ML21034A615

External Presentation PM GOLUB_ISG-06 ARP Process - Industry Feedback 20210203 Final

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

ISG-06 Alternate Review Process Industry ARP Feedback Pareez Golub Warren Odess-Gillett 10 February 2021

©2021 Nuclear Energy Institute

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 2

Presubmittal Meetings 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

©2021 Nuclear Energy Institute 3

Presubmittal Meetings 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

©2021 Nuclear Energy Institute 4

Presubmittal Meetings (cont.)

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 Present architecture information to be contained in LAR for level of detail

©2021 Nuclear Energy Institute 5

Presubmittal Meetings (cont.)

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

©2021 Nuclear Energy Institute 6

Presubmittal Meetings (cont.)

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

©2021 Nuclear Energy Institute 7

Presubmittal Meetings (cont.)

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)

©2021 Nuclear Energy Institute 8

Vendor Oversight Plan (VOP) and LAR Summary 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

©2021 Nuclear Energy Institute 9

Electronic Reading Rooms 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.

©2021 Nuclear Energy Institute 10

NRC Vendor QA Branch Inspections Industry conceptualized the following model when working with the NRC on ISG-06 ARP Timeline (not to scale)

Traditional Process LA Issued LAR Submitted NRC Review and Audits NRC Regional (Phase 1 Information) Inspection Phase 2 Supplemental Processes Information Licensee Activities Concepts High Level System Detailed HW & SW Design Implementation, Software Installation and and Pre-application Design, Planning and Fabrication V&V, and Factory Testing Site Acceptance Testing Meetings g

Alternate Review Process LA Issued NRC Vendor NRC Regional NRC Review and Inspection LAR Submitted Inspection Audits Processes Processes All Information

©2021 Nuclear Energy Institute 11

NRC Vendor QA Branch Inspections 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.

©2021 Nuclear Energy Institute 12

Summary 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

©2021 Nuclear Energy Institute 13