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
Month Year 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 Identifier Topic Section of Document Specific Comments NRC Staff Response NRC-2022-0075 DRAFT Regulations.gov Site Not Applicable Note that the underlying comment in M23167A038 and ML23167A039 are the same.
The NRC staff responded to the request as documented in ML23174A004. The response states in part:
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.
2 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response 0002-1/NRC-2022-0075 DRAFT 0003-1 Include in regulations.gov, as downloadable files, all documents for which public comments are being solicited the regulations.gov website identifies the documents (the advanced reactor content of application project (ARCAP) interim staff guidance (ISGs) and the technology inclusive content of application project (TICAP) draft 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-2022-0075 DRAFT 0002-1/NRC-2022-0075 DRAFT 0003-1 Extension of Comment Period Not Applicable Note that the underlying comment in M23167A038 and ML23167A039 are the same.
Alter the Federal Register notices to establish a reasonable, staggered schedule for document review and comment by the public.
The NRC staff responded to the request as documented in ML23174A004. As a result of this request and request from the Nuclear Energy Institute (ML23171B098) the NRC staff extended the comment period for nine interim staff guidance documents and DG-1404, revision 0, from July 10, 2023, to August 10, 2023.
NRC-2022-0075 DRAFT 0004-24 Editorial Pg 2 - 1st line at top of page Need space between a and non-LWR.
The NRC staff agrees with this comment.
ISG revised to add space.
NRC-2022-Section 2.7.2 -
Screening Pg 24 Additional guidance (or a more standardized approach) for screening external hazards could The NRC staff disagrees with this comment.
3 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response 0075 DRAFT 0004-25 Approach for Other External Hazards help streamline the process and minimize the number of pre-application interactions.
Consider developing a standardized approach detailing the elements that are required for an external hazard screening flow chart acceptable to the NRC.
The NRC staff is considering developing additional guidance for an approach detailing the elements that are required for an external hazard screening flow chart. However, development of such a flow chart and 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.
4 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response NRC-2022-0075 DRAFT 0004-26 Section 2.3.1 -
Nearby Industrial, Transportation, and Military Facilities Pg 10 In the second paragraph of this section it is stated Each hazard that could result in an event 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). Please remove the quoted text. This sentence implies requirements that exceed current requirements for evaluating external hazards.
The NRC staff agrees with this comment.
The NRC staff notes that the last paragraph in the section provides guidance that the evaluation should be performed in accordance with RG 1.233 and NEI 18-04. Based on this, the following sentence in the second paragraph of Section 2.3.1 has been deleted:
Each hazard that could result in an event 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
5 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response 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-2022-0074 DRAFT 0006-1 General The ARCAP documents are stated to be applicable to non-LWRs. However, all the guidance is technology-inclusive and is equally applicable to LWRs. Please indicate that the guidance is applicable to LWRs.
The NRC staff disagrees with this comment.
The NRC staff is considering expanding the applicability of ARCAP guidance documents 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
6 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response 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-2022-0074 DRAFT 0006-2 General The review should eliminate review of external hazards that are not possible for ML applicants, but remain applicable to CP, OL and COL applicants (e.g., stability of slopes).
Please add text similar to the following:
For an ML application the site description should describe the site characteristics as they affect the design (e.g., a site parameter envelope). Other site characteristics are left to the COL applicant to provide as well as the site-specific information necessary to demonstrate that site characteristics fit within the plant parameter envelope.
The NRC staff disagrees with this comment.
The NRC staff notes that the guidance includes the following paragraph that provides guidance for design certification (DC), standard design approval (SDA) and manufacturing license (ML) applicants that address the applicability of the guidance to these applications:
Under 10 CFR 52.47(a)(1), DC applications must describe the site parameters postulated for the design. Similarly, under 10 CFR 52.137(a)(1) and 10 CFR 52.157(f)(19),
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
7 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response 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-2022-0074 DRAFT 0006-3 Typo Pg 2 This is the same comment as 0004-24 above.
See response to comment 0004-24 above.
NRC-2022-0074 DRAFT 0006-4 Guidance Pg 5 The last sentence in the third full paragraph indicates that external hazards not supported by PRA will be covered deterministically. The guidance should not preclude a potential combination of PRA and deterministic techniques.
The NRC staff agrees with this comment.
As a result of the comment the following change has been made to the last sentence:
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-2022-0074 DRAFT 0006-5 Section 2.4 -
Regional Climatology, Local Meteorology, and Atmospheric Dispersion Pg 13 In the first paragraph on page 13 reference is made to RG 1.111 for estimating atmospheric transport and dispersion of gaseous effluents.
The title of RG 1.111 states it is for LWRs.
Has NRC made a determination of its applicability to non-LWRs?
No change to the ISG is being made as a result of this comment. The answer to the question is yes, the NRC staff has determined that guidance found in RG 1.111, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors, 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
8 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response despite the title of the RG the NRC staff considers the guidance to be generally applicable to non-LWRs.
NRC-2022-0074 DRAFT 0006-6 Section 2.6.5 -
Stability of Slopes Pg 22 The last sentences of paragraph 2.6.5.1 and item c in paragraph 2.6.5.2 denote the need for analysis and operating experience. This is excessive and conflicts with other text in this section denoting current practice and state-of-the-art. Revise the text to remove this excessive conservatism.
The NRC staff agrees with this comment.
The NRC staff notes that paragraph 2.6.5.1 with the exception of the last sentence provides sufficient guidance for expectations for information to be provided in the SAR related 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-2022-0074 DRAFT 0006-7 Section 2.7.2 -
Screening Approach for Other External Hazards Pg 24 This is the same as comment 0004-25 above.
See response to comment 0004-25 above.