ML23053A291

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Presentation - February 23, 2023 Licensing Review Framework for Advanced Reactors I&C Workshop 1
ML23053A291
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Issue date: 02/22/2023
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Office of Nuclear Reactor Regulation
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Licensing Review Framework for Advanced Reactors Instrumentation and Controls (I&C)

Workshop February 23, 2023 1 of 25

Introduction and Requests for Workshops on I&C Design Review Guide (DRG) Implementation

  • Final I&C Design Review Guide (DRG) issued in February 2021 (ML21011A140) for I&C design reviews by NRC staff
  • NRC staff reviews / pre-application engagements underway for a variety of potential LWR and non-LWR I&C designs
  • NRC staff engaged by industry interested in the background and details on the DRGand relationship to NEI documents 2 of 25

Workshop Agenda

  • Overview of recent and ongoing initiatives:

- Licensing Modernization Project (LMP) and RG 1.233

- Technology-Inclusive Content of Application Project (TICAP)

- Advanced Reactor Content of Application Project (ARCAP)

  • Overview of I&C DRG

- Focus on safety-significant SSCs; Use of reliability / capability targets

- Developed for non-LWRs, but can be used for all reactor designs

  • Specific industry perspectives and potential challenges 3 of 25

LMP Methodology Approach

  • Foundations laid in MHTGR, PBMR, and NGNP projects and incorporates NRC and ACRS reviews on key topics

- Technology-inclusive risk metrics

- Use of frequency-consequence targets

- Functional containment concept

- Treatment of multi-module plants

- Reliability targets in lieu of single failure criterion

- Technology-inclusive approach to defense-in-depth

  • Incorporates developments in risk-informed, performance-based decision making for wide spectrum of non-LWR designs 4 of 25

LMP is Risk-Informed and Performance-Based

  • Risk-informed

- Incorporating key inputs from a PRA

- Incorporating deterministic principles such as evaluation of defense-in-depth adequacy

  • Performance-based

- Use of a Frequency Consequence (F-C) Target and Cumulative Risk Targets to evaluate the risk significance of licensing basis events (LBEs) and structures, systems, and components (SSCs)

- Selection of performance targets for the reliability and capability of SSCs in the prevention and mitigation of LBEs

- Use of programs to monitor the performance of the plant and SSCs against the performance targets

  • Use of an Integrated Decision-Making Process to implement RIPB decisions that impact the safety case and its objective evaluation 5 of 25

Licensing Modernization Project (LMP)

(NEI 18-04 and RG 1.233)

  • Licensing Basis Events
  • SSC Classification
  • Defense-in-Depth 6 of 25

LMP SSC Classifications 7 of 25

Derivation of Special Treatments

- Functional Design Criteria derived from required safety functions

- Lower level design criteria derived from safety-related design criteria (SRDC)

- SSC reliability and capability performance targets

- Focus on prevention and mitigation functions from LBEs

- Integrated decision-making process (IDP) to derive specific special treatments

- Reflects Commissions expectations for RIPB regulation (SRM-SECY-98-0144) 8 of 25

Core Review Team Approach

  • Non-LWR Review Strategy - successfully implementing for non-LWR preapplication and application reviews
  • Multi-disciplinary core review team supported by subject matter experts from various offices
  • Focus on the Fundamental Safety Functions
  • Perform an integrated design review
  • Demonstrate compliance with applicable regulations 9 of 25

Content of Applications - Overview 10 of 25

Content of Applications Projects

  • Technology-Inclusive Content of Applications Project (TICAP) (NEI 21-07) o LMP process is used to define guidance for the content of major portions of the Safety Analysis Report (SAR)

Risk-informed, performance-based approach to select LBEs, develop SSC classification, identify special treatments for SSCs, and ensure DID adequacy o Industry developed TICAP guidance for key portions of the SAR for NRC endorsement o Industry TICAP guidance will be supplemented by NRC staff-developed guidance, as necessary

  • Advanced Reactor Content of Applications Project (ARCAP) (DG-1404 + 9 ISGs) o Covers guidance for non-LWR applications under 10 CFR Part 50 and Part 52 o Encompasses TICAP guidance, provides supplemental and additional guidance for SAR content, and covers application content guidance for areas that go beyond SAR 11 of 25

ARCAP and TICAP - Nexus Outline Safety Analysis Report (SAR) - Additional Portions of Application Based on TICAP Guidance

  • Technical Specifications
1. General Plant Information, Site Description,
  • Technical Requirements Manual and Overview of the Safety Case
  • Quality Assurance Plan (design)
2. Methodologies and Analyses and Site

Information*

  • Quality Assurance Plan (construction and
3. Licensing Basis Event (LBE) Analysis
4. Integrated Evaluations operations)
5. Safety Functions, Design Criteria, and SSC
  • Emergency Plan Safety Classification Audit/inspection of Applicant Records
  • Physical Security Plan
6. Safety Related SSC Criteria and Capabilities
  • Calculations
7. Non-safety related with special treatment
  • Analyses
  • SNM material control and accounting SSC Criteria and Capabilities
8. Plant Programs
  • System Descriptions
  • Design Drawings

Additional SAR Content -Outside the

  • Design Specifications
  • Radiation Protection Program Scope of TICAP
  • Procurement Specifications
9. Control of Routine Plant Radioactive
  • Inservice inspection/Inservice testing Waste (ISI/IST) Program
10. Control of Occupational Doses
  • Environmental Report
11. Organization and Human-System
  • Site Redress Plan Considerations
  • Exemptions, Departures, and Variances
12. Post-construction Inspection, Testing and
  • Facility Safety Program (under Analysis Programs consideration for Part 53 applications)
  • Financial Qualification and Insurance
  • SAR Chapter 2 derived from TICAP guidance as supplemented by ARCAP ISG
  • Aircraft Impact Assessment Chapter 2, Site Information
  • SAR structure based on clean sheet approach
  • Additional contents of application outside of SAR are still under discussion. The12 of 25 above list is draft and for illustration purposes only.

ARCAP - High Level Overview

  • ARCAP Roadmap ISG
  • Proposes a 12-chapter SAR guidance structure
  • Guidance for first 8 SAR chapters references the TICAP guidance
  • Chapters 9, 10, 11, and 12 point to individual ISGs developed for each SAR chapter
  • Includes pointers to draft white papers, guidance under development or to be developed for portions of the application outside the SAR
  • Examples of guidance that the staff has developed: TS, Risk Informed ISI/IST, and Fire Protection for Operations
  • Examples of high-level guidance embedded in the Roadmap ISG: Technical Requirements Manual, Quality Assurance Plan, Fire Protection (design), and Offsite Dose Calculation Model
  • Examples of guidance being considered: security, emergency planning, material control and accountability, financial qualification and cyber security 13 of 25

ARCAP - High Level Overview

  • ARCAP Roadmap ISG (continued)
  • Includes several appendices:
  • Appendix A on preapplication engagement guidance o Based on white paper discussed extensively during advanced reactor public stakeholder meetings o To capture the white paper guidance in a durable product that will have the benefit of a formal public comment period
  • Appendix B on Analysis of Applicability of NRC Regulations to non-LWRs o Based on white paper discussed extensively during advanced reactor public stakeholder meetings (ADAMS Accession No. ML21175A287) o Purpose of Appendix B is to capture the white paper guidance in a durable product that will have the benefit of a formal public comment period 14 of 25

ARCAP - High Level Overview

  • ARCAP Roadmap ISG (continued)
  • Includes several appendices (continued):
  • Appendix C on CP guidance o Common portions applicable to both LWRs and non-LWRs quoted from DNRL-ISG-2022-01 o Detailed CP guidance specific to non-LWRs
  • Appendix D on ARCAP guidance documents currently under development
  • April 2023 - DG-1404 (endorsing NEI 21-07) and 9 ARCAP ISGs expected to be published for public comment 15 of 25

Evolution of I&C Review Guidance

  • NUREG-0800, Standard Review Plan (SRP) Chapter 7 System-based approach for light-water reactor (LWR) licensing reviews Guidance not suitable for non-LWRs applications
  • NuScale Design-Specific Review Standard (DSRS)

Chapter 7 Improved safety-focused licensing review approach Improved licensing reviews efficiency and effectiveness

  • DRG for I&C Leverages the DSRS concepts Leverages lessons learned from recent new reactor I&C ADAMS Accession No. ML21011A140 licensing reviews 16 of 25

Goals of I&C DRG

  • Modernizes the I&C safety review in support of advanced non-LWR licensing applications Safety-focused Risk-informed Performance-based Technology-Inclusive
  • Supports the NRCs vision and strategy for advanced reactor safety reviews
  • Incorporates principles from RG-1.233 17 of 25

I&C System Review Framework 18 of 25

Overall Review Approach 19 of 25

Industry-specific Areas of Interest

  • DRG-related topics:

- Dependencies between NUREG-0800 (or NUREG-1537) and DRG

- Use of DRG for LWR designs

  • LMP-related topics:

- I&C design criteria for Anticipated Operational Occurrences (AOOs)

  • Can an applicant credit the expected response of all SSCs for AOOs?

- Quantitatively determining software reliability for use within LMP

- Non-safety functions to mitigate effects of CCF 20 of 25

Industry-specific Areas of Interest (continued)

  • NSRST-related topics:

- NSRST criteria limited to the DRG sections where specified, or consider the entire DRG?

- DRG Appendix A design criteria to support reliability and robustness

- Quality Assurance (QA) requirements/acceptance criteria for NSRST SSCs

- Are special treatments differentiated between NSRST SSCs relied on to perform risk-significant functions and those requirement special treatment for defense-in-depth adequacy?

21 of 25

NRC-specific Areas of Interest

  • Digital Technologies and use of NRC-approved I&C platforms
  • Self-Diagnostics to accomplish surveillance functions
  • Remote, Monitoring, and Control Rooms
  • Design Standards (i.e., U.S. vs. International standards)
  • Transition from LMP to specific I&C Design Requirements 22 of 25

Workshop #2 Proposed Topics

  • Codes and Standards

- How performance-based concepts can be applied to prescriptive requirements of endorsed codes and standards

- Applicability of IEEE 603 and related standards

- Use of international codes and standards

  • NRC staff review expectations

- I&C-specific Principal Design Criteria

- Fundamental I&C design principles

- I&C architecture and safety classification of I&C platforms 23 of 25

Workshop #3 Proposed Topics

  • Content of Applications (Near-term licensing actions)

- Clarity on applicability of Part 50/52 requirements

- Expectations for construction permit (CP) applications

- Expectations for operating license applications

- Non-power vs. power reactor applications

  • Difference in applicable regulatory requirements

Questions?

For more information, contact:

Jordan.Hoellman2@nrc.gov 25 of 25

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