ML21006A414

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Summary of 12/10/2020 Arcap Ticap Applicability of Regulations Public Meeting
ML21006A414
Person / Time
Issue date: 01/11/2021
From: Joseph Sebrosky
NRC/NRR/DANU/UARP
To: John Segala
NRC/NRR/DANU/UARP
Sebrosky J
Shared Package
ML21006A415:ML21007A259 List:
References
Download: ML21006A414 (6)


Text

January 11, 2021 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 Signed by Sebros FROM: Joseph M. Sebrosky, Senior Project Manager on 01/11/21 Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF DECEMBER 10, 2020, PUBLIC MEETING TO DISCUSS TECHNOLOGY INCLUSIVE CONTENT OF APPLICATION PROJECT, ADVANCED REACTOR CONTENT OF APPLICATION PROJECT, AND APPLICABILITY OF REGULATIONS TO NON-LIGHT WATER REACTORS On December 10, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff 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 applicability of regulations to non-light water reactors (non-LWRs). The meeting notice is available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML20344A139, and the presentation slides are available at ADAMS Accession No. ML20344A057. The Enclosure to this summary provides the attendees for the meeting as captured by Microsoft Teams.

Meeting Highlights Technology Inclusive Content of Application Project and Advanced Reactor Content of Application Project In preparations for the December 10, 2020, public meeting the NRC staff developed the following four documents to support the meeting (the first three documents provided in the list below are publicly available in ADAMS at Accession No. ML20316A013 and the last document is publicly available in ADAMS at Accession No. ML20321A326).

A document titled, Comments on Industry-Developed TICAP Annotated Outline. The purpose of this document was to provide NRC staff comments on the TICAP outline discussed during an October 22, 2020, meeting (available at ADAMS Accession No. ML20294A382).

Contact:

Joseph M. Sebrosky, NRR/DANU 301-4151132

J Segala 2 A document titled Draft Concept for Updated TICAP-ARCAP Combined Outline. The purpose of this document was to provide initial concepts for how the industry-developed TICAP final safety analysis report (FSAR) outline discussed during an October 22, 2020, meeting (available at ADAMS Accession No. ML20294A382) could be merged with the NRC staff developed ARCAP outline found at ADAMS Accession No. ML20107J565.

The staff developed ARCAP draft Chapter 2, Site Information. This document includes a proposal to limit the amount of material in safety analysis report (SAR) Chapter 2 to that which is necessary for establishing safety significant design parameters and performing the safety analysis, along with its supporting bases.

A document regarding considerations for the expected level of detail in an application that used the licensing modernization project approach.

Regarding industrys TICAP annotated outline and how the industry-developed TICAP annotated outline and NRC staff-developed ARCAP annotated outline could be integrated, the industry and the staff agreed that more dialogue was needed. In general, there was agreement that a different organization of the FSAR portion of an application for an LMP-based approach vice an FSAR organization for a non-LMP based application was appropriate. It was recognized that additional discussion was needed to clearly outline the scope of what guidance will be provided through the TICAP guidance and what guidance will be provided via ARCAP. For example, industry indicated that because validation of analytical codes is not addressed in Nuclear Energy Institute (NEI) 18-04, Revision 1, Risk-Informed Performance-Based Technology Inclusive Guidance for Non-Light Water Reactor Licensing Basis Development, as endorsed by the NRC, industry does not intend to provide detailed guidance on this topic as part of TICAP. The staff indicated this is an area that would be addressed as part of the ARCAP guidance it is developing.

In addition, the staff and industry agreed that additional discussion was needed to develop guidance for the expected level of detail in an application. There was agreement that a graded approach that leads to more information being provided for safety-related structures, systems, and components and less information for non-safety related structures, systems and components (SSCs) with special treatment was appropriate. However, the level of detail for SSCs that serve a defense-in-depth function was recognized as an area that needed additional discussions.

The staff provided an overview of draft ARCAP Chapter 2, Site Information. It was noted that additional discussion is appropriate to determine where this information should be placed in the FSAR since it does not appear as an area in the draft TICAP outline discussed during the meeting.

Industry provided an update on the status of the four tabletops that are scheduled over the next several months including:

TerraPower Molten Chloride Reactor Experiment - a less than 1 Megawatt (MW) thermal pool-type molten salt reactor X-energy Xe-100 - an 80 MW electric pebble bed high temperature gas cooled reactor Westinghouse eVinci - a heat pipe microreactor

J Segala 3 GE-Hitachi Versatile Test Reactor - a 300 MW thermal pool-type sodium-cooled fast reactor Industry took an action to continue to develop the schedules for the four tabletop exercises discussed during the meeting and to keep the NRC staff informed when the dates for NRC observation of the four tabletop exercises are identified.

Applicability of Regulations to Non-Light Water Reactors The purpose of this portion of the meeting was to discuss a document titled, NRC Staff Draft White Paper - Analysis of Applicability of NRC Regulations for Non-Light Water Reactors, dated September 2020, available at ADAMS Accession No. ML20241A017. Prior to the meeting the Nuclear Energy Institute provided a letter dated October 30, 2020, titled NEI Input on Analysis of Applicability of NRC Regulations for Non-Light Water Reactors. NEIs cover letter and associated enclosure are available in ADAMS at Accession No. ML20308A660, and Accession No. ML2030308A559, respectively.

As part of the discussion, NRC staff noted that future interactions would be beneficial in resolving the issues discussed in the slides. The NRC staff stated that the slides reflected a need to provide a durable and clear licensing basis using a decision-making process that was not arbitrary. Industry and NRC staff agreed that the applicability being discussed was on a generic basis, and that clarity in exemption requests would be beneficial for non-LWR applicants. Further, NRC staff pointed out that the industry slides appeared to take out of context the information found in the Staff Requirements Memorandum for SECY-19-0036, Application of the Single Failure Criterion to Nuscale Power LLC's Inadvertent Actuation Block Valves, (ADAMS Accession No. ML19183A408) and Commission Order CLI-20-03, Florida Power & Light Co. (Turkey Point Nuclear Generating Units 3 and 4), (ADAMS Accession No. ML20114E147).

The staff actions from this portion of the meeting included:

Consider revisions to the draft white paper to provide some clarity on the level of detail needed for an application to address the applicability of regulations for non-light water reactors.

Consider providing a template for exemptions for items found in Table 2 of the draft white paper.

Consider discussing at a future stakeholder meeting what the timeline may be for the staff update and next steps to issue a revised white paper.

NEI actions from this portion of the meeting included:

Identify examples of specific regulations where the NRC staff position in the draft white paper is not clear. NEI will identify the regulations that need clarification and in the near term will provide a schedule for this feedback.

Enclosure:

Attendance List

ML21006A414 NRC-001 OFFICE NRR/DANU/UARP/PM NRR/DANU/UART NRR/DANU/UARP/BC NRR/DANU/UARP/PM NAME JSebrosky BTravis JSegala JSebrosky DATE 1/07/2021 01/07/2021 01/08/2021 01/11/2021 December 10, 2020, Public Meeting to Discuss Technology Inclusive Content of Application Project, Advanced Reactor Content of Application Project, and Applicability of Regulations to Non-Light Water Reactors Attendance List*

NAME AFFILIATION NAME AFFILIATION Robert Taylor NRC/NRR Marc Nichol Nuclear Energy Institute (NEI)

Mohamed Shams NRC/NRR/DANU Kati Austgen NEI Brian Smith NRC/NRR/DANU Mike Tschiltz NEI Dayna Dority NRC/NRR/DANU Everett NEI Redmond John Segala NRC/NRR/DANU/UARP Cyril Draffin US Nuclear Industry Council Maryam Khan NRC/NRR/DANU/UARP Ed Wallace GNBC Associates Eric Oesterle NRC/NRR/DANU/UARP Steven Nesbit LMNT Consulting Arlon Costa NRC/NRR/DANU/UARP Frank A to Z Reactor Consulting Akstulewicz Services Juan Uribe NRC/NRR/DANU/UARP Darrell Kairos Power Gardner Amy Cubbage NRC/NRR/DANU/UARP Farshid Framatome Shahrokhi Joe Sebrosky NRC/NRR/DANU/UARP Jason INL Christensen Nan Valliere NRC/NRR/DANU/UARP Ross Moore Oklo Jordan Hoellman NRC/NRR/DANU/UARP Junaid Razvi Ultra Safe Nuclear Corporation Stephen Philpott NRC/NRR/DANU/UARP Rob Burg Engineering Planning and Management Inc.

Jim Kinsey Idaho National Brian Johnson TerraPower Laboratory (INL)

Tom Hicks INL Travis X-Energy Chapman Tom King INL Benjamin Sandia National Lab Cipiti Christopher Chwasz INL Christopher NA (Not available)

Courtenay Amir Afzali Southern Company Thomas NA Braudt Brandon Chisholm Southern Nuclear Richard NA Paese Jason Redd Southern Nuclear Rebecca NA Norris Donna Williams NRC/NRR/DANU UARL Andrew Arend NA Stu Magruder NRC/NRR/DANU/UARL David NA Holcomb Richard Rivera NRC/NRR/DANU/UARL Don Williams NA Enclosure

Mallecia Sutton NRC/NRR/DANU/UARL Jim Tomkins NA Michelle Hayes NRC/NRR/DANU/UART Marty ONeill NA Michelle Hart NRC/NRR/DANU/UART Mike Keller NA Marilyn Diaz NRC/NMSS/DFM/FFLB Niko NA Maldonado McMurray Ian Jung NRC/NRR/DANU/UART Pete Gaillard NA Chris Van Wert NRC/NRR/DANU/UART Ross NA Koningstein Boyce Travis NRC/NRR/DANU/UART Steve Burns NA Samuel Cuadrado NRC/NRR/DANU/UART Steve Kraft NA de Jesus Robert Weisman NRC/OGC Tom Roberts NA Julie Ezell NRC/OGC Gilbert Brown NA Brooke Clark NRC/OGC Taninaka NA Hiroshi Sheldon Clark NRC/OGC William Horak NA Susan Vrahoretis NRC/OGC Steve NA Schilthelm Marcia Carpentier NRC/OGC Chet Austin NA Sigmon Maxine Keefe NRC/OGC M. Sorouche NA Barbara Hayes NRC/NRR/DEX/EXHB Stephen NA Burdick Mike Lee NRC/NRR/DEX/EXHB Derek NRC/ACRS Widmayer Ken See NRC/NRR/DEX/EXHB Amitava NRC/NRR/DEX/ESEB Ghosh Kevin Quinlan NRC/NRR/DEX/EXHB Craig Harbuck NRC/NRR/DSS/STSB Jenise Thompson NRC/NRR/DEX/EXHB Pete Lee NRC/NSIR/DPCP/RSB Yuan Cheng NRC/NRR/DEX/EXHB Eric Schrader NRC/NSIR/DPR/POB Jason White NRC/NRR/DEX/EXHB Jose Pires NRC/RES/DE Cliff Munson NRC/NRR/DEX Robert Schaaf NRC/NMSS/REFS/ERNRB Kamal Manoly NRC/NRR/DEX Shakur NRC/COMM/OCMDW Walker

  • Attendance list based on Microsoft Teams Participant list. List does not include 26 individuals that connected via phone.

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