ML23262B435

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Staff Presentation for Public Meeting on Appendix B to DG-1404, Revision 1
ML23262B435
Person / Time
Issue date: 09/21/2023
From: Anders Gilbertson, Stutzke M
NRC/NRR/DANU/UARP
To:
References
DG-1404
Download: ML23262B435 (1)
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Appendix B to DG-1404, Revision 1:

Acceptability of a PRA Supporting a Non-LWR Construction Permit Application Based on the LMP Methodology Anders Gilbertson and Martin Stutzke Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Public Meeting September 26, 2023

Overview Publication of DG-1404, Framework for Achieving Revision 1, for Comment PRA Acceptability Appendix B to DG-1404, Open Discussion Revision 1 2

  • The availability of DG-14041, Revision 1, for comment on the proposed Appendix B was announced in the Federal Register (FR) on September 8, 2023 (88 FR 61989)
  • Comment period on Appendix B to DG-1404, Revision 1, closes on October 10, 2023 Publication of
  • Appendix B to DG-1404, Revision 1, applies the four related principles of PRA acceptability provided in trial RG 1.2473, published in March DG-1404, 2022 (ML21235A008), to a construction permit:
  • PRA scope Revision 1, for
  • PRA level of detail PRA elements Comment
  • Plant representation and PRA configuration control
  • Appendix B also addresses:
  • PRA documentation
  • Demonstrating PRA acceptability (self-assessment or peer review)
  • Applicability of supporting requirements in ASME/ANS RA-S-1.4-2021 1 DG-1404, Rev. 1, Guidance for a Technology-Inclusive Content-of-Application Methodology to Inform the Licensing Basis and Content of Application for Licenses, Certifications, and Approvals for Non-Light Water Reactors (ML23194A194) 2 NEI 21-07, Rev. 1, Technology Inclusive Guidance for Non-Light Water Reactors, Safety Analysis Report Content: For Applicants Using the NEI 18-04 Methodology, February 2022 (ML22060A190) 3 RG 1.247, Acceptability of Probabilistic Risk Assessment Results for Non-Light-Water Reactor Risk-Informed Activities (ML21235A008) 3

Development of guidance in Appendix B to DG-1404, Revision 1, is consistent with the NRCs framework for achieving PRA acceptability Framework for Achieving PRA Acceptability 4

Appendix B to DG-1404, Revision 1 Guidance was developed in Appendix B to inform the type and detail of PRA information to be included with a non-LWR CP application sufficient to provide confidence in the PRA results such that the PRA can be used in regulatory decision-making.

The CP application should demonstrate:

Processes and procedures are defined to Commensurate with the preliminary plant The PRA produces insights with appropriate adequately maintain and upgrade the PRA design and proposed site described in the fidelity to support implementation of the to support continued implementation of the CP application, information developed from LMP methodology and development of the LMP methodology as the plant design the PRA is sound and reliable. CP application. evolves, the plant is constructed, and leading up to the OL application submittal.

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Section B.3 PRA PRA Scope

  • Risk metrics
  • Radiological sources Acceptability *Plant operating states
  • Hazard groups for Non-LWR CP Applicants Section B.2 General:

Implementing Section B.6

  • Demonstrate, in Plant Representation and PRA part, that certain Section B.4 Configuration Control regulations are met PRA Elements LMP
  • Demonstrate that
  • PRA represents the as-designed, as-to- *Fundamental technical analyses (e.g.,

event trees, human reliability analysis, be built, as-to-be-operated plant design Commission policy etc.)

described in the PSAR expectations are met

  • Risk-informed applications (e.g.,

LMP)

Section B.5 PRA Level of Detail

  • Modeling resolution 6

Section B.7: PRA Documentation

  • The proposed guidance in Appendix B to DG-1404, Revision 1, addresses the acceptability of a PRA used to implement LMP for a non-LWR CP application
  • The TICAP guidance in NEI 21-07, Rev. 1, provides an acceptable approach and format for providing PRA submittal information
  • The staff recognizes that PRA results and key assumptions will be provided in the sections of the PSAR to which they apply
  • As referenced in the proposed Appendix B, Staff Position C.4.1 in RG 1.247 provides an acceptable approach for developing and preserving PRA archival information
  • PRA archival information may be controlled by a stand-alone program, or the quality assurance program required by 10 CFR 50.34(a)(7) 7

Section B.8: Demonstrating PRA Acceptability

  • The CP applicant should demonstrate the acceptability of the PRA by conducting a self-assessment or a peer review of the PRA, which will generally:
  • Indicate the extent to which the relevant HLRs and associated SRs are met
  • Reveal the PRAs strengths and limitations
  • Provide a basis for asserting that the PRA is acceptable
  • Consistent with the guidance in Appendix B of DG-1404, Revision 1, the guidance in DANU-ISG-2022-05, Organization and Human-System Considerations, (ML22048B542) provides an acceptable approach for describing:
  • Key management responsibilities for developing the PRA
  • Ability of the CP applicants technical staff to develop the PRA 8
  • Tables B-2 and B-3 provide the results of the staffs Applicability of application of the process provided in Section 3 of ASME/ANS RA-S-1.4-2021 for a CP applicant Supporting implementing the LMP methodology Requirements in the ASME/ANS Meanings of Table Entries:
  • YES means the related SR spans across CC-I and CC-II and is Non-LWR applicable
  • CC-I means the related CC-I SR is applicable Standard
  • CC-II means the related CC-II SR is applicable
  • SRs not listed were determined not to be applicable.
  • An applicant may perform a separate analysis using the process provided in Section 3 of the ASME/ANS non-LWR PRA standard and justify any deviations from or alternatives to Tables B-2 and B-3.

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Open Discussion 10

Reference Prior Public Meeting Presentations

Abbreviations ALWR advanced light-water reactor LBE licensing basis event ASME American Society of Mechanical Engineers LERF large early release frequency ANS American Nuclear Society LMP Licensing Modernization Project CC Capability Category LPSD low-power and shutdown CFR Code of Federal Regulations LWR light-water reactor COL combined license NEI Nuclear Energy Institute CP construction permit non-LWR non-light-water reactor DANU Division of Advanced Reactors and Non-Power Production OL operating license and Utilization Facilities POS plant operating state DBHL design-basis hazard level PRA probabilistic risk assessment DC design certification PSAR preliminary safety analysis report DG Draft Guide RG Regulatory Guide DRA Division of Risk Assessment RIM Reliability Integrity Management EAB exclusion area boundary SR supporting requirement FR Federal Register SRP Standard Review Plan HLR high-level requirement TICAP Technology-Inclusive Content of Application Project ISG Interim Staff Guidance TUPA trial use and pilot application 12

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