Site Infrastructure Baseline Information: EIA, EP, FSAR Existing Site Potential Issues Available Space UHS Considerations – Capacity, Dilution, Thermal Makeup Water Grid Capacity/Stability Transportation of Major Components Security