ML21049A274

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NRR E-mail Capture - Transmittal of NRC Staff Draft Slides to Support Upcoming Public Meeting Scheduled for February 25, 2021
ML21049A274
Person / Time
Issue date: 02/18/2021
From: Joseph Sebrosky
NRC/NRR/DANU
To: Afzali A, Austgen K, Draffin C
Nuclear Energy Institute, Southern Company Services, US Dept of Energy, Office of Nuclear Energy
References
Download: ML21049A274 (54)
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From: Sebrosky, Joseph Sent: Thursday, February 18, 2021 9:32 AM To: Afzali, Amir; AUSTGEN, Kati; Cyril Draffin Cc: NICHOL, Marcus; TSCHILTZ, Michael; Shams, Mohamed; Smith - NRR, Brian; Sanfilippo, Nathan; Segala, John; Bradford, Anna; Caldwell, Bob; Dudek, Michael; Lauron, Carolyn

Subject:

Transmittal of NRC Staff Draft Slides to Support Upcoming Public Meeting Scheduled for February 25, 2021 Attachments: NRC 2-25-21 Meeting Slides for CP TICAP and ARCAP portion of meeting.pdf Amir Afzali Southern Company Services Licensing and Policy Director - Next Generation Reactors Kati Austgen Sr. Project Manager, New Reactors Nuclear Energy Institute Cyril Draffin Senior Fellow, Advanced Nuclear United States Nuclear Industry Council Mr. Afzali, Ms. Austgen, and Mr. Draffin, The purpose of this email is to provide you with the attached NRC staff draft slides to support the upcoming February 25, 2021, public meeting on construction permit guidance, and advanced reactor stakeholder topics. The advanced reactor stakeholder topics include applicability of regulations, advanced reactor content of application project (ARCAP) guidance, and technology inclusive content of application project (TICAP) guidance. The attached draft slides do not include the NRC slides for the applicability of regulations discussion. These slides will be provided at a later date.

This email will be captured in ADAMS and the email will be made publicly available so that interested stakeholders will have access to the information prior to the meeting. The public meeting notice will be updated to provide a link to the attached document once the document is publicly available in ADAMS.

If you intend to make presentations please provide them to me by close of business on February 23, 2021, so that they can be integrated into the master slide package to support the meeting. As appropriate, the NRC attached draft slides will also be updated to incorporate the applicability of regulations slides and to reflect any updates that the staff might have.

Should you have any questions regarding the portions of the attached document related to light water reactor guidance please contact Carolyn Lauron. Questions related to the advanced reactor portion of the attached guidance or to advanced reactor stakeholder topics can be referred to me.

Sincerely, Joe Sebrosky Senior Project Manager Advanced Reactor Policy Branch

Office of Nuclear Reactor Regulation 301-415-1132

Hearing Identifier: NRR_DRMA Email Number: 1027 Mail Envelope Properties (MN2PR09MB5385FB4AE6D211FDE57B5BCBF8859)

Subject:

Transmittal of NRC Staff Draft Slides to Support Upcoming Public Meeting Scheduled for February 25, 2021 Sent Date: 2/18/2021 9:31:43 AM Received Date: 2/18/2021 9:31:43 AM From: Sebrosky, Joseph Created By: Joseph.Sebrosky@nrc.gov Recipients:

"NICHOL, Marcus" <mrn@nei.org>

Tracking Status: None "TSCHILTZ, Michael" <mdt@nei.org>

Tracking Status: None "Shams, Mohamed" <Mohamed.Shams@nrc.gov>

Tracking Status: None "Smith - NRR, Brian" <Brian.Smith@nrc.gov>

Tracking Status: None "Sanfilippo, Nathan" <Nathan.Sanfilippo@nrc.gov>

Tracking Status: None "Segala, John" <John.Segala@nrc.gov>

Tracking Status: None "Bradford, Anna" <Anna.Bradford@nrc.gov>

Tracking Status: None "Caldwell, Bob" <Robert.Caldwell@nrc.gov>

Tracking Status: None "Dudek, Michael" <Michael.Dudek@nrc.gov>

Tracking Status: None "Lauron, Carolyn" <Carolyn.Lauron@nrc.gov>

Tracking Status: None "Afzali, Amir" <AAFZALI@southernco.com>

Tracking Status: None "AUSTGEN, Kati" <kra@nei.org>

Tracking Status: None "Cyril Draffin" <cyril.draffin@usnic.org>

Tracking Status: None Post Office: MN2PR09MB5385.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 2028 2/18/2021 9:31:43 AM NRC 2-25-21 Meeting Slides for CP TICAP and ARCAP portion of meeting.pdf 1186079 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Advanced Reactor Stakeholder and Construction Permit Guidance Public Meeting February 25, 2021 Microsoft Teams Meeting Bridgeline: 301-576-2978 Conference ID: 644 910 374#

Agenda Time Topic Presenter 10:00 - 10:10 Introduction NRC am 10:10 - Construction Permit Guidance NRC 12:00pm x Discussion of NRC Draft Staff White Paper Safety Review Nuclear Energy of Power Reactor Construction Permit Applications Institute x Nuclear Energy Institute Construction Permit topics Other stakeholders x Stakeholder comments 12 pm to 1:30 Applicability of Regulations NRC/other pm stakeholders 1:30 to 2:00 pm Break All 2:00 to 3:45 Technology Inclusive Content of Application Project (TICAP) NRC/Southern and pm and Advanced Reactor Content of Application Project other stakeholders (ARCAP). Potential topics include: as appropriate x Status of TICAP guidance documents (Industry and NRC staff) x ARCAP roadmap draft guidance document considerations x Discussion of Draft ARCAP Chapter 11, Organization, and Chapter 12, Initial Startup Program.

3:45 to 4:00 pm Discussion of Possible Dates and Topics for Future Meetings All and Wrapup 2

Construction Permit Guidance 3

Construction Permit (CP) Guidance

Background

  • June 12, 2020, ARCAP public meeting - Industry commented on the need to develop near-term CP guidance for small light-water reactors (LWR).
  • July 31, 2020, ARCAP public meeting - Industry feedback:

- Guidance options (Interim Staff Guidance (ISG), Draft Strategy and Office Instruction) are viable for further consideration.

- ISG option considered most efficient and provides regulatory stability and durability.

- CP guidance development challenges recognized:

  • May take 6-9 months to receive needed industry input due to on-going activities supporting DOEs ARDP program.
  • First CP application submittals possible by end CY2021/early CY2022.
  • Draft CP guidance with application content guidance for critical areas available by Spring 2021 could support possible CP submittal schedule.

4

CP Guidance Background (continued)

  • August 27, 2020, ARCAP public meeting - NRC staff stated it is developing an ISG to clarify:

- CP regulatory requirements and findings necessary for NRC to issue permit.

- Information and level of detail needed in a CP application for NRC to review and issue a construction permit.

- Specific topics; e.g., siting.

  • Subsequent to August 27, 2020, ARCAP public meeting:

- NEI indicated it was developing a technology inclusive CP white paper.

- NRC expanded scope of CP guidance to consider LWR and advanced reactor designs based on:

  • Scope of NEI white paper, and
  • Possible near-term need for CP guidance for non-LWRs.

5

CP Guidance

  • Staff issued Draft White Paper, Safety Review of Power Reactor Construction Permit Applications, (ADAMS Accession No. ML21043A339)
  • Draft White Paper Highlights

- Focuses on the safety review of CP applications.

- Tentative plan is to develop further into an ISG.

- CP Guidance consists of three sections:

o Common guidance for both LWR CP applications following NUREG-0800 standard review plan (SRP) structure and advanced reactor CP applications o Guidance applicable to LWR CP applications following NUREG-0800 SRP approach o Guidance applicable to advanced reactor CP applications (i.e.,

Appendix C) 6

CP Guidance Applicable to both LWRs following NUREG-0800 and Advanced Reactors

  • Common Section includes:

- Requirements applicable to CPs o Includes discussion regarding finality

- Lessons Learned from recently issued CPs o Stresses need for preapplication engagement with NRC to optimize application reviews o Early interaction to support common understanding of level of information needed in preliminary safety assessment report (PSAR) to support NRC review o Early interaction to identify areas where only limited descriptions may be provided by applicant along with regulatory commitments to provide the complete information in the operating license application o Staffs CP review is focused on ensuring appropriate use of methodologies for analyses needed to demonstrate that requirements in the regulations are met 7

CP Guidance Applicable to both LWRs following NUREG-0800 and Advanced Reactors

  • Common Section includes:

- Special Topics o Concurrent applications o CP application incorporating prior NRC approvals o Discussion of potential impact of ongoing rulemaking activities on CP reviews o Caution - does not include guidance for obtaining licenses for receipt, possession and use of Source, Byproduct and Special Nuclear Material (10 CFR 40, 30 and 70, respectively) 8

CP Guidance Applicable to LWRs following NUREG-0800

  • Guidance refers to NUREG-0800 with clarifications for a subset of areas for a CP application including:

- Siting

- Radiological consequence analyses

- Transient and accident analyses

- Structures, systems and components (SSC categorization including codes used to design and build the plant)

- Instrumentation and control

- Electrical Systems

- Radiological Waste Management

  • The clarifications address a subset of topics that are reviewed in the CP application and not intended to be inclusive of all topics expected in a CP application.
  • Regulatory Guides 1.70 and 1.206 provide insights on the level of detail for an LWR CP application consistent with the NUREG-0800 SRP structure.

9

CP Guidance for Advanced Reactors (Appendix C)

  • References Advanced Reactor Content of Application Project (ARCAP) guidance instead of NUREG-0800

- ARCAP guidance is broad and addresses complete application

- ARCAP guidance references technology inclusive content of application project (TICAP) guidance under development

  • Uses italics to identify ARCAP/TICAP guidance and industry codes currently under development
  • Consistent with:

- Non-Light Water Reactor Review Strategy Staff White Paper, dated September 2019 (ADAMS Accession No. ML19275F299)

- Preapplication Engagement to Optimize Application Reviews January 12, 2021, version (ADAMS Accession No. ML21014A267) 10

CP Guidance for Advanced Reactors (Appendix C)

  • This guidance addresses the minimum information necessary in a CP application for the staff to issue a CP under 10 CFR 50.35(a) when the applicant has not supplied all of the technical information required to complete the application (i.e., 50.34(a)) and support the issuance of a CP which approves all proposed design features (i.e.,

obtains finality for the design).

  • Where an applicant desires design finality regarding a specific topic, the application should provide sufficient information about the topic at a level of detail that is expected at the operating license (OL) stage.

11

CP Guidance for Advanced Reactors (Appendix C)

  • Built on ARCAP/TICAP structure

- Alternate approaches to TICAP (which is based on the licensing modernization project (LMP) process) are recognized

  • Preapplication engagement with NRC is highly encouraged if applicant chooses an alternate approach to LMP
  • Several topical areas identified in Appendix C provide guidance applicable to approaches following NRC RG 1.233 guidance and to alternate approaches, such as:

- Safety and Accident Analysis Methodologies and Associated Validation

- Site Information

- Licensing Basis Event/Design Basis Accident selection 12

CP Guidance for Advanced Reactors (Appendix C)

  • Highlights/Discussion Topics

- 10 CFR 50.35(a)(1) states in part that the Commission may issue a construction permit if it finds that the applicant has identified the major features or components incorporated therein for the protection of the health and safety of the public.

  • Confirmation or discussion that this statement applies to safety-related and non-safety related SSC with special treatment following the LMP approach

- Guidance follows the ARCAP/TICAP structure and references industry TICAP CP guidance under development

  • Staff would like to have a better understanding of topics to be included in industry guidance and timing for providing this guidance 13

CP Guidance for Advanced Reactors (Appendix C)

  • Highlights/Discussion Topics

- Structure/Content of Appendix C minimizes duplication of guidance

  • Points to ARCAP/TICAP guidance and industry codes under development
  • How best to ensure that as guidance is developed expectations are clear? Examples include:

- SSC capabilities section follows the TICAP process.

>> Staff considers Design Review Guide for instrumentation and control (I&C) would be useful if applicant using LMP identifies need for I&C that is safety related or non-safety related with special treatment

- Expectation that the application will include consensus design codes and standards (ASME, ANSI, IEEE, etc.) used for the design along with applicability to design of specific SSCs

>> Staff consider ASME Section III Division 5 under development would be included in the CP application as appropriate.

14

CP Guidance for Advanced Reactors (Appendix C)

  • Highlights/Discussion Topics

- How best to ensure that as guidance is developed expectations are clear. Examples include (continued):

Special attention should be directed to the site evaluation factors identified in 10 CFR Part 100:

- References to 100.21(f): Site characteristics must be such that adequate security plans and measures can be developed

- 100.21(g): Physical characteristics unique to the proposed site that could pose a significant impediment to the development of emergency plans must be identified

- 10 CFR Part 50 appendix E requirement that PSAR include preliminary plans for coping with emergencies 15

CP Guidance for Advanced Reactors (Appendix C)

  • Highlights/Discussion Topics

- For emergency planning, guidance uses content requirements similar to an ESP application and includes references to new 10 CFR 50.160 rule:

  • Describe any physical characteristics of the proposed site, such as egress limitations from the area surrounding the site, that could pose a significant impediment to the development of emergency plans
  • Describe the major features of the emergency plans which are aspects of the plan necessary to:

- Address in whole or part either one or more of the 16 standards in 10 CFR 50.47(b) or the proposed requirements of 10 CFR 50.160(b) , as applicable; or

- Describe the emergency planning zones as required in 10 CFR 50.33(g).

16

Next Steps

  • Consider stakeholder feedback and further develop guidance
  • Issue Draft LWR CP ISG for public comment in Summer 2021
  • Appendix C - may be issued separately when the draft guidance is more developed 17

Applicability of Regulations 18

=

Background===

19

Status of Technology Inclusive Content of Application Project (TICAP) and Advanced Reactor Content of Application Project (ARCAP) 20

Background

  • High-level ARCAP proposal discussed during August 2020 and October 2020 TICAP/ARCAP public meetings. Proposal included:
  • ARCAP proposed guidance document would provide a roadmap for developing an application
  • Roadmap leverages existing guidance or guidance that is under development
  • Examples include:
  • TICAP developing guidance for portions of application using LMP process
  • Emergency planning and security rulemaking will provide insights to this portion of the application
  • Roadmap also identifies areas where additional guidance is needed (Technical Specifications).
  • ARCAP guidance document not intended to replicate NUREG-0800, Standard Review Plan for LWRs 21

Status of TICAP and ARCAP Guidance Documents

  • Industry-led TICAP guidance document continues to be developed and refined
  • Series of tabletops exercises scheduled to provide feedback for TICAP guidance document development effort.
  • February 3, 2021 - First TICAP tabletop exercise (X-Energy) observed by NRC
  • Additional TICAP tabletop exercises - three more being scheduled (see December 10, 2020, public meeting slides for details regarding tabletop exercise scope and purpose at ADAMS Accession No. ML20344A057)
  • Per recent discussions with Southern, the TICAP guidance document schedule has been revised to reflect:
  • Interim Southern-developed TICAP documents that will be provided
  • NEI proposed plans for providing industry TICAP guidance document, Revision 0 22

Status of TICAP and ARCAP Guidance Documents

  • Plans for staff-developed ARCAP guidance documents continue to evolve
  • Staff-developed ARCAP sections to be discussed during this meeting:
  • ARCAP Roadmap interim staff guidance (ISG) (to be discussed later)
  • ARCAP Chapter 11, Organization
  • ARCAP Chapter 12, Initial Startup Program
  • Previous ARCAP Sections that have been developed include:
  • ARCAP Chapter 2, Site Information
  • ARCAP Chapter 9, Control of Routine Plant Radioactive Effluents, Plant Contamination, and Solid Waste
  • ARCAP Chapter 10, Control of Occupational Dose 23

Status of TICAP and ARCAP Guidance Documents

  • Timeline from October 22, 2020, public meeting updated to reflect status of ARCAP/TICAP guidance documents
  • Changes include addition of interim industry-developed TICAP guidance documents
  • Integration of TICAP and ARCAP guidance documents
  • Overall impact is a slip of approximately 3 months for issuance of TICAP and ARCAP guidance documents 24

Status of TICAP and ARCAP Guidance Documents

  • Assumptions/Discussion Topics Outline (FSAR)
  • Industry-developed TICAP guidance document will not include guidance for the 1. General Plant Information, Site Description, and Overview of the Safety specific-portions of the first 8 SAR Case chapters that are outside the scope of the 2. Generic Analyses licensing modernization project (LMP) 3. Licensing Basis Event (LBE) Analysis
4. Integrated Plant Analysis
  • Examples where guidance is being 5. Safety Functions, Design Criteria, and developed outside the scope of LMP SSC Categorization
6. Safety Related SSC Criteria and that could affect the first 8 chapters of Capabilities a SAR are: 7. Non-safety related with special treatment SSC Criteria and Capabilities
  • Site information - ARCAP 8. Plant Programs chapter 2 9. Control of Routine Plant Radioactive
  • ASME Section III, Division 5 high Effluents, Plant Contamination, and Solid Waste temperature design guidance 10. Control of Occupational Doses
  • Fuel qualification guidance 11. Organization
12. Initial Startup Programs 25

Status of TICAP and ARCAP Guidance Documents

  • Questions
  • How will NRC TICAP RG acknowledge the guidance that is being developed to supplement the industry-led TICAP guidance for the first 8 chapters of the SAR?
  • Preliminary thinking is limit NRC TICAP RG scope to those portions of the SAR Chapters 1 through 8 associated with the LMP. This RG may provide supplemental guidance on chapters 1 - 8 application content.
  • ARCAP guidance will include supplemental guidance for application areas outside of the first 8 chapters of the SAR.
  • ARCAP acknowledges approaches for an applicant not using the LMP.

How best to update this guidance as Part 53 addresses this issue?

  • How will the NRC issue ARCAP guidance that references guidance still under development that has long lead times (e.g., security and EP rulemaking)?
  • Preliminary thinking is that ARCAP roadmap ISG will stay in draft form until guidance under development is finalized 26

Legend Timeline for Technology Inclusive Content of Industry TICAP Interim Guidance Document Industry Action Application Project (TICAP) Guidance and (Final) 9/8/2021 NRC Staff Action Advanced Reactor Content of Application NEI Revision 0 of TICAP Guidance Project (ARCAP) Guidance (rev 2/10/2021) Document Industry/NRC 10/8/2021 Joint Action NRC/Industry brief ACRS Subcommittee on TICAP guidance documents (NEI, Rev0 and Notes:

Staff Draft RG)

  • TICAP portion of the application based on applying licensing modernization project process to 11/15/2021 appropriate portions of an application. TICAP milestones shown above the timeline
  • ARCAP broader than TICAP. Provides roadmap for all portions of an application and NEI Revision 1 of TICAP Guidance Document encompasses TICAP 12/19/2021
  • Timeline does not reflect TICAP and ARCAP efforts that started in December of 2019. These early efforts led to the development of the industry-led TICAP Annotated Outline discussed in NRC/Industry brief ACRS an October 22, 2020, public meeting and the NRC-led ARCAP outline plan discussed in a Subcommittee on final TICAP August 27, 2020, public meeting guidance 1/12/2022 Industry TICAP Interim Guidance Document NRC/Industry brief ACRS (Draft) Full Committee on final 4/15/2021 TICAP guidance 2/3/2022 11/1/2020 TICAP Tabletop Exercises 4/2/2021 Issue TICAP Tabletop Exercises report 5/31/2021 NRC TICAP Regulatory Industry TICAP Annotated Outline NRC TICAP Regulatory Guide (Draft) Guide 10/22/2020 10/15/2021 3/25/2022 Aug Oct Dec Feb Apr Jun Aug Oct Dec Feb 2022 8/27/2020 1/30/2021 10/15/2021 NRC ARCAP entire application outline ARCAP Application Outline Updated to be Draft ARCAP Roadmap ISG, ARCAP ISG for Consistent with TICAP outline "Site Information," and ARCAP Chapters 9, 10, 11, and 12 issued 27

Advanced Reactor Content of Application Project (ARCAP) Draft Roadmap Interim Staff Guidance (ISG) Considerations 28

Draft ARCAP Roadmap ISG Considerations

  • Developed based on ARCAP plan discussed in past public meetings
  • Updated ARCAP spreadsheet available at ADAMS Accession No. MLxxxxxx
  • Spreadsheet provides pointers to various guidance being considered or under development including:
  • Pointers to Industry-developed TICAP guidance document (safety analysis report (SAR) Chapters 1 through 8) o As needed, Staff-developed TICAP Reg Guide provides supplemental guidance for these chapters (e.g., site information, ASME Section III, Division 5, etc.)
  • SAR Chapters outside of TICAP scope including:

o ARCAP chapters 9, 10, 11, and 12

  • Portions of the application outside the SAR 29

Draft Roadmap ARCAP Roadmap ISG with Performance Based Approach Additional Portions of Application Outline (FSAR)

  • Technical Specifications
  • Technical Requirements Manual*
1. General Plant Information, Site
  • Quality Assurance Plan (design)

Description, and Overview of the Safety

Case

  • PRA*
2. Generic Analyses
  • Quality Assurance Plan (construction
3. Licensing Basis Event (LBE) Analysis and operations)
4. Integrated Plant Analysis Audit/inspection of Applicant Records
5. Safety Functions, Design Criteria, and
  • Calculations
  • Physical Security Plan SSC Categorization
  • Analyses
6. Safety Related SSC Criteria and
  • SNM material control and accounting
  • System Descriptions Capabilities
  • Design Drawings plan
7. Non-safety related with special treatment
  • Design Specs
  • Procurement Specs
8. Plant Programs
  • Radiation Protection Program
9. Control of Routine Plant Radioactive
  • Inservice inspection/Inservice testing Waste (ISI/IST) Program
10. Control of Occupational Doses
  • Environmental Report
11. Organization
  • Site Redress Plan
12. Initial Startup Programs
  • Exemptions, Departures, and Variances
  • Facility Safety Program (under consideration for Part 53 applications)

Exemptions, departures and variations, new fuel shipping plan, and site redress plan not in ARCAP roadmap ISG at this time. May need to be considered for future applications

  • Denotes that expectations regarding the availability of the probabilistic risk assessment and the technical requirements manual as part of the application are a topic of future interactions.

30

Draft ARCAP Roadmap ISG

  • Highlights/Topics of Discussion
  • ARCAP structure for SAR informed by:

- industry led TICAP annotated outline discussed in October 2020, public meeting (see ADAMS Accession No. ML20294A382) and

- Staff developed annotated outline discussed in an April 2020, public meeting (see ADAMS Accession No. ML20107J565)

  • First 8 chapters of Staff-developed TICAP Reg Guide structure:

- Provides pointers to industry-developed TICAP guidance document

- Will describe any additional clarifications/exceptions to TICAP document

- Basis for additional reference section could consider guidance that is referenced in April 2020 annotated outline and fact of life changes since that time

>> As indicated in above slides, industry-led TICAP guidance limited to LMP portions of application found in first 8 chapters of the SAR 31

Draft ARCAP Roadmap ISG

  • Highlights/Topics of Discussion
  • ARCAP SAR Chapters 9, 10, 11, and 12, are under development and have been discussed in public meetings

- ARCAP Chapters 11 and 12 to be discussed later in this meeting

  • ARCAP ISG related to Site Information could be included in SAR Chapter 2

- Unsure if this will be part of Staff-developed TICAP guidance or Staff-developed ARCAP guidance

  • Placeholders for guidance outside of the SAR (e.g.,

technical specifications) 32

Draft ARCAP Roadmap ISG

  • Next Steps
  • As discussed in previous presentation on TICAP/ARCAP schedule there is a need to determine what will be within the scope of NRC RG associated with TICAP and what will be in ARCAP scope

- That is, how will supplemental guidance for SAR Chapters 1 through 8 be captured

  • Determine the structure of the ARCAP guidance

- If proposed structure is not workable, then alternate approach/structure needs to be developed

  • Need to determine if there are gaps in the TICAP/ARCAP SAR guidance under development
  • Need to consider feedback on advanced reactor construction permit guidance and impact it might have on TICAP or ARCAP guidance 33

Draft ARCAP Roadmap ISG

  • Next Steps
  • ARCAP guidance for portions of application outside of the SAR

- Staff believes that there is a near-term need to develop risk-informed, technology inclusive and performance-based guidance for technical specifications and risk-informed inservice inspection and inservice testing programs

>> Staff would like to understand if industry plans to develop guidance for these items

- Need to determine if there are gaps in guidance for portions of an application outside of the SAR

>> For example, facility safety program being considered for Part 53 is a known gap

- The scope of ARCAP needs to be determined

>> Staff considering whether it is appropriate to have an ARCAP roadmap ISG to support near-term Part 50/52 applications, and a separate ARCAP roadmap ISG for Part 53 applications 34

Advanced Reactor Content of Application Project (ARCAP) Chapter 11, Organization, and Chapter 12, Initial Startup Program.

35

ARCAP ISG Chapter 11, Organization

  • APPLICABILITY 3/4 The following Part 50/52 applications for light water reactors (LWRs), non-LWRs, stationary micro reactors and small modular LWRs:

o A construction permit (CP) or operating license (OL) under 10 CFR Part 50 o A combined license (COL), a design certification (DC), or a standard design approval (SDA) under 10 CFR Part 52 3/4 Applications for a power reactor construction permit and operating license under 10 CFR Part 53.

o As the 10 CFR Part 53 requirements are finalized this ISG guidance will be supplemented, as necessary, to provide guidance in the organizational and training areas to reflect any differences in requirements between Part 50/52 and Part 53 36

ARCAP ISG Chapter 11, Organization (cont.)

  • Guidance -

Design, Construction, Operating Organization - Key Management Positions 3/4 For a CP/OL or COL applicant provide, in part:

o Organizational charts of the applicant's corporate-level management, technical support, and operations organizations, including organizational and management structure responsible for direction and support of design and construction of the proposed plant o A general staffing plan for construction, startup testing o Plans (preliminary for CP applicants) for the applicant's operations organization, including a general staffing plan for operations (OL and COL) 37

ARCAP ISG Chapter 11, Organization (cont.)

  • Guidance -

Design, Construction, Operating Organization - Key Management Positions (continued) 3/4 For the design, construction and preoperational period (DC, SDA, CP/OL or COL), describe key management responsibilities in the following areas:

o Principal site-related engineering studies o Design of safety-significant (i.e., safety-related and non-safety-related with special treatment) SSCs, including SSC design features o Development of probabilistic risk assessment (PRA),

defense-in-depth, and license basis event analysis o Material and component specification review and approval o Procurement of materials and equipment o Management of construction activities o Quality assurance activities for design and construction 38

ARCAP ISG Chapter 11, Organization (cont.)

  • Guidance -

Design, Construction, Operating Organization - Key Management Positions (continued) 3/4 For the operational period (OL or COL), key management responsibilities in the following areas should be described:

o Nuclear, PRA, mechanical, structural, electrical, thermal-hydraulic, metallurgy and materials, and instrumentation and controls engineering (design and technical support) o Plant chemistry and health physics o Fueling and refueling operations support o Maintenance support o Operations support o Fire protection o Quality assurance o Training o Safety review o Startup testing o Emergency planning o Security 39

ARCAP ISG Chapter 11, Organization (cont.)

  • Guidance -

Educational and Experience Requirements for Key Management Personnel 3/4 The application should describe the educational and experience requirements for each key management position described on previous slides 3/4 For a CP or COL application, the information should describe the applicants past experience in the design and construction of nuclear power plants 3/4 The CP or COL applications should include information that demonstrates the ability of the technical staff to support or perform the safety-related activities specified in the application, as applicable, including the level of risk analysis experience available to perform necessary probabilistic risk assessments 40

ARCAP ISG Chapter 11, Organization (cont.)

  • Guidance -

Training for Plant Staff 3/4 Licensed Operator Training o OL and COL application should provide a description and schedule of the training programs for reactor operators and senior reactor operators including the use of a simulator 3/4 Non-licensed Personnel Training o For OL and COL applicants, describe the training program for non-licensed nuclear plant personnel that meets the requirements of 10 CFR 50.120(b)(2) and (b)(3) 3/4 An applicant may provide a commitment to meet the guidelines of Nuclear Energy Institute (NEI)06-13A, Template for an Industry Training Program Description, for its licensed operator and non-licensed personnel training programs 3/4 CP applicants should provide commitments to provide the information requested for the OL application 41

ARCAP ISG Chapter 11, Organization (cont.)

  • Guidance -

Basis/number of operating shift crews, their staffing and responsibilities 3/4 Describe the functions, responsibilities, and authorities of the following plant positions (OL or COL):

o operations supervisors o operating shift supervisors/managers o shift technical advisors o reactor operators and senior operators o non-licensed operators 3/4 The application should describe the shift position titles, applicable operator licensing requirements for each, and the minimum numbers of personnel planned for each shift for all combinations of modules/units proposed to be at the station in either operating or safe shutdown mode 42

ARCAP ISG Chapter 11, Organization (cont.)

  • Guidance -

Basis/number of operating shift crews, their staffing and responsibilities (continued) 3/4 If an exemption is necessary from the licensed operator staffing requirements described in 10 CFR 50.54(m), the applicant should provide a basis for this exemption utilizing the guidance contained in NUREG-1791, Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m) 3/4 For CP applicants, these plans are not required to be fully developed, provided that the applicant makes commitments to ensure that the staffing plans are included in the OL application 43

ARCAP ISG-Chapter 12

  • Applicability:

- ISG-12 (ML ) provides guidance for the Initial Startup Program (ISP) for CP, OL, COL, DC, SDA and ML applications.

- ISG-12 has been developed as part of ARCAP, since TICAP does not address this area.

- ISG-12 is written to describe what the NRC reviewer is expected to look for in the review.

- ISG-12 is subject to future revision to be compatible with Part 53.

44

ARCAP ISG-Chapter 12

  • Guidance:

- The purpose of the ISP is to demonstrate, to the extent possible, that the safety-related and safety-significant SSCs operate in accordance with the design and as described in the safety analysis report (SAR).

- ISG-12 allows all, or part, of the ISP to be documented in a report separate from the SAR, provided the document is referenced and summarized in the SAR.

45

ISG-12: Scope

  • Guidance (continued):

- Testing and analysis should be sufficient to demonstrate SSC performance over the full range of operating conditions.

- Risk insights should be used to help focus the testing on the most safety significant conditions.

- Retesting should be done if plant modifications are made.

- Parallels the scope contained in RG 1.68, Initial Test Programs for Water-Cooled Nuclear Power Plants, but expressed in technology inclusive terms in a less prescriptive fashion.

46

ARCAP ISG-Chapter 12

  • Guidance (continued):

- The ISP is organized into two phases:

3/4 Phase 1 - Preoperational Testing (prior to fuel load) 3/4 Phase 2 - Initial Startup (fuel load to power ascension)

- Phase 1 is applicable to all applications.

- Phase 2 is not applicable to CP applications.

- Programmatic items (applicable to all applications) include:

3/4 Test descriptions 3/4 Responsibilities and conduct of the ISP 3/4 Test sequencing, prerequisites and schedule 3/4 Use of procedures and qualified personnel 3/4 Use of plant procedures and Tech Specs 3/4 ITAAC, if applicable 47

ARCAP ISG-Chapter 12

  • Phase 1 Testing:

- Reactivity control features.

- Heat removal system operation and integrity.

- Integrity and operation of functional containment.

- Radioactive waste handling, processing and storage systems

- Radiation and criticality monitoring systems

- Testing required by Codes and Standards.

- Flow induced vibration and thermal expansion.

- I & C and electrical systems.

- Fuel handling and storage systems.

- Support systems.

48

ARCAP ISG-Chapter 12

  • Phase 2 Testing:

- Initial fuel loading and reactor physics tests.

- Low power testing.

- Power ascension testing.

- Residual heat removal system testing.

- Gaseous and liquid waste system testing.

- Flow induced vibration and thermal expansion.

- First-of-a-kind, inherent and passive safety feature testing.

49

Next Steps - Future Meeting Planning and Open Discussion - Tentative Near-Term Advanced Reactor Public Stakeholder Meetings March 4, 2021 (Part 53)

April 8, 2021 (Part 53)

April 15, 2021 (Periodic)

April 22, 2021 (Part 53 - ACRS Subcommittee)

May 6, 2021 (Part 53)

Next TICAP/ARCAP Meeting?

50

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