ML20294A438
| ML20294A438 | |
| Person / Time | |
|---|---|
| Issue date: | 10/22/2020 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | |
| Sebrosky J | |
| References | |
| Download: ML20294A438 (62) | |
Text
Technology Inclusive Content of Application Project (TICAP), and Advanced Reactor Content of Application Project (ARCAP) Meeting October 22, 2020 Telephone Bridgeline: : 301-576-2978 Passcode: 883 380 220#
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Agenda Time Topic Presenter 10:00 -10:10 am Introduction NRC 10:10 - 10:40 am NEI Guidance Document Annotated Outline Southern 10:40 - 11:20 am Level of Detail Task Southern 11:20 - 11:35 am Tabletop Exercises Southern 11:35 - 12:00 pm Stakeholder questions All 12:00 -1:00 pm Break All 1:00 - 1:45 pm Updated Proposal for ARCAP Guidance NRC/Idaho Document National Lab 1:45 -2:15 pm Additional Thoughts on Proposed ARCAP NRC/Idaho Chapters 8 and 9 National Lab 2:15 - 2:45 pm Industry and Other stakeholder feedback All 2:45 - 3:00 pm Next Steps and Concluding Remarks All 2 of 62
Technology Inclusive Content of Application Project (TICAP) Presentations Steve Nesbit, LMNT Consulting Ed Wallace, GNBC Associates Brandon Chisholm, Southern Company TICAP - Nuclear Regulatory Commission (NRC) Working Meeting October 22, 2020 3 of 62 1
Outline of Todays TICAP Presentations
- Introduction and Overview (Steve)
- Nuclear Energy Institute (NEI) Guidance Document Annotated Outline (Steve)
- Level of Detail (LoD) Task (Ed)
- Tabletop Exercises (Brandon)
Please note that we will be discussing work in progress, not a finished product. We request your indulgence and welcome your feedback.
Also, we have included a list of acronyms at the end of the presentation.
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TICAP Overview
- Product: Develop an endorsable Guidance Document that proposes an optional formulation of advanced reactor application content that
- Benefits from the insights and knowledge gained through licensing and safely operating the current US-based nuclear fleet for over 40 years to ensure adequacy of proposed content requirements.
- Is based on describing a technology-inclusive affirmative safety case that meets the underlying intent of the current requirements
>> To optimize application content (add where additional content is needed and reduce where current content requirements are not commensurate with the contribution to risk)
>> To provide the needed regulatory agility to accommodate review of spectrum of designs that are expected to submit licensing application,
- Is risk-informed, performance-based (RIPB) to right size the required information in an application (based on the complexity of the safety case) to increase efficiency of generating and reviewing an application
- Its scope is governed by the Licensing Modernization Project (LMP)-based safety case to facilitate a systematic, technically acceptable, and predictable process for developing a designs affirmative safety case
- Provides similar information as is currently required from a light water reactor (LWR) applicant 5 of 62 3
Background
LMP-Driven Application Content
- Projects Expected Outcomes:
- A standardized content structure that facilitates efficient
>> preparation by an applicant,
>> review by the regulator, and
>> maintenance by the licensee.
- A content formulation that, based on the complexity of a designs safety case, optimizes
>> the scope (the functions, the structures, systems, and components (SSCs), and the programmatic requirements that need to be discussed) based on what is relevant to the design specific safety case.
>> the type of information to be provided (e.g., licensing basis events (LBEs), Required Safety Functions (RSFs), Safety-Related SSCs, Defense-in-Depth (DiD), etc.),
>> level of detail to be provided
- based on the relevance to the safety determination Creating Clarity, Predictability, and Transparency 6 of 62 4
Affirmative Safety Case LMP-Based Affirmative Safety Case Definition - A collection of scientific, technical, administrative and managerial evidence which documents the basis that the performance objectives of the technology-inclusive fundamental safety functions (FSFs) are met by a design during design specific Anticipated Operational Occurrences (AOOs), Design Basis Events (DBEs), Beyond Design Basis Events (BDBEs), and Design Basis Accidents (DBAs) by
- Identifying design specific safety functions that are adequately performed by design specific SSCs and
- Establishing design specific features (programmatic (e.g., inspections) or physical (e.g., redundancy)) to provide reasonable assurance that credited SSC functions are reliably performed.
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Technology-Inclusive Content of Application Project (TICAP)
Guidance Document Annotated Outline Steve Nesbit TICAP - NRC Working Meeting October 22, 2020 8 of 62 6
NEI Guidance Document Annotated Outline
- NEI Guidance Document
- Key product from TICAP
- Guidance for structure, scope, and level of detail for portions of an advanced reactor safety analysis report (SAR) related to the affirmative safety case developed in accordance with NEI 18-04
- To be submitted by NEI to NRC around September 2021
>> Draft to NRC in Spring 2021
>> Development ongoing 9 of 62 7
Overall Outline of Guidance Document
- Chapter 1 - Introduction
- Purpose
- Background
- Scope
- Organization of the Report
- Chapter 2 - Chapter-by-chapter guidance for portions of a 10 CFR Part 52 combined license SAR
- Chapter 3 - Alternative Licensing Paths
- Construction Permit / Operating License (10 CFR Part 50)
- Design Certification (10 CFR Part 52)
- Chapter 4 - Summary and Conclusions
- Chapter 5 - References 10 of 62 8
Overall Outline (cont.)
- Appendix A - LMP-Based Affirmative Safety Case
- Appendix B - Fundamental Safety Function Mapping and General Design Criteria Binning
- Appendix C - Tabletop Exercises 11 of 62 9
SAR Organization (Guidance Document Chapter 2) 12 of 62 10
Chapter 1 - General Plant and Site Description and Overview of the Safety Case
- Overview of technology (size of the reactor and planned commercial application of the design)
- General description of the plant systems
- General site characteristics
- Summary of safety case findings
- Overview of NEI 18-04 methodology
- Summary of fundamental safety functions (FSFs)
- Summary of LBEs with a focus on DBAs
- Summary of radiological consequence assessments
- Summary of how the design meets the performance objectives of the FSFs
- Summary of the evaluation of DID adequacy 13 of 62 11
Chapter 2 - Generic Analyses
- Allows for discussion of analyses that are common to some or all LBEs
- Deterministic and probabilistic analyses
- Tools and methods
- Summary of results
- Examples
- Probabilistic Risk Assessment (PRA)
>> Overview of PRA
>> Summary of key PRA findings
- Source term
- Meteorology 14 of 62 12
Chapter 3 - Licensing Basis Events
- LBE selection methodology
- Description of event, end state, and consequences
- PRA safety functions; SSCs, and operator actions (if any)
- Design Basis Events (DBEs)
- Description of event, end state, and consequences
- PRA safety functions, SSCs, and operator actions
- Beyond Design Basis Events (BDBEs)
- Description of event, end state, and consequences
- PRA safety functions, SSCs, and operator actions 15 of 62 13
Chapter 3 - Licensing Basis Events (cont.)
- Design Basis Accidents (DBAs)
- Description of event, end state, and consequences
- PRA safety functions; SSCs; and operator actions (if any)
- More detail than other LBEs
>> Commensurate with LWR SAR Chapter 15 16 of 62 14
Chapter 4 - Integrated Evaluations
- Evaluation of Integrated Plant Risk relative to cumulative risk targets
- Frequency of exceeding 10 CFR Part 20 site boundary dose
- NRC Safety Goal quantitative health objective (QHO) for early fatality risk
- NRC Safety Goal QHO for latent cancer risk
- Quantification of LBE margins
- Qualitative evaluation of DID adequacy
- DID baseline
- Identification of additional measures (e.g., SSCs and operator actions) to add margin 17 of 62 15
Chapter 5 - Safety Functions, Principal Design Criteria (PDC) and SSCs
- Identification of Complementary Design Criteria (CDC) and non-safety-related SSCs with special treatment (NSRSTs) 18 of 62 16
Chapter 6 - Safety-Related SSC Criteria and Capabilities Criteria (PDC) and SSCs
- Information for all SR SSCs
- Short functional description
- Required functional design criteria
- Safety-related design criteria (SRDC)
- Reliability and capability targets
- Special treatment requirements 19 of 62 17
Chapter 7 - NSRST SSC Criteria and Capabilities
- Information for all NSRST SSCs
- Short functional description
- Reliability and capability targets
- Special treatment requirements 20 of 62 18
Chapter 8 - Plant Programs
- Special treatments for SSCs may involve plant programs relied upon to meet reliability and performance targets
- Potential examples include human factors, training, in-service inspection, and maintenance
- The intent is to focus on the performance objective of the relevant programs
- Not a description of all plant programs
- Example - material control and accounting
>> Program needed to meet NRC requirements in 10 CFR Part 74 related to tracking special nuclear material
>> No impact on radiological safety of the public 21 of 62 19
Summary
- Draft NEI Guidance Document annotated outline developed
- Draft outline established for SAR guidance (Part 52 combined license)
- Detailed SAR guidance in development
- Tabletop exercises forthcoming
- Inscription in stone has not yet begun 22 of 62 20
Technology Inclusive Content of Application Project (TICAP)
SAR Level of Detail Ed Wallace TICAP - NRC Working Meeting October 22, 2020 23 of 62 21
Meeting Objectives A TICAP objective is to right-size the Level of Detail (LoD) by:
- Using a graded approach, facilitated by the LMP-based safety case
- Using a performance-based approach by stating the performance outcomes and supporting programmatic requirements commensurate with the safety significance of the topic
- The detailed design and programs are part of the design-phase records, available for audit and inspection.
Begin the dialog on LoD regarding:
- How we are going about developing the LoD guidance proposal
- Determine if there is a technical/regulatory basis or precedent for the proposal
- Determine what questions need to be answered to establish the LoD guideline 24 of 62 22
TICAP Level of Detail Approach
- Determine a set of questions that provide direction for the TICAP Guidance on LoD
- Account for products from applying the LMP methodology
- Develop Guiding Principles for LoD
- Develop Attributes for consistent guideline development and subsequent use to provide an acceptable LoD in an application
- Collect inputs from TICAP developer companies based on recent experiences and working insights
- Obtain feedback from industry et al. and NRC and incorporate into TICAP guidance working draft
- Use the products to enhance the TICAP guidance on LoD 25 of 62 23
Major Questions To Be Addressed This is a working list for discussion:
- Are there any existing definitions or precedents for RIPB LoD?
- How can they be adapted for inclusion in TICAP guidance?
- What are the considerations to be accommodated? Such as:
- Informational items
- Safety Baseline content for approval
- Clear foundation for post-licensing change control
- Completeness of affirmative safety case description
- Use of, and LoD for, incorporated by reference statements
- Use of audit and inspection to verify details underpinning safety case results
- Transparency 26 of 62 24
Major Questions To Be Addressed (cont.)
- What is the cutoff for the LoD guidance development?
- Can the Principles and Attributes provide sufficient guidance beyond that specified in the TICAP guidance?
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Concept Logic Diagram for LMP-based LoD Development 28 of 62 26
Identification of LMP Products for SAR Inclusion
- Tables constructed to define more detailed output products expected to be available for an LMP-based application
- Products produced by PRA from application of ASME/ANS-RA-S-1.4-2020, and supporting guidance
- Products that document selection and evaluation of LBEs
- Products that document the SSC safety classification and derivation of SRDC and special treatment requirements
- Products that document the evaluation of DID adequacy
- Mapping LMP outputs to the SAR outline for an affirmative safety case
- Identification of candidates for:
- Inclusion in content of license application for the affirmative safety case
- Availability of supporting documentation for NRC audit reviews
- Reconciliation of this bottom-up review of LMP products and top-down definition of LMP based safety case to ensure appropriate and sufficient SAR content consistent with RG 1.233 29 of 62 27
Next Steps
- Incorporate initial feedback on approach
- Workshop session on fleshed out Questions, Principles and Attributes
- Pilot guidance section example discussion 30 of 62 28
Technology Inclusive Content of Application Project (TICAP)
Tabletop Exercises - Update and Status Brandon Chisholm TICAP - NRC Working Meeting October 22, 2020 31 of 62 29
Tabletop Exercises Refresher
- Objectives
- Exercise the TICAP guidance for content, structure, and LoD of SAR so that the guidance can be validated and, where necessary, improved
- Provide examples of an affirmative safety case
- Refine understanding of the broad set of inputs required to produce an affirmative safety case
- Develop feedback for the TICAP team to assist in the refining of the Guidance Document
- Tabletop reports (i.e., final deliverables) will be publicly available
- Vendors support NRC participation in tabletops as observers
- Due to intellectual property, the working meetings will not be public
- Preparing to kick off tasks with 4 different developers 32 of 62 30
TerraPower - Molten Chloride Reactor Experiment (MCRE)
- < 1 MWth pool-type molten salt reactor
- Focused on vertical slice of affirmative safety case
- Understand content and LoD associated with specific RSFs
- Includes exploration of content regarding the following concepts:
- LBEs
- Safety functions, PDC, CDC, and SSC categorization
- SR SSC criteria and capabilities
- NSRST SSC criteria and capabilities
- Plant programs
- Internal events
- Note: MCRE is planned for DOE Authorization, but for this work will use the LMPs performance objectives of the FSFs 33 of 62 31
X-energy - Xe-100
- 80 MWe pebble bed high temperature gas cooled reactor
- Focused on multiple design criteria, special treatments, and plant programs
- Includes exploration of content regarding the following concepts:
- Safety functions, PDC, CDC, and SSC categorization
- SR SSC criteria and capabilities
- NSRST SSC criteria and capabilities
- Plant programs
- Possibility to investigate impact of some external events (in addition to internal events)
- Similar to X-energy LMP tabletop exercise, can look to modular high temperature gas-cooled reactor safety case information 34 of 62 32
Westinghouse - eVinci
- Heat pipe-cooled microreactor
- Focused on horizontal slice of affirmative safety case
- Develop detailed annotated outline for as much of safety-related SAR content as possible
- Additional exploration of PDC identification
- Comparison of PDC developed using Advanced Reactor Design Criteria (RG 1.232) and PDC identified using RIPB approach (NEI 18-04 and RG 1.233)
- Consideration of internal events and some external events 35 of 62 33
GE-Hitachi - Versatile Test Reactor (VTR)
- 300 MWth pool-type sodium-cooled fast reactor
- Focused on multiple design criteria (especially those associated with non-safety-related SSCs), special treatments, and plant programs
- Exploration of DID baseline
- Consideration of internal events and some external events
- Note: VTR is planned for DOE Authorization
- VTR team has experience working with LMP approach within the DOE framework
- Ref.: J. Li, D. Henneke, G. Seeman, D. Grabaskas, M. Bucknor, J.
Andrus, and D. Gerstner, Versatile Test Reactor (VTR) PRA Supporting the Application of the Licensing Modernization Project (LMP).
ESREL2020/PSAM15, 2020. 36 of 62 34
Summary of Tabletop Exercises Developer/ Portions of Guidance Covered Exercise Focuses Kickoff Meeting Design GE Hitachi -
- Section 4.2 (DID)
- Defense in Early Nov VTR (w/ INL)
[solid fueled Categorization)
- External SFR, pool-type]
- Chapter 6 (SR SSC Criteria and Capabilities) Hazards
- Chapter 7 (NSRST SSC Criteria and Capabilities)
Westinghouse -
- Horizontal slice Late Nov eVinci
- Detailed outline for as much of SAR as possible (of affirmative
[micro reactor] safety case)
- External hazards TerraPower -
- Chapter 3 (LBEs)
- Vertical slice Mid Nov MCRE
[liquid fueled Categorization) safety case)
MSR, pool-
- Chapter 6 (SR SSC Criteria and Capabilities) type]
- Chapter 7 (NSRST SSC Criteria and Capabilities)
- Chapter 8 (Plant Programs)
X-energy - Xe-
- Special Late Oct 100 Categorization) Treatments
[HTGR, moving
- Chapter 6 (SR SSC Criteria and Capabilities) and Plant fuel]
- Chapter 7 (NSRST SSC Criteria and37Capabilities) of 62 Programs
- Chapter 8 (Plant Programs) 35
Acronyms Acronym Definition ANS American Nuclear Society AOO Anticipated Operational Occurrence ASME American Society of Mechanical Engineers BDBE Beyond Design Basis Event CDC Complementary Design Criteria CFR Code of Federal Regulations DBA Design Basis Accident DBE Design Basis Event DID Defense in Depth LBE Licensing Basis Event LMP Licensing Modernization Project 38 of 62 36
Acronyms (cont.)
Acronym Definition LoD Level of Detail LWR Light Water Reactor MCRE Molten Chloride Reactor Experiment MWe Megawatt-electric MWth Megawatt-thermal NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission NSRST Non-Safety-Related with Special Treatment PDC Principal Design Criteria PRA Probabilistic Risk Assessment QHO Quantitative Health Objective 39 of 62 37
Acronyms (cont.)
Acronym Definition RG Regulatory Guide RIPB Risk-Informed, Performance-Based RSF Required Safety Function SAR Safety Analysis Report SR Safety-Related SRDC Safety-Related Design Criteria SSC Structure, System, or Component TICAP Technology-Inclusive Content of Application Project VTR Versatile Test Reactor 40 of 62 38
Updated Proposal for Advanced Reactor Content of Application Project (ARCAP) Guidance Document 41 of 62
Background
- High-level ARCAP proposal discussed during August 2020 TICAP/ARCAP meeting. Proposal included:
- 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) 42 of 62
Proposal for ARCAP Guidance Document
- Updated high level ARCAP proposal found in document referenced in meeting notice
- Uses same structure as Idaho National Lab (INL) developed outline discussed in previous ARCAP meetings. Outline can be found at ADAMS Accession No. ML20107J565
- Recognizes that the Industry-developed TICAP final safety analysis report proposed structure is different than INL-developed structure
- Table will be updated based on final version of industry-developed TICAP structure
- Changes to ARCAP proposal from that discussed in August 27, 2020, meeting include:
- More information providing the basis for the proposal
- A draft schedule that integrates TICAP and ARCAP guidance development 43 of 62
Background
- Figure provides an overview of some of the more important efforts underway to develop advanced reactor guidance
- TICAP will use the NEI 18-04/RG 1.233 (upper left of figure) to develop portions of the application 44 of 62
Proposal for ARCAP Guidance Document
- Changes to ARCAP proposal from that discussed in August 27, 2020, meeting include (continued)
- Target issuing a final TICAP Regulatory Guide by the end of 2021 that endorses, as appropriate, industry-developed TICAP guidance
- ARCAP draft regulatory guidance focused on supporting 10 CFR Part 53 rulemaking
- Portions of the guidance that may be beneficial to a near-term non-LWR applicant will be broken out into individual interim staff guidance documents (e.g.,
Chapter 8, Control of Routine Plant Radioactive Effluents and Solid Waste) 45 of 62
Proposal for ARCAP Guidance Document
- Changes to ARCAP proposal from that discussed in August 27, 2020, meeting include (continued)
- Near term Part 50 or Part 52 non-LWR applicants encouraged to use
- Non-Light Water Reactor Review Strategy White Paper (ADAMS Accession No. ML19275F299) as amended by NRC Staff Draft White Paper Analysis of Applicability of NRC Regulations for Non-LWRs (ADAMS Accession No. ML20241A017)
- Regulatory Roadmap (ADAMS Accession No. ML17312B567)
- NEI Working Draft Industry Guideline for Development of Regulatory Engagement Plan (ADAMS Accession No. ML18122A293)
- Preapplication process found at ADAMS Accession No. ML20281A761 46 of 62
Proposal for ARCAP Guidance Document
- Changes to ARCAP proposal from that discussed in August 27, 2020, meeting include (continued)
- Portions of the TICAP guidance and ARCAP guidance can be used, as appropriate, to develop a Part 50/Part 52 application
- Changes to Table 1 to provide a more detailed roadmap to the TICAP and ARCAP guidance that supports portions of the application
- Assumes that TICAP will not address detailed programmatic aspects that support the NEI 18-04/RG 1.233 methodology
- TICAP chapters updated to reflect additional guidance under development that will support these chapters 47 of 62
Legend Timeline for Technology Inclusive Industry Action Content of Application Project (TICAP) Industry TICAP Guidance Document (Draft)
Guidance and Advanced Reactor 4/15/2021 NRC Staff Action NRC/Industry brief ACRS Subcommittee on Industry/NRC Content of Application Project draft TICAP guidance 5/15/2021 Joint Action (ARCAP) Guidance Industry TICAP Guidance Document (Final) 7/15/2021 Notes:
- TICAP portion of the application based on applying TICAP Tabletop Exercises NRC/Industry brief ACRS licensing modernization project process to appropriate 11/15/2020 12/30/2020 Subcommittee on final TICAP portions of an application. TICAP milestones shown guidance above the timeline Industry Regulation Mapping to FSFs Paper 8/15/2021
- ARCAP broader than TICAP. Provides roadmap for 8/5/2020 NRC/Industry brief ACRS all portions of an application and encompasses TICAP NRC Feedback on Mapping to FSFs Paper Full Committee on final TICAP guidance 8/20/2020 Industry Fundamental Safety Function (FSF) 9/3/2021 Definition Paper Issue Tabletop Exercises report 11/25/2019 1/30/2021 NRC TICAP Regulatory NRC Feedback on FSF Definition Paper Industry TICAP Annotated Outline NRC TICAP Regulatory Guide (Draft) Guide 1/21/2020 10/22/2020 4/15/2021 10/15/2021 Nov 2020 Mar May Jul Sep Nov 2021 Mar May Jul Sep 2021 2/15/2020 8/27/2020 4/15/2021 10/15/2021 Industry Feedback on ARCAP SAR Outline NRC ARCAP entire application outline Draft Interim Staff Guidance for ARCAP NRC ARCAP Chapters 2, 8 and 9 Issued Draft 4/15/2020 Regulatory NRC ARCAP SAR outline updated 1/30/2021 Guide and Final ARCAP Application Outline Updated to be ISG for Chapters 12/12/2019 Consistent with TICAP outline 2, 8, and 9 NRC ARCAP Safety Analysis Report (SAR)
Issued Draft Outline 48 of 62
Proposal for ARCAP Guidance Document 49 of 62
Proposal for ARCAP Guidance Document 50 of 62
Proposal for ARCAP Guidance Document 51 of 62
Proposal for ARCAP Guidance Document 52 of 62
Proposal for ARCAP Guidance Document 53 of 62
Continued Development of ARCAP Chapters Using a Performance-Based (PB) Approach (i.e., Approach 3) 54 of 62
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 (ML20197A234).
- In the August 27, 2020 ARCAP meeting, NRC presented a framework for these ARCAP chapters (ML20239B034):
- Chapter 2, Site Information
- Chapter 8, Section 8.3, Solid Waste
- Chapter 9, Control of Occupational Dose
- Draft versions on Chapters 8 and 9 will be discussed today.
Copies are available at ML20262H264 55 of 62
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) 56 of 62
ARCAP Section 8.3, Solid Waste
- Developed using same approach as Sections 8.1 and 8.2
- Reference applicable requirements for performance-based acceptance criteria, such as:
10 CFR 20.1302 and 10 CFR 10 CFR 50, Appendix A, Criterion 63 20.1301(e) 10 CFR 20.1406 10 CFR 61.55 and 10 CFR 61.56 10 CFR 50.34a 10 CFR 20.2006 and Appendix G to 10 CFR Part 20 For LWRs, 10 CFR Part 50, 10 CFR 20.2007 Appendix I, Sections II.A, II.B, II.C, and II.D 40 CFR Part 190 10 CFR 20.2108 10 CFR 50, Appendix A, Criterion 60 10 CFR Part 71 and 49 CFR Parts 171-180 10 CFR 50, Appendix A, Criterion 61 49 CFR 173.443 57 of 62
ARCAP Section 8.3, Solid Waste (cont.)
- 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 58 of 62
ARCAP Section 8.3, Solid Waste (cont.)
- 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 59 of 62
ARCAP Chapter 9, Control of Occupational Dose
- 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 acceptance 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 60 of 62
ARCAP Chapter 9, Control of Occupational Dose (cont.)
- Develop Acceptance Criteria - System Design, such as:
- 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.
- Major radiation sources including sources that require (1) shielding, (2) special ventilation systems, (3) special storage locations and conditions, (4) traffic or access control, (5) special plans or procedures, and (6) monitoring equipment. Information regarding sources terms used in license basis event analysis need not be described in this chapter as this information should be provided elsewhere in the application.
- 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.
- 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.
- Methods for reducing the production, distribution, and retention of activation products through design, material selection, water chemistry, decontamination procedures, and so forth.
61 of 62
ARCAP Chapter 9, Control of Occupational Dose (cont.)
- 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 62 of 62