Challenges in Demonstrating Safety Criteria Satisfaction for External Events under a Risk-Informed Performance-Based Framework
The NRC is currently developing 10 CFR Part 53 that would establish a technology-inclusive regulatory framework for use by applicants for new commercial advanced nuclear reactors. The new draft rule language brings new explicit regulatory requirements of the quantitative health objectives (QHOs) as a constraint on plant risk and safety criteria for the plant design, including external hazards. Historically, light water reactors (LWRs) have demonstrated satisfaction of the QHOs through the use of surrogates in the form of CDF/LERF. However, these risk surrogates are not broadly applicable for all advanced reactor types, and for advanced reactors where external events are likely to be the dominant contributor to plant risk, a direct calculation of the QHOs in terms of offsite consequence is likely necessary. While the detailed analysis of low frequency events provides insights that can help justify alternative treatments to past conservatisms, the findings are dependent on the quality and confidence associated with the analyses. The assessment of external hazards presents a unique challenge, as their potential frequency of occurrence, especially of largemagnitude events, is inherently uncertain given the long return periods in question. This paper evaluates the QHOs and their potential role as safety criteria in evaluating external event risk as it applies to advanced reactors to aid in the development of consistent and appropriate analysis methodologies.