ML20253A307
| ML20253A307 | |
| Person / Time | |
|---|---|
| Issue date: | 09/16/2020 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | John Segala NRC/NRR/DANU/UARL |
| Sebrosky J,NRR/DANU/UARL,(240)500-0614 | |
| References | |
| Download: ML20253A307 (6) | |
Text
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September 16, 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 AUGUST 27, 2020, PUBLIC MEETING TO DISCUSS TECHNOLOGY INCLUSIVE CONTENT OF APPLICATION PROJECT, ADVANCED REACTOR CONTENT OF APPLICATION PROJECT, AND CONSTRUCTION PERMIT GUIDANCE On August 27, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a Category 2 public meeting with stakeholders, to discuss the technology inclusive content of application project (TICAP), 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. ML20239B034, and the presentation slides are available at ADAMS Accession No. ML20239A957. This was a teleconference meeting, and an attempt was made to capture a list of the attendees as they called into the meeting. The Enclosure to this summary provides the attendees for the meeting as captured by the operator that helped to facilitate the meeting.
Meeting Highlights Technology Inclusive Content of Application Project The meeting began with a discussion of the industry-developed fundamental safety function1 (FSF) mapping report (ADAMS Accession No. ML20219A650), and the NRC staffs feedback on the report (ADAMS Accession No. ML20233A510). The objective of the industry developed FSF mapping report was to demonstrate that the existing design requirements contained in Title 10 of the Code of Federal Regulations (10 CFR) Parts 50 and 52 (and regulations referenced by those parts) are in place to substantiate that one or more FSFs are met.
The NRC noted that the overall conclusions of the industrys report align with the NRC staffs expectations that the NRCs existing regulations for light-water reactors ensure that the FSFs are fulfilled. As described in industrys report, the regulations provide that assurance by defining various high-level performance requirements as well as prescriptive requirements for some 1 Fundamental safety functions are defined as: 1) limiting the release of radioactive material, 2) removing decay heat from the reactor and waste stores, and 3) controlling reactivity.
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structures systems, and components and related programmatic controls. The NRC staff noted that it was not endorsing the industrys report for use as guidance, but the NRC staff is comfortable with an approach based on developing an affirmative safety case based on the FSFs and other elements of Revision 1 of NEI 18-04, Risk-Informed Performance-Based Guidance for Non-Light Water Reactor Licensing Basis Development (ADAMS Accession No. ML19241A336). The industry and NRC staff agreed that the objective of the mapping report had been met and that no further revisions or discussions associated with the report were needed.
Industry then provided the current status of the TICAP effort including the development of the structure for the safety analysis report (SAR), and the status of the tabletop exercises that would be used to demonstrate aspects of the TICAP process. There was a discussion of the principle design criteria (PDC) and complimentary design criteria (CDC). Industry defined PDCs as supporting demonstration of the performance objectives for the FSFs. The CDCs support plant functions related to risk significance or defense-in-depth. Industry provided examples of PDCs and CDCs. The NRC staff noted that while it understood the steps to develop PDCs and CDCs and that such work was insightful, the NRC staff questioned whether the concept of PDCs and CDCs was necessary for TICAP since the licensing modernization project (LMP) did not include these terms. Industry stated that it would consider the NRC staff feedback on PDCs and CDCs and whether there was a need to use these concepts in the TICAP guidance document that is under development.
Regarding the status of tabletop exercises to demonstrate aspects of the TICAP process, industry noted that it was still working on the logistics for the exercises. Both industry and the NRC staff agreed that it would be beneficial to have NRC staff observe portions of the exercises and the NRC staff noted that its observation of the exercises should not impede the ability to perform the exercises. Industry noted that publicly available reports would be developed and provided to the NRC staff highlighting the results of the exercises.
Light Water Small Modular Reactor Construction Permit Guidance The NRC staff noted that it was continuing to develop light water small modular reactor (SMR) construction permit guidance based on industrys identification that such guidance would be useful. Both the Nuclear Energy Institute (NEI) and U.S. Nuclear Industry Council (USNIC) supported the development of such guidance. NEI stated that it was developing a position paper on the topic that it hoped to provide to the NRC staff in December of 2020.
Advanced Reactor Content of Application Project The NRC staff noted that as a result of feedback from the July 31, 2020, ARCAP meeting, the NRC 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. Details regarding the ARCAP guidance document proposal can be found in ADAMS at Accession No. ML20231A563. 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
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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 NRC staff provided a table that listed 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. Industry and the NRC staff agreed that the approach would be discussed further in future ARCAP meetings.
The NRC staff and Idaho National Laboratory (INL) staff2 provided an update on the status of developing a performance-based approach for portions of an advance reactor application. The INL staff noted that it had previously provided proposed guidance for the liquid and gaseous effluent portions of Chapter 8, Control of Routine Plant Radioactive Effluents and Solid Waste.
Stakeholders were informed that the NRC and INL staff are developing a performance-based approach for other portions of an advanced reactor application including:
Chapter 2, Site Information, Chapter 8, Section 8.3, Solid Waste, and Chapter 9, Control of Occupational Dose.
The NRC staff noted that it was targeting discussing this additional guidance in more detail at the next ARCAP meeting that is tentatively scheduled for September 24, 2020.
Enclosure:
Attendance List 2 Idaho National Laboratory staff are supporting development of ARCAP guidance through an NRC contract.
- via e-mail NRC-001 OFFICE NRR/DANU/UARP/PM
- NRR/DANU/UARP/BC
- NRR/DANU/UARP/PM
- NAME JSebrosky JSegala JSebrosky DATE 9/9/2020 9/15/20 9/16/20 Enclosure August 27, 2020, Public Meeting to Discuss Technology Inclusive Content of Application Project, Advanced Reactor Content of Application Project, and Construction Permit Guidance Attendance List NAME AFFILIATION NAME AFFILIATION Anna Bradford NRC/NRR/DNRL Marc Nichol Nuclear Energy Institute (NEI)
Bob Caldwell NRC/NRR/DNRL Kati Austgen NEI Mike Dudek NRC//NRR/DNRL/NRLB Mike Tschiltz NEI Carolyn Lauron NRC/NRR/DNRL/NRLB Martin ONeill NEI John Segala NRC/NRR/DANU/UARP Jeff Merrifield Pillsbury Law Firm Maryam Khan NRC/NRR/DANU/UARP Cyril Draffin US Nuclear Industry Council Eric Oesterle NRC/NRR/DANU/UARP Denis Henneke GE Hitachi Bill Reckley NRC/NRR/DANU/UARP Steven Nesbit LMNT Consulting Amy Cubbage NRC/NRR/DANU/UARP Karl Fleming KNF Consulting Joe Sebrosky NRC/NRR/DANU/UARP Frank Akstulewicz A to Z Reactor Consulting Services Nan Valliere NRC/NRR/DANU/UARP George Wadkins GE Hitachi Jordan Hoellman NRC/NRR/DANU/UARP Martin Owens GE Hitachi Chris Van Wert NRC/NRR/DANU/UART Farshid Shahrokhi Framatome Jim Kinsey Idaho National Laboratory (INL)
Darrell Gardner Kairos Power Wayne Moe INL James Tomkins Kairos Power Tom Hicks INL Caroline Cochran Oklo Tom King INL Jacob Gabcwitez Oklo Amir Afzali Southern Company Tammy Morin Holtec International Brandon Chisholm Southern Nuclear Gary Becker NuScale Jason Redd Southern Nuclear Steve Schilthelm BWXT Ben Carmichael Southern Company Pete Dillard Terra Power Ryan Henderson Southern Company John Bolan General Atomics Clint Medlock Southern Company Jill Monahan Westinghouse Gracen Ray Southern Tim Lucas X Energy Stu Magruder NRC/NRR/DANU/UARL Bill Horak Brookhaven National Laboratory Adrian Muniz NRC/NRR/DANU/UARL Christopher Chwasz INL Michelle Hart NRC/NRR/DANU/UART Jason Christensen INL Ian Jung NRC/NRR/DANU/UART David Holcomb Oak Ridge National Lab (ORNL)
Michelle Hayes NRC/NRR/DANU/UART Mike Poore ORNL Bob Fitzpatrick NRC/NRR/DEX/EENB Jason Andrus INL Nadim Khan NRC/NRR/DEX/EENB Rory Stanley US Senate Environment and Public Works (EPW)
Eric Bowman NRC/COMM/OCMKS Brad Williams US Senate EPW
2 NAME AFFILIATION NAME AFFILIATION Shakur Walker NRC/COMM/OCMDW Ed Wallace GNBC Valerie Gray NRC/OCHCO/ADHRTD/
NRANB Prasad Kadambi Consultant Hayden Brundage NRC/OCHCO/ADHRTD/
NRANB Jenna Bergman Curtiss-Wright Derek Widmayer NRC/ACRS Donald Helton NASA Casper Sun NRC/RES/DSA/RPB Alan Levin Public Donald Palmrose NRC/NMSS/RESS Karen Cochran Public Scott Bussey NRC/OCHCO/ADHRTD/
RTTB Alex Hashemian AMS Rob Burg Engineering Planning and Management Inc.
Alice Reener Hopewell Inc.
Bruce Weir Dubose National Energy April Rice PLS Stacey Wheeler Public Don Hulting NBS National Labs