ONR perspectives on design assessment and licensing of SMRs

Transcription

1 ONR perspectives on design assessment and licensing of SMRs Nuclear Institute June 2016 Craig Reiersen Head of New Reactor Licensing Office for Nuclear Regulation Ana Gomez-Cobo New Reactor Safety Case Lead Office for Nuclear Regulation

2 Scope of Presentation Licensing The licensing process SMRs: licensing challenges Design assessment The design assessment process SMRs: design assessment challenges

3 Regulating new nuclear build Phase 1 - Generic Design Assessment Acceptability of Generic Design Acceptability of Generic Site Phase 2 Licensing Artist impression of Wylfa Newydd. Copyright Horizon Nuclear Power. Phase 3 Construction & commissioning Excavation works HPC. Copyright EDF Energy

4 Nuclear Site Licence Cannot conduct prescribed nuclear activities without a nuclear site licence Licensing is: A process by which ONR satisfies itself that: a corporate body Has the capability to conduct specified activities on an identifiedsite subject to conditions attached to the nuclear site licence compliance enforced by ONR Moorside power station artist s impression. Copyright NuGeneration Ltd

5 Licensing a new nuclear facility Licensing process & regulatory expectations published 1 Focus on 5 key areas: Head of New Reactor Licensing Organisational capability Licence condition compliance Site, legal, safeguards Security Design & Safety case Safety analysis Science Engineering 1

6 Potential challenges for Licensing of SMRs Selected Issues Regulatory oversight of off-site modular construction Potential for resource sharing between companies Potential to license separate construction and operating companies Prospect of separate ownership of modules on a single site Potential for multi-module operation by small number of operators from centralised facility

7 Regulatory oversight of off-site modular construction Desired outcome: Clear regulatory authority to inspect plant and equipment, and related records, intended for use on a nuclear licensed site, whether the module supplier is in Great Britain or an overseas location Clarity that enforcement is through the licensee or prospective licensee where activities are conducted prior to site licence grant Consider whether ONR has adequate legal mechanisms for securing regulatory oversight

8 Potential for resource sharing between companies Desired outcome: A pragmatic and flexible ONR approach that enables licensees to share resource whilst ensuring that visible licensee control of safety throughout design, construction and operation is retained. ONR to consider whether current guidance, e.g. on intelligent customer, core capability and design authority, might present difficulties to licensee organisational models involving resource sharing. ONR to establish clear red-line positions on licensee access to the capability it needs to take safety decisions.

9 Potential for multi-module operation by small number of operators Desired outcome: Confirmation that operator staffing levels & concepts are suitable for multimodule operation ONR to ensure that claims on operator actions are substantiated by human factors analysis. This includes consideration of claims for control room staffing and other safety roles to be identified within the licensee organisational baseline.

10 Potential to license separate construction and operating companies Desired outcome: Clarity of licensee control, including resource, capability and demonstrable authority and responsibility for decision-making that affects safety. Standard GB approach is to have a cradle to grave licensee -but no legal impediment to corporate vehicles being established which enable licensing of one company for construction and another for operations. ONR to consider the implications for licensing, and related matters such as transfer of knowledge and capability, of potential new and different business models.

11 Prospect of separate ownership of modules on a single site Desired outcome: Clear responsibility and accountability for nuclear safety to remain with the body that gives rise to hazard and risk. Demonstrable licensee control over safety during construction and operation. ONR favours licensing of a single body on a defined site to ensure that there is absolute clarity regarding the body that has legal responsibility for the safe operation of a licensed site. Consider for licensing, and subsequent regulation, the implications of alternative proposals

12 The Generic Design Assessment (GDA) GDA is an upfront, step-wise assessment of a generic reactor design undertaken by joint Regulators (ONR / Environment Agency / Natural Resources Wales) GDA was developed as a process of regulatory assessment of candidate new reactor designs on a generic basis to be carried out in advance of: site specific proposals specific operating organisations This would permit deployment of the generic design on any site, subject to site specific safety cases and environmental acceptability Allows early regulatory intervention Aim and advantage is identifying and resolving key issues and design changes long before build reducing construction cost and time risks It remains a voluntary process, but a Government expectation

13 GDA (cont.) Generic assessment uses bounding site characteristics (Generic Site Envelope) for aspects such as civil engineering (geology) and external hazards if preferred, the GDA site envelope can reflect the characteristics of a specific proposed site Allows for earlier regulatory assessment as does not require firm choices regarding, for example: number of reactor units and site layout detailed design of all systems / components Does not remove the need for site specific assessments but these will be informed by GDA work reducing programme time

14 Current GDA Process & Typical Timescales 6-9m 6-8m 12m 28m Level of scrutiny Step 1 Preparation Step 2 Overview of Claims Step 3 Review of Arguments Step 4 Detailed Assessment of Evidence (EA / NRW) Public Consultation idac isoda DAC SoDA DAC: ONR s Design Acceptance Confirmation (idac: interim DAC) SODA: EA/NRW s Statement of Design Acceptability (isoda: interim SODA)

15 Potential challenges for design assessment of SMRs Selected Issues Suitability of existing ONR assessment standards Availability of evidence base to support regulatory decisions Time to complete GDA process

16 Suitability of existing ONR assessment standards ONR s Safety Assessment Principles for Nuclear Facilities (SAP): The SAPs are principles to be followed by ONR Inspectors when assessing Safety Cases They provide a framework for consistent regulatory judgements on the acceptability of Safety Cases SAPs are supported by more detailed Technical Assessment Guides (TAG) Issue: SMRs present novel design, construction and operational concepts that may not be currently reflected in ONR SAPs and TAGs Desired outcome: Regulatory expectations that are clear and proportionate and, therefore, ONR is planning to review existing SAPs and other guidance to identify and address gaps or lack of suitability with respect to candidate SMR design concepts

17 But overarching requirement (for SMRs also): demonstration that the risk is ALARP The requirement for risks to be As Low As Reasonably Practicable (ALARP) is fundamental It is a requirement to take all measures to reduce risk which where doing so is reasonable In most cases demonstrating ALARP is not done through explicit comparison of costs and benefits, but rather by applying established relevant good practice and standards Where standards and relevant good practice are less evident the duty holder needs to implement measures to the point where the costs of any additional measures (in terms of money, time or trouble the sacrifice) would be grossly disproportionate to the further risk reduction that would be achieved (the safety benefit) Both the generic and site specific safety cases for any future SMRs to be deployed in the UK will need to provide a demonstration that risks have been reduced to a level which is ALARP

18 Availability of evidence base to support regulatory decisions Issue:design maturity affects the availability of safety case evidence; the SMR design/s coming forward for GDA may not yet be supported by adequate evidence, based on research data, analysis or experimental testing Desired outcome: timely delivery of a clear evidence base which supports design safety claims and enables regulatory decisions on the adequacy of design and safety case and, therefore, ONR will work with industry to understand the maturity of the evidence base underpinning the safety case, and the programme to further develop this base ONR will need to provide clarity on what is required (e.g. level of prototyping, simulation, V&V, trials, etc)

19 Time to complete GDA process Issue: there is a government desire to see deployment of SMR technology in the 2020s This is a challenging timescale, noting that the GDA process typically takes in the order of 5 years to complete Desired outcome: aclear, robust and proportionate design assessment process that does not introduce unnecessary delays to SMR deployment and, therefore, ONR will review lessons learned from application of the GDA process to date and consider whether alternative, more flexible, approaches could be developed

20 Other plans for ONR.

21 Final Remarks Way forward Understand candidate designs and potential business models Ensure fitness for purpose of regulatory framework Review guidance Affirm red-line positions Provide early advice to prospective developers/licensees subject to funding! Approach: ONR intends to be a flexible, pragmatic, enabling regulator