Status Report on Regulatory Criteria Applicable to the Use of Artificial Intelligence (AI) and Machine Learning (ML)
Although the interest in the use of artificial intelligence (AI) and machine learning (ML) in nuclear energy is increasing rapidly, at present their implementation is limited. This rapid increase in interest is not surprising considering that implementing AI and ML technology would allow for continuous monitoring, facilitate the implementation of predictive maintenance with optimized staffing plans, enable automation and autonomy opportunities that could drastically reduce fixed operation and maintenance costs, and provide training for operations and maintenance. Other industries are using AI for construction, and in the nuclear arena AI could provide great benefit in decommissioning activities. The ability of AI and ML to operate in real time vastly increases their potential impact. Before AI can be used in design, operations, or as a regulatory tool, the specifics on the regulations applicable to the use of AI for nuclear power applications need to be established. The difficulty is that the specific use cases will dictate the applicability of regulations. For example, even within the application domain associated with operations, the regulations might vary if the AI is used to create a virtual reference for plant operations or is used for training, optimization of maintenance intervals, prioritization of maintenance activities, etc. Different still is if the AI is to be used for design or setting technical specifications, which will introduce additional requirements. US Nuclear Regulatory Commission (NRC) licensing reviews are based on an applicant’s design meeting its performance assessment based on (1) safety goals and objectives, (2) deterministic and/or probabilistic analysis of accident scenarios, and (3) quantitative assessment of design alternatives against the safety goals and objectives using accepted engineering tools, methodologies, and performance criteria. The current regulatory framework does not explicitly address AI or autonomous control. However, as implementing AI technology will require the use of a digital platform, it must meet the requirements of an instrumentation and control (I&C) system. The regulatory requirements for AI, which will be incorporated into the I&C system, will be very dependent on how it is used (i.e., its functionality, safety classification, etc.). The licensing process is primarily risk-based with the identification of components and systems as nonsafety, important to safety, or safety related. A risk-informed approach allows further gradation of components and systems based on risk metrics such as core damage frequency or large early release fractions. Thus, the use cases and the risk categorization of impacted systems and components will determine the regulatory requirements. Regardless of how AI is used it presents new opportunities for risk-informing operating, maintenance, and regulatory decisions. Trustworthiness, transparency, and the ability to validate and verify the results will be paramount in showing that the systems and plant still meet their performance requirements. This report describes the results of research to identify regulatory implications of AI technologies and their uses. Specifically, this report reviews current regulatory guidance relevant to the application of AI for design (including design changes or new designs including advanced reactors), construction, operations, training, maintenance, research, testing, and as a regulatory tool. AI can be automated at different levels from purely informative purposes to autonomous controls. The focus of this review included determination of constraints on the application of AI technology, identification of any regulatory gaps or uncertainties, and clarification of anticipated technical basis information likely to be important for regulatory acceptance of these technologies. Currently, any use of AI at nuclear power plants is focused on nonsafety-related applications. The NRC and other regulatory bodies are evaluating providing guidance to address gaps rather than create new regulations to address the use of AI and ML. This approach seems to be the best to encourage AI development without adding regulatory uncertainty.