ML18340A183

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M181206: Scheduling Note and Slides - Meeting with the Advisory Committee on Reactor Safeguards (Public)
ML18340A183
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Issue date: 12/06/2018
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M181206
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SCHEDULING NOTE

Title:

MEETING WITH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (Public)

Purpose:

Semi-annual meeting with the NRC's independentAdvisory Committee on Reactor Safeguards (ACRS) for the ACRS to provide their views to the Commission on issues recently reviewed by the Committee.

Scheduled: December 6, 2018 10:00 a.m.

Duration: Approx. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Location: Commissioners' Conference Room, 1st fl OWFN

Participants:

Presentation ACRS Members 50 mins.*

Michael Corradini, ACRS Chairman

  • Draft Digital Instrumentation & Controls Interim Staff Guidance, Digital l&C-ISG-06, "Licensing Process," Revision 2 Ronald Ballinger, ACRS Member
  • Report on the Safety Aspects of the APR1400 Commission Q & A 50 mins.

Discussion - Wrap-up 5mins.

  • For presentation only and does not include time for Commission Q & A's 1

~U.S.NRC*

United States Nuclear Re*gulatory Commission Protecting People and the Environment ACRS MEETING WITH THE* U.S. NUCLEAR REGULATORY

. COMMISSION December .6, 2018

l

<:~U.S.NRC United States Nuclear Regulatory Commission

  • Protecting People and the Environment Overview Mike Corradini
  • Accomplishments Since our last meeting with the Commission on April 5, 2018, we .
  • issued 13 Reports
  • Draft Proposed Rule, Emergency
  • Preparedness for Small Modular Reactors and Other New Technologies~

2

Reports.

  • Draft Digital lnstrumen*tation &

Controls Interim Staff Guidance, Digital l&C-ISG-06, Licensing Process, Revision 2

  • Report on the Safety Aspects of the APR1400 I

3

Reports

  • Draft SECY Paper, Functional
  • Containment Performance Criteria for Non-Light Water Reactor Designs
  • Safety Evaluation for WCAP-17936-P, Revision 2, AP1000 In-Containment Cables and Non-Metallic Insulation Debris Integrated Assessment*

4

Re~orts

  • Long-Term Core Cooling for the APR1400
  • Safety Evaluation for Topical Report APR1400-F-A-TR -12004-P, -Revision 1, - - -

Realistic Evaluation Methodology for Large-Break Loss of Coolant

  • Accident of the APR1400-

5

.Reports*

  • Safety Evaluation. of the NuScale
  • Power, LLC Topical Report TR-0616-48793, Revision O, *Nuclear Analysis Codes and Methods Qualification

and Safety Evaluation of the NuScale Power, LLC Topical Report TR-0116-21012, Revision 1, NuS*cale Power Critical Heat Flux Correlations

6

Reports

  • Brunswick Steam Electric Plant Units 1 and 2 Maximum Extended Load Line Limit Analysis Plus License Amendment Request *
  • Interim _Letter: Chapters 7 and 8 of the_ NRC Staff's Safety Evaluation.

Report with Open Items Related to the Certification of the. NuScale Small Modular Reactor 7

Reports

  • Safety Evaluation -of the NuScale Power, LLC Topical Report. TR-0915-*

17564-P, Revision 1, Subchannel Analysis Methodology

  • . Report on the Safety Aspects of the

.. Steam Electric Station, Unit 3 8

Reports*

  • Report on the Safety As_pects of the License Renewal for the River Bend Station, Unit 1

/

9

Ongoing / Future Reviews

  • Design Certification

-NuScale

  • Early Site Permit

- Clinch River

-Seabrook

--Browns Ferry Units 1, 2 & 3 10

  • Ongoing / Future* Reviews
  • Guidance and Bases

- Draft Regulatory Guide DG-1327, -

Reactivity--1 n itiated Accidents

~ NUREG-2224 on High Burnup Fuel Storage and Transportation

- NUREG/BR-0058, Regulatory Analysis Guidelines

  • Licensing Modernization Framework*

11

Ongoing / Future Reviews

  • Digital I &C *

- Integrated Action Plan

  • Rulemaking

- Non-Povver Production or Utilization Facility 12

Ongoing / Future Reviews

  • Thermal-Hydraulic Phenomenology

- GSl-191 oPWR Ovvners Group In-vessel Debris Test Results

- Framato*me oAURORA-B Transient Code Suite:

LOCA o RAMONAS for ATWS 13

Ongoing / Future. Reviews

  • Thermal-Hydraulic Phenomenology *

- Westinghouse .

o D5 Critica*I Power Correlation for SVEA-96 Opti.ma3 Fuel o WCAP-16260P, Revision _2, The Spatially Corrected Inverse Count Rate Methods for Subcritical Reactivity Measurement

14

Ongoing / Future Reviews

  • Reliability and PRA

- Level 3 PRA

- Human Reliability Analysis Method _

Devel.opment o ID H EAS program -

oControl Room Abandonment Risk 15

(

United States Nuclear Regulatory Commission Protecting People and the Environment Draft Proposed* Rule, "Emergency Preparedness For Small Modular Reactors and

History Leading to Rule

_* S_E-CY-10-0034: EP key issue for SMRs

  • SECY-11-0152: Intent to develop

. tech-neutral, dose-based, .

consequence-oriented EP

  • SECY-14-0038: Requested to revise EP toward more performance-based _

oversight regimen

  • SECY-15-0077: Proposed rule-making EP framework for SMRs &

ONTs 17

Related Activities

  • WASH uncontrolled* release+

exclusion area of R = 0.01 ~P

  • Practical power reactors must rely_ more on containment than .

isolation

  • 1960 - Siting criteria considered:
  • ACRS recommended caution .

Related Activities

  • 1973 - WASH-1400: source terms calculated for release categories

_* 1978 - NUREG-0396: planning basis *

. for emergency response plans

  • 2000 - Alternative radiological

Related ACRS Letters

  • 1964 - Engineered Safeguards
  • 1976 - ACRS hearing testimony before JCAE
  • 1984 - Draft Task Action Plan on Containment. Performance
  • 1987 - Source Term Uncertainty 20

Related ACRS Letters

  • 1999 _- Defense-in-Depth_ in Risk-informed Regulation
  • 2007 - Technology-Neutral Framework
  • 2013 - NGNP Key Licensing.Issues

-* 2017 - Non-LWR Vision & 'Strategy 2018 - Principal De~ign Criteria RG-

- * . 2018 - Functional Containment SECY 21

Proposed Rule (1)

& Appendix E, with two changes

- Organizes Emergency Plan requirements

- Alternative EPZ require111ents

- Organized into more logical order

- Performance-based requirements 22

Proposed Rule (2)

  • EPZ requirements

- Main purpose of new rule * \.

- Currently plume exposure pathway EPZ 10 miles & ingestion pathvvay *

  • Proposed rule EPZ requirements

- Plume exposure pathway <10 mSv i.e., <1 Rem

Purpose:

  • provide area where pred.etermine*d protective actions are implemented, which reduce dose and associated early health effects 23

Proposed Rule (3}

  • Proposed rule EPZ requirements

- Applicant would consider plume exposure doses from a spectrum of credible accidents for the facility

~ The rule \NOUld allo\N SMR and ONT applicants to develop reduced EPZ sizes, commensurate with the accident source terms, fission .

product releases, and accident dose

-characteristics specific to their reactor designs 24

Guidance DG-1350

  • Guidance for using the new .

alternative EPZ ',

- Key to defending a smaller EPZ is the source term

- Guidance for determination of release scenarios and source terms for possible accidents criteria is sparse 25

Source Term

  • Developing mechanistic source terms is not an easy task; it
  • involves complex physics and
  • .. chemical phenomena including the evolution and transport of aerosols.

26

ACRS Findings & .

i I

Recommendations

1. No technical obstacles to the*
  • rulemaking

- Recommend that rulemaking moves forvvard --

2. Staff will need to provide guidance to define their _

ex-pectations for the technical adequacy of mechanistic source terms 27

ACRS Comment

  • Arguments presented in the draft rule and guidance apply equally
  • well to all reactors

- No technical basis for restricting use of the nevv rule to SMRs and ONTs vvith a limit on thermal power

- Staff to request stakeholder input on this topic 28

~U.S.NR C

. United States Nuclear Regulatory Commission*

Protecting People and the Environment Draft Digital Instrumentati on &

Controls Interim Staff Guidance, Digital l&C-ISG-06,

Bac kgro und - Pur pos e & Sco pe

  • ISG- 06 defin es the licen sing proc ess for revie w of licen se ame ndm ent

~

requ ests (LAR s) for safe ty-re lated Dl&C mod ifica tions in oper ating plan ts and in new plan ts once they beco me

  • oper ation al
  • Prov ides indu stry guid ance
  • for pre-L AR activ ities and LAR revie w
  • Revi sion 1 issu ed in 2011 30

Revision 1 vs Draft Revision 2

  • lncorporat~d Lessons Learned and Industry Feedback
  • Added focus on fundamental design principles

- Redundancy

-Independence

- Deterministic Processing

- Div~rsity and Defense-in-Depth

- Control of Access 31 -

Revision 1 vs Draft- Revision 2

  • Alternate Review Process added

. *that provides LAR approval before completion of deta*iled design, implementation~ or factory acceptance testing 32

ACRS Observations

  • ISG emphasizes software*
  • development but largely silent on hardwi.fre configuration control and
  • management
  • Did not address applicant ownership
  • of the l&C system changes during*

the .development process . '"

33

  • Staff has ensured that four of the five fundamentalr digital design princi-ples are addressed in the ISG
  • We remain concerned th-at the fifth
  • critical fundamental design principle for architecture design* of- DI &C applications, Control of Access, is not included 34

ACRS Observations .

/

  • Currently, design approaches and administrative controls to restrict internal plant access to systems are 1
  • used
  • Control of Access also means preventing remote electronic access to in-plant systems and networks from sources external to the plant 35

ACRS Observations

  • To* ensure remote access is prevented, plant and system data transmission should be configured .

to be one-way from in-plant to .

external recipients using. only

  • hardware-based processes, which are not configured by software
  • Our letter report urged the s.taff to formally incorporate this: principle into the licensing design evaluation process 36 .

Conclusions & Recommendations

  • Draft* Digital ISG-06, Licensing Process, Revision 2, should be" issued*for public comment
  • Provide the draft final Digital l&C-ISG-06, Revision 2, for our review following resolution of public comments and addr*e*ss the configuration management concern befor_e final publication 37

EDO Response

  • The EDO response was satisfactory regarding the specific recommendations in the July 18, 2018 ACRS Letter
  • However, the revised ISG did not address o~,r concern regarding the fifth. fundamental_ design principle _
  • for Control of Access 38

ACRS Continuing Concern

  • Our November 8, 2018 response letter requested staff to provide the basis for not explicitly addressing the. Control of .

I Access critical fundamental design principle for the architecture design of Dl&C or any other revision that vvould help ensure prevention of remote

. electronic access from sources external to the plant

  • We vvill continue to follow this concern 39

~JU.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment

  • Safety Aspects of the APR1400 Pressurized Water Reactor Ronald Ballinger

ACRS Letter Reports Issued

.

  • APR1400 Design Certification -

July 2018

._ _ - Four 1*nterim Letter Reports

  • Four Topical Reports.
  • Long-Term Core Cooling Report 41

APR1400 Design

  • Based on CE System 80+ with Safety Enhancement Features

- Innovative ECCS-Fluidic Device

- In-Vessel Ret_ention Option . -

  • Instrumentation & Control ,

- Common Q Platform

Conclusion

  • The APR1400 design is mature and*robust
  • There*is reasonable assurance that it can be constructed *and
  • operated without undue risk to the* health and safety of the public .

43

Review:* Lessons Learned

  • .
  • Essential that staff and applicant
  • be supportive and responsive in their interactions with ACRS
    • Scheduling flexibility is essential to successful and timely review 44

Abbreviations ACRS Advisory Committee on Reactor MELLLA+ Maximum Extended Load Line Limit Safeguards Analysis Plus ATWS Anticipated Transient Without Scram mSv milliSieverts CE Combustion Engineering NGNP Next Generation Nuclear Plant CFR Code of Federal Regulations Non-LWR Non-Light Water Reactor ECCS Emergency Core Cooling System NRC Nuclear Regulatory Commission EDO Executive Directors for Operations ONTs Other New Technologies EP Emergency Planning PRA Probabilistic Risk Assessment EPZ Emergency Planning Zone RG Regulatory Guide GSI Generic Safety Issue SMR Small Modular Reactor l&C. Instrumentation and Control TR Topical Report IDHEAS Integrated Human Event Analysis System ISG Interim Staff Guidance JCAE *Joint Committee on Atomic Energy LAR License Amendment Request LOCA Loss-of-Coolant Accident LR License Renewal 45

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