ML20233A990
| ML20233A990 | |
| Person / Time | |
|---|---|
| Issue date: | 08/21/2020 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | John Segala NRC/NRR/DANU/UARP |
| Sebrosky J,NRR/DANU/UARP,2405000614 | |
| References | |
| Download: ML20233A990 (7) | |
Text
J. Segala 1 August 21, 2020 MEMORANDUM TO: John P. Segala, Chief Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM: Joseph M. Sebrosky, Senior Project Manager /RA/
Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF JULY 31, 2020, PUBLIC MEETING TO DISCUSS ADVANCED REACTOR CONTENT OF APPLICATION PROJECT AND CONSTRUCTION PERMIT GUIDANCE On July 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a Category 2 public meeting with stakeholders, to discuss the advanced reactor content of application project (ARCAP) and construction permit (CP) guidance. The meeting notice is available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML20212L518 and the presentation slides are available at ADAMS Accession No. ML20212L398. This was a teleconference meeting, and an attempt was made to capture a list of the attendees as they called into the meeting. Enclosure 1 provides the attendees for the meeting as captured by the operator that helped to facilitate the meeting.
Meeting Highlights Construction Permit Guidance During a June 12, 2020, public meeting (see meeting summary dated July 15, 2020, at ADAMS Accession No. ML20195B104) both the U.S. Nuclear Industry Council (USNIC) and the Nuclear Energy Institute (NEI) suggested that the NRC staff develop construction permit guidance for light water small modular reactors (SMRs). During the July 31, 2020, meeting the staff presented the options it considered for developing such guidance and noted the three options that it was actively considering (i.e., Interim Staff Guidance (ISG), Draft Strategy Paper for SMR CP reviews, or an Office Instruction).
USNIC provided a presentation on light water SMR CP guidance development and indicated that it generally believed that the ISG is the most efficient approach and will provide regulatory certainty. USNIC stated that it is in the process of gathering information from developers regarding their plans for CP submittals and noted that it may take six to nine months for the USNIC to provide feedback to the NRC staff.
NEI stated that it expects that a light water SMR CP application could be submitted to the NRC as early as the end of calendar year 2021. NEI stated that having draft guidance by the Spring
J. Segala 2 of 2021 would be helpful. As a result of the meeting NEI has the following action items:
- Provide feedback to the NRC staff on dual track approach for CP guidance that was presented by the NRC staff during the meeting. The dual track approach described by the staff during the meeting was to develop light water SMR CP guidance for applications not using the LMP approach and separate guidance for non-light water reactors (LWRs) using the licensing modernization project (LMP) process.
The Tennessee Valley Authority (TVA) provided comments regarding the development of light water SMR CP guidance. The NRC staff requested that the TVA provide the comments via email so that the comments could be captured as part of the meeting summary. TVAs comments can be found in Enclosure 2 of this document.
The staff noted that if a non-LWR applicant does not intend to use the LMP approach, then the applicant needs to reach out to NRC as soon as possible so that the NRC staff understands how the applicant intends to identify licensing basis events, structures systems and component classification and ensure defense-in-depth. The NRC staff stressed the need for potential near-term applicants to inform the NRC staff of their plans. The NRC noted that it needs to ensure that it has adequate resources budgeted to perform the reviews and that appropriate guidance is in place or in development to perform the review. The NRC staff stated that it intends to issue a regulatory issue summary (RIS) in the near-term requesting information from industry on their intentions for submitting applications. The NRC staff noted that applicants can also provide their intentions in response to existing RIS 2017-08, Process for Scheduling and Allocating Resources for Fiscal Years 2020 Through 2022 for the Review of New Licensing Applications for Light-Water Reactors and Non-Light-Water Reactors, (ADAMS Accession No. ML17262B022).
Advanced Reactor Content of Application Project The NRC staff and its contractor Idaho National Laboratory (INL) stated that as a result of feedback from the June 12, 2020, ARCAP meeting it had further refined the performance-based approach described in that meeting. INL staff provided an overview of the updated Chapter 8, Control of Routine Plant Radioactive Effluents, Plant Contamination and Solid Waste, that was referenced in the meeting notice (ADAMS Accession No. ML20197A234). INL described the changes to the updated Chapter 8 that included changes to address comments from the previous draft document. Changes to the updated Chapter 8 include: adding guidance such that it can be used for Part 50 applicants, making the guidance more technology inclusive, adding acceptance criteria, including guidance for microreactors, and providing more guidance related to the level of detail expected in an application.
Industry Feedback on ARCAP Annotated Outline USNIC and NEI generally supported the development of the performance-based approach and noted that it should be applied to other areas of an application. NEI took an action to provide feedback on the updated Chapter 8 outline. Based on an NEI comment, the NRC took an action to determine how ARCAP guidance would include guidance such as the recently issued Design Review Guide (DRG), Instrumentation and Controls for Non-Light-Water Reactor
J. Segala 3 Reviews, (ADAMS Accession No. ML20045D302). The staff noted that it was in the process of developing performance-based guidance for other portions of an application and that the INL developed annotated outline would have to be eventually updated to be consistent with the outline that is being developed by the industry-led technology inclusive content of application project.
Enclosures:
- 1. Attendance List
- 2. Tennessee Valley Authority Construction Permit Guidance Comments
ML20233A990 *via e-mail NRC-001 OFFICE NRR/DANU/UARP/PM
- NRR/DANU/UARP/BC
- NAME JSebrosky JSegala DATE 8/21/20 8/21/20 July 31, 2020, Public Meeting to Discuss Advanced Reactor Content of Application Project and Construction Permit Guidance Attendance List NAME AFFILIATION NAME AFFILIATION Bob Caldwell NRC/DNRL Marc Nichol Nuclear Energy Institute (NEI)
Mike Dudek NRC/DNRL/NRLB Kati Austgen NEI Carolyn Lauron NRC/DNRL/NRLB Mike Tschiltz NEI Demetrius Murray NRC/DNRL/NRLB Martin ONeill NEI Mo Shams NRC/DANU Jeff Merrifield Pillsbury Law Firm Brian Smith NRC/DANU Cyril Draffin US Nuclear Industry Council Steve Lynch NRC/DANU/UNPL Martin Owens GE Hitachi Eric Oesterle NRC/DANU/UARP Denis Henneke GE Hitachi Bill Reckley NRC/DANU/UARP Michelle Catts GE Hitachi Amy Cubbage NRC/DANU/UARP Bernard Gilligan Hitachi America Joe Sebrosky NRC/DANU/UARP Frank Misehler Hitachi America Nan Valliere NRC/DANU/UARP Jun Matsumoto Hitachi - GE Jordan Hoellman NRC/DANU/UARP Farshid Shahrokhi Framatome Chris Van Wert NRC/DANU/UART Ben Tomkins Kairos Power Jim Kinsey Idaho National Laboratory Darrell Gardner Kairos Power (INL)
Wayne Moe INL Margaret Ellanson Kairos Power Tom Hicks INL Matthew Denman Kairos Power Tom King INL Caroline Cochran Oklo Amir Afzali Southern Company Alex Winter Oklo Ben Carmichael Southern Nuclear Caroline Clarke Westinghouse Jason Redd Southern Nuclear Travis Chapman X Energy Ray Schiele Tennessee Valley Steven Nesbit LMNT Consulting Authority (TVA)
Roger Scott TVA Bill Horak Brookhaven National Laboratory Daniel Stout TVA Joshua Hogancamp INL Kevin Casey TVA David Luxat Sandia National Lab (SNL)
Stu Magruder NRC/NRR/DANU/UARL Jamal Mohmand SNL Arlon Costa NRC/NRR/DANU/UARP Ed Wallace GNBC Maryam Khan NRC/NRR/DANU/UARP Nicholas McMurray Clear Path Michelle Hart NRC/NRR/DANU/UART Prasad Kadambi Consultant Ian Jung NRC/NRR/DANU/UART Jenna Bergman Curtiss-Wright Alyssa Beasley NRC/NRR/DANU/UART Frank Akstulewicz A to Z Reactor Consulting Services Hanh Phan NRC/NRR/DANU/UART Donald Helton NASA Bob Fitzpatrick NRC/NRR/DEX/EENB Karen Conchran Public Dave Cullison NRC/OCIO/GEMSD Kelvin Montague UVA Enclosure 1
NAME AFFILIATION NAME AFFILIATION Eric Bowman NRC/COMM/OCMKS Mark Jaeger Structural IA Shakur Walker NRC/COMM/OCMDW Peter LeJeune Balch Charles Murray NRC/NSIR/DPR/POB Phil Sharpe Studesvik Scand Power Derek Widmayer NRC/ACRS Rick Wachowiak Jensen Hughes Michael Spencer NRC/OGC Robert Armsitaad Public 2
Tennessee Valley Authority Construction Permit Guidance Comments Mr. Ray Schiele, the Licensing Manager for Nuclear Technology Innovation - Small Modular Reactors, for the Tennessee Valley Authority, provided the following comment during the meeting. The NRC staff requested that Mr. Shiele email the comments to the NRC so that his comments could be captured in this meeting summary. Mr. Scheiles comments provided during the meeting were the following:
TVA would like to thank the NRC for this very important meeting on Construction Permit Application guidance.
TVA, in planning for a potential 10 CFR 50 application supporting deployment of an advanced reactor at the Clinch river nuclear site, has evaluated the delta between guidance provided in RG 1.70 and that provided in the NUREG 0800 (SRP). Some identified deltas are:
- Alignment is needed regarding what specific level of detail is required for Preliminary.
- Alignment/applicability of advanced reactor design features to specific requirements in SRP.
Considering the current and proposed near term guidance available for clarifying Construction Permit Applications, TVA suggests that the following near term approach might prove most efficient:
- 1. Develop a set of Regulatory Framework Documents as an integral part of the Regulatory Engagement Plan.
- 2. Use the Regulatory Engagement Plan to support early and often NRC pre-application engagement to gain alignment on:
- b. What specific level of detail is required for Preliminary?
- c. Where the existing review guidance is not applicable to advanced reactor design features.
- d. Where appropriate review guidance doesnt exist (and is needed) for design of choice and
- e. To establish (where identified) a design-specific set of agreements establishing what detail is needed for a complete and technically accurate CP application.
- 3. Obtain feedback from NRC management in writing. This doesnt have to be binding with finality, but should be something that industry and NRC management can refer to should the staff reviewing the Application materially deviate from the agreed upon REP.
As part of TVA near term regulatory engagement activities, TVA would like to use that opportunity to inform the development of ISG guidance. Thanks Enclosure 2