Regulatory Treatment of Low Frequency External Events under a Risk-Informed Performance-Based Licensing Pathway: Safety Criteria Evaluation
There has been recent progress in the development of risk-informed performance-based (RIPB) design and licensing approaches, which leverage the insights gained from detailed risk assessments and utilize performance-based metrics to permit flexibility and innovation. The RIPB approaches have included the probabilistic treatment of external hazards, including low frequency events that are beyond the design basis. A preceding study conducted in FY21 noted that there are certain challenges to the probabilistic treatment of low frequency external events, which are primarily the result of uncertainty in the hazard curve and the associated plant response to rare, severe events. The current work expands on the previous study by examining the regulatory safety criteria contained within draft 10 CFR Part 53 and associated draft RIPB seismic design guidance. The evaluation identified potential challenges in demonstrating satisfaction of the safety criteria for low frequency external events, with specific difficulties associated with demonstrating compliance with cumulative safety criteria metrics, such as the quantitative health objectives (QHOs). Non-LWRs are expected to utilize the direct calculation of offsite consequence, rather than use surrogates, for comparison to the QHOs, which can be particularly challenging as the previously identified uncertainties are compounded by uncertainties in the response of the neighboring population. The current work details this evaluation and key findings. The central recommendation from this effort is that it is necessary to develop an approach for demonstrating compliance with the safety criteria in draft Part 53 that addresses the key challenges while providing flexibility to applicants.