ML20231A563
| ML20231A563 | |
| Person / Time | |
|---|---|
| Issue date: | 08/17/2020 |
| From: | John Segala NRC/NRR/DANU |
| To: | Austgen K, Nichol M Nuclear Energy Institute |
| References | |
| Download: ML20231A563 (8) | |
Text
From: Segala, John Sent: Monday, August 17, 2020 3:31 PM To: NICHOL, Marcus; AUSTGEN, Kati Cc: Sebrosky, Joseph
Subject:
Proposal for ARCAP Guidance Document Hi Marc and Kati, The purpose of this email is to provide you with a proposal for an ARCAP guidance document.
This proposal is an outcome of the July 31, 2020, ARCAP meeting. We would like to discuss the proposal with you during our normal biweekly call tomorrow to support possible discussions during the August 27, 2020, TICAP/ACRAP/CP meeting.
I look forward to our discussions tomorrow.
Thanks, John Proposal As a result of feedback from the July 31, 2020, meeting, the ARCAP team met and developed a roadmap document describing that ARCAP will provide high-level guidance that will provide pointers to advanced reactor guidance that is under development (e.g., TICAP, security and emergency planning rulemaking) and provide guidance for areas that are not being addressed under an advanced reactor activity. There is a very limited set of new guidance that will be developed as part of ARCAP. ARCAP new guidance will be developed such that it is technology inclusive, to the maximum extent possible, so a light water or non-light water reactor applicant can use the guidance if they so desire. A subset of the ARCAP guidance will address construction permit guidance and will be developed in parallel with industrys effort to develop TICAP construction permit guidance. A fundamental assumption is that it has never been the intention of ARCAP to develop an approach similar to the guidance found in the standard review plan (NUREG-0800) for large light water reactors or the guidance found in thousands of regulatory documents (e.g., regulatory guides, NUREGs, etc..) that have been developed over the last 50 plus years for large light-water reactors. The proposed structure of the ARCAP guidance document would be in the form of a roadmap that would list various parts of an application and point to where guidance is being developed outside of ARCAP (e.g.,
TICAP, emergency planning and security rulemaking) and would contain appendices for portions of the application for which ARCAP is providing standalone guidance. The Table below provides a listing of the portions of the application (using the INL-developed annotated structure available at ADAMS Accession No. ML20107J565) and how the ARCAP would address the guidance. Please note that the ARCAP annotated outline and the industry TICAP annotated outline described during the July 30, 2020, TICAP meeting have not yet been consolidated so the chapter names are subject to change. The Table is color coded showing where ARCAP would simply point to guidance outside of ARCAP, where new stand-alone guidance is being developed, and where a combination of new ARCAP guidance and pointers to guidance outside of ARCAP is being considered for development. As shown in the Table there is a very limited set of new ARCAP guidance that is being considered for development.
Preliminary ARCAP Roadmap
Legend: - - ARCAP points to guidance that is being developed as part of another advanced reactor activity (e.g., TICAP)
- New ARCAP guidance being developed
- Combination of new ARCAP guidance and pointers to guidance that is being developed as part of another advanced reactor activity (e.g.,
TICAP, rulemaking etc.)
Item # Description ARCAP Disposition Comment 1 FSAR Chapter 1 - Combination of TICAP INL developed annotated outline suggests that major portions of General Information and ARCAP-developed chapter 1 would come from TICAP and would layout the safety case guidance for the design 2 FSAR Chapter 2 - Site Combination of TICAP Portions of this chapter expected to come from TICAP (see TICAP Information and ARCAP - developed chapter 8, External Hazards Assessment, from proposed outline guidance found in July 30, 2020 meeting handouts available at:
https://www.nrc.gov/docs/ML2021/ML20210M083.pdf). In addition, ARCAP will consider Commission guidance associated with SECY-20-0045, Population Related Siting Considerations for Advanced Reactors, as part of the Chapter 2 guidance development.
3 FSAR Chapter 3 - ARCAP points to TICAP License Basis Event Analysis 4 FSAR Chapter 4 - ARCAP points to TICAP https://www.nrc.gov/docs/ML2021/ML20210M083.pdf Integrated Plant Analysis 5 FSAR Chapter 5 - ARCAP points to TICAP Description and Classification of SSCs 6 FSAR Chapter 6 - ARCAP points to TICAP Design Basis Accident Analysis 7 FSAR Chapter 7 - ARCAP points to TICAP
Defense in Depth 8 FSAR Chapter 8 - ARCAP - developed ARCAP team developed draft guidance that discusses a Control of Routine guidance performance based approach. The draft guidance has been well Plant Radioactive received by stakeholders in public meetings. Team is furthering Effluents and Solid refining the approach Waste 9 FSAR Chapter 9 - ARCAP - developed ARCAP team to develop draft guidance based on FSAR chapter 8 Control of Occupational guidance Dose 10 FSAR Chapter 10 - ARCAP points to TICAP Human Factors Analysis 11 FSAR Chapter 11 - ARCAP to point to See physical security plan below Physical Security physical security rulemaking guidance and other existing physical security guidance 12 FSAR Chapter 12 - ARCAP points to TICAP Overview of PRA 13 FSAR Chapter 13 - ARCAP points to TICAP Administrative Control Programs 14 FSAR Chapter 14 - Combination of TICAP Unclear at this point how much TICAP guidance will be provided in Initial Startup Programs and ARCAP-developed this area guidance 15 Technical Specification Combination of TICAP TICAP will have a major impact on technical specifications. NRC and ARCAP-developed and INL have identified the need for TICAP to consider tech spec guidance development as part of TICAP. Unclear at this point how much TICAP guidance will be provided in this area 16 Technical Combination of TICAP Existing guidance in this area needs to be adjusted to reflect LMP Requirements Manual and ARCAP-developed terminology guidance 17 Quality Assurance Plan Combination of TICAP TICAP outcomes expected to heavily influence quality assurance (design) and possibly ARCAP- plan for the design. Appendix B expected to apply to safety-related developed guidance SSCs. Unclear at this point how TICAP will address QA for Non-safety related special treatment SSCs 18 Fire Protection Combination of TICAP Results of TICAP developed affirmative safety case expected to Program (design) and possibly ARCAP- influence fire protection program developed guidance 19 PRA Mostly TICAP. ARCAP See FSAR Chapter 12 and Non-LWR PRA review standard that is will point to Non-LWR under development PRA review standard that is under development 20 Quality Assurance Plan Combination of TICAP Similar to item 17 above (Construction and and possibly ARCAP-Operations) developed guidance 21 Emergency Plan ARCAP point to EP EP rulemaking expected to develop guidance in this area rulemaking 22 Physical Security Plan ARCAP point to physical Physical security rulemaking expected to develop guidance in this security rulemaking area 23 SNM physical ARCAP point to existing protection plan guidance 24 SNM material control ARCAP will point to MC&A is an issue that has identified as needing to have guidance and accounting plan guidance that is expected developed for some of the non-lwrs. A pebble-bed MC&A to be developed application standard and review standard has been developed by ORNL. MC&A for liquid fueled molten salt reactors will be a particular challenge 25 Fire Protection Combination of TICAP See item 18 above Program (Operational) and possibly ARCAP-developed guidance 26 Radiation Protection ARCAP - developed Relates to FSAR chapter 8 above Program guidance 27 Offsite Dose ARCAP - developed Relates to FSAR chapter 8 above Calculation Manual guidance 28 Inservice Combination of TICAP TICAP outcomes expected to heavily influence ISI/IST. In addition Inspection/Inservice and ARCAP guidance ASME Section XI Section 2 guidance identified as needing to be testing (ISI/IST) developed 29 Environmental Report ARCAP pointer Point to environmental guidance that is being developed and Site Redress Plan 30 Financial Qualification ARCAP pointer SECY paper under development to address issues and Insurance and Liability 31 Cyber Security Plan Combination of TICAP Unclear at this point how much TICAP guidance will be provided in
and ARCAP guidance Hearing Identifier: NRR_DRMA Email Number: 730 Mail Envelope Properties (MN2PR09MB53074738F7F2C7D026E96A4EE55F0)
Subject:
Proposal for ARCAP Guidance Document Sent Date: 8/17/2020 3:30:43 PM Received Date: 8/17/2020 3:30:45 PM From: Segala, John Created By: John.Segala@nrc.gov Recipients:
"Sebrosky, Joseph" <Joseph.Sebrosky@nrc.gov>
Tracking Status: None "NICHOL, Marcus" <mrn@nei.org>
Tracking Status: None "AUSTGEN, Kati" <kra@nei.org>
Tracking Status: None Post Office: MN2PR09MB5307.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 8765 8/17/2020 3:30:45 PM image004.png 526 image005.png 526 image006.png 526 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: