ML21181A335

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June 23, 2021, Summary of Public Meeting to Discuss Technology Inclusive Content of Application Project
ML21181A335
Person / Time
Site: Grand Gulf, Arkansas Nuclear, River Bend, Waterford  Entergy icon.png
Issue date: 07/01/2021
From: Joseph Sebrosky
NRC/NRR/DANU
To: John Segala
NRC/NRR/DANU
Sebrosky J
References
Download: ML21181A335 (6)


Text

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 Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF JUNE 23, 2021, PUBLIC MEETING TO DISCUSS TECHNOLOGY INCLUSIVE CONTENT OF APPLICATION PROJECT On June 23, 2021, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting with stakeholders, to discuss the technology inclusive content of application project (TICAP).

The meeting notice is available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML21173A335, and the presentation slides are available at ADAMS Accession No. ML21173A262. The enclosure to this summary provides the attendees for the meeting as captured by Microsoft Teams.

The purpose of this meeting was to discuss with the nuclear industry issues related to the draft TICAP guidance document for Safety Analysis Report (SAR) content for an advanced reactor application based on the licensing modernization project. The draft TICAP guidance document is available in ADAMS at Accession No. ML21106A013. The June 23, 2021, meeting was a follow-on meeting to public TICAP workshops held on:

May 11, 2021 (meeting summary available in ADAMS at Accession No. ML21132A295)

May 19, 2021 (meeting summary available in ADAMS at Accession No. ML21154A290)

May 26, 2021 (meeting summary available in ADAMS at Accession No. ML21158A223)

During these workshops the industry and NRC staff worked through 23 issues that were identified prior to the workshops. The meeting summaries note the outcome of the issues discussed during the workshops. During the May 26, 2021, workshop industry and the staff CONTACT: Joseph Sebrosky, NRR/DANU 301-4151132 July 1, 2021 Signed by Sebrosky, Joseph on 07/01/21

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identified the need to have additional discussion on two of the 23 issues: (1) principal design criteria (PDC) which was identified as issued #6 in the previous workshops, and (2) reliability and capability targets which was identified as issue #9 in the previous workshops.

Principal Design Criteria During the May 26, 2021, workshop the staff stated that the industrys TICAP approach to establishing the required functional design criteria (RFDC) as the PDC are too narrow and for example would not capture important design criteria outside the scope of the licensing modernization project (LMP) process. During the May 26, 2021, workshop industry stated that it did not believe the intent of NEI 18-04, Revision 1, Risk-Informed Performance-Based Technology Inclusive Guidance for Non-Light Water Reactor Licensing Basis Development (ADAMS Accession No. ML19241A336) was to impose deterministic PDC on a risk informed, performance-based process or to develop PDC that are outside the scope of LMP.

The June 23, 2021, meeting continued the discussion from the May 23, 2021, workshop. The staff provided several examples of advanced reactor design criteria (ARDC) from regulatory guide (RG) 1.232, Developing Principal Design Criteria for Non-Light Water Reactors (ADAMS Accession No. ML17325A611) that the staff believed the LMP process might not properly identify as PDC. The ARDC examples that the staff provided included: ARDC 10, Reactor design; ARDC 26, Reactivity control systems; ARDC 35, Emergency core cooling system; ARDC 39, Inspection of containment heat removal system; ARDC 40, Testing of containment heat removal system; and ARDC 62, Prevention of criticality in fuel storage and handling.

Industrys position is that the LMP-based safety case provides a more complete basis for a facilitys safety based on the specifics of the unique design and provides the same type of information described as PDC in the introductory text of Title 10 of the Code of Federal Regulations (CFR) Part 50 Appendix A. Industrys proposed solutions during the meeting did not include changes to the industry draft TICAP guidance document.

The staff stated that it would consider industrys position and noted that it needed to consider both the technical and legal aspects of industrys position. The staff noted that providing feedback to industry on its position prior to industrys target date of a revised TICAP guidance document in mid-July 2021, would be challenging.

Reliability and Capability Targets The NRC staff noted that industrys draft TICAP guidance document does not appear to be consistent with NEI 18-04, Rev. 1, in that the reliability and capability targets are not proposed to be captured in the safety analysis report (SAR). From the staffs perspective the SAR should describe reliability targets and performance requirements used as input to the probabilistic risk assessment and for structures, systems and components (SSCs) that were used to develop the selection of special treatment requirements (e.g., programmatic actions used to maintain performance within the design reliability targets). The staff noted this information is important to capture in the SAR and in some cases could also be captured as part of technical specification requirements.

Industry provided an example of how the reliability and capability targets are developed and proposed changes to the industry developed TICAP guidance document. Industry proposed a change to TICAP Chapter 8, Plant Programs, that would describe the programs which capture and control the SSC-level reliability and capability targets, and incorporated them by reference

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in the SAR, and that would be subject to the 10 CFR 50.59 change control process. The staff stated that it would review industrys proposed change to the TICAP guidance document and will provide feedback after it has had time to review the proposed change.

The meeting concluded with a discussion of the schedule for development of TICAP guidance documents. Highlights of this discussion included industry providing a revision to the April 15, 2015, TICAP guidance document in mid-July 2021, the staff performing a high-level review of this document, and industry providing a revision 0, to the TICAP guidance document in a Nuclear Energy Institute format in late August 2021. Interactions with the Advisory Committee on Reactor Safeguards (ACRS) were discussed and included possible interactions with the ACRS Future Plant Designs Subcommittee in late July 2021, and October of 2021.

Enclosure:

Attendance List

ML21181A335 NRC-001 OFFICE NRR/DANU/UARP/PM NRR/DANU/UARP/BC NRR/DANU/UARP/PM NAME JSebrosky JSegala JSebrosky DATE 07/01/2021 07/01/2021 07/01/2021 Enclosure June 23, 2021, Public Meeting to Discuss Technology Inclusive Content of Application Project Attendance List*

NAME AFFILIATION NAME AFFILIATION Robert Taylor NRC/NRR Amir Afzali Southern Company Nathan Sanfilippo NRC/NRR/DANU Brandon Chisholm Southern Company Martin Stutzke NRC/NRR/DANU Mike Tschiltz Nuclear Energy Institute (NEI)

Dayna Dority NRC/NRR/DANU Benjamin Holtzman NEI John Segala NRC/NRR/DANU/UARP Ed Wallace GNBC Associates William Reckley NRC/NRR/DANU/UARP Cyril Draffin US Nuclear Industry Council Maryam Khan NRC/NRR/DANU/UARP Steven Nesbit LMNT Consulting Eric Oesterle NRC/NRR/DANU/UARP George Flanagan Oak Ridge National Lab Arlon Costa NRC/NRR/DANU/UARP Frank Akstulewicz A to Z Reactor Consulting Services Juan Uribe NRC/NRR/DANU/UARP Dennis Henneke GE Power Amy Cubbage NRC/NRR/DANU/UARP Travis Chapman X-Energy Joe Sebrosky NRC/NRR/DANU/UARP Raymond Wang X-Energy Nan Valliere NRC/NRR/DANU/UARP Tom King Idaho National Lab (INL)

Jordan Hoellman NRC/NRR/DANU/UARP Tom Hicks INL Stephen Philpott NRC/NRR/DANU/UARP Jordan Hagaman Kairos Power Dawnmathews Kalathiveettil NRC/NRR/DANU/UARP Peter Hastings Kairos Power Adrian Muniz NRC/NRR/DANU/UARL William Womack Kairos Power Jan Mazza NRC/NRR/DANU/UARL Darrell Gardner Kairos Power Alexandra Siwy NRC/NRR/DANU/UART Farshid Shahrokhi Not Available (NA)

Michael Orenak NRC/NRR/DANU/UART Lance Sterling NA Imtiaz Madni NRC/NRR/DANU/UART Michael Mayfield NA Michelle Hart NRC/NRR/DANU/UART Karl Fleming NA Timothy Lupold NRC/NRR/DANU/UART Jana Bergman NA Hanh Phan NRC/NRR/DANU/UART Rob Burg NA Chris Van Wert NRC/NRR/DANU/UART Maxine Keefe NA Boyce Travis NRC/NRR/DANU/UART Adam Stein NA Tim Drzewiecki NRC/NRR/DANU/UART Richard Paese NA Alexander Chereskin NRC/NRR/DANU/UART Harry Liao NA Christian Cowdrey NRC/NRR/DRO/IOLB Srinivasan Makuteswara NA Jesse Seymour NRC/NRR/DRO/IOLB/HFT Scott Nelson NA Brian Green NRC/NRR/DRO/IOLB/HFT Tammy Morin NA David Desaulniers NRC/NRR/DRO Jason Wheelwright NA Ed Miller NRC/NRR/DORL Mike Keller NA Steven Vitto NRC/NSIR/DPCP/RSB Jason Andrus NA

2 NAME AFFILIATION NAME AFFILIATION Shakur Walker NRC/COMM/DW Ted Garrish NA Marcia Carpentier NRC/OGC Luke McSweeney NA Cameron Tarry NRC/OGC Scott Ferrara NA Derek Widmayer NRC/ACRS Kurt Harris NA Scott Bussey NRC/OCHCO/ADHRTD/

RTTB Zee St Hilaire NA Andrew Zach EPW Patrick White NA Daniel Schroeder NA Matthew Lund NA Frank Schaaf NA Fred Silady NA

  • Attendance list based on Microsoft Teams Participant list. List does not include 8 individuals that connected via phone.