Transcript Slide 1

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
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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
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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
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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)
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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
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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
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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
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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
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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
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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
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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
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 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