ML21034A615
| ML21034A615 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 02/03/2021 |
| From: | Golub P, Odess-Gillet W Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| C. Cheung 301-415-3813 | |
| References | |
| Download: ML21034A615 (13) | |
Text
©2021 Nuclear Energy Institute Industry ARP Feedback Pareez Golub Warren Odess-Gillett ISG-06 Alternate Review Process 10 February 2021
©2021 Nuclear Energy Institute 2 ARP Feedback Topics Pre-submittal Meetings Vendor Oversight Plan (VOP) and LAR VOP Summary Electronic Reading Rooms NRC Vendor QA Branch Inspections Summary
©2021 Nuclear Energy Institute 3 Presubmittal meetings provided the opportunity to discuss:
Technical topics for which licensee needs feedback to mitigate project risk Use and limitation of precedent licensing actions LAR contents since all LARs are unique Industry is very pleased with the amount of preapplication NRC interaction allowed for DI&C LARs Presubmittal Meetings
©2021 Nuclear Energy Institute 4 Topics included:
Vendor Oversight Plan (VOP)
LAR VOP summary Use of approved digital platform topical reports Plant/Application Specific Action Items What P/ASAIs are covered by the VOP vs. regulatory commitment How platform changes since topical report approval are addressed Presubmittal Meetings
©2021 Nuclear Energy Institute 5 Topics included (cont.)
System Architecture
System interfaces including data communications
Human-System Interface changes
Plant modification impact on current NPP Defense-in-Depth and the LAR approach to addressing CCF Presubmittal Meetings (cont.)
Present architecture information to be contained in LAR for level of detail
©2021 Nuclear Energy Institute 6 Presubmittal meeting devoted to draft LAR Conducted before submittal Allowed for NRC feedback on possible gaps that could prevent acceptance Confirms content and level of detail Presubmittal Meetings (cont.)
©2021 Nuclear Energy Institute 7 Future considerations Ensure all applicable NRC review branches are represented Confirm LAR contents, i.e., identify augmented information based on modification specifics
TS surveillance requirement reductions
Significant MCR changes Presubmittal Meetings (cont.)
©2021 Nuclear Energy Institute 8 Future considerations NRC has commented that LAR review processes (e.g., ARP, Tier 1) are not necessarily distinct - industry would like clarity
Including impact of design lifecycle schedule in relationship to ARP (NRC licensing process)
Presubmittal Meetings (cont.)
©2021 Nuclear Energy Institute 9 ISG-06 provided little guidance on what should be contained in the LAR to describe the VOP Presubmittal meetings should be used to determine level of detail for LAR VOP summary For one project, a LAR supplement was required to provide a revised VOP Summary after NRC review of the VOP Industry needs to understand regulatory basis or guidance for VOP Summary One lesson learned - utilize Licensees 10 CFR 50 Appendix B QA implementing procedures for the VOP and cite them in the LAR VOP summary Vendor Oversight Plan (VOP) and LAR Summary
©2021 Nuclear Energy Institute 10 ERRs facilitate remote auditing of documents for NRC review Some projects require separate ERRs for licensee vs. vendor documentation ERR migration issues occurred for one project causing hiccoughs in the NRC review process. These were quickly resolved by the vendor.
Electronic Reading Rooms
©2021 Nuclear Energy Institute 11 Industry conceptualized the following model when working with the NRC on ISG-06 ARP NRC Vendor QA Branch Inspections NRC Regional Inspection Processes g
Concepts and Pre-application Meetings Implementation, Software V&V, and Factory Testing NRC Review and Audits LARSubmitted (Phase1Information)
Installation and Site Acceptance Testing LARSubmitted AllInformation NRC Review and Audits Detailed HW & SW Design and Fabrication NRC Vendor Inspection Processes Timeline(nottoscale)
High Level System Design, Planning TraditionalProcess AlternateReviewProcess LicenseeActivities
NRC Regional Inspection Processes
LAIssued LAIssued Phase 2 Supplemental Information
©2021 Nuclear Energy Institute 12 Industry envisaged NRC Vendor QA Branch involvement following the LAR SER as depicted in the figure For one project the NRC Vendor QA Branch began its interaction with the licensee just after LAR acceptance to initiate planning for inspections.
NRC Vendor QA Branch inspections will be conducted concurrent with the LAR review This process challenges project resources to complete the project and respond to two NRC branches concurrently.
NRC Vendor QA Branch Inspections
©2021 Nuclear Energy Institute 13 Industry appreciates continued NRC interactions to understand LAR review process Valuable lessons learned These learned lessons can assist future DI&C LAR planning and submittals Industry still values the ARP process to reduce licensing risk for project Fewer NRC submittals SER based on planning, system requirements, and architecture Summary