ML23283A115
| ML23283A115 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/2023 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | |
| Shared Package | |
| ML23283A092 | List: |
| References | |
| DANU-ISG-2022-02 | |
| Download: ML23283A115 (1) | |
Text
This draft comment resolution table is the latest version of the table that the NRC staff has publicly released to support interactions with the Advisory Committee on Reactor Safeguards (ACRS). This version is based on reviews by NRC staff and consideration of stakeholder input. The NRC staff expects to adopt further changes to the comment resolution table.
This comment resolution table has not been subject to complete NRC management or legal review, and its contents should not be interpreted as official agency positions. The NRC staff plans to continue working on the information provided in this document.
Analysis of Public Comments on Draft ISG DANU-ISG-2022-02 Advanced Reactor Content of Application Project Site Information Comments on the draft interim staff guidance (ISG) are available electronically at http://www.nrc.gov/reading-rm/adams.html. From this page, the public can access the Agencywide Documents Access and Management System (ADAMS), which provides text and image files of the U. S.
Nuclear Regulatory Commission (NRC) public documents. The following table lists the comments the NRC received on the draft ISG.
Comment Number ADAMS Accession Number Commenter Affiliation Commenter Name NRC-2022-0075 - DRAFT 0002 ML23167A038 Hybrid Power Technologies, LLC Michael Keller NRC-2022-0075 - DRAFT 0003 ML23167A039 Hybrid Power Technologies, LLC Michael Keller NRC-2022-0075 - DRAFT 0004 ML23234A052 X Energy, LLC Travis Chapman NRC-2022-0074 - DRAFT 0006 ML23234A039 Nuclear Energy Institute Ben Holtzman Comment Topic Section of Specific Comments NRC Staff Response Identifier Document NRC- Regulations.gov Not Note that the underlying comment in The NRC staff responded to the request as 2022- Site Applicable M23167A038 and ML23167A039 are the documented in ML23174A004. The response 0075 same. states in part:
DRAFT Month Year
Comment Topic Section of Specific Comments NRC Staff Response Identifier Document 0002- Include in regulations.gov, as downloadable the regulations.gov website identifies the 1/NRC- files, all documents for which public documents (the advanced reactor content of 2022- comments are being solicited application project (ARCAP) interim staff 0075 guidance (ISGs) and the technology inclusive DRAFT content of application project (TICAP) draft 0003-1 guide (DG)) for which the NRC staff is seeking public comment. While the Federal Register notices for the ARCAP ISGs reference NRC-issued, approved, or endorsed documents, the NRC staff is only requesting comment on the ARCAP ISGs proposed use of the referenced documents, and not the referenced documents themselves. As such, the NRC staff will not be providing documents referenced in the ARCAP ISGs on regulations.gov as this could imply that the NRC staff is seeking comments on these documents.
NRC- Extension of Not Note that the underlying comment in The NRC staff responded to the request as 2022- Comment Applicable M23167A038 and ML23167A039 are the documented in ML23174A004. As a result of 0075 Period same. this request and request from the Nuclear DRAFT Energy Institute (ML23171B098) the NRC staff 0002- Alter the Federal Register notices to establish extended the comment period for nine interim 1/NRC- a reasonable, staggered schedule for document staff guidance documents and DG-1404, 2022- review and comment by the public. revision 0, from July 10, 2023, to August 10, 0075 2023.
DRAFT 0003-1 NRC- Editorial Pg 2 - 1st Need space between a and non-LWR. The NRC staff agrees with this comment.
2022- line at top 0075 of page ISG revised to add space.
DRAFT 0004-24 NRC- Section 2.7.2 - Pg 24 Additional guidance (or a more standardized The NRC staff disagrees with this comment.
2022- Screening approach) for screening external hazards could 2
Comment Topic Section of Specific Comments NRC Staff Response Identifier Document 0075 Approach for help streamline the process and minimize the The NRC staff is considering developing DRAFT Other External number of pre-application interactions. additional guidance for an approach detailing 0004-25 Hazards Consider developing a standardized approach the elements that are required for an external detailing the elements that are required for an hazard screening flow chart. However, external hazard screening flow chart development of such a flow chart and acceptable to the NRC. associated guidance for the broad range of external hazards is premature at this time.
In the interim, it is noted that Section 2.7.2, Screening Approach for Other External Hazards, of the final interim staff guidance continues to provide an option for an applicant to use a hazard screening flow diagram, such as the one for volcanic hazards found in Regulatory Guide 4.26, Revision 1, Volcanic Hazards Assessment for Proposed Nuclear Power Reactor Sites, August 2023 (ML23167A078) or for flooding hazards as found in Appendix K of DG-1290 (Regulatory Guide 1.59, Revision 3), Design Basis Floods for Nuclear Power Plants, February 2022 (ML19289E561). As noted in the ISG applicants choosing to follow such a screening approach for other hazards should discuss their approaches with the NRC staff during the preapplication phase of the review.
No technical change made to the ISG as a result of this comment. Updates were made to reflect a revision to regulatory guide (RG) 4.26 and an addition was made to Appendix A of the ISG to include DG-1290, Design Basis Floods for Nuclear Power Plants.
3
Comment Topic Section of Specific Comments NRC Staff Response Identifier Document NRC- Section 2.3.1 - Pg 10 In the second paragraph of this section it is The NRC staff agrees with this comment.
2022- Nearby stated Each hazard that could result in an 0075 Industrial, event sequence with an estimated frequency of The NRC staff notes that the last paragraph in DRAFT Transportation, occurrence greater than 5 in 10 million per the section provides guidance that the 0004-26 and Military year should be evaluated for its potential to evaluation should be performed in accordance Facilities cause a radiological release exceeding the with RG 1.233 and NEI 18-04. Based on this, dose guidelines of 10 CFR 50.34(a) or 10 CFR the following sentence in the second paragraph 52.79(a)(1)(iv). Please remove the quoted of Section 2.3.1 has been deleted:
text. This sentence implies requirements that exceed current requirements for evaluating Each hazard that could result in an event external hazards. sequence with an estimated frequency of occurrence greater than 5 in 10 million per year should be evaluated for its potential to cause a radiological release exceeding the dose guidelines of 10 CFR 50.34(a) or 10 CFR 52.79(a)(1)(iv).
As a result of the review of this comment the NRC staff also reviewed the acceptance criteria in Section 2.3.2 and noted that additional clarification related to aircraft impacts is warranted. Specifically, the NRC staff added the following to 2.3.2.e see appendix A for guidance that the staff is considering developing in this area. The following item was added to Appendix A:
The NRC staff is considering updating the guidance found in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 3.5.1.6, Aircraft Hazards, The data found in this regulatory guide is old and does not reflect that accidental aircraft 4
Comment Topic Section of Specific Comments NRC Staff Response Identifier Document impact frequency has been reduced over the years. The American Nuclear Society (ANS) is considering developing a new standard - ANS 2.36-202x, Accident Analysis for Aircraft Crash into Reactor and Nonreactor Nuclear Facilities. The NRC staff is monitoring the development of this proposed standard and will update this ISG, as appropriate, based on the NRC staffs review and possible acceptance of this standard.
NRC- General The ARCAP documents are stated to be The NRC staff disagrees with this comment.
2022- applicable to non-LWRs. However, all the 0074 guidance is technology-inclusive and is The NRC staff is considering expanding the DRAFT equally applicable to LWRs. Please indicate applicability of ARCAP guidance documents 0006-1 that the guidance is applicable to LWRs. beyond non-light water reactors (non-LWRs).
However, expansion of the guidance beyond non-LWRs at this time is premature.
The final ISG continues to note that the NRC is developing an optional performance-based, technology-inclusive regulatory framework for licensing nuclear power plants designated as 10 CFR Part 53, Licensing and Regulation of Advanced Nuclear Reactors, (RIN 3150-AK31). It is envisioned that the 10 CFR Part 53 guidance would be applicable to both LWR and non-LWRs. Should the 10 CFR Part 53 rulemaking include requirements for both LWR and non-LWRs the NRC staff envisions that the concepts found in the ARCAP ISGs guidance would be expanded beyond non-LWRs. In the interim, the NRC staff notes that the applicability section of the ISG notes that 5
Comment Topic Section of Specific Comments NRC Staff Response Identifier Document applicants desiring to use the ISG for a light water reactor application should contact the NRC staff to hold pre-application discussions on their proposed approach.
No change has been made to the ISG.
NRC- General The review should eliminate review of The NRC staff disagrees with this comment.
2022- external hazards that are not possible for ML 0074 applicants, but remain applicable to CP, OL The NRC staff notes that the guidance includes DRAFT and COL applicants (e.g., stability of slopes). the following paragraph that provides guidance 0006-2 Please add text similar to the following: for design certification (DC), standard design approval (SDA) and manufacturing license For an ML application the site description (ML) applicants that address the applicability of should describe the site characteristics as they the guidance to these applications:
affect the design (e.g., a site parameter envelope). Other site characteristics are left to Under 10 CFR 52.47(a)(1), DC applications the COL applicant to provide as well as the must describe the site parameters postulated for site-specific information necessary to the design. Similarly, under 10 CFR demonstrate that site characteristics fit within 52.137(a)(1) and 10 CFR 52.157(f)(19),
the plant parameter envelope. respectively, SDA and ML applications must describe the site parameters postulated for their designs. Applicants for these types of licenses should include in Chapter 2 of their SARs the complete set of postulated site parameters considered in the design. Because evaluations of the safety of the design use the postulated site parameters, the actual characteristics of the site at which the facility is to be located must fall within the postulated site parameters specified in the design and safety analysis.
There is additional guidance in the ISG that states how a combined license (COL) applicant 6
Comment Topic Section of Specific Comments NRC Staff Response Identifier Document referencing an SDA, DC, or ML must provide additional information to demonstrate that the site characteristics fall within the postulated site parameters specified for the SDA, DC, or ML.
No change has been made to the ISG.
NRC- Typo Pg 2 This is the same comment as 0004-24 above. See response to comment 0004-24 above.
2022-0074 DRAFT 0006-3 NRC- Guidance Pg 5 The last sentence in the third full paragraph The NRC staff agrees with this comment.
2022- indicates that external hazards not supported 0074 by PRA will be covered deterministically. The As a result of the comment the following DRAFT guidance should not preclude a potential change has been made to the last sentence:
0006-4 combination of PRA and deterministic techniques. External hazards not supported by a probabilistic external hazard analysis will be addressed by DBHLs [design basis hazard levels] identified using traditional deterministic methods or a combination of probabilistic and deterministic methods.
NRC- Section 2.4 - Pg 13 In the first paragraph on page 13 reference is No change to the ISG is being made as a result 2022- Regional made to RG 1.111 for estimating atmospheric of this comment. The answer to the question is 0074 Climatology, transport and dispersion of gaseous effluents. yes, the NRC staff has determined that DRAFT Local The title of RG 1.111 states it is for LWRs. guidance found in RG 1.111, Methods for 0006-5 Meteorology, Has NRC made a determination of its Estimating Atmospheric Transport and and applicability to non-LWRs? Dispersion of Gaseous Effluents in Routine Atmospheric Releases from Light-Water-Cooled Reactors, Dispersion is relevant to non-light water reactors. The manner in which RG 1.111 is referenced in the ISG reflects the NRC staff determination that 7
Comment Topic Section of Specific Comments NRC Staff Response Identifier Document despite the title of the RG the NRC staff considers the guidance to be generally applicable to non-LWRs.
NRC- Section 2.6.5 - Pg 22 The last sentences of paragraph 2.6.5.1 and The NRC staff agrees with this comment.
2022- Stability of item c in paragraph 2.6.5.2 denote the need 0074 Slopes for analysis and operating experience. This is The NRC staff notes that paragraph 2.6.5.1 with DRAFT excessive and conflicts with other text in this the exception of the last sentence provides 0006-6 section denoting current practice and state- sufficient guidance for expectations for of-the-art. Revise the text to remove this information to be provided in the SAR related excessive conservatism. to stability of slopes. The NRC staff agrees that the last sentence: The application should also discuss comparative field performance of similar slopes whenever possible, would not be a significant part of the slope stability analysis and, therefore, this last sentence was removed from the final version of this ISG.
Consistent with the change to Section 2.6.5.1, the NRC staff has removed the associated acceptance criteria in Section 2.6.5.2. That is the following acceptance criteria was removed from the final version of this ISG:
The application describes the performance of similar slope designs and confirms their stability.
NRC- Section 2.7.2 - Pg 24 This is the same as comment 0004-25 above. See response to comment 0004-25 above.
2022- Screening 0074 Approach for DRAFT Other External 0006-7 Hazards 8