ML20161A350
| ML20161A350 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/2020 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | |
| Sebrosky J, NRR/DANU/UARP, 301-415-1132 | |
| References | |
| Download: ML20161A350 (56) | |
Text
1 Technology Inclusive Content of Application Project Public Meeting June 11, 2020 Telephone Bridgeline: 888-566-1533 Passcode: 2647310 1 of 56
2 Agenda Time Topic Presenter 10 -10:10 am Introduction NRC 10:10 -10:40 am More detailed discussion of the industry Southern developed licensing modernization project (LMP)- based safety case 10:40 - 11:40 am Industry developed draft annotated outline Southern for an application following the TICAP approach 11:40 - 12:00 pm Intention to pilot the LMP-based safety case Southern and the annotated outline for three designs in the summer of 2020 12 pm - 1:30 pm Extended Break to allow for industry and All NRC caucus 1:30 - 2:30 pm Continuation of Discussions from the All morning session (if applicable) and Questions from Extended Break 2:45 - 3:00 pm Concluding Remarks All 2 of 56
3 Technology Inclusive Content of Application Project (TICAP)
TICAP - NRC Working Meeting June 11, 2020 3 of 56
Outline of Todays Presentations 4
- General overview of TICAP Objectives and Principles
- Discussion of LMP-Based Safety Case
- Discussion of Final Safety Analysis Report (FSAR) Formulation Approach
- Planned TICAP Table-top efforts
- Next Steps
- Takeaways 4 of 56 2
5 Purpose of Presentation
- To present our approach for proposing an optimized formulation of the FSAR portion of the combined license (COL) application. The formulation will use an affirmative safety case basis for presenting the type of information that is asked for in the current COL application content from a light water reactor (LWR) design applicant.
- The conceptual outline presents information limited to the envelope established by the LMP methodology( NEI 18-04). It does not address requirements for normal operation nor all regulations which are applicable to a nuclear facility application, (i.e. financial qualifications of the applicant, material control and accountability, etc.) It also does not address requirements for information that can be found in other parts of the application outside the FSAR (security or emergency preparedness plans).
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6 Background LMP-Driven Application Content
- Project Objective: Develop a document that can be submitted to NRC for endorsement that outlines the content of an application in a manner that is technology inclusive, is risk-informed, and its scope is governed by LMP methodology.
- The need for the proposal:
- Current prescriptive content of application requirements are based on the large LWR safety case which could be substantially different than the non-LWR energy generating systems safety case
- A compliance-based application content for a non-LWR is likely to be costly and unpredictable to develop, time consuming to review, and create inconsistencies between reviews of different applications.
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7 Background LMP-Driven Application Content (Cont.)
- Guiding Principles:
- LMP-Based Safety Case focuses on direct radiological risk to the health and safety of the public
- LMP-Based Safety Case, anchored around designs Principal Design Criteria (PDCs), meets the underlying safety objectives of the current regulations
- Content and level of detail are risk-informed (RI) graded fashion developed within LMP process) to meet NRCs objective of requiring information commensurate with the importance of the safety functions to be performed.
- Content is organized in a logical safety-focused manner that is usable for the licensee and reviewable by the regulator
- Guidance can be applied to any reactor using the NEI 18-04 methodology 7 of 56 5
8 Background LMP-Driven Application Content (Cont.)
- Projects Expected Outcomes:
- A standardized content structure that facilitates efficient
>> preparation by an applicant,
>> review by the regulator, and
>> maintenance by the licensee.
- A content formulation that , based on the complexity of a designs safety case, optimizes
>> the scope (the functions, the structures, systems, and components (SSCs), and the programmatic requirements that need to be discussed) based on what is relevant to the design specific safety case.
>> the type of information to be provided (e.g., licensing basis events (LBEs), Required Safety Functions (RSFs), safety-related (SR) SSCs, defense-in-depth (DiD), etc.),
>> level of detail to be provided
- based on the importance of the functions and SSCs to the safety case (risk-informed, performance-based (RIPB) details).
- based on the relevance to the safety finding determination.
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9 Technology Inclusive Content of Application Project (TICAP)
LMP-Based Safety Case Discussion TICAP - NRC Working Meeting June 11, 2020 9 of 56
Discussion Topics for the LMP-based Safety Case 10
- TICAP Definitions
- Use of LMP-Based Affirmative Safety Case
- What, When, How, and How Well (WWHHW) Labeling of LMP-Based Safety Case
- Summary 10 of 56 8
TICAP Specific Definitions 11
- Generic Safety Case Definition- A collection of scientific, technical, administrative and managerial arguments and evidence in support of the safety objectives of a nuclear facility covering the suitability of the site and the design, construction, and operation of the facility, the assessment of radiation risks and assurance of the adequacy and quality of all the safety related work associated with the nuclear facility.
- Affirmative Safety Case Definition - an affirmative safety case presents the scientific, technical, administrative, and managerial information in support of the safety objectives that the design will provide reasonable assurance of adequate protection of public health and safety. The safety case does not provide arguments and evidence that justifies why certain requirements of the current regulations are not needed.
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TICAP Specific Definitions 12
- LMP-Based Affirmative Safety Case Definition- A collection of scientific, technical, administrative and managerial evidence which document the basis that the performance objectives of the technology inclusive fundamental safety functions (FSFs) are met by a design during design specific AOOs, DBEs, DBAs, and BDBEs by
- Identifying design specific safety functions that are adequately performed by design specific SSCs AND.
- Establishing design specific features (programmatic (e.g., inspections) or physical (e.g., redundancy)) to provide reasonable assurance that credited SSCs are reliably performed.
- Compared with the current content of application, an application content based on the LMP-Based Affirmative Safety Case
- Will include information on new functions, SSCs, and programs when are needed (e.g., functions/SSC/program to prevent coolant catching fire)
- Will not provide evidence where certain functions, SSCs, and programmatic requirements for the LWRs are not applicable 12 of 56 or needed (e.g., Human Factors 10 program)
Foundation of the TICAP Affirmative Safety 13 Case Description
- The underlying intent of the current Application Content (within TICAP scope) is met by providing the LMP-Based Safety Case, anchored around PDCs, on the basis that
>> The LMPs approach to meet the radiological risk performance objectives provide evidence that the underlying safety objectives of the regulations for providing reasonable assurance of adequate protection . . . is met.
>> The principal design criteria establish the necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components important to safety; that is, structures, systems, and components that provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public
- To facilitate PDC-anchored articulation of the LMP-Based Safety Case, the constituents of the LMP process are labeled as follows:
>> What are the performance objectives for the FSFs,
>> When do the FSFs performance objectives need to be demonstrated,
>> How plant capabilities (functional and structural) demonstrate that the fundamental safety functions are met.
>> How Well do these capacities need to be performed 13 of 56 to provide reasonable assurance 11
14 Defining WWHHW - What
- At the highest level, the Atomic Energy Act (AEA) establishes standard as no undue risk
- LMP implements the no undue risk standard, within its scope, by using the RDLT
( regulatory dose limit targets) as the performance objectives for the FSFs.
- In TICAP, the performance objectives of the FSFs, to demonstrate that the no undue risk standard, within its scope, is met, is labeled as WHAT.
- Inputs to What:
- Regulatory dose limits and the quantitative health objective (as shown by the frequency consequence targets and as provided in NEI 18-04))
- Outputs from What:
- Demonstration that reasonable assurance of adequate protection is provided by the selected design 14 of 56 12
15 FSF Chart - What What? Required Safety Required Functional SR SSC Design Functions (RSFs) Design Criteria Criteria (SRDC)
(RFDC)
Frequency-Fundamental Consequence Safety SR SSC SR SSC Special Safety Functions and Cumulative Related Performance Treatment (FSFs)
Risk Targets (SR) SSCs Targets Requirements LBEs from PRA Design Basis Design Basis PRA Safety (AOOs, DBEs, Accidents External Hazard Functions (PSFs) and BDBEs) (DBAs) Levels (DBEHLs)
Input to Design and Functions Other Risk Provided in the Significant Design Non-SR NSRST SSC Safety Functions NSRST SSC with ST Special Performance (NSRST) Treatment Content of Application Targets SSCs Requirements Other Safety Functions for Adequate DID Non-SR Other Safety With No ST Functions SSCs (NST) 15 of 56 13
16 Defining WWHHW - When
- When is the label assigned to the category of information that is obtained from the design-specific LBEs.
- Inputs to When
- Design-specific PRA model, including consequence analysis,
- NEI 18-04 methodology for developing design specific AOOs, DBEs, and BDBEs
- NEI 18-04 methodology for defining design-specific DBAs.
- Outputs defined as When
- Identification of design-specific AOOs, DBEs (including DBAs), and BDBEs that are used to contextualize when different LMP-defined safety functions must be performed.
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17 FSF Chart - When What? Required Safety Required Functional SR SSC Design Functions (RSFs) Design Criteria Criteria (SRDC)
(RFDC)
Frequency-Fundamental Consequence Safety SR SSC SR SSC Special Safety Functions and Cumulative Related Performance Treatment (FSFs)
Risk Targets (SR) SSCs Targets Requirements LBEs from PRA Design Basis Design Basis PRA Safety (AOOs, DBEs, Accidents External Hazard Functions (PSFs) and BDBEs) (DBAs) Levels (DBEHLs)
Input to Design and Functions Other Risk Provided in the Significant Design Non-SR NSRST SSC Safety Functions NSRST SSC When? with ST (NSRST)
Performance Special Treatment Content of Application Targets SSCs Requirements Other Safety Functions for Adequate DID Non-SR Other Safety With No ST Functions SSCs (NST) 17 of 56 15
18 Defining WWHHW - How
- This label is assigned to the capabilities (LMP-defined functions and SSCs) that are credited to show performance-objective of the FSFS are met.
- The necessary capabilities include SSCs that can be used to form a designs principal design criteria through specification of the LMP-Defined Required Safety Functions.
- Inputs to How:
- Design-specific event sequences classified as AOOs, DBEs, DBAs and BDBEs;
- Analytical tools and resources for deterministic design and analyses.
- NEI 18-04 process for classification of functions and SSCs
- Output:
- Classification of design-specific functions and SSCs; In TICAP we plan to introduce the concept of
>> Required Safety Functions = Principal Design Criteria = Safety-Related SSCs = Adequate Protection
>> Complimentary Design Criteria (CDC)* = The design specific SSCs, classified as Non-Safety Related with Special Treatment (NRST) in the LMP process, to provide additional margins for adequate protection finding.
- This new term is suggested to convey the message that information on the SSCs classified as NRST will also be provided.
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19 FSF Chart - When What? Required Safety Required Functional SR SSC Design How?
Functions (RSFs) Design Criteria Criteria (SRDC)
(RFDC)
Frequency-Fundamental Consequence Safety SR SSC SR SSC Special Safety Functions and Cumulative Related Performance Treatment (FSFs)
Risk Targets (SR) SSCs Targets Requirements LBEs from PRA Design Basis Design Basis PRA Safety (AOOs, DBEs, Accidents External Hazard Functions (PSFs) and BDBEs) (DBAs) Levels (DBEHLs)
Input to Design and Functions Other Risk Provided in the Significant Design Non-SR NSRST SSC Safety Functions NSRST SSC When? with ST (NSRST)
Performance Special Treatment Content of Application Targets SSCs Requirements Other Safety Functions for Adequate DID Non-SR Other Safety With No ST Functions SSCs (NST) 19 of 56 17
Defining WWHHW - How Well 20
- This label is applied to the features (programs and configurations) that are credited in a design to provide reasonable assurance that the functions and SSCs labeled as How will perform the design specific credited functions.
- NEI 18-04 provides the methodology and guidance to identify and apply appropriate special treatments to SR and NSRST SSC.
- Inputs to How Well:
- NEI 18-04 methodology for methodology and guidance to identify and apply appropriate special treatments to SR and NSRST SSC;
- Performance Targets for both SR and NRST.
- Outputs defined as How Well:
- Assignment of appropriate special treatments to SR and NSRST SSC such as environmental qualification, inspection and testing, technical specifications for monitoring and maintenance, treatment of uncertainties.;
- Identification and assignment of site-specific (or bounding) Design Basis External Hazard Levels (DBEHL) for use in analysis of SR and NSRST SSC performance.
- Design specific physical features needed to address redundancy and diversity concerns
- Industry Standards (e.g., Quality Assurance, ASME Section III, XI, IEEE, etc.)
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FSF Chart - How Well 21 What? Required Safety Required Functional SR SSC Design How?
Functions (RSFs) Design Criteria Criteria (SRDC)
(RFDC)
Frequency-Fundamental Consequence Safety SR SSC SR SSC Special Safety Functions and Cumulative Related Performance Treatment (FSFs)
Risk Targets (SR) SSCs Targets Requirements LBEs from PRA Design Basis Design Basis PRA Safety (AOOs, DBEs, Accidents External Hazard Functions (PSFs) and BDBEs) (DBAs) Levels (DBEHLs)
Input to Design and Functions Other Risk Provided in the Significant Design Non-SR NSRST SSC Safety Functions NSRST SSC When? with ST (NSRST)
Performance Special Treatment Content of Application Targets SSCs Requirements Other Safety Functions for Adequate DID Non-SR Other Safety With No ST Functions SSCs (NST)
How Well?
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Summary of the LMP-Based Safety Case Presentation 22
- LMP-Based Safety Case- An affirmative safety case where reasonable assurance of adequate protection of the public health and safety, from the radiological risk point of view, is demonstrated by illustrating that the performance objectives of the FSFs are met
- during design specific LBEs by crediting certain design specific LMP-defined functions that are adequately performed by the LMP-classified SSCs where reasonable assurance of such SSCs are established through design specific features (programmatic (e.g., inspections) or physical (e.g., redundancy)).
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23 Technology Inclusive Content of Application Project (TICAP)
Potential FSAR LMP-Based Content of Application TICAP - NRC Working Meeting June 11, 2020 23 of 56
Discussion Topics for Content Formulation 24 Discussion
- Outcomes Reminder
- Caveats and Limitations
- Application Universe (TICAP vs ARCAP)
- Conceptual Formulation 24 of 56 22
25 Outcome Reminder
- Projects Expected Outcomes:
- A standardized content structure that facilitates efficient
>> preparation by an applicant,
>> review by the regulator, and
>> maintenance by the licensee.
- A content formulation that, based on the complexity of a designs safety case, optimizes
>> the scope (the functions, the structures, systems, and components (SSCs), and the programmatic requirements that need to be discussed) based on what is relevant to the design specific safety case.
>> the type of information to be provided (e.g., licensing basis events (LBEs), Required Safety Functions (RSFs), safety-related (SR) SSCs, defense-in-depth (DiD), etc.),
>> level of detail to be provided
- based on the importance of the functions and SSCs to the safety case (risk-informed, performance-based (RIPB) details).
- based on the relevance to the safety finding determination.
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A Standardized Application Content Structure 26
- A potential Application Content structure will be discussed today with the following caveats:
- Starting point for conversation with the stakeholders
- Once mature enough will be used as part of the tabletop exercises and refined.
- Will be finalized based on additional socialization with the industry and the NRC.
- Application content formulation will be subject of the next meeting with the NRC.
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Potential Formulation of FSAR LMP-Based content 27
- Limitations:
- Information within TICAP scope presents information developed within the envelope established by the LMP methodology( NEI 18-04).
- It does not address requirements for normal operation nor all regulations which are applicable to a nuclear facility application ( see figure) 27 of 56 25
Universe of Application Content and TICAP Scope 28 The current licensing basis (CLB) includes the NRC regulations contained in 10 CFR parts 2, 19, 20, 21, 26, 30, 40, 50, 51, 52, 54, 55, 70, 72, 73, 100 and appendices thereto; orders; license conditions; exemptions; and technical specifications. It also includes the plant-specific design-basis information defined in 10 CFR 50.2 as documented in the most recent final safety analysis report (FSAR) as required by 10 CFR 50.71 Security Part 73 Safeguards Public Administrative Radiological (Applicant) Safety Case Environmental Part 50,52 Protection Part 51 Occupational (LMP information) Dose Part 20 Administrative Colors are not (NRC) Fuel and Waste Transportation meant to Disposal communicate any 28 of 56 particular message 26
Conceptual Formulation of FSAR LMP content 29 Chapter 1 - General plant description and Overview of LMP-Based Safety Case Chapter 2 - LBE and DBA Development Chapter 3 - Radiological Consequence Assessments Chapter 4 - Required Safety Functions and Principal Design Criteria Chapter 6 - Special treatment Chapter 5 - Safety-related SSCs requirements for safety related SSCs Chapter 10 - Chapter 9 - Chapter 8 - Special PRA Hazards Treatment Chapter 7 - Non-development development Requirements for non -
safety-related SSCs Safety-related SSCs Chapter 11 Defense in Depth 29 of 56 evaluation (?) 27
Conceptual FSAR Contents of Application- Chapter 1 30 Chapter 1 - General Plant Description and Overview of the Safety Case
-Overview of technology (size of the reactor and intent of the design - power production/industrial application, etc.)
- General description of the plant systems and roles that they play in normal and off normal conditions, including refueling
- Summary of safety case findings using FSF as meeting adequate protection
- Summary of Fundamental Safety Functions
- summary of LBE
- summary of radiological consequence assessment
- summary of how design demonstrates providing FSFs
- evaluation of defense in depth capabilities
- General description of references to Reg Guides used
- General site characteristics 30 of 56 28
Conceptual FSAR Contents of Application- Chapter 2 31 Chapter 2 - Licensing Basis Events
- description of risk-informed methodology used to select licensing basis
- AOO selection results
- DBE selection results
- DBA selection results
- BDBE selection results 31 of 56 29
Conceptual FSAR Contents of Application- Chapter 3 32 Chapter 3 - Analytical assessment of Radiological Consequences for Design Basis Accidents
- description of analytical methods used
- description of analysis assumptions used
- supporting basis for analysis assumptions that are unique applications
- description of acceptance criteria for each evaluated design basis accidents
- description of results versus established regulatory criteria 32 of 56 30
Conceptual FSAR Contents of Application - Chapter 4 33 Chapter 4 - Required Safety Functions and Principal Design Criteria
- 4.1 Required Safety Functions
- 4.2 Principal Design Criteria ( specific to facility capabilities)
- 4.2 SSC Classification 33 of 56 31
Conceptual FSAR Contents of Application - Chapter 5 34 Chapter 5 - Safety Related Structures, Systems, and Components
- 5.1 Safety-Related Structures
- description of structure functional requirements - what is it that this structure is included in design to do for both normal operation and off normal conditions
- description of materials of construction
- schematic of building structures with location of important components and with important boundaries shown
- structural analysis
- 5.2 Safety-Related Systems
- description of system functional requirements - what is it that this system is included in the design to do for both normal operation and off normal conditions
- description of materials of construction
- schematic of building structures with location of important components and with important boundaries shown
-5.3 Safety-Related Components (not discussed as part of systems or structures)
- description of system functional requirements - what is it that this system is included in the design to do for both normal operation and off normal conditions
- description of materials of construction
- schematic of building structures with location of important components and with important boundaries shown 34 of 56 32
Conceptual FSAR Contents of Application- Chapter 6 35 Chapter 6 - Special Treatment Requirements for Safety Related Structures, Systems, and Components 6.1 Safety-Related Structures ---- description of technical programs that programmatically support the reliability and integrity of safety related system functions. What things are needed to provide reasonable assurance the required functions will be performed when called upon.
- description of construction and qualification codes to be used and important design parameters
- description of Inservice Inspection and testing requirements
- discussion of quality standards used for procurement and fabrication 6.2 Safety-Related Systems ---- description of technical programs that programmatically support the reliability and integrity of safety related system functions. What things are needed to provider reasonable assurance the required functions will be performed when called upon.
- same as 6.1 above 6.3 Safety Related Components ( things like reactor vessel, fuel, unique passive components not included in System or structure discussions)
- same as 6.1 above 35 of 56 33
Conceptual FSAR Contents of Application- Chapter 7 36 Chapter 7 - Non-Safety-Related with Special Treatments Structures, Systems, and Components Design Bases
-7.1 Non-safety-Related Structures with Risk Significance (if any)
- description of system functional requirements - what is it that this system included in the design to do for both normal operation and off normal conditions
- description of materials of construction
-7.2 Non-safety-related Structures with defense-in-depth importance, (if any)
(same as 7.1 above)
-7.3 Non-safety-related systems with risk significance
( same as 7.1 above)
-7.4 Non- safety related systems with defense-in-depth importance, if any
( same as 7.1 above) 36 of 56 34
Conceptual FSAR Contents of Application- Chapter 7 37 Chapter 7 - Non-Safety-related Structures, Systems, and Components Design Bases (continued)
- 7.7 non-safety related components with risk significance ( not discussed as part of structure or systems discussion (same as 7.1 above)
- 7.8 non safety related components with defense in depth importance
( same as 7.1 above) 37 of 56 35
Conceptual FSAR Contents of Application- Chapter 8 38 8.0 Special Treatment for non safety related SSCs
-8.1 non safety related Structures with risk significance-- description of technical programs that programmatically support the reliability and integrity of non safety related structure functions.
- description of construction and qualification codes to be used and important design parameters
- schematic of building structures with location of important components with important boundaries shown
- description of Inservice Inspection and testing requirements
- discussion of quality standards used for procurement and fabrication
- specification of structure performance targets
-8.2 Non-safety-Related Systems with risk significance
- (same as 8.1 above for information)
-8.3 Non-safety-related Systems with defense-in-depth importance
- (same as 8.1 above for information) 38 of 56 36
Conceptual FSAR Contents of Application- Chapter 8 39 8.0 Special Treatment for non safety related SSCs (continued)
-8.4 Non-safety-related systems with defense in depth importance
-8.5 non- safety related components with risk significance
-( same as 8.1 above for information)
- 8.6 non safety related components with defense in depth importance
- (same as 8.1 above for information) 39 of 56 37
Conceptual FSAR Contents of Application-Chapter 9 40 Chapter 9 - External and Internal Hazards Assessments 9.1 - External Hazard identification
- 9.1.1 Weather induced events maximum precipitation snow flooding tsunami storm surges nearby industrial, transportation or military facilities
- 9.1.2 Wind induced events tornado winds and missiles hurricane winds and missiles
- 9.1.3 natural phenomena seismic - geotechnical engineering meteorology - (X/Q dispersion) other(?)
40 of 56 38
Conceptual FSAR Contents of Application-Chapter 9 41 Chapter 9 - Internal and External Hazards Assessments (continued) 9.2 - Internal Hazard identification
- 9.2.1 Fires
- 9.2.2 Chemicals
- 9.2.3 Flooding
- 9.2.4 Dynamic effects 41 of 56 39
Conceptual FSAR Contents of Application- Chapter 10 42 Chapter 10 - Probabilistic Risk Assessment 10.1- Scope of PRA 10.2 - description of methodology used to develop the PRA
- standards used 10.3 - Peer Review Finding 42 of 56 40
Conceptual FSAR Contents of Application- Chapter 11 43 Chapter 11 - Defense in Depth Assessment Summary
- Plant capabilities available
- Programmatic evaluation supporting DID
- Integrated Evaluation 43 of 56 41
44 Technology Inclusive Content of Application Project (TICAP)
Tabletop Exercises TICAP - NRC Working Meeting June 11, 2020 44 of 56
Tabletop Exercises 45
- Scope of tabletop exercises-
- Planned start date- August
- Potential interactions with the NRC as observers
- Public release of results
- The following developers have expressed
- GE - Prism Design- Solid fuel in a pool of coolant
- WEC - A micro reactor design - Solid fuel, heat pipe cooled
- Kairos - fluoride salt-cooled solid TRISO pebble-based fuel 45 of 56 43
46 Technology Inclusive Content of Application Project (TICAP)
Next Steps TICAP - NRC Working Meeting June 11, 2020 46 of 56
Next Steps 47 Alignment on the FSFs NEI Guidance definitions Document Mapping of current regulations to FSFs and mapping of GDCs to WWHHW labels Suggested outline for the final NEI document NEI Content of An LMP-based safety case Application Formulation Formulation of Application Guidance Content Document Tabletop Exercises Results Annotated Outlien of the FSAR 47 of 56 45
48 Technology Inclusive Content of Application Project (TICAP)
Takeaways TICAP - NRC Working Meeting June 11, 2020 48 of 56
Takeaways 49
- LMP-Based Safety Case- An affirmative safety case where reasonable assurance of adequate protection of the public health and safety, from the radiological risk point of view, is demonstrated by illustrating that the performance objectives of the FSFs are met
- during design specific LBEs by crediting certain design specific LMP-defined functions that are adequately performed by the LMP-classified SSCs where reasonable assurance of such SSCs are established through design specific features (programmatic (e.g., inspections) or physical (e.g., redundancy)).
49 of 56 47
Takeaways 50
- LMP-Based Safety Case constituents can be organized into the following categories:
>> What are the performance objectives for the FSFs,
>> When do the FSFs performance objectives need to be demonstrated,
>> How plant capabilities (functional and structural) demonstrate that the fundamental safety functions are met.
>> How Well do these capacities need to be performed to provide reasonable assurance 50 of 56 48
Takeaways (Continued) 51
- FSAR Formulation Approach- Proposal will be anchored by a LMP-safety-case-based approach for developing PDCs and Complimentary Design Criteria (CDC) because:
- 10 CFR 52.47(a)(3)(i) require that an application for a combined license include the PDC for a proposed facility (similar requirements exist for other licensing paths).
- 10 CFR Part 50, Appendix A, contains the GDC that establish the minimum requirements for the PDC for water-cooled nuclear power plants.
- For LWRs, GDCs provide minimum requirements for PDC, which establish the necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components (SSCs) that, as stated in Appendix A, SSCs that provide reasonable assurance that the nuclear power plant can be operated without undue risk to the health and safety of the public.
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Takeaways (Continued) 52
- "The GDC serve as the fundamental criteria for the NRC staff when reviewing the SSCs that make up a nuclear power plant design particularly when assessing the performance of their intended safety functions in design basis events postulated to occur during normal operations, anticipated operational occurrences (AOOs), and postulated accidents
- LMP-safety-case-based (LMP-SCB) PDCs and CDCs meet the underlying intent of the GDCs for the LWRs because [Will be demonstrated in the mapping report]
>> At a high level, the current radiological risk to the public related Regulations, can be mapped into the same FSFs that the LMP-Safety-Case are mapped to.
>> The GDC-based PDCs for LWRs, which reflect radiological risk to the public related Regulations, include the How and How Well of meeting the FSFs but for different When.
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Takeaways - (continued) 53
- Projects Expected Outcomes:
- A standardized content structure that facilitates efficient
>> preparation by an applicant,
>> review by the regulator, and
>> maintenance by the licensee.
- A content formulation that, based on the complexity of a designs safety case, optimizes
>> the scope (the functions, the structures, systems, and components (SSCs), and the programmatic requirements that need to be discussed) based on what is relevant to the design specific safety case.
>> the type of information to be provided (e.g., licensing basis events (LBEs), Required Safety Functions (RSFs), safety-related (SR) SSCs, defense-in-depth (DiD), etc.),
- PDCs will only include SSCs that are credited to perform the RSFs
- PDCs and CDCs will be limited to those SSCs that are credited to perform the functions (Only Hows will be included)
>> level of detail to be provided
- based on the importance of the functions and SSCs to the safety case (risk-informed, performance-based (RIPB) details).
- based on the relevance to the safety finding determination.
53 of 56 51
Additional Questions 54
- Additional Questions or comments 54 of 56 52
Acronyms55 AEA - Atomic Energy Act ASME - American Society of Mechanical Engineers AOO - Anticipated Operational Occurrences BDBE - Beyond Design Basis Events CDC - Complimentary Design Criteria DBA - Design Basis Accidents DBE - Design Basis Events DBEHL - Design Basis External Hazard Levels DID - Defense-in- Depth FSF - Fundamental Safety Function GDC - General Design Criteria NEI - Nuclear Energy Institute NSRST - Non-safety Related Special Treatment LBE - Licensing Basis Events LMP - Licensing Modernization Project LMP-SCB - Licensing Modernization Project Safety Case Based PDC - Principal Design Criteria PRA - Probabilistic Risk Assessment RSF - Required Safety Functions SSC - Structures, Systems, and Components 55 of 56 53
56 Break 56 of 56