ML22048B544
| ML22048B544 | |
| Person / Time | |
|---|---|
| Issue date: | 05/15/2023 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | |
| Joseph Sebrosky, 301-415-1132 | |
| Shared Package | |
| ML22048A520 | List: |
| References | |
| DANU-ISG-2022-04 | |
| Download: ML22048B544 (10) | |
Text
DANU-ISG-2022-04
Advanced Reactor Content of Application Project
Chapter 10, Control of Occupational Dose
Draft Interim Staff Guidance May 2023
ML22048B544 OFFICE QTE NRR/DANU/UTB1/BC NRR/DANU/UTB2/BC(A) NRR/DANU/UARL/PM NAME KAzariah-MHayes SPhillpot MOrenak Kribbs DATE 3/10/22 5/3/22 4/22/22 2/14/23 OFFICE OGC (NLO) NRR/DANU/UARP/BC(A) NRR/DANU/D NAME MCarpentier SLynch MShams DATE 5/4/23 3/15/23 5/4/23 DRAFT INTERIM STAFF GUIDANCE
ADVANCED REACTOR CONTENT OF APPLICATION PROJECT
CHAPTER 10, CONTROL OF OCCUPATIONAL DOSE
DANU-ISG-2022-04
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC or Commission) staf f is providing this interim staff guidance (ISG) for two reasons. First, this ISG p r o v i d e s g u idance on the contents of applications to an applicant submitting a risk-informed, perfor mance-based application for a construction permit (CP) or operating license (OL) under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utiliz ation Facilities (Ref. 1), or for a combined license (COL), a manufacturing lice nse (ML), a standard design approval (SDA), or a design certification (DC) under 10 CFR Par t 52, Licenses, Certifications, and Approvals for Nuclear Power Plants (Ref. 2), for a non-lig ht-water reactor (non-LWR). The application guidance found in this ISG supports the development of the portion of a non-LWR reactor application associated with an applicants control of o ccupational dose.1 Second, this ISG provides guidance to NRC staff on how to review such an app lication.
As of the date of this ISG, the NRC is developing a rule to ame nd 10 CFR Parts 50 and 52 (RIN 3150-Al66). The NRC staff notes this guidance may need to be up dated to conform to changes to 10 CFR Parts 50 and 52, if any, adopted through that rulemak ing. Further, as of the date of this ISG, the NRC is developing an optional performance-based, technology-inclusive regulatory framework for licensing nuclear power plants designated as 10 C FR Part 53, Licensing and Regulation of Advanced Nuclear Reactors, (RIN 3150-AK31). Afte r promulgation of those regulations, the NRC staff anticipates that this guidance will be updated and incorporated into the NRCs Regulatory Guide (RG) series or a NUREG series docume nt to address content of application considerations specific to the licensing processes in this document.
BACKGROUND
This ISG is based on the advanced reactor content of applicatio n project (ARCAP), whose purpose is to develop technology-inclusive, risk-informed, and performance-based application guidance. The ARCAP is broader than, and encompasses, the indus try-led technology-inclusive content of application project (TICAP). The guidance in this IS G supplements the guidance found in Division of Advanced Reactors and Non-power Production and Utilization Facilities (DANU)-ISG-2022-01, Review of Risk-Informed, Technology-Inclus ive Advanced Reactor Applications - Roadmap, issued in May 2023 (Ref. 3), which pro vides a roadmap for developing all portions of an application. The guidance in this ISG is limited to the portion of a
1 The NRC is issuing this ISG to describe methods that are acceptable to the NRC staff for implementing specific parts of the agencys regulations, to explain techniques that the NRC staff uses in evaluating specific issues or postulated events, and to describe information that the NRC staff needs in its review of applications for permits and licenses. The guidance in this ISG that pertains to applicants is not NRC regulations and compliance with it is not required. Methods and solutions that differ from those set forth in this ISG are acceptable if supported by a basis for the issuance or continuance of a permit or license by the Commission.
DANU-ISG-2022-04 Page 2 of 8
non-LWR application associated with the control of occupational dose and the NRC staff review of that portion of the application.
Following approval of the 10 CFR Part 53 final rule, this ISG g uidance will be supplemented, as necessary, to provide guidance for developing controls for occu pational dose to reflect any differences between current requirements in 10 CFR Parts 50 and 52 and new requirements in 10 CFR Part 53. The 10 CFR Part 53 rulemaking would revise the NRC's regulations by adding a risk-informed, technology-inclusive regulatory framework for commercial nuclear reactors, in response to the related requirements of the Nuclear Energy Inno vation and Modernization Act (NEIMA; Public Law 115-439), as amended by the Energy Act of 20 20. Key documents related to the 10 CFR Part 53 rulemaking, including preliminary and dra ft proposed rule language and stakeholder comments, can be found at Regulations.gov under Doc ket ID NRC-2019-0062.
RATIONALE
The current application guidance related to control of occupati onal dose is directly applicable only to light water reactors (LWRs) and may not fully identify the information to be included in a non-LWR application or efficiently provide a technology-inclusi ve, risk-informed, and performance-based review approach for non-LWR technologies. Thi s ISG serves as the non-LWR application guidance for controlling occupational dose. Thi s ISG provides both applicant content of application and NRC staff review guidance.
APPLICABILITY
This ISG is applicable to applicants for non-LWR 2 permits and licenses that submit risk-informed, performance-based applications for CPs or OLs under 1 0 CFR Part 50 or for COLs, SDAs, DCs, or MLs under 10 CFR Part 52. This ISG is also applic able to the NRC staff reviewers of these applications.
PAPERWORK REDUCTION ACT
This ISG provides voluntary guidance for implementing the manda tory information collections in 10 CFR Parts 50 and 52 that are subject to the Paperwork Reduct ion Act of 1995 (44 U.S.C.
3501 et. seq.). These information collections were approved by the Office of Management and Budget (OMB), approval numbers 3150-0011 and 3150-0151. Send co mments regarding this information collection to the FOIA, Library, and Information Co llections Branch (T6-A10M),
U.S. Nuclear Regulatory Commission, Washington, DC 20555 0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the OMB reviewer at: OMB Office of Information and Regulatory Affairs (3150-0011 and 3150-0151), Attn: Desk Office r for the Nuclear Regulatory Commission, 725 17th Street, NW Washington, DC 20503; e-mail:
oira_submission@omb.eop.gov.
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct or sponsor, and a person is not require d to respond to, a collection of information unless the document requesting or requiring the collection displays a currently valid OMB control number.
2 Applicants desiring to use this ISG for a light water reactor application should contact the NRC staff to hold pre-application discussions on their proposed approach.
DANU-ISG-2022-04 Page 3 of 8
GUIDANCE
Requirements described in 10 CFR 50.34, Contents of applicatio n; technical information; 10 CFR 52.47, Contents of applications; technical information ; 10 CFR 52.79, Contents of application; technical information in final safety analysis rep ort; 10 CFR 52.137, Contents of application; technical information; and 10 CFR 52.157, Conten ts of application; technical information in the final safety analysis report, specify that an application for a OL, DC, COL, SDA, or ML needs to describe, among other things, the kinds and quantities of radioactive materials expected to be produced in the operation of the facil ity. In 10 CFR 20.1101, Radiation protection programs, the NRC requires the control of occupatio nal radiation exposures within the limits set forth in 10 CFR Part 20, including assuring that occupational radiation exposure will be ALARA for OLs and COLs. In 10 CFR 19.12, Instruction t o workers, the NRC requires keeping workers who may receive an occupational radiation expos ure of over 100 millirem informed regarding radiation protection at the worksite. The ap plicant and the NRC staff should also refer to the Radiation Protection Program, portion of DA NU-ISG-2022-01 for related guidance on this topic.
Application Guidance
Chapter 10 of an application for an OL, COL, DC, or ML should p rovide information on facility and equipment design and radiation sources that are necessary t o ensure that the occupational radiation protection standards set forth in 10 CFR Part 20, St andards for the Protection against Radiation (Ref. 4), are met. For an OL and COL, the applicatio n should also include operational programs necessary to ensure that the occupational radiation pr otection programs standards in 10 CFR Part 20 are met. The applicant may describe information needed for this final safety analysis report (FSAR) chapter in a separate radiation protecti on program (RPP) description document, which may be part of a separate submittal and incorpo rated by reference. For an OL or COL, the applicant should provide a description of the manag ement policy and organizational structure necessary to ensure occupational radiation exposures are as low as is reasonably achievable (ALARA).
The application should include proposed principal design criter ia (PDC) that address the design, fabrication, construction, testing, and quality of the structur es, systems, and components necessary to control occupational exposure to within regulatory limits. For LWRs, 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, General Design Criterion (GDC) 19, Control room, requires the provisi on of conditions that allow for safe operation under normal conditions. Additionally, GDC 61, 6 3, and 64, and 10 CFR 50.34(f)(2) items (viii), (xxvi), (xxvii), and (xxviii) provide criteria regarding protecting workers from occupational exposure. For non-LWRs, the applicati on should describe design-specific PDC, including those necessary for the control of occupational exposure that allow the safe operation of the plant under normal and accident operations. The design-specific PDC should include those necessary to control occupational expo sure, including ensuring occupational radiation exposures are ALARA, such as shielding, ventilation, area radiation and airborne radioactivity monitoring instrumentation, and dose ass essment for expected occupancy. Further guidance on the development of PDC for non-L WRs appears in Regulatory Guide (RG) 1.232, Guidance for Developing Principal Design Cri teria for Non-Light-Water Reactors, (Ref. 5).
For a DC and ML, certain parts of the design information may be conceptual (refer to RG 1.206, Applications for Nuclear Power Plants, (Ref. 6) for DCs and 1 0 CFR 52.157(f)(22) for MLs),
and the programmatic information may be deferred according to r egulation to the COL stage DANU-ISG-2022-04 Page 4 of 8
using COL action items.
For an SDA, the application should describe the means for contr olling and limiting radiation exposures within the limits set forth in Part 20 for those area s addressed by the SDA scope.
The programmatic information may be deferred according to regul ation to the COL stage.
In accordance with 10 CFR 50.34(a)(6), the preliminary safety a nalysis report in the application for a CP need only provide the following information related to the control of occupational dose:
a preliminary plan for the applicant's organization, training o f personnel, and conduct of operations. The means for controlling and limiting radioactive effluents and radiation exposures within the limits set forth in Part 20 is only required at the FSAR stage pursuant to 10 CFR 50.34(b)(3). Consistent with these requirements, CP application should include (1) a description of its plans to develop, at the OL or stage, comprehensive work er protection programs, organizational structure, training, and monitoring to ensure th e requirements are met in 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations (Ref. 7); and 10 CFR Part 20; and (2) a description of the desi gn-specific PDC necessary to control occupational exposures, and (3) a preliminary descripti on of design provisions necessary to control occupational exposure, including ensuring that occupational doses are ALARA, such as shielding, ventilation, area radiation and airbo rne radioactivity monitoring instrumentation, and dose assessment for expected occupancy. Th e applicant can provide the additional information requested below during the OL applicatio n review.
The NRC staff reviewers will rely on information in both the RP P description document and the FSAR to make its safety finding, and information from an RPP de scription does not need to be repeated in the FSAR. However, the FSAR should incorporate the RPP description document by reference to ensure that future changes to it are properly e valuated through the FSAR change process to determine the need for prior NRC approval.
Staff Review Guidance
The NRC staff reviewers must determine whether the application provides assurance that occupational doses will be controlled and meet the requirements in 10 CFR Part 19 and 10 CFR Part 20. Specifically, the NRC staff must ensure that th e applicant has addressed the following:
- a. 10 CFR 19.12, Instruction to workers, as it relates to kee ping workers who receive occupational radiation exposure informed regarding radiation pr otection at the worksite
- b. 10 CFR 20, Subpart C, Occupational Dose Limits (10 CFR 20.1201-20.1208)
- c. 10 CFR 20, Subpart G, Control of Exposure From External Sou rces in Restricted Areas (20.1601 - 20.1602)
- d. 10 CFR 20.1101 and the definition of ALARA in 10 CFR 20.1003, Definitions, as they relate to those measures that ensure that radiation exposures r esulting from licensed activities are below specified limits and ALARA
DANU-ISG-2022-04 Page 5 of 8
Acceptance criteria are based on meeting the relevant requireme nts of the following Commission regulations:
- design-specific PDC for non-LWRs equivalent to GDCs 19, 61, 63, and 64, as applicable
- 10 CFR Part 20, Subparts C (10 CFR 20.1201-20.1208) and G (20. 1601 - 20.1602)
- 29 CFR 1910.134 Occupational Safety and Health Standards - Re spiratory Protection (Ref. 8)
Acceptance Criteria
The NRC staff reviewer should ensure that the application inclu des sufficient information to understand the general design and operational controls that wil l be used to control occupational doses. The reviewer should be able to reach and document the ap plicable safety findings for this topic in the NRC staffs safety evaluation report if the a pplication includes the following information:
- a. Describe important equipment and facility design features th at satisfy the design-specific PDC necessary to control occupational exposure, including ensur ing occupational radiation exposures are ALARA, such as shielding, ventilation, area radiation and airborne radioactivity monitoring instrumentation, and dose ass essment for expected occupancy.
- b. Describe major radiation sources, including sources that req uire (1) shielding, (2) special ventilation systems, (3) special storage locations and conditio ns, (4) traffic or access control, (5) special plans or procedures, and (6) monitoring eq uipment. This chapter need not include information on source terms used in licensing-basis event analysis, as this information should be provided elsewhere in the applicatio n.
- c. Describe the design features provided to control access to r adiologically restricted areas (including potentially very high radiation areas), describe eac h very high radiation area, and indicate physical access controls and radiation monitor loc ations for each of these areas.
- d. Describe those features that reduce the need for maintenance and other operations in radiation fields, reduce radiation sources in areas where opera tions may be performed, allow quick entry and easy access, provide remote operation cap ability, or reduce the time spent working in radiation fields, as well as any other fe atures that reduce radiation exposure of personnel.
- e. Describe methods for reducing the production, distribution, and retention of activation products through design, material selection, water chemistry, d econtamination procedures, and so forth.
DANU-ISG-2022-04 Page 6 of 8
- f. DCs, MLs, and SDAs may use COL action items to defer certain technical information to a COL application that references the DC/ML/SDA, such as: (1) c omplete design information for the remainder o f a proposed facility, (2) verification of site parameters, (3) completion of analyses and design reports for as-built plant sy stems, and (4) development and implementation of operational programs. A COL application that references a DC/ML/SDA should describe how the applicant propos es to resolve each COL action item.
- g. For OL and COL applications, provide a description of the co mprehensive worker protection programs, organizational structure, training, and mo nitoring to ensure the 10 CFR Part 19 and 10 CFR Part 20 requirements are met. Describ e the important elements of these programs. Incl ude a discussion of any relevan t RGs, Nuclear Energy Institute (NEI) templates, or standards.
- i. As an option to ensure the 10 CFR Part 19 and 10 CFR Part 20 requirements are met, an applicant may refer to NEI 07-08A, Generic FSAR Templa te Guidance for Ensuring that Occupational Radiation Exposures are as Low a s is Reasonably Achievable (ALARA) (Ref. 9), which provides a comple te generic ALARA program description for use in developing COL application s. While the NRC staff has not endorsed NEI 07-08A in an NRC RG, it has appr oved the NEI 07-08A generic program description template via safety evaluati on and NEI 07-08A is similar to an approved topical report. Accordingly, an applicant who wishes to adopt the NEI 07-08A program description template to ensure occupational radiation exposures are ALARA should explain why t he program template applies to its proposed facility, including how the co nditions for use of the template, if any, are satisfied, and add any information th e program description identifies as an applicants responsibility If an a pplicant chooses to reference this template to address the above acceptance criteri a, there is no need to replicate text in the FSAR. An applicant may need to up date or revise the template to reflect operation of the specific non-LWR and/or if they are submitting an OL application.
ii. These criteria for operational controls could also be addre ssed in the RPP description document provided the RPP document is incorporated by reference into the FSAR.
IMPLEMENTATION
The NRC staff will use the information discussed in this ISG to review non-LWR applications for CPs, OLs, COLs, SDAs, DCs, and MLs under 10 CFR Part 50 and 10 CFR Part 52. The NRC staff intends to incorporate this guidance in updated form in t he RG or NUREG series, as appropriate.
BACKFITTING AND ISSUE FINALITY DISCUSSION
The NRC staff may use DANU-ISG-2022-04 as a reference in its re gulatory processes, such as licensing, inspection, or enforcement. However, the NRC staff d oes not intend to use the guidance in this ISG to support NRC staff actions in a manner t hat would constitute backfitting as that term is defined in 10 CFR 50.109, Backfitting, and as described in NRC Management Directive 8.4, Management of Backfitting, Forward Fitting, Iss ue Finality, and Information DANU-ISG-2022-04 Page 7 of 8
Requests (Ref. 10), nor does the NRC staff intend to use the g uidance to affect the issue finality of an approval under 10 CFR Part 52, Licenses, Certif ications, and Approvals for Nuclear Power Plants. The NRC staff also does not intend to us e the guidance to support NRC staff actions in a manner that constitutes forward fitting as t hat term is defined and described in Management Directive 8.4. If an applicant or licensee believes that the NRC is using this ISG in a manner inconsistent with the discussion in this paragraph, th en the licensee may file a backfitting or forward fitting appeal with the NRC in accordanc e with the process in Management Directive 8.4.
CONGRESSIONAL REVIEW ACT
Discussion to be provided in the final ISG.
FINAL RESOLUTION
The NRC staff will transition the information and guidance in t his ISG into the RG or NUREG series, as appropriate. Following the transition of all pertine nt information and guidance in this document into the RG or NUREG series, or other appropriate guid ance, this ISG will be closed.
ALARA as low as is reasonably achievable ARCAP advanced reactor content of application project CFR Code of Federal Regulations COL combined license CP construction permit DANU Division of Advanced Reactors and Non-Power Production and Utilization Facilities DC design certification FSAR final safety analysis report GDC general design criterion/a ISG interim staff guidance LWR light-water reactor ML manufacturing license NEI Nuclear Energy Institute NRC U.S. Nuclear Regulatory Commission OL operating license PDC principal design criterion/a RG regulatory guide RPP radiation protection program SDA standard design approval TICAP technology-inclusive content of application project
REFERENCES
- 1. Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Domestic Licensing of Production and Utilization Facilities.
- 2. 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.
DANU-ISG-2022-04 Page 8 of 8
- 3. U.S. Nuclear Regulatory Commission, DANU-ISG-2022-01, Revie w of Risk-Informed, Technology-Inclusive Advanced Reactor Applications - Roadmap, May 2023 (Agencywide Documents Access and Management System (ADAMS) Acce ssion No. ML22048B546).
- 4. 10 CFR Part 20, Standards for Protection against Radiation.
- 5. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.232, Guidance for Developing Principal Design Criteria for Non-Light Water Reacto rs, Washington, DC
- 6. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.206, Applications for Nuclear Power Plants, Washington, DC
- 7. 10 CFR Part 19, Notices, Instructions and Reports to Worker s: Inspection and Investigations.
- 8. Title 29 of the Code of Federal Regulations, Part 1910, Personal Protective Equipment, Chapter 134, Occupational Safety and Health Standards.
- 9. Nuclear Energy Institute, NEI 07-08A, Generic FSAR Template Guidance for Ensuring that Occupational Radiation Exposures are as Low as is Reasonab ly Achievable (ALARA).
- 10. U.S. Nuclear Regulatory Commission, Management Directive 8. 4, Management of Backfitting, Forward Fitting, Issue Finality, and Information R equests.