atw - International Journal for Nuclear Power | 02.2022

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atw Vol. 67 (2022) | Ausgabe 2 ı März OPERATION AND NEW BUILD 38 Setting-up the Pre-Licensing Phase for Alfred Mirela Nitoi Introduction The licensing process of a nuclear installation is governed by the national legislation and regulations in-place, and although the general principles of the process [14] are quite similar between different countries, the whole process and in particular the licensing approach [10], [11], [12] may be very different. To have a clear image about which rules of the authorization process are not flexible [12] and which parts of the process can be modified to reflect the peculiarities of innovative reactors [15], is necessary to have a good knowledge and understanding about the separation between the mandatory requirements (stipulated in laws or decrees) and other safety recommendations. As the existing regulatory requirements are mainly based on LWR technology experience, it becomes necessary to recommend and implement improvements for regulatory framework to account for the specific characteristics of innovative reactors also. Recent initiatives [12], [18] aimed to address early in time the technology-specific elements in the mandatory part of the regulatory framework, are focused on reviewing the design criteria to cover advanced technologies. For those countries that fully endorse a prescriptive regulatory framework, as Romania, the prescribed and mandatory part [2] is much larger than in other countries where different regulatory approaches are established. The Romanian experience of both the National Safety Authority in Nuclear and the Technical Support Organizations is typically related to CANDU or light-water-reactors, and that is reflected in the in-place regulations, the regulatory framework [2] not considering the innovative reactors licensing issues. Up-to-now the licensing requirements specific for Generation IV reactors are not included in any of the existing regulatory frameworks, despite the on-going initiatives [12], 18] and the fact that is recognized at the international level the necessity to amend the regulatory framework and address the development of the new generation of reactors, within the broader umbrella of improving nuclear safety. In the process of licensing the innovative reactors, part of the new generation reactors fleet, it is highly recommended to capture and integrate in national regulations the international experience [4]. Pre-licensing phase At international level, it was acknowledged that there is a significant challenge to develop a project for a Gen IV reactor or to apply for a license to validate the project [17], pursuing the aim to apply later for the construction or operation of such reactor. In order to somehow overcome the difficulties of this process, a preliminary stage, needed to prepare the actual licensing process, was proposed. Even if the validation process of a project is approached differently in each country, the pre-licensing process is considered by the nuclear industry as an effective means of improving / enhancing predictability of the process [10]. While the basic safety principles [13], [16], [19] governing the design of nuclear reactors are the same, regardless the type of the involved technology, the differences between the operational reactors and advanced reactors count more when the regulatory requirements are prescriptive, in terms of the design and performance of certain safety systems and / or components having the function to prevent and / or to reduce the consequences of accident scenarios that are specific to each type of reactor. The final objective of the pre-licensing phase is to obtain, through an iterative process, a final concept of the installation that complies with all the requirements and expectations of the safety authority. Going through a pre-licensing stage should provide a clear picture of the safety, security, and radiation protection arguments [11] expected to be developed and used by the applicant in the licensing application and during the licensing phase. This period should be also used to establish a Operation and New Build Setting-up the Pre-Licensing Phase for Alfred ı Mirela Nitoi
atw Vol. 67 (2022) | Ausgabe 2 ı März well-defined framework for future exchanges between the applicant and the regulatory body [8]. Licensing Involvement Plan A Licensing Involvement Plan (LIP) can be a valuable mean [8] for establishing an efficient communication between an applicant for license and the National Safety Authority staff. It can be used to document the agreement between the applicant and regulatory body staff regarding the licensing approach, modalities for resolution of issues, schedule expectations, and other topics. The document could be very helpful in reducing the inherent uncertainties of licensing process, by establishing agreements and setting-up the frame for licensing process [6] as early as possible. The technology readiness level of the reactor design will be taken into account in development of the document, including innovative features and related research and development activities, since all of that will constitute the focusing points for near-term activities, having in center the development of pre-application submittals [8]. The applicant may choose to provide background information regarding the project, the design, or its regulatory approach, to the extent it considers as helpful in establish the right context for licensing involvement or review. This information may include [6]: p the extent to which the specific reactor technology has been developed based on prior designs or technologies (description of novelty and innovation level); p discussion of technology or regulatory evolution to the extent it informs the regulatory review of the technology. LIP is really useful for both parties involved in the licensing process: p On one hand, for the applicant, LIP can define schedules for the interactions and submittals, along with the expected outcomes from early interactions (i.e., statements, recommendations, decisions). p On the other hand, for the regulatory staff, LIP will be an informative document, specifying the planning and foreseen interactions with the applicant. The LIP should be elaborated taking into considerations the interactions with the regulatory staff to reach mutual agreement on the desired outcomes of defined interactions and estimated costs and planning. As one of the strategic documents intended to support the licensing process of an innovative reactor, LIP can be developed in several phases [6]. Planning This phase begins when the decision is made to develop the document. In this phase, the need for the elaboration and the scope of the document are outlined, the core team involved in the elaboration is formed and the intention to elaborate the document is announced. Elaboration Once the need for elaboration and the applicability are defined, the actual phase of elaboration of the document may begin. The document development could also have three stages: planning, drafting and approval. This phase is most important, in terms of its two components, planning and approval. Without proper planning, implementation could be jeopardized, which translates in not obtaining the desired outcomes; also, without a formal approval, the document may not receive proper support for implementation. Implementation and monitoring Monitoring process will help to verify if the implementation activities are carried out according to the plan and if the intermediate/ desired objectives are met. This activity should be carried out in accordance with the monitoring procedures established since the drafting phase of the document. Monitoring and implementation must take place in parallel. LIP should address at minimum the project planning, the way to handle the confidential information, interactions with regulatory body, topics important for the process, as well as documents that should be elaborated during this stage. Information LIP information may include proprietary or sensitive information, and this kind of information should be appropriately managed, by strict rules, agreed by both parties. Certain information is not suitable for disclosure to the public, and the applicant may choose to discuss in the LIP the types of withheld information that it expects to produce, and any specific controls or constraints expected to be applicable to that information. An applicant may choose to seek withholding from public disclosure of the LIP itself to the extent it contains commercially sensitive or proprietary information [8]. The technology information could be provided in a separate appendix or a separate document, for better convenience, including as minimum information on the energy output, fuel type, important design constraints, planned development of OPERATION AND NEW BUILD 39 Operation and New Build Setting-up the Pre-Licensing Phase for Alfred ı Mirela Nitoi
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atw - International Journal for Nuclear Power | 02.2022

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