ML18054A075

Slide Package on February 14, 2018, Licensing Modernization Project Meeting

ML18054A075
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Site:	Nuclear Energy Institute
Issue date:	03/14/2018
From:	Nuclear Energy Institute
To:	Office of New Reactors
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Licensing Modernization Project (LMP)First Working Meeting between NRC Staff and NEIRegulatory Process Improvements for Advanced Reactor DesignsFebruary 14, 2018 *USNRC Rockville MD 1

Agenda *Discussion of Guidance Document (GD) Annotated Outline

• High level path to NRC endorsement of LMP guidance document

-LMP vision

-NRC vision

• Applicable NRC regulatory requirements

-LMP insights

-NRC insights

• LMP GD objectives for addressing those requirements

-LMP insights

-NRC suggestions

• Use of References

• Definitions

• NRC to suggest a content model to follow

-Regulatory vs. Developer content 2

• 1.Purpose *2.Background

• 3.Applicability and Scope

• 4.Process for Preparing Input for Application

-4.1 Overview

-4.2 Selection of LBE Event

-4.3 Safety Classification of SSC

-4.4 RIPB Defense in Depth 3Discussion of Annotated Outline The primary objectives of the LMP guidance document provide an means acceptable to the NRC of satisfying applicable regulations for non

-light water reactors. NEI and industry will request NRC endorsement of the completed guidance document.*RIPB LMP Guidance Document completed and approved as an NEI document by NEI management;

• NEI request for NRC endorsement via letter;

• Pending NRC approval, endorsement of RIPB LMP Guidance Document via appropriate regulatory vehicle.

4High Level Path to NRC Endorsement 10 CFR Part 52 requires that the FSAR included in a license application must include the following content:

• 52.79(a)(1)(vi):* A description and safety assessment - . The assessment must contain an analysis and evaluation of the major structures, systems, and components of the facility that bear significantly on the acceptability of the site under the radiological consequence evaluation factors -. In performing this assessment, an applicant shall assume a fission product release from the core into the containment assuming that the facility is operated at the ultimate power level contemplated.

• 52.79(a)(2):A description and analysis of the structures, systems, and components of the facility with emphasis upon performance requirements, -and the evaluations required to show that safety functions will be accomplished. It is expected that reactors will reflect - an extremely low probability for accidents that could result in the release of significant quantities of radioactive fission products.

• 52.79(a)(5): An analysis and evaluation of the design and performance of structures, systems, and components - provided for the prevention of accidents and the mitigation of the consequences of accidents.

5Selected Regulatory Requirements Similar requirements are reflected in the regulations associated with the Part 50 licensing path:

• 50.34 (a) for the PSAR

• 50.34(b) for the FSARThese regulatory requirements center around the following underlying questions:

• What are the plant events and accidents that are associated with the design?

• How does the proposed design and its SSCs respond to those events?

• What are the margins provided by the facility's response, as it relates to radiological release limits and protecting public health and safety?

6Foundation of Regulatory Review

• The Standard Review Plan (NUREG

-0800) for LWRs requires the applicant to propose AOOs and postulated accidents and includes examples applicable to LWRs only;

• Given the lack of a method for selecting LBEs, NUREG

-0800 does not provide useful guidance for non

-LWRs on this topic.

-This creates significant uncertainty for reactor developers, future facility owner

-operators, and the NRC staff.

• RIPB Guidance Document describes a set of acceptable processes for LBE selection, SSC classification, performance criteria and special treatment, and evaluation of DID.

7Challenge for Advanced non

-LWRs The primary objectives of the LMP guidance document are to address this cross

-cutting uncertainty by:

• Providing a technology

-inclusive, risk

-informed, and performance

-based approach for selecting and evaluating licensing basis events, applying SSC safety classification, and evaluating DID adequacy for advanced non

-LWRs*Establishing this approach as an acceptable means for addressing and complying with the associated regulatory requirements, including those summarized above (50.34 or 52.79)

• Gaining formal NRC endorsement of this approach in a form that can be referenced and implemented by future applicantsEndorsement of this licensing approach also significantly reduces advanced reactor development uncertainty, since it establishes an approach that the designer can employ at an early stage to ensure effective risk management of challenges to the safety design process.

8LMP Guidance Document Objectives The RIPB LMP Guidance Document is based on a foundation of research and development stretching back decades to the present day. As an NRC endorsable document however, the GD is structured and written as a stand

-alone document.

• No LMP white papers are incorporated by reference.

-NRC Staff formal review and approval of LMP documents other than the GD is not intended.

-External references provide history, context, detailed guidance for specific tasks, etc. and are not included for NRC endorsement.

• LMP seeks NRC feedback on this GD philosophy.

9Use of References within GD As has been previously noted, the RIPB LMP GD relies on decades of foundational work by the NRC Staff, national laboratories, and industry. In order to ensure understanding among readers of the RIPB LMP GD, the following is proposed:

• LMP and Staff identify a list of terms frequently used within the GD.-LMP and Staff propose terms at next working meeting for consolidation and discussion.

• End goal is to prepare an endorsable glossary of terms that have precise meaning within the GD.

10Definition of Key Terms In seeking to provide an acceptable product to the NRC Staff, LMP requests NRC identify any NRC

-endorsed documents that are particularly useful models for content and endorsement process steps.

• GD "licensing focus" vs. "design focus".

11Content Model Precedents ADDITIONAL BACKGROUND SLIDES 12

• 10 CFR 50.2: Safety-relatedstructures, systems and components means those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

-The integrity of the reactor coolant pressure boundary

-The capability to shut down the reactor and maintain it in a safe shutdown condition; or

-The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in

§50.34(a)(1) or

§100.11 of this chapter, as applicable.

• LMP approach for SSC safety classification based on keeping DBEs within F-C target and considers aspects of 10 CFR 50.69 safety significance categories with understanding that all LMP safety

-related SSCs are regarded as risk

-significant.

• QA requirements for safety

-related SSC are consistent with 10 CFR 50, Appendix A.

13SSC Safety Classification

• Defense in Depth is a general NRC philosophy, but regulatory guidance/process to determine defense in depth adequacy has not been developed

• LMP approach is consistent with historical philosophy and Commission policy

• NUREG/KM-0009, "Historical Review and Observations of Defense-in-Depth" was considered

• LMP approach considered related industry standards, including IAEA's Safety Report Series No. 46, "Assessment of Defense in Depth for Nuclear Power Plants" 14Defense in Depth

• Includes-.

15Draft B -02/12/2018 Advanced Reactor Guidance DocumentsFebruary 14, 2018 1Bridge Number Pass Code (888) 793-9929 18396 Advanced Reactor Program 2*NRC Vision and Strategy: "Safely Achieving Effective and Efficient Non

-LWR Mission Readiness"

-December 2016

• Implementation Action Plans (IAPs)

• SECY-18-0011, "Advanced Reactor Program Status"

-ML17334B217 IAPs Strategy 3Contributing Activities 3 1)Establish criteria, as necessary, to reach a safety, security, or environmental finding for non

-LWR technologies 2)Determine appropriate licensing bases and accident sets for non

-LWR technologies 3)Identify and resolve gaps in current regulatory framework associated with non-LWR reactors and the associated fuel cycle 4)Develop a regulatory review "roadmap" reflecting design development lifecycle and appropriate interactions, including potential research and test reactor interactions 5)Update prototype reactor guidance 6)Engage on technology

-or design-specific licensing project plans and develop regulatory approaches commensurate with the risks posed by the technology 7)Support longer

-term efforts to develop, as needed, a new non

-LWR regulatory framework that is risk

-informed and performance

-based, and that feature staff review efforts commensurate with the demonstrated safety performance of the non-LWR NPP design being considered Advanced Reactor Landscape 4Technology working group (TWG) members

• GOAL: As much as possible, develop technology

-inclusive approaches Advanced Reactor Program 5*General Description of the Plant

• Site Characteristics

• Design of SSCs and Equipment

• Reactor *Reactor Coolant and Connecting Systems

• Engineered Safety Features

• Instrumentation and Controls

• Electric Power

• Auxiliary Systems

• Steam and Power Conversion System

• Radioactive Waste Management

• Radiation Protection

• Conduct of Operations

• Verification Programs

• Transient and Accident Analyses

• Technical Specifications

• Quality Assurance and Reliability Assurance

• Human Factors Engineering

• Probabilistic Risk Assessment/Severe Accident Evaluation

• Emergency Planning

• Security*Staffing*Mitigating Strategies

• Aircraft Impact Assessment

• Environmental Report

• Financial*Inspections, Tests, Analyses, and Acceptance Criteria

• Insurance*Fuel Cycle

• Other (design or technology specific)All or selected topics to support critical decisionsRG 1.206Chapters 1

-19Other Parts ofApplications & Possible IssuesNeed for Discussions / Guidance on Format & Content ?Feb/March 2017 stakeholder meetings Format 6Feb/March 2017 stakeholder meetings Key Inputs for Licensing (INL Figure) 7March 2017 stakeholder meeting Staff FeedbackLicensing Basis Events (LBEs) 8FrameworkJune 2017 stakeholder meeting 9Integrating ActivitiesNov/Dec 2017 stakeholder meetings Methodology to Identify Performance Criteria10 Mechanistic Source Term 11 Guidance Document12*Applicable Regulatory Requirements

-10 CFR 50.34(a) (preliminary)

• The safety features that are to be engineered into the facility -

• The principal design criteria for the facility.

• A preliminary analysis and evaluation of the design and performance of structures, systems, and components of the facility with the objective of assessing the risk to public health and safety-

• An identification of those structures, systems, or components of the facility, if any, which require research and development to confirm the adequacy of their design-Guidance Document13*Applicable Regulatory Requirements

-10 CFR 50.34(b) (final)

• A description and analysis of the structures, systems, and components of the facility, with emphasis upon performance requirements ..

• For nuclear reactors, such items as the reactor core, reactor coolant system, - shall be discussed insofar as they are pertinent.

• A final analysis and evaluation of the design and performance of structures, systems, and components -

• A description and evaluation of the results of the applicant's programs, including research and development, -

-Similar content required in 10 CFR 52.47 (design certifications) and 10 CFR 52.79 (combined licenses)

Comments/Questions Defense in Depth White Paper14Feb 2018 stakeholder meeting Related Examples15Feb 2018 stakeholder meeting

• RG 1.181, Content of UFSAR (NEI 98-03)*RG 1.186, 50.2 Design Basis (NEI 97-04)*RG 1.188, License Renewal Applications (NEI 95-10)*RG 1.201, Categorizing SSCs (NEI 00-04)*NUREG-0800 (SRP) Introduction

-Part 2-Enhanced Safety Focused Review 16Some Assembly Required 17Discussion