ML20162A197

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Advanced Reactor Content of Application Project Public Meeting
ML20162A197
Person / Time
Issue date: 06/12/2020
From: Joseph Sebrosky
NRC/NRR/DANU/UARL
To:
joseph Sebrosky NRR/DANU, 415-1132
References
Download: ML20162A197 (51)
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Advanced Reactor Content of Application Project Public Meeting June 12, 2020 Telephone Bridgeline: 888-566-1533 Passcode: 2647310 1 of 51

Agenda Time Topic Presenter 10:00 - 10:10 am Introduction NRC 10:10 - 10:40 am Discussion of ARCAP concepts NRC 10:40 -11:40 am Overview of NRCs vision on the broad scope and intended benefits of NRC/Idaho ARCAP. Focused discussion of draft Chapter 8 for insights on a more National Lab performance based approach to regulatory compliance, considering (INL) both normal operations and applicable licensing basis events.

11:40 - 12:00 pm Feedback on Industry comments on annotated outline provided during NRC/INL 4/22 meeting 12:00 -1:00 pm Break All 1:00 - 1:10 pm Discussion of annotated outline provided during 4/22 meeting and NRC NRC questions from 4/22 meeting 1:10 - 1:40 pm Feedback from Nuclear Energy Institute (NEI) on updated annotated NEI outline presented during 4/22 meeting and questions from 4/22 meeting 1:40 - 2:10 pm U.S, Nuclear Industry Council (NIC) feedback on updated annotated USNIC outline and NRC questions from 4/22 meeting 2:10 - 2:30 pm Other stakeholder feedback on updated annotated outline and NRC All questions from 4/22 meeting 2:30 - 2:45 pm TICAP/ARCAP next steps (options) NRC

  • Separate TICAP and ARCAP guidance
  • Keep TICAP and ARCAP guidance together
  • Other 2:45 - 3:00 pm Next meeting and concluding remarks All 2 of 51

Discussion of Advanced Reactor Content of Application Project Concepts 3 of 51

DG-1353 (Regulatory Guide 1.233)

  • Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light Water Reactors
  • This RG provides guidance for informing the licensing basis and determining an appropriate level of information for parts of preliminary or final safety analysis reports for advanced non-LWRs. The regulations at 10 CFR 50.34(a), 10 CFR 50.34(b), 10 CFR 52.47, 10 CFR 52.79, and 10 CFR 52.157 require that applications for a construction permit, operating license, DC, COL, or ML, respectively, include the level of design information sufficient to enable the Commission to reach a conclusion on safety questions before issuing a license or certification. Applications for an SDA are likewise required by 10 CFR 52.137 to include information needed for NRC staff approval.
  • The integrated process described in NEI 18 04 and its consideration of plant capabilities and programmatic controls for non-LWRs is well suited to inform the content of applications, including discussions of appropriate performance based controls of ancillary SSCs, thereby reducing the level of detail in the descriptions of the physical systems. The general guidance on the content of applications provided in this RG will need to be supplemented by other RGs and documents to help non-LWR developers and the NRC staff prepare and review applications for licenses, certifications, and approvals.

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DG-1353 (Regulatory Guide 1.233)

  • Provides guidance for non-LWR reactor designers and the NRC staff in the key areas of selecting and evaluating LBEs, identifying safety functions and classifying SSCs, selecting special treatment requirements, identifying appropriate programmatic controls, and assessing DID. Taken together, these activities provide essential insights for the reactor design process, define needed SSC capabilities and programmatic controls, and support documenting the safety arguments supporting applications for licenses, certifications, or approvals.
  • Limits on operation [preventing failures or degradation or to remain within the bounds of testing or qualification of related SSCs] thus establish the safety functions needed to prevent damage to barriers to the release of radionuclides (e.g., functions to maintain integrity of fuel cladding, coatings, or other fuel system boundary). This information is needed to address the NEI 18 04 methodologies and for the development of a mechanistic source term for the specific non-LWR design.

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DG-1353 (Regulatory Guide 1.233)

  • This guidance focuses on the design features, programmatic controls, and licensing decisions related to limiting the unplanned release of radioactive material resulting from plant transients and postulated accidents. Various NRC regulations and related guidance address radiological effluents from normal operation and the content of applications provided in licensing basis documents other than Final Safety Analysis Reports (e.g., security plans, technical specifications, and environmental reports). RG 1.206 describes various licensing basis documents and a typical organization of those documents within applications for a combined license, early site permit, or design certification. The overall organization of applications described in RG 1.206, including chapter-level organization of a final safety analysis report, is generally applicable to non-LWR applications.
  • A description of ancillary plant systems or the interface between the ancillary and primary plant systems should focus on any safety functions being supported and possible contributions to initiating events. Where SSCs do not play a meaningful role in preventing or mitigating LBEs, minimal information on those SSCs should be provided within an application.

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DG-1353 (Regulatory Guide 1.233)

  • The level of detail for ancillary SSCs can also reflect potential performance based approaches within applications for licenses, certifications, or approvals. Guidance for NRC staff reviews of advanced reactors encourages the staff to consider performance-based approaches, which can likewise be used to inform the appropriate level of detail in applications. Part 2 to the Introduction to NUREG-0800 for light water small modular reactors includes the following guidance on the use of performance based approaches as part of an integrated review for small modular reactors:

Second, the framework incorporates an integrated review approach by using the satisfaction of selected requirements to provide reasonable assurance of some aspects of SSC performance (for example, performance based acceptance criteria related to SSC capability, reliability, and availability).

Examples of requirements that could be applied for this purpose include 10 CFR Part 50, Appendix A (general design criteria, overall requirements, criteria 1 through 5), 10 CFR Part 50, Appendix B (quality assurance program), 10 CFR 50.49 (electric equipment environmental qualification program),

10 CFR 50.55a (code design, inservice testing and inservice inspection programs), 10 CFR 50.65 (maintenance rule), Technical Specifications (TSs), Availability Controls for SSCs subject to Regulatory Treatment of Non-Safety Systems (RTNSS), the Initial Test Program (ITP), and ITAAC. In preparing the safety evaluation for the application, the staff may use the satisfaction of these selected requirements to augment or replace, as appropriate, technical analysis and other evaluation techniques to obtain reasonable assurance that the performance-based acceptance criteria are satisfied. Under the framework, the staff also has the flexibility to use these selected requirements to demonstrate satisfaction of design based acceptance criteria for the SSCs with low risk significance. The staff will verify the demonstration of the design basis capabilities of SSCs that are important to safety as part of the ITAAC completion review prior to plant operation.

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SECY-19-0117

  • The purpose of this paper [SECY-19-0117] is to request that the Commission find that the U.S. Nuclear Regulatory Commission (NRC) staff's use of the technology-inclusive, risk-informed, and performance-based methodology described in this paper is a reasonable approach to establish key parts of the licensing basis and content of applications for licenses, certifications, and approvals for non-light-water reactors (non-LWRs). Related industry guidance was developed as part of the Licensing Modernization Project (LMP), a cost-shared initiative led by nuclear utilities and supported by the U.S. Department of Energy (DOE).
  • The major elements of the methodology are identifying licensing basis events (LBEs);

classifying structures, systems, and components (SSCs); and assessing the adequacy of defense in depth (DID).

  • The development and approval of the methodology described in this paper will also be part of the NRC's response to Section 103, "Advanced Nuclear Reactor Program," of the Nuclear Energy Innovation and Modernization Act (Public Law No: 115-439), which requires the NRC to ( 1) within 2 years develop and implement, where appropriate, strategies for the increased use of risk-informed, performance-based licensing evaluation techniques and guidance for commercial advanced nuclear reactors within the existing regulatory framework; and (2) complete a rulemaking by December 31, 2027, to establish a technology-inclusive, regulatory framework for optional use by commercial advanced nuclear reactor applicants for new reactor license applications.

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SECY-19-0117 9 of 51

Technology-Inclusive Regulatory Framework (Part 53)

- Rulemaking Plan on Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors (RIN-3150-AK31; NRC-2019-0062)

Normal operations/effluents Continuity: Desire to use RG 1.233 and Subsequent RGs (TICAP/ARCAP) as Other regulatory/licensing topics guidance for Part 53 10 of 51

Vision and Intended Benefits of Advanced Reactor Content of Application Project 11 of 51

Advanced Reactor Content of Applications

  • Staffs draft outline was discussed on Dec. 12 and is found in ADAMS at Accession No. ML19325C089
  • Draft outline addresses Sections 1 through 14

- Final safety analysis report (FSAR) portion of application

  • Staffs draft outline annotated to suggest additional background and clarification regarding FSAR section content

- Initially discussed in April 22 public meeting with stakeholders

- Annotated outline is found in ADAMS at Accession No. ML20107J565

- Continues to include a summary listing of other (non-FSAR) portions of an application for completeness 12 of 51

NEI 18-04 Background The NEI 18-04 approach provides a repeatable method for addressing the following broad questions:

o What are the plant Initiating Events and event sequences that are associated with the design?

o How does the proposed design and its SSCs respond to Initiating Events and event sequences?

o What are the margins provided by the facilitys response, as it relates to prevention and mitigation of radiological releases within prescribed limits in the protection of public health and safety?

o Is the philosophy of DID adequately reflected in the design and operation of the facility?

These questions are primarily associated with the assessment of licensing basis events (LBEs) as they relate to protection of the public 13 of 51

Other FSAR Considerations Other areas must also be addressed in the FSAR, including for instance, various issues and controls associated with normal operations

  • Excerpts from 50.34 (b) regarding required FSAR content: The final safety analysis report shall include information that describes the facility, presents the design bases and the limits on its operation, and presents a safety analysis of the structures, systems, and components and of the facility as a whole, and shall include the following:
  • (3) The kinds and quantities of radioactive materials expected to be produced in the operation and the means for controlling and limiting radioactive effluents and radiation exposures within the limits set forth in part 20 of this chapter.

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ARCAP Chapter 8 Background

  • NEI 18-04 utilizes Part 20 as the basis for one of its cumulative risk metrics when evaluating LBEs
  • Since Part 20 provides annual exposure limits both for abnormal and normal operation, compliance must be evaluated and demonstrated through both the integrated consideration of associated LBEs resulting from application of the NEI 18-04 process, as well as the effluent releases from normal operations 15 of 51

ARCAP Chapter 8 Background - continued

  • Similar to LMP, application guidance for Part 20 requirements regarding normal operation can be addressed through a performance-based approach
  • This suggests that the LMP and non-LMP portions of the FSAR must be closely coordinated for this topical area 16 of 51

ARCAP Chapter 8 Excerpt

Background

A portion of the currently envisioned content of the draft ARCAP Chapter 8 (control of effluents) has been further examined and refined using a more performance-based approach to improve overall project alignment among the integrated scope and purpose of TICAP & ARCAP 17 of 51

Developing Performance-Based Approaches Outline (FSAR) - LMP areas highlighted Additional Portions of Application Introduction

1. General Information*
  • Technical Specifications
2. Site Information
  • Technical Requirements Manual
3. Licensing Basis Event (LBE) Analysis*
  • Quality Assurance Plan (design)
4. Integrated Plant Analysis*
5. Description and Classification of SSCs*
  • Fuel qualification report
6. Design Basis Accidents Analysis (10 CFR
  • Exemptions 50.34)*
  • Quality Assurance Plan (construction and
7. Defense in Depth (DID)* Audit/inspection of Applicant Records operations)
  • Calculations
8. Control of Routine Plant Radioactive
  • Analyses
  • Physical Security Plan Effluents &Solid Waste
9. Control of Occupational Dose
  • System Descriptions
  • SNM material control and accounting plan
10. Human Factors Analysis*
  • Design Drawings
  • Design Specs
  • New fuel shipping plan
11. Physical Security
  • Procurement Specs
12. Overview of PRA*
  • Radiation Protection Program
13. Administrative Control Programs* (special
  • Inservice inspection/Inservice testing (ISI/IST)

Program

14. Initial Startup Programs* (special treatment)
  • Environmental Report
  • Site Redress Plan
  • Exemptions, Departures, and Variances Underlying regulatory requirements & guidance supporting possible performance-based licensing approach for areas outside scope of TICAP; for instance:
  • Part 20 monitoring & reporting

Also - many of the additional portions topics above must be included in the application to address the corresponding regulations (QA, Security, etc.)

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Example Approaches for Non-LMP SAR Content (Chapter 8 - Radioactive Waste Disposal)

Approach Content of Application Comments

1) Use Existing ARCAP
  • Use guidance in current annotated outline.
  • Allows some reduction from RG Chap 8 Guidance.
  • Requires analysis and SSCs demonstrating 1.206 and SRP guidance based upon SAR Contains compliance with regs be described in the SAR. risk significance.

Analysis and Design

  • Monitoring described in Radiation Protection
  • Post OL performance monitoring Info to Demonstrate Program. verifies compliance.

System Performance.

  • Must comply with Pt 20 reqts.
2) Performance-Based
  • Requires analysis demonstrating compliance
  • Requires some design detail be in the with Analysis to with regulations be described in the SAR. SAR.

Demonstrate System

  • Only SSC descriptions necessary to support
  • Post OL performance monitoring Performance. Limited analysis need be described in the SAR. verifies compliance.

Design Info.

  • Monitoring described in Radiation Protection
  • Must comply with Pt 20 reqts.

Program.

3) Reduced SAR Content
  • Requires summary description of systems.
  • Reduced amount of info in SAR.

Based on the Use of

  • Analysis reqd by Pt 20 not included in SAR.
  • Compliance with regulations not Performance-Based
  • Monitoring program sufficient to demonstrate demonstrated in SAR.

Regulation. compliance with regs described in the SAR.

  • Post OL performance monitoring used to demonstrate compliance with requirements.
  • Must comply with Pt 20 reqts.

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ARCAP Approach - More Performance Based?

  • Recent precedent and associated expectations regarding scope and content may be excessive for this portion of the FSAR (traditionally Chapters 11 & 12). For instance, NUREG-0800 includes expectations for describing:
  • Quality assurance (QA) provisions for radioactive waste management structures, systems, and components (SSCs) in support of design criteria using the guidelines of RG 1.143 for liquids and liquid wastes produced during normal operation, including AOOs
  • Types and characteristics of filtration, ion-exchange resins, and adsorbent media to treat liquid process and effluent streams, including expected removal efficiencies, decontamination factors, holdup or decay times, and the applications of these characteristics in estimating releases by specific waste streams and treatment methods. The information describing the types of proposed filtration and adsorption media should include details from the applicant or suppliers, as generic or plant-specific information, in characterizing removal efficiencies, decontamination factors, and holdup or decay times.
  • Availability of standby equipment, alternate processing routes, and interconnections between permanently installed subsystems and skid-mounted processing equipment in order to evaluate the overall system capability to meet anticipated demands imposed by major processing equipment downtime and waste volume surges resulting from AOOs.

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ARCAP Approach - More Performance Based?(continued)

  • ARCAP provides an opportunity to re-think the level of detail required in the FSAR through the use of a more performance-based approach
  • What non-LMP topics traditionally found in the FSAR should be relocated from the FSAR to a separate (non-50.59 controlled) application document?

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Example of Approach Differences Regulatory Requirements

§ 50.34.a - Approach 1 (b) Each applicationshall include: FSAR Chapter 8 should include analysis (2) An estimate of: that demonstrates these requirements will be met.

(i) The quantity of each of the principal radionuclides expected to be released annually to unrestricted areas Approach 2 in liquid effluents produced during normal reactor FSAR Chapter 8 should include analysis operations; and that demonstrates these requirements will be met.

(ii) The quantity of each of the principal radionuclides of the gases, halides, and particulates expected to be released annually to unrestricted areas in gaseous Approach 3 effluents produced during normal reactor operations. FSAR does not need to include the

§ 20.1301 Dose limits for individual members of the analysis that demonstrates these public requirements will be met.

a) Each licensee shall conduct operations so that - However, the analysis must be performed (2) The dose in any unrestricted area from external at the time of application review and sources.does not exceed 0.002 rem (0.02 millisievert) available for NRC staff audit.

in any one hour .

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ARCAP Approach - More Performance Based?

Following up on April 22 meeting questions on ARCAP content:

  • Should ARCAP be structured to allow LMP concepts (i.e., performance-based approach) to be used in other non-LBE sections of the application that are not typically associated with the NEI 18-04 process?

- Should performance-based criteria for the licensing review inspection of Part 20 requirements be used vice a more prescriptive, detailed system design application content licensing review?

  • Routine release and ALARA requirements (contained in 10CFR20, App. B, and 10CFR50, App. I, respectively) are based on LWR technology. How should ARCAP address these performance-based requirements for non-LWR technology?

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Discussion of Significant Comments on the December 2019 ARCAP Outline 24 of 51

  • Many of the comments contained in the April 10, 2020, memo from Southern are likely addressed in the April 2020 annotated outline.
  • However, those comments of a broader nature are discussed below:

Comment #18 - Analytical Code V&V - dont need a separate discussion in Chap 1.

Discussion: Open for discussion. This section is intended to provide a summary of reference documents that support the validation of new analytical codes that were used to demonstrate the performance of new safety features that differ significantly from currently licensed plants. Could be addressed elsewhere.

Comment #21 - Conformance with RGs discussion not necessary.

Discussion: RGs describe methods that the NRC staff considers acceptable for implementing the general design criteria (GDC). Thus, applicants should provide an evaluation of conformance with applicable guidance. That evaluation should also include an identification and description of deviations from guidance in applicable RGs as well as suitable justifications for any alternative approaches proposed by the applicant.

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Comment #23 - Organization of LBE and DBA information still being worked on.

Discussion: Open for discussion. Followed NEI 18-04.

Comment #32 - Sections 4.3 & 4.4 - What level of detail is needed in describing SR and NSRST SSCs?

Discussion: Annotated outline provides clarification. Less design detail required for NSRST SSCs, but need to describe special treatment.

Comment #34 - Section 4.5 Non-Safety Related SSCs - SAR should not have to address these SSCs.

Discussion: Intent is to give the reviewer a complete understanding of the plant. Perhaps cover in Chapter 1.

Comment #39- Chapter 7 - Is a stand-alone section on DID necessary? Fold DID into Chapters 3 and 4.

Discussion: Outline follows NEI 18-04 which has a section on DID. DID process deserves a separate section due to the extensive discussion contained in 18-04.

Comment #43 - Chapter 9 - There is no need to address occupational dose in the SAR. SAR should be limited to public health and safety.

Discussion: SAR needs to show compliance with Part 20, which includes occupational dose.

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Comment #24 - Please explain what is intended by this stand-alone section for source term. Is this intended to cover both the calculation of radionuclide inventories and the transport of the radionuclides to the accessible environment during LBEs? Mechanistic would seem to imply that it is dependent on the phenomena of the event, but this appears to be a one size fits all section.

Discussion: Since the mechanistic source term is used as an underlying basis for the LBE analysis, it is important to discuss the basis and analysis methods used to develop the source term somewhere in the FSAR. The location of this information is open for discussion.

Comment #28 - It is not clear why there is a section for Aircraft Impacts - this is not called out as a special case under LMP. Inadvertent impacts would be addressed as part of the PRA. Is this intended to address 10 CFR 50.150? If so, it might best be addressed in another section.

Discussion: Open for discussion. The requirements in 50.150 need to be addressed in some way in the application.

Comment #42 - Capabilities for emergency plan protective actions - Such information would more appropriately be included in the Emergency Plan.

Discussion: This section of the DID discussion is intended to describe how EP has been factored into the DID evaluation. The details of the EP would be in the Emergency Plan itself.

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Comment #44- The need for Chapter 10 Human Factors Analysis is not clear. Treat as part of DID.

Discussion: Open for discussion. LMP will identify the important human actions. Human factors analysis is needed to ensure they are carried out with little chance of error. If this information is provided elsewhere in the FSAR (e.g., DID Chapter) then perhaps Chapter 10 may not be necessary.

Comment #45 - Physical Security should not be part of the SAR. Treat it separately.

Discussion: Open for discussion. Note the Physical Security Plan may not address how considerations for safety and security requirements together were addressed in the design process such that security issues (e.g., newly identified threats of terrorist attacks) can be effectively resolved through facility design and engineered security features, and formulation of mitigation measures, with reduced reliance on human actions.

Comment #47 - SAR should only include Administrative Control Programs with a connection to safety.

Discussion: Agree, but those required by regulation (e.g. Reliability Assurance Program) should also be included.

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Break 29 of 51

NRC Advanced Reactor Content of Application Project Questions from April 2020 Meeting 30 of 51

Format and Content Question on International Alignment (e.g., CNSC, IAEA)

  • Industry interest in pursuing alignment ?

I. Introduction II. General Plant Description III. Management of Safety IV. Site Evaluation V. General Design Aspects VI. Description of Plant Systems VII. Safety Analyses VIII. Commissioning IX. Operational Aspects X. Operational Limits and Conditions XI. Radiation Protection XII. Emergency Preparedness XIII. Environmental Aspects XIV. Radioactive Waste Management XV. Decommissioning and End of Life Aspects 31 of 51

Format and Content Questions for ARCAP Content

  • Is the general direction incorporated into the ARCAP outline consistent with the Technology Inclusive Content of Application Project (TICAP) direction?
  • Should ARCAP scope include construction permit guidance

- What should ARCAP include in this area?

- Does TICAP include a construction permit process?

  • Should ARCAP include guidance for microreactors?
  • Does the ARCAP draft annotated outline have an appropriate level of detail?
  • Are there other topics that should be included in the draft?
  • Are there items in the draft that are inconsistent with LMP?

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Format and Content Questions for ARCAP Content

  • Should the outline be updated to allow LMP concepts to be used in other sections of the outline that are not typically associated with the process? (e.g., risk inform quality assurance program, radioactive waste management).

- Should performance-based criteria for inspection of Part 20 requirements be used vice a licensing review?

  • Routine release and ALARA requirements (contained in 10CFR20, App.

B, and 10CFR50, App. I, respectively) are based on LWR technology.

How should ARCAP address these performance-based requirements for non-LWR technology?

  • What non-LMP topics traditionally found in the FSAR should be relocated from the FSAR to a separate (non-50.59 controlled) application document?

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Format and Content Questions on Alignment for Technical Specifications (10 CFR 50.36)

Construct of Technical Specifications Safety Limits, Limiting Safety System Settings Limiting Conditions of Operation (LCOs), Surveillance Requirements Associated 4 Criteria LCOs represent the lowest functional capability or performance levels of equipment required for safe operation Design Features, Administrative Controls Use exemptions or guidance?

Replace or define Significant Safety Function language in 50.36?

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Format and Content Questions on Alignment for Technical Specifications (10 CFR 50.36) o Scope of Technical Specifications (TS)

  • Should LCOs address only requirements for safety-related structures, systems and components (SSCs) or also address non-safety-related with special treatment?
  • Relationship between TS, safety classification, and requirements associated with adequate protection and safety enhancements?
  • Which events should LCOs address? [All, or a subset of licensing basis events (e.g., Design Basis Accidents)]?
  • Role of administrative controls in maintaining configurations and reliability of SSCs consistent with licensing basis events and frequency-consequence targets 35 of 51

Industry Perspective on ARCAP Marc Nichol Senior Director, New Reactors June 12, 2020 36 of 51

©2020 Nuclear Energy Institute

Starting with the big picture Deployment timelines

  • First commercial reactors operating before 2030, possibly by 2026
  • DOE demonstrations 2025 to 2027
  • Suggests numerous license applications in 2021/2022 Regulatory priorities - NEI presentation to Commission on 2/6/20
1. Construction and licensing decisions
2. Advanced reactor policy decisions
3. Streamlining processes 37 of 51

©2020 Nuclear Energy Institute 2

Need to streamline reviews Recommendations for Enhancing the Safety Focus of New Reactor Regulatory Reviews, NEI White Paper, 2018 (ML18116A053, ML18116A052)

  • NRC regulating beyond reasonable assurance of adequate protection
  • NRC requesting information and detail beyond that needed for safety decisions Activities that can lead to streamlined reviews
1. Clarify the safety decision that NRC makes for a given section, and why/how requested information is used to make the decision
2. Clarify what historically provided information, is not necessary for NRC to make safety decisions RG 1.233: Guidance on specific technical areas (e.g., NUREG-0800) addresses scope and level of detail for applications ©2020 Nuclear Energy Institute 3 38 of 51

Relationship to Part 53 Part 53 should begin by establishing the requirements

  • Starting with the Atomic Energy Act
  • Clean page approach to achieve technology-inclusive, risk-informed
  • Adapted Part 50/52 requirements relevant where Important to stability (e.g., safety goals, backfit protection)

Opportunity for a modern approach (E.g., quality assurance, radiation protection, design criteria)

Technical guidance follows requirements

  • What is established for Part 50/52 may have minimal applicability Content of applications (e.g., RG 1.206 equivalent) is last step 39 of 51

©2020 Nuclear Energy Institute 4

Feedback on Updated Outline - 4/15/20 Non-LMP/TICAP Scope No influence on the scope and level of detail in applications

  • References the need to meet guidance in NUREG-0800
  • Requests same level of detail as RG 1.206
  • Application content guidance by nature focuses on format Increases uncertainty, relative to RG 1.206
  • Removes requirements and criteria for acceptance
  • Specifies information to provide without insight into what the NRC would find acceptable
  • Not applicable to Part 50 applications Not technology-inclusive (limited to non-LWRs using LMP)
  • Some near-term applications expected to be LWR SMRs and/or use non-LMP approaches 40 of 51 ©2020 Nuclear Energy Institute 5

Feedback on Updated Outline - 4/15/20 LMP/TICAP Scope LMP topics

  • No additional technical guidance
  • Guidance on format provides little value to applicants TICAP topics
  • Unnecessary to duplicate activities of TICAP team Recommended NRC role in TICAP
  • Near-term: engage with TICAP team and provide feedback
  • Long-term: NRC endorsement of TICAP process 41 of 51

©2020 Nuclear Energy Institute 6

Feedback on Supplement Info. 5/28/2020 Preliminary Impressions Option 1 - not worth pursuing - little benefit to application scope and level of detail Option 2 - possible benefits, but minimal compared to Option 3 Option 3 - a risk-informed approach that

  • Could result in application scope and detail appropriate to the safety decision
  • Is technology-inclusive - applicable beyond non-LWRs using LMP
  • Need clarification on description of systems - should be limited to what is needed to demonstrate safety
  • Need clarification on the use of monitoring programs to demonstrate compliance 42 of 51

©2020 Nuclear Energy Institute 7

Additional feedback NRC collaboration with TICAP, culminating in the final product, is needed in order for the NRC to be able to align ARCAP.

NRCs efforts to risk-inform the scope and content of applications should include Part 50 and Part 52 applications. It should encompass all types of advanced reactors (e.g., micro-reactors, LWR SMRs, non-LWRs)

Use of Regulatory Guidance is voluntary and there is no need for applicants to explain why they do not use a particular RG.

The application scope and level of detail should only cover what is needed for the NRC to make a safety decision. Non-safety systems do not need to be included only for information/familiarization purposes.

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©2020 Nuclear Energy Institute 8

Recommendations

1. Focus on streamlining reviews and achieving appropriate scope and level of detail in applications to support near term applications
  • Must be technology-inclusive (more than just non-LWRs using LMP)
  • Clarify the safety decision that NRC will make for a given topic, and why/how requested information is used to make the decision
  • Clarify what historically provided information, is not necessary for NRC to make safety decisions Option 3 for radioactive material control headed in right direction
  • Work with industry to prioritize technical areas
  • Implement through ISGs (similar to environmental considerations)
2. Engage with TICAP and prepare for review and endorsement
3. Part 53 should begin by establishing the requirements
1. Consider potential applicability of risk-informed concepts developed in near-term 44 of 51 2. Near-term guidance not likely to align with Part 53 requirements©2020 Nuclear Energy Institute 9

U.S. Nuclear Industry Council Comments on Advanced Reactors Content of Applications (ARCAP)

Nuclear Regulatory Commission Meeting Jeffrey S. Merrifield Chairman, Advanced Reactor Task Force U.S. Nuclear Industry Council 12 June 2020 45 of 51

U.S. Nuclear Industry Council (USNIC) feedback on NRC licensing issue NRC needs a feasible method to streamline and modernize the licensing of Advanced Reactor designs before 2027

  • Recognize there already is a license application submitted to the NRC and there will be multiple license applications in 2021-22
  • Process necessitates prompt identification of policy issues to expedite Commission decision-making
  • Licensing process for Advanced Reactors should be risk informed, allow the agency to meet its safety goals and provide clear guidance for applicants
  • An explicit goal should be reduction of unnecessary burden particularly in areas where there is no nexus to safety 1 l U.S. Nuclear Industry Council Comments on Advanced Reactors Content of Applications (ARCAP) 46 of 51

U.S. Nuclear Industry Council (USNIC) feedback on ARCAP approach

  • NRC needs a clear vision for how ARCAP fits within TICAP and a risk-informed regulatory framework
  • ARCAP resources should not take away from Part 53 development
  • Part 53 needs to go beyond the LMP/TICAP/ARCAP effort to achieve the transformational goals expected by Congress and AR developers
  • Part 53 needs to be built with a framework focusing on high level safety requirements
  • ARCAP should include all advanced reactor types including micro-reactors and small light water reactors 2 l U.S. Nuclear Industry Council Comments on Advanced Reactors Content of Applications (ARCAP) 47 of 51

U.S. Nuclear Industry Council (USNIC) feedback on ARCAP approach

  • ARCAP needs to be sufficiently transformative and must include a forward-leaning perspective to support Advanced Reactor developers (non-LWRs, microreactors, and LWR SMRs) using Parts 50 and 52
  • Needs to provide a clear benefit to near and long term applicants
  • Process should not merely be a distillation of existing guidance, but should be strategic and creative (and only require analysis needed for safety case)
  • Should consider other performance-based requirements, beyond the Chapter 8 example, to accomplish this goal 3 l U.S. Nuclear Industry Council Comments on Advanced Reactors Content of Applications (ARCAP) 48 of 51

U.S. Nuclear Industry Council (USNIC) feedback on ARCAP approach

  • For ARCAP, NRC staff should consider other areas that could apply Approach 3 (e.g., EPZ, Security and Siting)
  • The use of Approach 3 could also support Part 53 development (e.g., design criteria, quality assurance and rad protection)
  • ARCAP could provide input for transformative change to Part 53 by identifying areas for reduced focus or elimination in a risk-informed review
  • Some developers are concerned about how they will meet the NRCs expectations for an application using ARCAP without specific guidance o Need to have clear acceptance criteria to help developers understand the scope and depth of an application 4 l U.S. Nuclear Industry Council Comments on Advanced Reactors Content of Applications (ARCAP) 49 of 51

U.S. Nuclear Industry Council (USNIC) feedback on NRC questions from 4/22 meeting- ARCAP Content Is the general direction incorporated into the ARCAP outline consistent with the Technology Inclusive Content of Application Project (TICAP) direction?

  • USNIC believes the approach should be flexible to utilize for near-term LWR SMRs Should ARCAP scope include construction permit guidance?
  • USNIC believes the approach should include construction permit guidance Should ARCAP include guidance for microreactors?
  • USNIC believes the approach should include guidance for microreactors Does the ARCAP draft annotated outline have an appropriate level of detail?
  • USNIC believes the outline needs additional work to be useful o Currently, the outline increases uncertainty because it is unclear what NRC would find acceptable o Focused workshops on topic-specific criteria would be helpful o End product should not be conventional guidance but a collaborative template for near term use given the application timelines 5 l U.S. Nuclear Industry Council Comments on Advanced Reactors Content of Applications (ARCAP) 50 of 51

U.S. Nuclear Industry Council For questions/comments contact Jerey S. Merri"eld Cyril W. Draffin, Jr.

Chairman, US Nuclear Industry Council Senior Fellow, Advanced Nuclear, Advanced Reactors Task Force U.S. Nuclear Industry Council U.S. NRC Commissioner (1998-2007) Cyril.Draffin@usnic.org Je.Merri"eld@pillsburylaw.com 6 l U.S. Nuclear Industry Council Comments on Advanced Reactors Content of Applications (ARCAP) 51 of 51

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