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 -
General Information Combination of TICAP and ARCAP-developed guidance INL developed annotated outline suggests that major portions of chapter 1 would come from TICAP and would layout the safety case for the design 2
FSAR Chapter 2 - Site Information Combination of TICAP and ARCAP - developed guidance Portions of this chapter expected to come from TICAP (see TICAP chapter 8, External Hazards Assessment, from proposed outline 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 -
License Basis Event Analysis ARCAP points to TICAP 4
FSAR Chapter 4 -
Integrated Plant Analysis ARCAP points to TICAP https://www.nrc.gov/docs/ML2021/ML20210M083.pdf 5
FSAR Chapter 5 -
Description and Classification of SSCs ARCAP points to TICAP 6
FSAR Chapter 6 -
Design Basis Accident Analysis ARCAP points to TICAP 7
FSAR Chapter 7 -
ARCAP points to TICAP
Defense in Depth 8
FSAR Chapter 8 -
Control of Routine Plant Radioactive Effluents and Solid Waste ARCAP - developed guidance ARCAP team developed draft guidance that discusses a performance based approach. The draft guidance has been well received by stakeholders in public meetings. Team is furthering refining the approach 9
FSAR Chapter 9 -
Control of Occupational Dose ARCAP - developed guidance ARCAP team to develop draft guidance based on FSAR chapter 8 10 FSAR Chapter 10 -
Human Factors Analysis ARCAP points to TICAP 11 FSAR Chapter 11 -
Physical Security ARCAP to point to physical security rulemaking guidance and other existing physical security guidance See physical security plan below 12 FSAR Chapter 12 -
Overview of PRA ARCAP points to TICAP 13 FSAR Chapter 13 -
Administrative Control Programs ARCAP points to TICAP 14 FSAR Chapter 14 -
Initial Startup Programs Combination of TICAP and ARCAP-developed guidance Unclear at this point how much TICAP guidance will be provided in this area 15 Technical Specification Combination of TICAP and ARCAP-developed guidance TICAP will have a major impact on technical specifications. NRC and INL have identified the need for TICAP to consider tech spec development as part of TICAP. Unclear at this point how much TICAP guidance will be provided in this area 16 Technical Requirements Manual Combination of TICAP and ARCAP-developed guidance Existing guidance in this area needs to be adjusted to reflect LMP terminology 17 Quality Assurance Plan (design)
Combination of TICAP and possibly ARCAP-developed guidance TICAP outcomes expected to heavily influence quality assurance plan for the design. Appendix B expected to apply to safety-related SSCs. Unclear at this point how TICAP will address QA for Non-safety related special treatment SSCs 18 Fire Protection Program (design)
Combination of TICAP and possibly ARCAP-developed guidance Results of TICAP developed affirmative safety case expected to influence fire protection program 19 PRA Mostly TICAP. ARCAP will point to Non-LWR PRA review standard that is under development See FSAR Chapter 12 and Non-LWR PRA review standard that is under development 20 Quality Assurance Plan (Construction and Operations)
Combination of TICAP and possibly ARCAP-developed guidance Similar to item 17 above 21 Emergency Plan ARCAP point to EP rulemaking EP rulemaking expected to develop guidance in this area 22 Physical Security Plan ARCAP point to physical security rulemaking Physical security rulemaking expected to develop guidance in this area 23 SNM physical protection plan ARCAP point to existing guidance 24 SNM material control and accounting plan ARCAP will point to guidance that is expected to be developed MC&A is an issue that has identified as needing to have guidance developed for some of the non-lwrs. A pebble-bed MC&A 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 Program (Operational)
Combination of TICAP and possibly ARCAP-developed guidance See item 18 above 26 Radiation Protection Program ARCAP - developed guidance Relates to FSAR chapter 8 above 27 Offsite Dose Calculation Manual ARCAP - developed guidance Relates to FSAR chapter 8 above 28 Inservice Inspection/Inservice testing (ISI/IST)
Combination of TICAP and ARCAP guidance TICAP outcomes expected to heavily influence ISI/IST. In addition ASME Section XI Section 2 guidance identified as needing to be developed 29 Environmental Report and Site Redress Plan ARCAP pointer Point to environmental guidance that is being developed 30 Financial Qualification and Insurance and Liability ARCAP pointer SECY paper under development to address issues 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:
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