ML22297A240
| ML22297A240 | |
| Person / Time | |
|---|---|
| Site: | 99902088 |
| Issue date: | 01/26/2023 |
| From: | Rivera R NRC/NRR/DANU/UARP |
| To: | Michael Wentzel NRC/NRR/DANU/UAL2 |
| Richard R | |
| References | |
| EPID L-2022-NFN-0003 | |
| Download: ML22297A240 (1) | |
Text
MEMORANDUM TO:
Michael Wentzel, Branch Chief Advanced Reactor Licensing Branch 2 Division of Advanced Reactors and Non-power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM:
Richard Rivera, Project Manager Advanced Reactor Licensing Branch 1 Division of Advanced Reactors and Non-power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
REPORT ON THE PRE-SUBMITTAL REGULATORY AUDIT OF THE ABILENE CHRISTIAN UNIVERSITY PRELIMINARY SAFETY ANALYSIS REPORT (EPID L-2022-NFN-0003)
Abilene Christian University (ACU) began pre-application discussions with the U.S. Nuclear Regulatory Commission (NRC) staff on the proposed ACU Molten Salt Research Reactor (MSRR) in November 2019. Prior to submitting the MSRR construction permit preliminary safety analysis report (PSAR), the NRC staff audited a pre-submittal version of the PSAR to assess any potential gaps relative to the applicable regulations and NRC staff guidance, identify regulatory or technical issues which may complicate the review, and enhance NRC staff knowledge of the MSRR design.
The audit plan, dated March 9, 2022, is provided in the NRCs Agencywide Documents Access and Management System at Accession No. ML22054A140. The audit was conducted during March through August 2022 via the ACU electronic reading room and teleconference.
Project No.: 99902088
Enclosure:
Audit Report CONTACT:
Richard Rivera, NRR/DANU (301) 415-7190 January 20, 2023 Signed by Rivera, Richard on 01/20/23
ML22297A240 NRR-106 OFFICE NRR/DANU/UAL1/PM NRR/DANU/UAL1/LA NRR/DANU/UTB1/BC NAME RRivera DGreene MHayes DATE 10/28/2022 10/31/2022 11/14/2022 OFFICE NRR/DANU/UAL2/BC NRR/DANU/UAL1/PM NAME MWentzel RRivera DATE 11/14/2022 1/20/2023
Enclosure ABILENE CHRISTIAN UNIVERSITY
SUMMARY
REPORT ON THE PRE-SUBMITTAL REGULATORY AUDIT OF ABILENE CHRISTIAN UNIVERSITY PRELIMINARY SAFETY ANALYSIS REPORT March - August 2022
1.0 BACKGROUND
Abilene Christian University (ACU) began pre-application discussions with the U.S. Nuclear Regulatory Commission (NRC) staff on the Molten Salt Research Reactor (MSRR) in November 2019. ACU submitted a regulatory engagement plan (REP) by letter dated July 24, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20241A071), and ACU provided an updated REP by letter dated May 27, 2022 (ML22157A033). As discussed in the REPs, ACU planned to submit an application for a construction permit (CP), including a preliminary safety analysis report (PSAR), for the MSRR in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities. In its REPs, ACU also stated that its PSAR would follow guidance including NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Part 1, Format and Content (ML042430055), and ORNL/TM-2020/1478, Proposed Guidance for Preparing and Reviewing a Molten Salt Non-Power Reactor Application (ML20219A771), Appendix A, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power MSRs: Format and Content.
2.0 AUDIT REGULATORY BASES The bases for the audit are the regulations in 10 CFR Part 50, Sections 50.34(a), Preliminary safety analysis report, 50.35, Issuance of construction permits, and 50.40, Common standards. The NRC staff also conducted the audit using the guidance in NUREG-1537 and ORNL/TM-2020/1478.
3.0 AUDIT PURPOSE AND OBJECTIVES The purpose of this audit was to provide the NRC staff with an opportunity to assess the readiness of the draft PSAR before ACU formally submitted the construction permit application.
This audit allowed the NRC staff to (1) identify any required information that is missing from the application, (2) identify technical or regulatory issues that may complicate the acceptance or technical reviews of the application, and (3) become familiar with the content of the application.
4.0 SCOPE OF THE AUDIT AND AUDIT ACTIVITIES The audit was conducted during March through August 2022 via the ACU electronic reading room and teleconference. The NRC staff conducted the audit in accordance with the pre-
2 application audit plan dated March 9, 2022 (ML22054A140). There were no deviations from the audit plan.
NRC staff audit team members included:
Richard Rivera Project Manager (responsible for audit logistics)
Edward Helvenston Project Manager Christopher Van Wert Sr. Reactor Systems Engineer (Lead Technical Reviewer)
Kenneth See Sr. Hydrologist David Heeszel Geophysicist (Seismologist)
Kevin Quinlan Meteorologist Andrew Prinaris Civil Engineer Joseph Ashcraft Electronics Engineer Calvin Cheung Electronics Engineer Sheila Ray Sr. Electrical Engineer Kenneth Mott Emergency Preparedness Specialist Michael Norris Sr. Emergency Preparedness Specialist Shawn Harwell Financial Analyst Patricia Vokoun Environmental Project Manager Donald Palmrose Sr. Reactor Engineer Aaron Eyler Student Intern Ryan Pecharo Student Intern The NRC staff audited parts of the following documents:
Overall Introduction to the MSRR Design
ACU MSRR PSAR Chapters 2 through 19 The NRC staff did not acquire any documents during the audit.
5.0
SUMMARY
OF OBSERVATIONS The NRC staffs summary of observations listed below is based on the notes taken by the staff during the audit. The main purpose of the audit was to identify issues which could challenge potential acceptance of the PSAR when submitted and highly challenging regulatory or technical issues which may need additional documentation. In particular, the NRC staff noted:
Observations on potential acceptance review issues:
Related primarily to draft PSAR Chapter 3, the NRC staff noted that further details on the design of structures, systems, and components (SSCs) would be necessary for the staff to evaluate the sufficiency of the facility design. The NRC staffs observation was based on 10 CFR 50.34(a)(3)(iii), which states that the PSAR must include Information relative to materials of construction, general arrangement, and approximate dimensions,
3 sufficient to provide reasonable assurance that the final design will conform to the design bases with adequate margin for safety, and 10 CFR 50.34(a)(4), which states that the PSAR must include A preliminary analysis of evaluation of the design and performance of [SSCs] of the facility with the objective of assessing the risk to public health and safety resulting from operation of the facility, and the adequacy of [SSCs] provided for the prevention of accidents and the mitigation of the consequences of accidents. The NRC staff informed ACU of this concern during a teleconference on June 30, 2022.
Related primarily to draft PSAR Chapter 7, the NRC staff noted that further details of the instrumentation and control (I&C) architecture, and information on how the I&C protects MSRR safety limits that is consistent with other PSAR chapters, would be necessary for the staff to evaluate the sufficiency of the MSRR I&C systems. The NRC staffs observation was based on 10 CFR 50.34(a)(3)(iii), which states that the PSAR must include Information relative to materials of construction, general arrangement, and approximate dimensions, sufficient to provide reasonable assurance that the final design will conform to the design bases with adequate margin for safety, and 10 CFR 50.34(a)(4), which states that the PSAR must include A preliminary analysis of evaluation of the design and performance of [SSCs] of the facility with the objective of assessing the risk to public health and safety resulting from operation of the facility, and the adequacy of [SSCs] provided for the prevention of accidents and the mitigation of the consequences of accidents. The NRC staff informed ACU of this concern during a teleconference on July 29, 2022.
Related primarily to draft PSAR Chapters 9 and 13, the NRC staff noted that it is unclear if there are any planned operational states in which used fuel could be stored in tanks within the fuel storage enclosure, which is outside the reactor cell (other than potentially during decommissioning). If so, it is possible that the current MHA would not be bounding. The NRC staffs observation was based on 10 CFR 50.34(a)(4), which states that the PSAR must include A preliminary analysis of evaluation of the design and performance of [SSCs] of the facility with the objective of assessing the risk to public health and safety resulting from operation of the facility.. The NRC staff informed ACU of this concern during a teleconference on July 28, 2022.
General observations (the NRC staff does not consider these to be potential acceptance review issues but may seek additional information on specific items as necessary):
The NRC staff observed that in many instances throughout the draft PSAR, it is not clear if MSRR components are safety-related or non-safety-related. It is also unclear in some cases what the criteria for components being safety-related are.
The NRC staff noted that, in some cases, PSAR figures and descriptions indicated multiple or conflicting names for the MSRR components. Some descriptions of components also included conflicting information.
4
The NRC staff observed that in some cases the PSAR does not clearly distinguish and/or justify what information is planned to be deferred to an operating license application.
The NRC staff observed that the methodology for selecting the maximum hypothetical accident scenario is not fully clear. In addition, it is not fully clear how the fuel salt will support the functional containment concept.
The NRC staff observed that in some instances it is not clear what the design criteria for some systems are and how the criteria are met.
The NRC staff observed that while the MSRR does not contain traditional experimental facilities (e.g., bays, ports, etc.), the MSRR itself and its unusual and novel SSCs could be considered to be experiments. Additional clarification may be needed regarding any special safety features for these SSCs, and any added instrumentation or other features to monitor their performance.
The NRC staff noted that some referenced documents do not include the version or date of publication, to make it clear which version ACU is referencing.
The NRC staff notes that based on the draft PSAR, MSRR analysis methodologies may include significant changes from established methodologies (e.g., analysis codes).
Accordingly, additional staff review may be necessarily during reviews of a construction permit and/or operating license application. (Topical reports may be a vehicle to address these cases.)
6.0 EXIT BRIEFING The NRC staff conducted an audit closeout meeting on August 5, 2022. At the exit briefing the NRC staff reiterated the purpose of the audit and discussed the activities conducted.
7.0 REQUESTS FOR ADDITIONAL INFORMATION RESULTING FROM AUDIT NRC staff did not use the formal request for additional information (RAI) process as part of this audit. The staff provided ACU questions and feedback during the audit, which ACU could consider and use to revise the PSAR prior to submittal of the CP application.
8.0 OPEN ITEMS AND PROPOSED CLOSURE PATHS Not applicable. There are no open items as a result of this audit.