ML23265A185

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Staff Presentation on Appendix B to DG-1404, Revision 1
ML23265A185
Person / Time
Issue date: 09/26/2023
From: Anders Gilbertson
NRC/NRR/DANU/UARP
To:
References
DG-1404, Rev 1
Download: ML23265A185 (1)
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Text

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 2

Purpose Framework for Achieving PRA Acceptability Appendix B to DG-1404, Revision 1 Submitting Comments on Appendix B to DG-1404, Revision 1 Open Discussion

Purpose

  • Facilitate stakeholder understanding of the guidance in Appendix B to DG-1404, Revision 1
  • Share that 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)
  • Provide guidance on how to submit written comments.

Comments on this document will not be taken in todays meeting. Please submit your comments in accordance with the instruction in the Federal Register notice

  • The comment period for Appendix B to DG-1404, Revision 1, closes on October 10, 2023 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) 3

Framework for Achieving PRA Acceptability 4

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

Appendix B to DG-1404, Revision 1

  • Appendix B to DG-1404, Revision 1, applies the four related principles of PRA acceptability provided in trial RG 1.2472, published in March 2022 (ML21235A008), to a construction permit:
  • PRA level of detail
  • Plant representation and PRA configuration control
  • Appendix B also addresses:
  • PRA documentation
  • Demonstrating PRA acceptability (self-assessment or peer review)

Appendix B to DG-1404, Revision 1 6

The CP application should demonstrate:

Commensurate with the preliminary plant design and proposed site described in the CP application, information developed from the PRA is sound and reliable.

The PRA produces insights with appropriate fidelity to support implementation of the LMP methodology and development of the CP application.

Processes and procedures are defined to adequately maintain and upgrade the PRA to support continued implementation of the LMP methodology as the plant design evolves, the plant is constructed, and leading up to the OL application submittal.

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.

PRA Acceptability for Non-LWR CP Applicants Implementing LMP 7

Section B.3 PRA Scope

  • Risk metrics
  • Radiological sources
  • Plant operating states
  • Hazard groups Section B.4 PRA Elements
  • Fundamental technical analyses (e.g.,

event trees, human reliability analysis, etc.)

Section B.5 PRA Level of Detail

  • Modeling resolution Section B.6 Plant Representation and PRA Configuration Control
  • PRA represents the as-designed, as-to-be built, as-to-be-operated plant design described in the PSAR Section B.2 General:

Demonstrate, in part, that certain regulations are met Demonstrate that Commission policy expectations are met Risk-informed applications (e.g.,

LMP)

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) 8

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 9

Applicability of Supporting Requirements in the ASME/ANS Non-LWR Standard

  • Tables B-2 and B-3 provide the results of the staffs application of the process provided in Section 3 of ASME/ANS RA-S-1.4-2021 for a CP applicant implementing the LMP methodology Meanings of Table Entries:
  • YES means the related SR spans across CC-I and CC-II and is applicable
  • CC-I means the related CC-I SR is applicable
  • 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.

10

Submitting Comments on Appendix B to DG-1404, Revision 1 Comments may be submitted two ways:

1.

Federal Rulemaking Website: Go to https://www.regulations.gov using Docket ID NRC-2022-0073

  • Address questions about Docket IDs in Regulations.gov to Stacy Schumann; telephone: 301-415-0624
  • Email: Stacy.Schumann@nrc.gov 2.

Mail comments to:

Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001, ATTN: Program Management, Announcements, and Editing Staff 11

Open Discussion 12

Reference Information Prior Public Meeting Presentations Please see the Advanced Reactor Content of Application Project webpage on NRC.gov (https://publish.nrc.gov/reactors/new-reactors/advanced/rulemaking-and-guidance/advanced-reactor-content-of-application-project.html) 13

Abbreviations ALWR advanced light-water reactor ASME American Society of Mechanical Engineers ANS American Nuclear Society CC Capability Category CFR Code of Federal Regulations COL combined license CP construction permit DANU Division of Advanced Reactors and Non-Power Production and Utilization Facilities DBHL design-basis hazard level DC design certification DG Draft Guide DRA Division of Risk Assessment EAB exclusion area boundary FR Federal Register HLR high-level requirement ISG Interim Staff Guidance LBE licensing basis event LERF large early release frequency LMP Licensing Modernization Project LPSD low-power and shutdown LWR light-water reactor NEI Nuclear Energy Institute non-LWR non-light-water reactor OL operating license POS plant operating state PRA probabilistic risk assessment PSAR preliminary safety analysis report RG Regulatory Guide RIM Reliability Integrity Management SR supporting requirement SRP Standard Review Plan TICAP Technology-Inclusive Content of Application Project TUPA trial use and pilot application 14

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