ML20233A822
| ML20233A822 | |
| Person / Time | |
|---|---|
| Issue date: | 08/27/2020 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | |
| Sebrosky J | |
| References | |
| Download: ML20233A822 (27) | |
Text
Technology Inclusive Content of Application Project, Advanced Reactor Content of Application Project, and Construction Permit Guidance Public Meeting August 27, 2020 Telephone Bridgeline: 877-779-7419 Passcode: 9782874
Agenda Time Topic Presenter 10: -10:10 am Introduction NRC 10:10 - 10:40 amUpdates on industry-led Technology Inclusive Content of Application Project (TICAP) efforts including status of fundamental safety function mapping, status of table top exercises Southern 10:40 - 11:20 am Discussion of the concept (including examples) of Principle Design Criteria, and Complementary Design Criteria Southern 11:20 - 11:45 am TICAP next steps Southern 11:45 - 12:00 pm Feedback on fundamental safety function mapping and other areas NRC 12:00 - 12:30 pm Stakeholder questions All 12:30 - 1:30 pm Break All 1:30 -1: 50 pm Updates on Construction Permit Guidance for light water small modular reactors NRC 1:50 - 2:20 pm Industry and other Stakeholder feedback Industry, All 2:20 - 3:00 pm Discussion of Advanced Reactor Content of Application Project Including Additional Thoughts on Use of Performance-Based Approach NRC/Idaho National Lab 3:00 - 3:25pm Industry and Other stakeholder feedback All 3:25-3:30 pm Next Steps and Concluding Remarks All 2
Light-Water Small Modular Reactor Construction Permit Review Guidance August 27, 2020 3
Light-Water SMR Construction Permit Guidance During the July 31 ARCAP meeting, the staff received the following feedback:
The staffs guidance options (Interim Staff Guidance (ISG), Draft Strategy, and Office Instruction) are viable options that need further industry consideration.
Of the three options, the ISG would likely be the most efficient and provide regulatory stability and durability.
Challenges to developing guidance recognized:
- It may take 6-9 months to receive specific industry input needed in the guidance because of on-going activities for the DOE program.
- The first CP applications could be submitted by the end of 2021/early 2022. Draft guidance with application content or critical areas for a CP application by Spring 2021 could support this schedule.
Prospective applicants have been encouraged to contact the NRC regarding the application process and the applicants schedule.
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Light-Water SMR Construction Permit Guidance (continued)
Specific public feedback:
- Based on a review of Regulatory Guide (RG) 1.70 and the Standard Review Plan (SRP):
- Clarity needed on Preliminary Safety Analysis Report (PSAR) content vs Final Safety Analysis Report (FSAR) content.
- Alignment needed regarding what specific level of detail is required for preliminary.
- Alignment needed on the applicability of specific [regulatory] requirements
[and staff guidance] identified in the SRP to advanced reactor design features.
- A more efficient approach may be the following:
- Developing a set of Regulatory Framework Documents as an integral part of the [applicants] Regulatory Engagement Plan.
- Using the Regulatory Engagement Plan to support early and often NRC preapplication engagement to gain alignment.
- Obtaining feedback from NRC management in writing that the applicant and NRC can refer to during the review.
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Light-Water SMR Construction Permit Guidance (continued)
The staff is considering developing the ISG to clarify the following:
Regulatory requirements and findings for issuing a CP.
Information needed and level of detail in an application to review and issue the CP.
Specific topics; e.g., siting.
The staff is interested in hearing feedback on:
The draft ISG details above.
Additional topics to consider.
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Light-Water SMR Construction Permit Guidance (continued)
Next Steps:
- The staff plans to present additional initial considerations for the ISG during the monthly ARCAP meetings and is interested in hearing feedback on the considerations.
- The staff would like more information to better understand the guidance needs of prospective applicants.
- The staff encourages early engagement to better prepare and plan for a CP review.
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Proposal for Advanced Reactor Content of Application Project (ARCAP) Guidance Document 8
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Background===
9 ARCAP Proposed Guidance document would provide a roadmap for developing an application Roadmap would leverage existing guidance or guidance that is under development Examples include:
Technology Inclusive Content of Application Project (TICAP) developing portions of the application associated with the Licensing Modernization Project (LMP)
Emergency planning and security rulemaking will provide insights to this portion of the application Never the intention of the ARCAP guidance document to attempt to replicate the Standard Review Plan for Light Water Reactors (NUREG-0800)
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Background===
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- Figure provides an overview of some of the more important efforts underway to develop advanced reactor guidance
- TICAP will use the LMP (upper left of figure) to develop portions of the application
Proposal for ARCAP Guidance Document High level ARCAP proposal found in document referenced in meeting notice (ADAMS Accession No. ML20231A563)
Proposed guidance includes table providing roadmap Table based on Idaho National Laboratory (INL) developed annotated structure for final safety analysis report (FSAR) portion of the application INL developed outline discussed in previous ARCAP meetings and can be found at ADAMS Accession No. ML20107J565 Recognized that the TICAP FSAR proposed structure is different than INL-developed structure Table will be updated based on final version of TICAP structure 11
Proposal for ARCAP Guidance Document High level ARCAP proposal found in document referenced in meeting notice (ADAMS Accession No. ML20231A563) (continued) o First 14 items in table associated with FSAR, the rest of the items in the table associated with other portions of the application o
Table color coded to note where proposed guidance would :
point to guidance that is being developed as part of another advanced reactor activity (e.g., TICAP)
Note where new ARCAP guidance is being developed Note where a combination of new ARCAP guidance is being developed and provide pointers to guidance that is being developed as part of another advanced reactor activity (e.g., TICAP, rulemaking etc.)
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Proposal for ARCAP Guidance Document 13
Proposal for ARCAP Guidance Document 14
Proposal for ARCAP Guidance Document 15
ARCAP Chapters Under Consideration for a Performance-Based (PB) Approach (i.e., Approach 3) 16
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Background===
In the July 31, 2020 ARCAP meeting, NRC provided additional details on a potential PB approach (Approach 3) for ARCAP Chapter 8, Control of Routine Plant Radioactive Effluents and Solid Waste. At the same meeting, industry suggested siting, EP and security as candidates for a PB approach.
At the present time, the following ARCAP chapters are under consideration for a more PB approach:
- Chapter 2, Site Information
- Chapter 8, Section 8.3, Solid Waste
- Chapter 9, Control of Occupational Dose Since there are rulemaking activities underway for EP and security that may incorporate PB approaches, work on these topics will be dependent upon the outcome of the rulemakings.
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ARCAP Chapter 2, Site Information 10 CFR 100, Subpart B, requires that site characteristics be determined in order to establish (1) the external hazards (man-made and natural) the plant must be designed for, (2) the hydrological radionuclide transport properties, (3) if the site poses a significant impediment to EP and (4) that the individual and societal risk of potential accidents is low.
Much of the above information is contained in Chapter 2 of the SAR, with the result that the chapter becomes very large. For example, the SARs contain information on historical records of the site (such as floods, temperatures, seismic events, etc.) as well as the results of recent site characterization work (e.g. meteorology, core samples).
It is recognized that TICAP Chapter 1 will address siting, however, until TICAP Chapter 1 is provided, weve considered work on ARCAP Chapter 2 to identify areas where the amount of information that is required to be in the SAR might be reduced.
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ARCAP Chapter 2 - Changes Being Considered What is being considered is using the guidelines in NEI 98-03 Guidelines for Updating FSARs (endorsed by RG 1.181), developed to identify areas where information can be removed from FSARs, as the starting point for determining if it was needed in the first place. Examples include:
Historical information (floods, storms, etc.)
Information not expected to change with time (geological data, seismic data, etc.)
Redundant information Excessive detail The intent is to limit the amount of material in SAR Chapter 2 to that which is necessary for establishing safety significant design parameters and performing the safety analysis, along with its supporting bases.
If necessary, any additional supporting information (e. g. historical records, geological data) could be documented in a separate report available for audit.
Note: Site population density considerations are dependent on Commission action on SECY-20-045, Population-Related Siting Considerations for Advanced Reactors and are not included in the ARCAP Chapter 2 work at this time.
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ARCAP Section 8.3 and Chapter 9
- Overview
- Continue to develop performance-based guidance for additional non-TICAP safety analysis report chapters
- Section 8.3, Solid Waste
- Chapter 9, Control of Occupational Dose
- Related to the two performance-based content areas above, address continued applicability of NEI developed FSAR content templates:
- NEI 07-10A, Generic FSAR Template Guidance for Process Control Program (PCP)
- NEI 07-08A, Generic FSAR Template Guidance for Ensuring that Occupational Radiation Exposures are as Low as is Reasonably Achievable (ALARA) 20
Develop using same approach as Sections 8.1 and 8.2 Reference applicable requirements for performance-based criteria, such as:
10 CFR 20.1301(a) regarding the allowable annual dose and allowable hourly dose to members of the public from routine operation 10 CFR 20.1301(e) regarding compliance with EPA's generally applicable environmental radiation standards in 40 CFR part 190 10 CFR Part 61 as it relates to requirements for classifying, processing, and disposing of dry solid and wet wastes 10 CFR 20.2006 and Appendix G to 10 CFR Part 20, as they relate to the requirements for transferring and manifesting radioactive materials shipments to authorized facilities (e.g., disposal sites, waste processors) 10 CFR 20.2007, as it relates to compliance with other applicable Federal, State, and local regulations governing any other toxic or hazardous properties of radioactive wastes, such as mixed wastes 10 CFR Part 71 and 49 CFR Parts 171-180, as they relate to the use of approved containers and packaging methods for the shipment of radioactive materials 49 CFR 173.443, as it relates to methods and procedures used to monitor for the presence of removable contamination on shipping containers, and 49 CFR 173.441, as it relates to methods and procedures used to monitor external radiation levels for shipping containers and vehicles ARCAP Section 8.3, Solid Waste 21
- Develop Acceptance Criteria - System Design, such as:
Provide a high-level description of the solid waste management system (SWMS)
Describe expected sources of waste Describe equipment design capacities for expected waste volumes and radioactivity inventories of Class A, B and C waste Describe design provisions to control and collect any solid waste spillage from equipment malfunction or puncture of waste containers ARCAP Section 8.3, Solid Waste (cont.)
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- Develop Acceptance Criteria - Operational Controls, such as:
Provide a description of operational controls for waste processing and surveillance requirements which assure that:
Allowable doses to members of the public remain within required levels The final waste product meets the requirements of applicable Federal, State and disposal site waste form requirements for burial at a 10 CFR 61 licensed Low-Level Waste (LLW) disposal site As an option, applicant may refer to NEI 07-10A, Generic FSAR Template Guidance for Process Control Program (PCP)
If an applicant chooses to reference this template to address the above acceptance criteria no need to replicate text in the FSAR; may need to update/revise template to reflect operation of specific non-LWR ARCAP Section 8.3, Solid Waste (cont.)
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Develop using same approach as Chapter 8 Address applicability to:
Part 50 operating license and construction permit applications Part 52 design certification and combined license applications Non-LWRs and small modular LWRs Reference applicable requirements for performance-based criteria, such as:
- 10 CFR 19.12, as it relates to keeping workers informed who receive occupational radiation exposure (ORE)
- 10 CFR 20, Subpart C, Occupational Dose Limits (20.1201 -
20.1208)
- 10 CFR 20.1101 and the definition of ALARA in 10 CFR 20.1003, as they relate to those measures that ensure that radiation exposures resulting from licensed activities are below specified limits and ALARA ARCAP Chapter 9, Control of Occupational Dose 24
Develop Acceptance Criteria - System Design, such as:
Describe important equipment and facility design features used to ensure that occupational radiation exposures are ALARA such as, shielding, ventilation, area radiation and airborne radioactivity monitoring instrumentation and dose assessment Describe the design features provided to control access to radiologically restricted areas (including potentially very high radiation areas) and describe each very high radiation area and indicate physical access controls and radiation monitor locations for each of these areas Describe those features that reduce the need for maintenance and other operations in radiation fields, reduce radiation sources in areas where operations may be performed, allow quick entry and easy access, provide remote operation capability, or reduce the time spent working in radiation fields, as well as any other features that reduce radiation exposure of personnel Describe methods for reducing the production, distribution, and retention of activation products through design, material selection, water chemistry, decontamination procedures, and so forth ARCAP Chapter 9, Control of Occupational Dose (cont.)
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Develop Acceptance Criteria - Operational Controls, such as:
Provide commitments to develop comprehensive worker protection programs, organizational structure, training and monitoring to ensure 10 CFR 19 and 10 CFR 20 requirements are met. Include commitments to any relevant regulatory guides, NEI templates, or standards As an option, applicant may refer to NEI 07-08A, Generic FSAR Template Guidance for Ensuring that Occupational Radiation Exposures are as Low as is Reasonably Achievable (ALARA)
If an applicant chooses to reference this template to address the above acceptance criteria no need to replicate text in the FSAR; may need to update/revise template to reflect operation of specific non-LWR These criteria for operational controls could also be addressed in the Radiation Protection Program with a reference in the FSAR ARCAP Chapter 9, Control of Occupational Dose (cont.)
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2020 Tentative Schedule for Technology Inclusive Content of Application Project Public Meetings September 24 October 22 November 19 Future Meetings 27