ML24271A187
| ML24271A187 | |
| Person / Time | |
|---|---|
| Issue date: | 10/25/2024 |
| From: | Norbert Carte Office of Nuclear Reactor Regulation |
| To: | Fanta Sacko Office of Nuclear Reactor Regulation |
| References | |
| Download: ML24271A187 (1) | |
Text
MEMORANDUM TO:
Fanta Sacko, Branch Chief Instrumentation & Controls Branch Division of Engineering and External Hazards Office of Nuclear Reactor Regulation FROM:
Norbert Carte, Senior Electronics Engineer Instrumentation & Controls Branch Division of Engineering and External Hazards Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF MAY 29, 2024, PUBLIC COMMENT GATHERING MEETING ON PERFORMANCE BASED ENGINEERING On May 29, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff held a public comment gathering meeting with external stakeholders to hold a technical information exchange about what it means to be performance-based in scientific and engineering knowledge. Both NRC staff and external stakeholders made formal presentations in the meeting. The NRC staff and external stakeholders engaged in discussion on the merits of performance-based engineering. The meeting notice and agenda dated May 17, 2022, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML24138A167. Enclosed is a list of attendees at the meeting.
Meeting Summary During the meeting, Ralph Hill, Chair ASME Plant Systems Design Standards Committee from Hill Eng Solutions, LLC presented about Plant Systems Design, a standard under development, (ML24150A112) with a focus on how it encompasses performance-based design consideration.
The main theme of Ralph Hills presentation was that the Plant Systems Design standard (PSD-1) incorporates and integrates systems engineering, hazard and risk evaluation, and probabilistic design methods into traditional design processes. It provides detailed process and guidance on performance-based and risk-informed engineering, including: defense in depth, safety significance, and plant availability into a seamless design process. Regulatory requirements were described as one of the inputs to the design.
After the presentation, the NRC staff and the external stakeholders engaged in discussion based on Ralph Hills presentation.
Several participants agreed that several layers of abstraction are needed for the representation of requirements (Ralph Hills word for the mandatory aspects of all levels of abstraction), but there was some disagreement about what those layers should be called. Some thought that words such as goals, objectives, or design criteria should be used for the upper layers, in part, because each layer should be named and characterized.
October 25, 2024 It was noted several times by different participants that terminology used in applications should be consistent with NRCs definitions, otherwise the regulatory review process may not be as efficient as possible. It was also mentioned that explicitly identifying alternative terminology or usage may also be useful (although there were some doubts raised on this matter).
Ralph Hill explained that, although PSD-1 was being described as a facility level process, it could be applied to a topical area such as digital Instrumentation and control (DI&C).
The applicability of a systems engineering framework was discussed and it was concluded that there is no incompatibility with SRM-SECY-98-144.
Norbert Carte, NRC staff from the Office of Nuclear Reactor Regulation (NRR), Division of Engineering and External Hazards (DEX) presented his perspective on what is meant by the term performance-based design (ML24150A116).
The presentation identified that the NRC has one definition for performance-based, (i.e., that in SRM-SECY-98-0144) and the presenter described two very different senses in which it could be used: (1) performance monitoring of ongoing activities, and (2) performance-based design (i.e., as opposed to prescriptive design). The NRC presentation then described performance-based design as being about establishing goals or objectives and allowing flexibility in how they are achieved. However, the licensing of a design (or a facility) includes evaluating whether the design will accomplish the stated safety goals or objectives, and there is currently not sufficient guidance for how to do this for Digital I&C; therefore, the NRC has funded safety assurance case (SAC) and model-based system engineering (MBSE) research as a means to establish the technical basis for review guidance for performance-based design of Digital I&C. The presenter stated that he believes the key to efficient and effective evaluation of a performance-based design must include good layers of abstraction that enable easy understanding.
The presentation also described that the prescriptive criteria established for the large light water reactors (LWRs) may not be optimal for more modern designs and that performance-based design could be a way to improve efficiency and effectiveness of licensing of these facilities.
The NRC presentation also identified several sectors where performance-based design engineering (and associated standards) has been in use much longer than at the NRC; therefore, within the nuclear power industry, the DI&C domain should look to these other sectors to adopt and adapt efficient and effective practices. The presentation identified that differences in terminology in these other sectors could decrease licensing efficiency and effectiveness. Therefore, for NRC licensing purposes SRM-SECY-98-144 continues to be the best source for understanding for terms such as risk-informed (RI), performance-based (PB), and RIPB.
After the presentation the NRC staff and the external stakeholders engaged in discussion based on Norbert Cartes presentation.
There was general agreement with the NRC presentation.
In part, it was agreed that further meetings would be helpful. Since the discussions were mostly high level, in many areas, and the subsequent meetings should drill down into specific areas (as agreed by participates), with presentations on just that one small area/topic.
Conclusion At the end of the meeting, NRC staff requested feedback. No regulatory decisions were made.
Ralph Hill, Prasad Kadambi, Rani Franovich, and other external stakeholders provided comments about how beneficial the meeting was. Public Meeting Feedback forms were not received.
Enclosure:
List of Attendees
LIST OF ATTENDEES MAY 29, 2024, PUBLIC COMMENT GATHERING MEETING ON ON PERFORMANCE BASED ENGINEERING Microsoft Teams Meeting ATTENDEE ORGANIZATION1 Fanta Sacko U.S. Nuclear Regulatory Commission (NRC)
Norbert Carte NRC David Rahn NRC Joseph Ashcraft NRC William Roggenbrodt NRC Hang Vu NRC Gilberto Blas Rodriguez NRC Kamal Manoly NRC Laurel Bauer NRC Sergiu Basturescu NRC Derek Halverson NRC Joshua Derosier NRC N. Prasad Kadambi Kadambi Engineering Consultants Pvt Ltd Rani Franovich Nuclear ROSE Consulting, LLC Ralph Hill American Society of Mechanical Engineers Mohaghegh, Zahra University of Illinois Urbana-Champaign (UIUC)
Joslin, George Frederick UIUC Rowell, Arden UIUC Bui, Ha Hoang UIUC Péter Kárpati Institute for Energy Technology (IFE)
Sizarta Sarshar IFE Xueli Gao IFE Cindy Williams NuScale Power Sarah Bristol NuScale Power Leigh Lloveras Breakthrough Institute Adam Stein Breakthrough Institute Caroline Tilton TerraPower Matthew Hertel X-energy Golliet, Matthew Westinghouse Chisholm, Brandon M.
Southern Company Bergman, Jana Curtiss-Wright Tim Sande Enercon Ingrid Nordby Deep Fission Burg, Rob EPM Mohamed M. Talaat Simpson Gumpertz & Heger Ferrante, Fernando Electric Power Research Institute Nack, Andrew Michael The University of Tennessee Knoxville Greg Hudson Unknown Hammad Khalid Unknown 1 Unknown organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.
Enclosure
Package: ML24271A180 Meeting Notice: ML24138A167 Meeting Summary: ML24271A187 Meeting Slides: ML24150A112, ML24150A116 *e-concurrence OFFICE NRR/DEX/EICB/TR*
NRR/DEX/EICB/BC*
NAME NCarte FSacko DATE 10/04/2024 10/11/2024