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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ML18054A073	List: ML18054A075 ML18054A078
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Licensing Modernization Project (LMP)

First Working Meeting between NRC Staff and NEI Regulatory Process Improvements for Advanced Reactor Designs February 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 3

Discussion 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.

4 High 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.

5 Selected 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 FSAR These 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 facilitys response, as it relates to radiological release limits and protecting public health and safety?

6 Foundation 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.

7 Challenge 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 applicants Endorsement 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.

8 LMP 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.

9 Use 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.

10 Definition 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.

11 Content Model Precedents

ADDITIONAL BACKGROUND SLIDES 12

10 CFR 50.2: Safety-related structures, 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.

13 SSC 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 IAEAs Safety Report Series No. 46, Assessment of Defense in Depth for Nuclear Power Plants 14 Defense in Depth

• Includes.

15 Draft B - 02/12/2018

Advanced Reactor Guidance Documents February 14, 2018 1

Bridge 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 3 Contributing 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 4

Technology 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 decisions RG 1.206 Chapters 1-19 Other Parts of Applications &

Possible Issues Need for Discussions / Guidance on Format & Content ?

Feb/March 2017 stakeholder meetings

Format 6

Feb/March 2017 stakeholder meetings

Key Inputs for Licensing (INL Figure) 7 March 2017 stakeholder meeting

Staff Feedback Licensing Basis Events (LBEs) 8 Framework June 2017 stakeholder meeting

9 Integrating Activities Nov/Dec 2017 stakeholder meetings

Methodology to Identify Performance Criteria 10

Mechanistic Source Term 11

Guidance Document 12

• 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 Document 13

• 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 Paper 14 Feb 2018 stakeholder meeting

Related Examples 15 Feb 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

16 Some Assembly Required

17 Discussion