ML21278A029

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10-5 Ticap Meeting Combined Slides
ML21278A029
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Issue date: 10/05/2021
From: Joseph Sebrosky
NRC/NRR/DANU
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Sebrosky J
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Download: ML21278A029 (35)
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Technology Inclusive Content of Application Project Public Meeting October 5, 2021 Microsoft Teams Meeting Bridgeline: 301-576-2978 Conference ID: 968 028 925#

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Agenda Time Topic Speaker 2:00 - 2:10 pm Opening Remarks NRC/Industry 2:10 - 2:40 pm Overview of Staff Comments on NEI NRC 21-07, Revision 0*

2:40 - 3:30 pm Discussion of Comments NRC/Industry 3:30 - 3:45 pm Stakeholder Questions All 3:45 - 4:00 pm Break (if needed) All 4:00 - 4:15 pm Continuation of Discussion of NRC NRC/Industry Comments 4:15 - 4:20 pm Stakeholder Questions All 4:20 - 4:30 pm Next Steps and Closing Remarks NRC/Industry

  • Note that Industry's TICAP guidance document is available at:

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML21250A378 2 of 35 2

TICAP Public Meeting

  • The purpose of this meeting is to discuss with the nuclear industry issues related to the draft guidance document for safety analysis report (SAR) content for an advanced reactor application based on the licensing modernization project (LMP) described in NEI 18-04
  • Key documents associated with this meeting are referenced in the meeting notice and include:
  • NEI 21-07, Rev 0, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Using the NEI 18-04 Methodology (ADAMS Accession No. ML21250A378)
  • NRC draft exceptions, clarifications, and additions (ADAMS Accession No. ML21274A032)

ARCAP and Technology Inclusive Content of Application Project (TICAP) - Nexus Outline Safety Analysis Report (SAR) - Additional Portions of Application Based on TICAP Guidance

  • Technical Specifications
1. General Plant Information, Site
  • Technical Requirements Manual Description, and Overview of the Safety
  • Quality Assurance Plan (design)

Case

2. Methodologies and Analyses
  • Quality Assurance Plan
3. Licensing Basis Event (LBE) Analysis (construction and operations)
4. Integrated Evaluations Audit/inspection of Applicant Records
5. Safety Functions, Design Criteria, and
  • Calculations
  • Physical Security Plan SSC Safety Clasification
  • Analyses
6. Safety Related SSC Criteria and
  • SNM material control and Capabilities
  • System Descriptions accounting plan
7. Non-safety related with special treatment
  • Design Drawings
  • Design Specs
8. Plant Programs
  • Procurement Specs (operational)
  • Radiation Protection Program Additional SAR Content -Outside the Scope
  • Inservice inspection/Inservice
9. Control of Routine Plant Radioactive testing (ISI/IST) Program Effluents, Plant Contamination, and Solid
  • Environmental Report Waste
  • Site Redress Plan
10. Control of Occupational Doses
  • Exemptions, Departures, and
11. Organization Variances
12. Initial Startup Programs
  • Facility Safety Program (under consideration for Part 53
  • Safety Analysis Report (SAR) structure based on clean applications) sheet approach 4 of 35
  • Additional contents of application outside of SAR are still under discussion. The above list is draft and for illustration purposes only. 4

Overview of NRC Comments on NEI 21-07, Rev 0 Table identifying exceptions, clarifications, and additions, keyed to the NEI 21-07 section numbers as follows:

  • Exception - used to indicate statements, or portions thereof, in NEI 21-07 that are factually incorrect or guidance that would result in the need for an NRC Request for Additional Information (RAI) if followed by an applicant in developing a safety analysis report (SAR)
  • Clarification - used to indicate statements or guidance in NEI 21-07 that are ambiguous and would require clarification by the NRC to limit the possible interpretations by an applicant or other stakeholder consulting NEI 21-07.
  • Addition - used to indicate staff regulatory guidance that should be followed by an applicant in addition to the guidance in NEI 21-07 in order to develop a SAR that addresses the safety case.

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Overview of NRC Comments on NEI 21-07, Rev 0 41 items

  • 3 exceptions
  • Interpretation of principal design criteria (PDC) has not been categorized
  • Staff position under development
  • 17 clarifications
  • 11 clarifications/additions
  • 9 additions 6 of 35 6

Overview of NRC Comments on NEI 21-07, Rev 0 Exceptions

  • The SAR should include a description of the models, site characteristics, and supporting data associated with the calculation of the mechanistic source terms and radiological consequences (to the extent such information is not provided in Section 2.2) for AOOs, DBEs and BDBEs
  • The following is the basis for the exception:
  • The models, site characteristics, and supporting data associated with the calculation of the mechanistic source terms and radiological consequences for AOOs, DBEs and BDBEs are essential elements used in the safety case establishing the design bases or in the safety analyses.
  • The SAR should capture the safety case for the reactor; the safety case is tied to appropriately identifying licensing basis events, including AOOs, DBEs, DBAs, and BDBEs.
  • Omission of this information from the SAR would run counter to the Commission's regulations on the control of changes. (See, e.g., 10 CFR 50.59.)

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Overview of NRC Comments on NEI 21-07, Rev 0 Evaluation of Changes to the Plant

  • Several criteria in 10 CFR 50.59 could apply to licensing basis event information developed from the LMP process including:
  • (c)(2)(ii) more than minimal increase in the likelihood of a malfunction of an SSC important to safety
  • (c)(2)(iv) more than minimal increase in the consequences of a malfunction of an SSC important to safety
  • (c)(2)(viii) results in a departure from a method described in the FSAR in establishing the design bases or in the safety analysis
  • Criteria for evaluation of changes to the plant proposed for 10 CFR Part 53 rulemaking that assume licensing basis event information is captured in the FSAR 8 of 35 8

Overview of NRC Comments on NEI 21-07, Rev 0 Examples of Level of Information for AOOs, DBE, BDBEs in the safety analysis report based on level of information found in Vogtle 3 and 4 final safety analysis report from Section 15.6.2, Failure of Small Lines Carrying Primary Coolant Outside Containment (see: ADAMS Accession No. ML21179A102) 9 of 35 9

Overview of NRC Comments on NEI 21-07, Rev 0 Examples of Level of Information for AOOs, DBE, BDBEs in the safety analysis report (continued) 10 of 35 10

Overview of NRC Comments on NEI 21-07, Rev 0 Example clarifications

  • Item A.2 - In addition to making a safety case, an applicant should also make a licensing case that focuses on compliance with applicable regulations and includes any exemptions necessary.
  • Item A.3b, and B2 - the safety case should include normal operations as well as licensing basis events.
  • Item B.3 - Explanation and use of text that is in italics. Further explanation is needed clarifying the use of regular text and text in italics. Staff identified 15 areas where regular text vice italicized text should be used.
  • Item 5.6b and 5.6c - Complementary Design Criteria discussion in the SAR should include the relevance of CDC in establishing the engineering criteria for the design 11 of 35 11

Overview of NRC Comments on NEI 21-07, Rev 0 Example clarifications/additions

  • Item A.3a - the staff will continue to reference in TICAP RG the guidance that is relevant to the first 8 chapters of the SAR (e.g.,

siting, fuel qualification, instrumentation and control design review guide).

  • Item 2.1.1b - Discussion of PRA information to be included in the SAR.
  • Item 5.6a - Complementary design criteria should be provided in the SAR as part of the safety case. The staff notes that the discussion of the CDC in the SAR could be influenced by the outcome of the discussion of principal design criteria.

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Overview of NRC Comments on NEI 21-07, Rev 0 Example additions

  • Human Factors consideration in the SAR - relates to items 4.2.2, 4.2.2.3, 6.4.1a, 6.4.1b, 7.3.1a, and 7.3.1b.
  • Staff is considering additions to either the TICAP RG or ARCAP Chapter 11 (or both) to capture guidance regarding human factors engineering.

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NEI 21-07 Rev. 0 Technical Report Technology Inclusive Guidance for Non-Light Water Reactors Initial Clarification Questions on Nuclear Regulatory Commission (NRC) Feedback Steve Nesbit, LMNT Consulting NEI - Nuclear Regulatory Commission (NRC) Meeting October 5, 2021 14 of 35 1

2 Overview

  • NEI submitted NEI 21-07 Rev 0 Technology Inclusive Guidance for Non-Light Water Reactors to the NRC on August 30, 2021
  • NRC provided draft exceptions, clarifications and additions to NEI on September 30, 2021

- Technology Inclusive Content of Application Project (TICAP) Team appreciates the NRC feedback

- Team has not had time to address all draft exceptions, clarifications and additions in detail

  • This presentation summarizes initial clarification questions for the NRC 15 of 35 2

B.2 Affirmative Safety Case

  • NRC wishes to clarify that an affirmative safety case should include normal operation as well as LBEs (licensing basis events)
  • The TICAP affirmative safety case definition does not include normal operations (see Section A.3, p. 3), consistent with the Licensing Modernization Project (LMP) focus
  • NRC has not previously commented on the affirmative safety case definition

- Does NRC want to change the definition?

- Why is this comment tied to the SAR Outline (Section B.2)?

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B.3 Explanation and Use of Italics

  • NRC says further discussion is needed in either NEI 21-07, Revision 1, or the TICAP draft RG white paper clarifying the meaning of the use of the regular text and text in italics throughout the SAR content guidance in Section C of NEI 21-07 (examples provided)
  • TICAP modified the italics criteria in Section B.3 (top of p. 9) to make them clear and straightforward prior to submitting NEI 21-07
  • Does NRC believe the criteria need further explanation, or does NRC disagree with the application of the criteria as noted by the examples?

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B.5 Two-Step Licensing

  • In the first paragraph NRC raises points about

- inclusion of normal operation in the affirmative safety case

- compliance with or exemptions from the regulations

  • Are these possibly general points rather than items to be addressed under two-step licensing?
  • Why is the ITAAC point applicable to two-step licensing?
  • In the second paragraph NRC discusses the shift from prescriptive regulations to a focus on the identification and performance of fundamental safety functions

- Is this a point for two-step licensing, or more general?

- The point may be addressed already generically, in other parts of the introductory material 18 of 35

>> See Section A.3, paragraph following the definition of affirmative safety case (p. 4) 5

B.6 Design Certification

  • NRC desires more discussion to clarify that the SAR content developed through use of LMP is similar in scope only to the Tier 2 information required for a DC application.
  • Is the NRC implying that the LMP scope information is only Tier 2 information for a design certification?

- If so, what is the basis for that perspective?

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1b Licensing Basis Information

  • Regarding the first part of the sentence (Chapter 1 material), the NRC wants clarification on what is part of the licensing basis
  • During the development of the guidance, the TICAP team removed statements in earlier drafts of the guidance that the material is not part of the licensing basis and added, in the guidance, the statement that It is understood that as part of the SAR, Chapter 1 will be maintained and updated as changes to Chapters 2 through 8 occur. (p. 15)

- What additional clarification is sought?

  • Regarding the second part of the sentence (what parts of the regulation the material seeks to fulfill), is the intent that the guidance instruct the inclusion of a compliance matrix?

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1.3.3 Defense in Depth (DID) in Chapter 1

  • The NRC states Further discussion is needed in either NEI 21-07, Revision 1, or the TICAP draft RG white paper to clarify that DID adequacy is based on 3-elements; plant capability DID, programmatic DID, and RIPB DID. Applicants should address risk-informed, performance-based DID also and cite key examples for this DID element.
  • What is the basis for providing such a description in the Chapter 1 introductory material?

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2.1.1a Trial Use Regulatory Guide 1.247

  • The NRC says NRC staff positions in RG 1.247, once issued, should be addressed along with the Std.
  • Does this clarification have any relevance for the current version of NEI 21-07?

- It was the TICAP teams intention not to address the regulatory guide until it has been formally issued 22 of 35 9

2.1.2 Summary of Key PRA Results

  • The NRC desires to see further discussion of human actions
  • Is the comment about human actions pertinent to this PRA section or is it intended as a broader comment on NEI 21-07 as a whole?

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3.3 Anticipated Operational Occurrences (AOOs)

  • The NRC states Further discussion is needed in either NEI 21-07, Revision 1, or the TICAP draft RG white paper to clarify that non-DBA LBE as analyzed in the PRA should be summarized in the SAR.
  • NEI 21-07 requires documentation of AOOs, design basis events, beyond design basis events, and design basis accidents

- What is the basis for the stated need for further discussion, given that it appears to be covered already in the guidance?

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3.3.1 - Key Information on AOOs (also 3.4.1 and 3.5.1)

  • The NRC states in this clarification and exception comment that additional information should be required by the guidance (models, site characteristics, etc., associated with radiological consequences)
  • The stated basis is that the safety case is tied to licensing basis events and the information needs to be in the SAR for purposes of change control
  • The TICAP team seeks clarification of the nexus between the desired information and the stated basis
  • This also applies to the clarification and exception for 3.4.1 (design basis events) and 3.5.1 (beyond design basis events) 25 of 35 12

4.1 Overall Plant Risk Information

  • The NRC desires further discussion of the analytical methodologies used (site parameters, location of members of the public, source of dose, analysis method, etc.)
  • What is the basis for the need for this information?

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4.2.1.4 Prevention-Mitigation Balance

  • The NRC is requesting the inclusion of ADAMS ML numbers or hyperlinks for ease of reference
  • Please clarify that this is a generally applicable comment and not specific to Section 4.2.1.4 of NEI 21-07 27 of 35 14

4.2.3c Change Process for Defense-in-Depth

  • The NRC wishes to add guidance that the applicant describe the change control process in the SAR
  • What is the basis for putting descriptive information on the change control process in the SAR?

- The TICAP team agrees that guidance is needed, but that does not necessarily justify a requirement for such information in the SAR 28 of 35 15

5.3 Principal Design Criteria (PDC)

  • The NRC comment is not categorized, and it covers a lot of matters related to PDC
  • What are the fourth paragraph proposed edits?

- The NRC markup provides no proposed edits to the fourth paragraph

  • The comment refers to stated NRC positions

- Please clarify what those positions are and where they can be found

  • Please clarify the end of the comment

- It ends with a sentence fragment that is not clear 29 of 35 16

5.5.1 Non-Safety-Related Structures, Systems and Components (SSCs)

  • The NRC comment indicates a desire for similar information to Tables 5-1 and 5-2 for some Non-Safety-Related with Special Treatment (NSRST) SSCs
  • Note that Tables 5-1 and 5-2 are supporting material in the guidance and the tables are not intended for inclusion in the SAR for safety-related SSCs per NEI 21-07

- Please clarify this stated need for information on NSRST SSCs 30 of 35 17

5.6a, 5.6b, and 5.6c Complementary Design Criteria (CDC)

  • The NRC clarification and addition comments address aspects of CDC relating to the affirmative safety case and PDC
  • The TICAP team would like clarification on the comments themselves and the basis for the cited needs for additional discussion in the SAR
  • Do these comments relate to the forthcoming NRC position on PDC?

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6.1.1b Design Basis Hazard Levels (DBHLs)

  • The NRC clarification comment cites a need for further discussion on the calculation methodology for DBHL loads
  • The TICAP team attempted to address this point in NEI 21-07 through the last italicized paragraph on p. 52 which states that it is covered by ARCAP instead of TICAP
  • Please explain the need for additional clarification 32 of 35 19

6.1.1c DBHL Discussion

  • The NRC clarification and addition comment is to summarize the basis for the DBHLs in the SAR
  • The TICAP team attempted to address this point in NEI 21-07 through the paragraph above Table 6-1
  • Please explain the need for additional clarification 33 of 35 20

Appendix B Example LBE Descriptions

  • The NRC says The staff does not plan to endorse Appendix B Example Descriptions of NEI 21-07 because the agency does not endorse examples provided in guidance documents due to the need for technical review and approval.
  • The TICAP team never intended that the NRC perform a technical review of the material

- The intent of the examples is only to show how to document LBE descriptions

- TICAP considers the validity of the underlying analyses to be irrelevant to the value of the example

  • Please clarify why any technical review and approval by the staff is considered necessary 34 of 35 21

Next Steps - Future Milestones TICAP Near-Term Milestones Target Date Update of NRC Draft Guidance Documents October 2021 ACRS Future Plants Designs December 15, 2021 Subcommittee Meeting on ARCAP/TICAP Guidance Documents Continuation of Discussion of NRC draft TBD Exceptions, Clarifications, and Additions (possibility of future draft industry or staff documents)

NEI 21-07, Revision 1 February 2022 35 of 35

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