ML22028A393
| ML22028A393 | |
| Person / Time | |
|---|---|
| Issue date: | 02/18/2022 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | Steven Lynch NRC/NRR/DANU/UARP |
| Sebrosky J | |
| References | |
| Download: ML22028A393 (8) | |
Text
February 18, 2022 MEMORANDUM TO: Steven Lynch, Acting 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 JANUARY 18, 2022, PUBLIC MEETING TO DISCUSS TECHNOLOGY INCLUSIVE CONTENT OF APPLICATION PROJECT On January 18, 2022, 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. ML22014A284, and the presentation slides are available at ADAMS Accession No. ML22014A167. 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 stakeholders issues related to the Nuclear Energy Institute (NEI) Technical Report 21-07, Revision 0-B, Technology Inclusive Guidance for Non-Light Water Reactors: Safety Analysis Report Content for Applicants Using the NEI 18-04 Methodology (ADAMS Accession No. ML21343A292). This meeting was a follow-on meeting to previous public TICAP meetings held on:
May 11, 2021 (meeting summary available at ADAMS Accession No. ML21132A295)
May 19, 2021 (meeting summary available at ADAMS Accession No. ML21154A290)
May 26, 2021 (meeting summary available at ADAMS Accession No. ML21158A223)
June 23, 2021 (meeting summary available at ADAMS Accession No. ML21181A335)
August 17, 2021 (meeting summary available at ADAMS Accession No. ML21245A442)
October 5, 2021 (meeting summary available at ADAMS Accession No. ML21301A189)
November 9, 2021 (meeting summary available at ADAMS Accession No. ML21328A233)
December 14, 2021 (meeting summary available at ADAMS Accession No. ML21354A833)
CONTACT: Joseph Sebrosky, NRR/DANU 301-415-1132
S. Lynch 2 Meeting Highlights The meeting included a discussion of the following topics:
guidance for developing principal design criteria (PDCs) for an application using the licensing modernization project (LMP) process, level of detail in the safety analysis report (SAR) for anticipated operational occurrences (AOOs), design-basis events (DBEs), and beyond-design-basis events (BDBEs),
an updated preliminary exemptions, clarifications, and additions table associated with the NRC staffs review of NEI 21-07, an industry representative briefing on its intention to develop guidance for the change process for an LMP-based application, and next steps for the NEI and staff guidance.
Principal Design Criteria The NEI TICAP team discussed the proposed changes to NEI 21-07 to address the staffs recommendations regarding the scope of PDCs presented in the public meeting held on December 14, 2021. The NEI TICAP team stated the next revision of NEI 21-07 would address the following:
The first change aligns with the staffs recommendation that under Title 10 of The Code of Federal Regulations (10 CFR) Parts 50 and 52, the full scope of PDCs must address the criteria associated with design, fabrication, construction, testing and performance for important-to-safety structures, systems, and components (SSCs). In addition, the staffs recommendation stated that important-to-safety SSCs includes both safety-related and non-safety-related with special treatment SSCs and that the proposed design criteria should not be limited to those associated with required functional design criteria (RFDC), which only include safety-related SSCs. The changes to the PDC guidance will include:
o applicable special treatments (e.g., design, fabrication, construction, testing) o safety-significant functions associated with complimentary design criteria (non-safety related SSCs with special treatment)
For the second change, the NEI TICAP team indicated that it would include an option in NEI 21-07 for applicants to request exemptions from the PDC requirement to allow applicants to propose PDCs only for RFDCs and to address a limited set of criteria by addressing the special treatments within the body of the SAR. The NRC staff noted in the December 14, 2021, public meeting that this was a possible option to address the issue.
The NEI TICAP team indicated that some applicants may want to retain the approach because the preliminary draft language for the 10 CFR Part 53 rulemaking effort does not currently have a requirement for PDCs. The Part 53 rulemaking concept includes functional design criteria (FDCs) for design basis accidents (DBAs), FDCs for licensing basis events (LBEs) other than DBAs, and FDCs for normal operations. The exemption option could be used if an applicant developed its application to align with 10 CFR Part 50 and later decided to submit an application under 10 CFR Part 53.
The NEI TICAP team took an action to revise NEI 21-07 to include the changes described during the meeting. The NEI TICAP team noted that PDC associated with areas outside of LMP (e.g., normal operations) are outside the scope of NEI 21-07 and should be addressed by the
S. Lynch 3 advanced reactor content of application project (ARCAP). The NRC staff took an action to consider whether it would develop guidance associated with NEIs TICAP team proposed exemption approach that could include example justifications for the exemptions. The NRC staff also took an action to consider the guidance associated with proposed exemption related to the PDC requirement to develop PDC associated with SSCs that are important to safety.
This proposed exemption to allow PDCs to only address RFDCs had not been identified in the NRC staffs December 14, 2021, presentation.
Level of Detail in the Safety Analysis Report for AOOs, DBEs, and BDBEs Prior to the meeting the NRC staff provided additional considerations for developing guidance in this area in an email dated January 12, 2022 (see ADAMS Accession No. ML22012A274). The staff noted that NEI 21-07 guidance for SAR Chapter 2 provided a level of detail for AOOs, DBEs and BDBEs that the staff believed was appropriate and that the NEI 21-07 guidance for SAR Chapter 3, proposing that such information would be included in the probabilistic risk assessment (PRA) documents retained only in plant records, conflicts with the appropriate guidance on SAR level of detail in Chapter 2. The NEI TICAP team agreed that there was a discrepancy between the SAR Chapter 2 and SAR Chapter 3 guidance. However, the NEI TICAP team stated that it would remove the level of detail guidance found in SAR Chapter 2 (that the NRC staff indicated was appropriate) to make it consistent with SAR Chapter 3 guidance.
The NEI TICAP team stated that it would consider making changes to NEI 21-07, Section 2.1.1, Overview of PRA, guidance to partially address the NRC staffs concerns. The NEI TICAP team and the NRC staff stated that it would review guidance found in the American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) Standard ASME/ANS RA-S-1.4-2021, Probabilistic Risk Assessment Standard for Advanced Non--Light Water Reactor Nuclear Power Plants, Table 4.3.17.8-5, to determine if the information provided in this table might provide insights for resolving the issue on the appropriate level of detail in the SAR for AOOs, DBEs, and BDBEs.
The staff raised the issue of the lack of a definition for the term accessible environment found in NEI 21-07 Chapter 2 guidance. The use of this term is noted at the bottom of page 1 of the document attached to the January 12, 2022, email referenced above. The NEI TICAP team took an action to look at the guidance in this area and determine if a change to the guidance is needed.
Updated Preliminary List of Exceptions, Clarifications and Additions to NEI 21-07 Prior to the meeting the NRC staff provided an updated table with a preliminary list of exceptions, clarifications, and additions to NEI 21-07 (see ADAMS Accession No. ML22013B183). The NRC staff updated this table, which had been discussed in previous TICAP public meetings, based on revisions to the TICAP guidance found in NEI 21-07, Revision 0-B, and proposed changes that NEI indicated that it would make. There was general agreement that the updated table accurately captured the status of the NRC staffs review based on revisions to the NEI 21-07 guidance. The NRC staff took an action to review the status of item 3.3 in the table, related to AOO information in the SAR, to ensure that it is not
S. Lynch 4 redundant to other issues identified in the Table and that it appropriately considered industrys position on this issue.
Development of Guidance for an LMP-based Change Process A member of industry stated that Southern Company was sponsoring an effort to develop guidance for controlling changes to licensing basis information developed using the LMP process. The industry representative stated that this effort is Phase 3 of LMP-based guidance development. The representative considers Phase 1 LMP-based guidance to be captured in NEI 18-04, Revision 1, Risk-Informed Performance-Based Technology Guidance for Non-Light Water Reactors, and Phase 2 of the LMP-based guidance development being captured in the proposed guidance found in NEI 21-07. The industry representative indicated that it is expected that they would be engaging the staff on the LMP-based change process guidance and the representative desired to participate in public meetings on the topic in the near term.
The NRC staff noted it had a comment on NEI 21-07 related to the change control process for defense-in-depth information and that it may be more appropriate to include the change control process for this information in NEI 21-07 rather than in a separate guidance document. The staff stated that it would engage NRR Division of Reactor Oversight (DRO) about the forthcoming effort since the DRO is responsible for change control guidance for the currently operating power reactor fleet under 10 CFR 50.59. The staff also indicated that it would engage the Division of New and Renewed Licenses (DNRL) because of the possibility the change process that was under development could affect 10 CFR Part 52. For example, the change process for a standard design is codified in the respective 10 CFR Part 52 design certification appendix rather than 10 CFR 50.59.
Next Steps The NEI TICAP team briefly described minor changes that it intended to make to NEI 21-07 Sections 6.4.1, Description for SR SSC-1, and 7.3.1, Description for NSRST SSC-1, to make the guidance clearer. A snapshot of the proposed change to Section 6.4.1 was shown during the meeting as follows:
S. Lynch 5 A snapshot of the proposed change to Section 7.3.1 was shown during the meeting as follows:
The NRC staffs initial feedback was that the proposed changes seemed reasonable, but the staff would withhold any final determination until after it completed its review of Revision 1 to NEI 21-07. The NEI TICAP team stated that it was targeting late February or early March for providing Revision 1 to NEI 21-07. The NRC staff stated that the guidance contained in NEI 21-07, Revision 1, should be at the point where the staff could develop a draft regulatory guide with appropriate exceptions, clarifications, and additions, that could be issued for public comment.
Enclosure:
Attendance List
S. Lynch 6
SUBJECT:
SUMMARY
OF JANUARY 18, 2022, PUBLIC MEETING TO DISCUSS TECHNOLOGY INCLUSIVE CONTENT OF APPLICATION PROJECT DATED: FEBRUARY 18, 2022 DISTRIBUTION:
PUBLIC RidsNrrDanu Resource RidsNrrDanuUarp Resource JSegala SLynch JSebrosky EOesterle EBowman ADAMS Accession Number: ML2208A393 NRC-001 OFFICE NRR/DANU/UARP/PM NRR/DANU/UARP/BC NRR/DANU/UARP/PM NAME JSebrosky SLynch JSebrosky (EOesterle for)
DATE 2/1/2022 2/15/2022 2/18/2022 OFFICIAL RECORD COPY
January 18, 2022, Public Meeting to Discuss Technology Inclusive Content of Application Project Attendance List*
NAME AFFILIATION NAME AFFILIATION John Segala NRC/NRR/DANU Amir Afzali Southern Company Martin Stutzke NRC/NRR/DANU Brandon Chisholm Southern Company Steven Lynch NRC/NRR/DANU/UARP Ben Holtzman Nuclear Energy Institute (NEI)
Prosanta NRC/NRR/DANU/UARP Ed Lyman Union of Concerned Chowdhury Scientists Maryam Khan NRC/NRR/DANU/UARP Cyril Draffin U.S. Nuclear Industry Council Eric Oesterle NRC/NRR/DANU/UARP Steven Nesbit LMNT Consulting Jordan Hoellman NRC/NRR/DANU/UARP Ed Wallace GNBC Associates Joe Sebrosky NRC/NRR/DANU/UARP Neil Haggerty Excel Stephen Philpott NRC/NRR/DANU/UARP Eddie Grant Excel Arlon Costa NRC/NRR/DANU/UARP Frank Akstulewicz A to Z Reactor Consulting Services Amy Cubbage NRC/NRR/DANU/UARP Dennis Henneke GE Power Binesh Tharakan NRC/NRR/DANU/UARP Lisa Schichlein GE Power William Jessup NRC/NRR/DANU/UARL Karl Fleming KNF Consulting Eric Bowman NRC/NRR/DANU/UARL Raymond Wang X-energy Michelle Hayes NRR/NRR/DANU/UTB1 Jon Facemire X-energy Candace de NRC/NRR/DANU/UTB2 Steve Vaughn X-energy Messieres Michael Orenak NRR/NRR/DANU/UTB1 Charlotte Geiger X-energy Hosung Ahn NRC/NRR/DANU/UTB1 Ingrid Nordby X-energy Alexander NRC/NRR/DANU/UTB1 Tanju Sofu Argonne National Lab Chereskin Boyce Travis NRC/NRR/DANU/UTB1 Adam Stein Breakthrough Institute Michelle Hart NRC/NRR/DANU/UTB2 Mike Keller Hybrid Power Technologies Hanh Phan NRC/NRR/DANU/UTB2 Jeff Julius Jensen Hughes Christopher Van NRC/NRR/DANU/UTB1 Christopher Courtenay Duke Energy Wert Timothy Lupold NRC/NRR/DANU/UTB1 Roger Mattson INL Ian Jung NRC/NRR/DANU/UTB1 Mike Montecalvo TerraPower Carolyn Lauron NRC/NRR/DNRL/NRLB Bryan Eyers TerraPower Ed Miller NRC/NRR/DORL/LPL2-1 Amanda Spalding Westinghouse Robert Roche- NRC/RES/DE/RGPMB William Winslow U.S. Army Rivera Robert Krsek NRC/COMM/JB Andrew Zach Senate Committee on Environment and Public Works (EPW)
Shakur Walker NRC/COMM/DW Matthew Marzano Senate EPW Henry Marchiewski OCHCO/ADHRTD/NRANB Dave Grabaskas Argonne National Lab Scott Bussey OCHCO/ADHRTD/RTTB Adam Stein Breakthrough Institute Enclosure
Bob Weisman NRC/OGC Farshid Shahrokhi Not Available (NA)
Marcia Carpentier NRC/OGC Lisa Peterson NA Weijun Wang NRC/RES/DE/SGSEB Paul Loza NA Carolyn Wolf NRC/OCA Ben Chen NA Derek Widmayer NRC/ACRS Rob Burg NA Jim Kinsey INL Alan Levin NA Chris Chwasz INL Kiersten Smith NA Tom King INL Kurt Harris NA Tom Hicks INL Michael Mayfield NA Ewa Muzikova NA Stanton Harris NA Steven Pope NA Mike Dunkelberger NA Mike Tschiltz NA Donald Behnke NA Ian Gifford NA William Horak NA Henry Marchlewski NA Meg Audrian NA Matthew Gordon NA Robert Ballentine NA Jana Bergman NA Maggie Staiger NA Keeshia NA Archie Manocharan NA Goodenough Scott Nelson NA Lance Sterling NA
- Attendance list based on Microsoft Teams Participant list. List does not include 3 individuals that connected via phone.
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