ML23053A291

Presentation - February 23, 2023 Licensing Review Framework for Advanced Reactors I&C Workshop 1

ML23053A291
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Issue date:	02/22/2023
From:	Office of Nuclear Reactor Regulation
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Licensing Review Framework for Advanced Reactors Instrumentation and Controls (I&C)

Workshop February 23, 2023 1 of 25

Introduction and Requests for Workshops on I&C Design Review Guide (DRG) Implementation

• Final I&C Design Review Guide (DRG) issued in February 2021 (ML21011A140) for I&C design reviews by NRC staff

• NRC staff reviews / pre-application engagements underway for a variety of potential LWR and non-LWR I&C designs

• NRC staff engaged by industry interested in the background and details on the DRGand relationship to NEI documents 2 of 25

Workshop Agenda

• Overview of recent and ongoing initiatives:

- Licensing Modernization Project (LMP) and RG 1.233

- Technology-Inclusive Content of Application Project (TICAP)

- Advanced Reactor Content of Application Project (ARCAP)

• Overview of I&C DRG

- Focus on safety-significant SSCs; Use of reliability / capability targets

- Developed for non-LWRs, but can be used for all reactor designs

• Specific industry perspectives and potential challenges 3 of 25

LMP Methodology Approach

• Foundations laid in MHTGR, PBMR, and NGNP projects and incorporates NRC and ACRS reviews on key topics

- Technology-inclusive risk metrics

- Use of frequency-consequence targets

- Functional containment concept

- Treatment of multi-module plants

- Reliability targets in lieu of single failure criterion

- Technology-inclusive approach to defense-in-depth

• Incorporates developments in risk-informed, performance-based decision making for wide spectrum of non-LWR designs 4 of 25

LMP is Risk-Informed and Performance-Based

• Risk-informed

- Incorporating key inputs from a PRA

- Incorporating deterministic principles such as evaluation of defense-in-depth adequacy

• Performance-based

- Use of a Frequency Consequence (F-C) Target and Cumulative Risk Targets to evaluate the risk significance of licensing basis events (LBEs) and structures, systems, and components (SSCs)

- Selection of performance targets for the reliability and capability of SSCs in the prevention and mitigation of LBEs

- Use of programs to monitor the performance of the plant and SSCs against the performance targets

• Use of an Integrated Decision-Making Process to implement RIPB decisions that impact the safety case and its objective evaluation 5 of 25

Licensing Modernization Project (LMP)

(NEI 18-04 and RG 1.233)

• Licensing Basis Events

• SSC Classification

• Defense-in-Depth 6 of 25

LMP SSC Classifications 7 of 25

Derivation of Special Treatments

• SR SSCs

- Functional Design Criteria derived from required safety functions

- Lower level design criteria derived from safety-related design criteria (SRDC)

• SR and NSRST SSCs

- SSC reliability and capability performance targets

- Focus on prevention and mitigation functions from LBEs

- Integrated decision-making process (IDP) to derive specific special treatments

- Reflects Commissions expectations for RIPB regulation (SRM-SECY-98-0144) 8 of 25

Core Review Team Approach

• Non-LWR Review Strategy - successfully implementing for non-LWR preapplication and application reviews

• Multi-disciplinary core review team supported by subject matter experts from various offices

• Focus on the Fundamental Safety Functions

• Perform an integrated design review

• Demonstrate compliance with applicable regulations 9 of 25

Content of Applications - Overview 10 of 25

Content of Applications Projects

• Technology-Inclusive Content of Applications Project (TICAP) (NEI 21-07) o LMP process is used to define guidance for the content of major portions of the Safety Analysis Report (SAR)

Risk-informed, performance-based approach to select LBEs, develop SSC classification, identify special treatments for SSCs, and ensure DID adequacy o Industry developed TICAP guidance for key portions of the SAR for NRC endorsement o Industry TICAP guidance will be supplemented by NRC staff-developed guidance, as necessary

• Advanced Reactor Content of Applications Project (ARCAP) (DG-1404 + 9 ISGs) o Covers guidance for non-LWR applications under 10 CFR Part 50 and Part 52 o Encompasses TICAP guidance, provides supplemental and additional guidance for SAR content, and covers application content guidance for areas that go beyond SAR 11 of 25

ARCAP and TICAP - Nexus Outline Safety Analysis Report (SAR) - Additional Portions of Application Based on TICAP Guidance

• Technical Specifications

1. General Plant Information, Site Description,

• Technical Requirements Manual and Overview of the Safety Case

• Quality Assurance Plan (design)

2. Methodologies and Analyses and Site

• Fire Protection Program (design)

Information*

• Quality Assurance Plan (construction and

3. Licensing Basis Event (LBE) Analysis

4. Integrated Evaluations operations)

5. Safety Functions, Design Criteria, and SSC

• Emergency Plan Safety Classification Audit/inspection of Applicant Records

• Physical Security Plan

6. Safety Related SSC Criteria and Capabilities

• Calculations

• SNM physical protection program

7. Non-safety related with special treatment

• Analyses

• SNM material control and accounting SSC Criteria and Capabilities

• P&IDs plan

8. Plant Programs

• System Descriptions

• Cyber Security Plan

• Design Drawings

• Fire Protection Program (operational)

Additional SAR Content -Outside the

• Design Specifications

• Radiation Protection Program Scope of TICAP

• Procurement Specifications

9. Control of Routine Plant Radioactive

• Offsite Dose Calculation Manual

• Probabilistic Risk Assessment Effluents, Plant Contamination, and Solid

• Inservice inspection/Inservice testing Waste (ISI/IST) Program

10. Control of Occupational Doses

• Environmental Report

11. Organization and Human-System

• Site Redress Plan Considerations

• Exemptions, Departures, and Variances

12. Post-construction Inspection, Testing and

• Facility Safety Program (under Analysis Programs consideration for Part 53 applications)

• Fitness for Duty Program

• Financial Qualification and Insurance

• SAR Chapter 2 derived from TICAP guidance as supplemented by ARCAP ISG

• Aircraft Impact Assessment Chapter 2, Site Information

• SAR structure based on clean sheet approach

• Additional contents of application outside of SAR are still under discussion. The12 of 25 above list is draft and for illustration purposes only.

ARCAP - High Level Overview

• ARCAP Roadmap ISG

• Proposes a 12-chapter SAR guidance structure

• Guidance for first 8 SAR chapters references the TICAP guidance

• Chapters 9, 10, 11, and 12 point to individual ISGs developed for each SAR chapter

• Includes pointers to draft white papers, guidance under development or to be developed for portions of the application outside the SAR

• Examples of guidance that the staff has developed: TS, Risk Informed ISI/IST, and Fire Protection for Operations

• Examples of high-level guidance embedded in the Roadmap ISG: Technical Requirements Manual, Quality Assurance Plan, Fire Protection (design), and Offsite Dose Calculation Model

• Examples of guidance being considered: security, emergency planning, material control and accountability, financial qualification and cyber security 13 of 25

ARCAP - High Level Overview

• ARCAP Roadmap ISG (continued)

• Includes several appendices:

• Appendix A on preapplication engagement guidance o Based on white paper discussed extensively during advanced reactor public stakeholder meetings o To capture the white paper guidance in a durable product that will have the benefit of a formal public comment period

• Appendix B on Analysis of Applicability of NRC Regulations to non-LWRs o Based on white paper discussed extensively during advanced reactor public stakeholder meetings (ADAMS Accession No. ML21175A287) o Purpose of Appendix B is to capture the white paper guidance in a durable product that will have the benefit of a formal public comment period 14 of 25

ARCAP - High Level Overview

• ARCAP Roadmap ISG (continued)

• Includes several appendices (continued):

• Appendix C on CP guidance o Common portions applicable to both LWRs and non-LWRs quoted from DNRL-ISG-2022-01 o Detailed CP guidance specific to non-LWRs

• Appendix D on ARCAP guidance documents currently under development

• April 2023 - DG-1404 (endorsing NEI 21-07) and 9 ARCAP ISGs expected to be published for public comment 15 of 25

Evolution of I&C Review Guidance

• NUREG-0800, Standard Review Plan (SRP) Chapter 7 System-based approach for light-water reactor (LWR) licensing reviews Guidance not suitable for non-LWRs applications

• NuScale Design-Specific Review Standard (DSRS)

Chapter 7 Improved safety-focused licensing review approach Improved licensing reviews efficiency and effectiveness

• DRG for I&C Leverages the DSRS concepts Leverages lessons learned from recent new reactor I&C ADAMS Accession No. ML21011A140 licensing reviews 16 of 25

Goals of I&C DRG

• Modernizes the I&C safety review in support of advanced non-LWR licensing applications Safety-focused Risk-informed Performance-based Technology-Inclusive

• Supports the NRCs vision and strategy for advanced reactor safety reviews

• Incorporates principles from RG-1.233 17 of 25

I&C System Review Framework 18 of 25

Overall Review Approach 19 of 25

Industry-specific Areas of Interest

• DRG-related topics:

- Dependencies between NUREG-0800 (or NUREG-1537) and DRG

- Use of DRG for LWR designs

• LMP-related topics:

- I&C design criteria for Anticipated Operational Occurrences (AOOs)

• Can an applicant credit the expected response of all SSCs for AOOs?

- Quantitatively determining software reliability for use within LMP

- Non-safety functions to mitigate effects of CCF 20 of 25

Industry-specific Areas of Interest (continued)

• NSRST-related topics:

- NSRST criteria limited to the DRG sections where specified, or consider the entire DRG?

- DRG Appendix A design criteria to support reliability and robustness

- Quality Assurance (QA) requirements/acceptance criteria for NSRST SSCs

- Are special treatments differentiated between NSRST SSCs relied on to perform risk-significant functions and those requirement special treatment for defense-in-depth adequacy?

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NRC-specific Areas of Interest

• Digital Technologies and use of NRC-approved I&C platforms

• Self-Diagnostics to accomplish surveillance functions

• Remote, Monitoring, and Control Rooms

• Design Standards (i.e., U.S. vs. International standards)

• Content of Applications Format (e.g., NUREG-0800, NUREG-1537, DSRS, DRG)

• Transition from LMP to specific I&C Design Requirements 22 of 25

Workshop #2 Proposed Topics

• Codes and Standards

- How performance-based concepts can be applied to prescriptive requirements of endorsed codes and standards

- Applicability of IEEE 603 and related standards

- Use of international codes and standards

• Applicability of on-going I&C Commercial Grade Dedication and Common Cause Failure (CCF) activities to advanced reactors

• NRC staff review expectations

- I&C-specific Principal Design Criteria

- Fundamental I&C design principles

- I&C architecture and safety classification of I&C platforms 23 of 25

Workshop #3 Proposed Topics

• Content of Applications (Near-term licensing actions)

- Clarity on applicability of Part 50/52 requirements

- Expectations for construction permit (CP) applications

- Expectations for operating license applications

- Non-power vs. power reactor applications

• Difference in applicable regulatory requirements

• Use of NUREG-1537 with I&C guidance and standards

• Use of NUREG-0800 with I&C guidance and standards 24 of 25

Questions?

For more information, contact:

Jordan.Hoellman2@nrc.gov 25 of 25