Why We Need to Risk-inform the Regulatory Framework

Commissioner George Apostolakis U.S. Nuclear Regulatory Commission

CmrApostolakis@nrc.gov Halden Program Group Meeting 2 October 2011

The Pre-PRA Era

Management of (unquantified at the time) uncertainty was always a concern. Defense-in-depth and safety margins became embedded in the regulations. Defense-in-Depth is an element of the NRCs safety philosophy that employs successive compensatory measures to prevent accidents or mitigate damage if a malfunction, accident, or naturally caused event occurs at a nuclear facility. [Commissions White Paper,
February 1999]

Design Basis Accidents

A DBA is a postulated accident that a facility is designed and built to withstand without exceeding the offsite exposure guidelines of the NRCs siting regulation. They are very unlikely events. They are evaluated using approved conservative codes and conservative criteria. Human intervention is not included. They protect against unknown unknowns.

A Major DBA: Loss-of-Coolant Accident (LOCA)

An Emergency Core Cooling System (ECCS) must be designed to withstand the following postulated LOCA:
a double-ended break of the largest reactor coolant line, the concurrent loss of offsite power, and a single failure of an active ECCS component in the worst possible place.

Technological Risk Assessment (Reactors)

Study the system as an integrated sociotechnical system. Human intervention is included. Probabilistic Risk Assessment (PRA) supports Risk Management by answering the questions: What can go wrong? (accident sequences or scenarios) How likely are these scenarios? What are their consequences? Which systems and components contribute the most to risk?
5

Proposal for Risk-Informing 10 CFR 50.46 (ECCS for LWR)

In a risk-informed 50.46, the frequency of break size determines the requirements 10-5 frequency Current Requirements New Requirements LBDEGB

TBS

Break Size
Size6

PWR Sump Performance (GSI 191)

Debris blockage of the sumps during loss-ofcoolant accidents could impede long-term core cooling Very complex issue that has many variables and requires plant specific resolution Critical testing regarding in-vessel effects needed for final resolution expected to be completed by the end of 2011 NRC is considering a risk-informed resolution approach

Combining the Frameworks

RiskTraditional Deterministic Informed Approach Approach

Unquantified Probabilities

Risk-Based Approach
Quantified Probabilities

Limited Number of Stylized DBAs Combination of Thousands of Scenarios traditional and Defense in Depth with multiple failures risk-based Can impose unnecessary Realistic approaches regulatory burden Incomplete Incomplete Quality is an issue

A More Holistic Risk-Informed, Performance-Based Regulatory Approach Task Force for Assessment of Options formed in February 2011 Task Force charter is to develop a strategic vision and options for adopting a more comprehensive and holistic risk-informed, performance-based regulatory approach for reactors, materials, waste, fuel cycle, and transportation that would continue to ensure the safe and secure use of nuclear material Final report in Spring 2012 Seeking broad stakeholder input
9

Atomic Energy Act

Ensure adequate protection of public health and safety, promote the common defense and security, and protect the environment

10

Objective

Ensure adequate protection of public health and safety, promote the common defense and security, and protect the environment

Manage the risks from the use of byproduct, source and special nuclear materials through appropriate regulatory controls and oversight

11

Risk Management Goal

Ensure adequate protection of public health and safety, promote the common defense and security, and protect the environment Manage the risks from the use of byproduct, source and special nuclear materials through appropriate regulatory controls and oversight

Defense-in-depth protections are provided to: (1)Establish appropriate barriers and controls to prevent, contain, and mitigate possible releases of radioactive material according to the hazard present and the associated uncertainties; and (2)Ensure that the risks from events that degrade or challenge the established barriers and controls are maintained acceptably low
12

A Proposed Risk Management Regulatory Framework

Ensure adequate protection of public health and safety, promote the common defense and security, and protect the environment Manage the risks from the use of byproduct, source and special nuclear materials through appropriate regulatory controls and oversight
Defense-in-depth protections are provided to: (1) Establish appropriate barriers and controls to prevent, contain, and mitigate possible releases of radioactive material according to the hazard present and the associated uncertainties; and (2) Ensure that the risks from events that degrade or challenge the established barriers and controls are maintained acceptably low

Atomic Energy Act

Objective

Risk Management Goal

Use a disciplined, risk management process to identify and evaluate issues and make decisions regarding appropriate defense-in-depth protections

Decision-Making Process

Problem

Options

Analysis

Performance Monitoring

Implementation

Integrated Decision Making

13