ML24150A116

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NRC_Presentation_on_Performance-Based_Design
ML24150A116
Person / Time
Issue date: 05/29/2024
From: Norbert Carte
NRC/NRR/DEX/EICB
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Download: ML24150A116 (1)
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Text

What is Performance-Based Design?

(as applied to I&C)

Norbert Carte Sr. I&C Technical Reviewer of I&C NRC/NRR/DEX/EICB May 29, 2024 (2pm-4pm) 1

Goals for Meeting

  • Present my understanding of performance-based design
  • Solicit ideas on how to do performance-based design of I&C.

(e.g., as an alternative to software development processes and diversity)

  • Existing facilities
  • New facilities following traditional approaches 2

Fundamental Concepts

  • Words & Terms can have many meanings
  • Within the NRC, Performance-based has been used with different meanings, e.g.
  • 10 CFR 50.48(c) - National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for LWR Electric Generating Plants (NFPA 805)
  • RG 1.233 and NEI 18 use term risk-informed performance-based (RIPB)
  • Layered Design - Layers of abstraction concretion flow-down
  • Top layer is goal(s) or objective(s)
  • Bottom layer is a detailed prescriptive engineering specification
  • Middle layers tie the two together in a way that makes sense
  • Licensing as a view of the design
  • Subset of Design Information & Focusing on a Particular Concern (e.g., safety) 3

What is Performance-Based Design?

  • A performance-based approach to engineering design consists of:
1) Establishing goals and identifying the design objectives to achieve the goals
2) Describing what must be done to achieve the design objectives and explaining why it achieves the design objectives
3) Describing how it is done and explaining why it works
4) Providing evidence that the I&C conforms with 3).
  • Generally:

(A) What are the hazards? and How are they addressed?

(B) What are the properties and functions needed to ensure safety?

(C)How do we know (A) & (B) are complete and correct?

4

What is adequate evidence?

  • DEPENDS on the claim(s) being made!
  • Some claims can be confirmed by inspection.
  • During the construction process (e.g., weld rods)
  • After the fact (e.g., cable separation)
  • Some claims cannot be confirmed by inspection but rather require an engineering evaluation.

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Two Understandings of Performance

1) Performance monitoring
  • Appropriate for NRC oversight of licensees
2) Performance-Based design
  • Appropriate for licensing of designs (a design is evaluated, not monitored)
  • This is how it can be done in other design disciplines
  • 2024 ICC Performance Code for Buildings and Facilities (ICCPC)
  • ASCE/SEI 43-19, Seismic Design Criteria for Structures, Systems, and Components in Nuclear Facilities 6

10 CFR 50.34 supports performance-based design of I&C The technical part of a safety analysis report (as described in 10 CFR 50.34) includes the descriptions and analyses to demonstrate safety, supported with the following kinds of information:

1)

A description of the location of the facility.

2)

A description of the facility as well as how it is operated and maintained.

3)

The principal safety consideration associated with the above information.

4)

The principal design criteria of the facility to ensure safety (e.g., anticipated transients will not cause fuel damage).

5)

The design bases (i.e., functions and values of structures systems and components) to achieve the principal design criteria of the facility (e.g., trip at 110

% power).

6)

Assurance that the system and equipment will perform as needed (e.g., sufficient technical or design information about the system and equipment to provide reasonable assurance that the systems and equipment will perform the design bases functions in accordance with the design bases values and not produce unexpected problems).

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10 CFR 50.34(a)(3)(iii) can be met using a performance-based design of I&C approach.

(a) Preliminary safety analysis report. Each application for a construction permit shall include a preliminary safety analysis report. The minimum information to be included shall consist of the following:

A description and safety assessment of the site and a safety assessment of the facility (2) A summary description and discussion of the facility, with special attention to design and operating characteristics, unusual or novel design features, and principal safety considerations.

(3) The preliminary design of the facility including:

(i) The principal design criteria for the facility (ii) The design bases and the relation of the design bases to the principal design criteria; (iii) Information relative to materials of construction, general arrangement, and approximate dimensions, sufficient to provide reasonable assurance that the final design will conform to the design bases with adequate margin for safety.

8

10 CFR 50.34 can be met using a performance-based design approach.

For practical reasons associated with the way the US NRC does its regulatory reviews, the above supports two types of concerns:

(A) facility or system-of-system concerns, see (1) through (5) above, and (Existing Facilities; New Facilities: TI-RIPB, RG 1.233, NEI 18-04, Part 53)

(B) system or equipment concerns, see (6) above. I&C Domain (e.g., SW Development Process, Diversity to address CCF,)

Simplistically, the need to protect the health and safety of the public and the environment is a facility concern, and this facility concern is addressed by ensuring that equipment and systems perform in accordance with the needs established at the facility level. In effect, what must the equipment do (and not do)? and how do we know the equipment will do that, and only that?

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At least three levels of abstraction in 50.34 (i.e., can be more)

  • Principle Design Criteria
  • Design Bases (i.e., functions and values)
  • Equipment Design I&C Domain 10

Implied Layers from 10 CFR 50 Appendix A 11

Implied Objectives from 10 CFR 50 Appendix A The development of these General Design Criteria is not yet complete. For example, some of the definitions need further amplification. Also, some of the specific design requirements for structures, systems, and components important to safety have not as yet been suitably defined. Their omission does not relieve any applicant from considering these matters in the design of a specific facility and satisfying the necessary safety requirements. These matters include:(4) Consideration of the possibility of systematic, nonrandom, concurrent failures of redundant elements in the design of protection systems and reactivity control systems. (See Criteria 22, 24, 26, and 29.)

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The Meaning of Performance-Base in International Code Council Performance code for Buildings and Facilities Performance codes, such as the ICC International performance code, define the problem and allow the designer to devise the solution. The word performance in this context refers to the problem definition and to the setting of parameters for deciding if the proposed solution solves the problem adequately.The basic form of modern performance-code language can be described as objective based.

Building Codes Illustrated by Francis D.K. Ching et al (2007) Second edition The 2024 ICCPC presents provisions based on outcomes rather than prescriptive rules. It encourages new design methods by allowing broader options for meeting the intent of the International Codes. An updated Users Guide is included. For the most current adoptions details go to International Code Adoptions 2024 ICCPC - About this Title 13

Remaining Slides are screen captures from

  • 2024 ICC Performance Code for Buildings and Facilities (ICCPC)

(https://codes.iccsafe.org/content/ICCPC2024P1)

  • Do not try inventing from scratch (you will rediscover what the others already found)
  • Adopt and adapt -the following slides include some interesting ideas 14

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16

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18

19

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References

  • 2024 ICC Performance Code for Buildings and Facilities (ICCPC)

(https://codes.iccsafe.org/content/ICCPC2024P1)

UIUC College of Law teams up with Nuclear Engineering to further safe regulation of advanced nuclear reactors SoTeRiA Laboratory teams up with law school to analyze risk-informed regulation of advanced nuclear reactors Arden Rowell Faculty Page Zahra Mohaghegh Faculty Page

  • IFE Sample of Related Projects:
  • The Halden Reactor Project
  • OECD NEA Halden HTO Project Includes:

Digital I&C - Safety assurance Risk-informed Safety Assurance Evidence Collection, Evaluation and Combination for Safety

  • Other Interesting IFE Projects
  • Trust in AI
  • Small Modular Reactors - SMR
  • Vision-Based Diagnostics
  • Advanced Control and Automation Support
  • Diagnostic Decision Support
  • Digital Instrumentation & Control
  • Collaborative Decision Making using Diagnostic and Prognostic Reasoning 21

References

  • SAM.gov - Where the NRC lists solicitations for proposals, for example:
  • Safety Assurance Case Framework for Performance-Based DI&C Applications for Operating Reactors.
  • On page:

https://www.fedconnect.net/FedConnect/default.aspx?ReturnUrl=%2fFedConnect%2f%3fdoc%3d31 310023R0086%26agency%3dNRC&doc=31310023R0086&agency=NRC

  • For Statement of work follow link 31310023R0086 on right hand side
  • Assessment Operating Experience in Digital Systems
  • On page:

https://www.fedconnect.net/FedConnect/default.aspx?ReturnUrl=%2fFedConnect%2f%3fdoc%3d31 310023R0098%26agency%3dNRC&doc=31310023R0098&agency=NRC

  • For Statement of work follow link 31310023R0098 on right hand side
  • The National Academies report, Performance-based Safety Regulation
  • The SFPE Code Officials Guide to performance-Based Design Reviews (2004)
  • Reactor Safety Study (WASH-1400)
  • IAEA Safety Series - SF-1, "Fundamental Safety Principles"
  • IAEAs Safety Report Series No. 46, Assessment of Defense in Depth for Nuclear Power Plants
  • IAEA-TECDOC-1570 - Proposal for a Technology-Neutral Safety Approach for New Reactor Designs 22

References - NRC 10 CFR 50.34 Contents of applications; technical information.

10 50.48 Fire protection.

(c) National Fire Protection Association Standard NFPA 805. (National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition" (NFPA 805))

Appendix A to Part 50General Design Criteria for Nuclear Power Plants NRC Glossary Defense in Depth Performance indicator Performance-based regulation Performance-based regulatory action Risk Risk-based decisionmaking Risk-informed decisionmaking Risk-informed regulation Risk-significant SRM to SECY-98-144, White Paper on Risk-Informed and Performance-Based Regulation SECY 00-0191, High Level Guidelines for Performance Based Activities, and NUREG/BR-0303, Guidance for Performance-Based Regulation.

RG 1.233 (06/2020), Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light Water Reactors NEI 18-04, Risk-Informed Performance-Based Technology Inclusive Guidance for Non-Light Water Reactor Licensing Basis Development.

NUREG/KM-0009, Historical Review and Observations of Defense-in-Depth.

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