ML23283A117
| ML23283A117 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/2023 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | |
| Shared Package | |
| ML23283A092 | List: |
| References | |
| DANU-ISG-2022-04 | |
| Download: ML23283A117 (1) | |
Text
Analysis of Public Comments on Draft DANU-ISG-2022-04 Advanced Reactor Content of Application Project Chapter 10, Control of Occupational Dose 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-2022-0074-DRAFT-0006 ML23229A120 Nuclear Energy Institute Ben Holtzman Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document RC-2022 General General Please rephrase to indicate the guidance is technology- The NRC staff partially agrees with this comment.
0074- DRAFT- inclusive and is equally applicable to both LWR and non-0006- 1 LWR designs. The NRC staff is considering expanding the applicability of Advanced Reactor Content of Application Project (ARCAP) guidance Throughout all the documents of the package, there are documents beyond non-light water reactors (non-LWRs). However, statements that this guidance is applicable to nonLight expansion of the guidance beyond non-LWRs at this time is Water Reactors (LWRs). However, all the guidance is premature.
technology-inclusive and is equally applicable to LWRs.
ARCAP is supposed to be applicable for any technology The final ISG continues to note that the NRC staff is developing an (non-LWR and LWR), any licensing approach (LMP, optional performance-based, technology-inclusive regulatory classical, etc.), and any licensing path (CP, COL, DC etc.). framework for licensing nuclear power plants designated as 10 CFR Part 53, Licensing and Regulation of Advanced Nuclear Reactors, For the ARCAP guidance, industry specifically requested (RIN 3150-AK31). It is envisioned that the 10 CFR Part 53 guidance the NRC develop guidance applicable to both non-LWRs would be applicable to both LWR and non-LWRs. Should the 10 CFR
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document and LWR SMRs, and we were informed in various meetings Part 53 rulemaking include requirements for both LWR and non-that this would be the NRCs approach. While NEI 18-04 LWRs the NRC staff envisions that the concepts found in the ARCAP and NEI 21-07 were developed specifically for advanced ISGs guidance would be expanded beyond non-LWRs. In the interim, non-LWRs, applicants with LWR designs should also be the NRC staff notes that the applicability section of the ISG notes that able to use the Licensing Modernization Project (LMP) applicants desiring to use the ISG for a light water reactor application methodology if they elect to do so (e.g., NEI 18-04 and NEI should contact the NRC staff to hold pre-application discussions on 21-07). It would be up to the applicants to justify the use of their proposed approach.
the guidance documents and associated regulatory guides.
No change has been made to the ISG at this time.
NRC-2022- As low as ARCAP The commenter provided the following comment in the NEI did not propose any changes to the ARCAP ISG because of this 0074 DRAFT - reasonably Roadmap ISG ARCAP roadmap ISG regarding ALARA. The specific comment. The NRC staff does not agree with NEIs characterization 14 achievable and ARCAP comment is; of the guidance in ISG Chapter 10. The guidance references design ISG Chapter 10 elements to control occupational exposures in several instances and The wording on ALARA in Chapter 10 indicates that the include the following acceptance criteria:
guidance will continue the well-established operational program for ALARA but not extend ALARA into the design, Describe important equipment and facility design features that as a regulatory requirement. Industry agrees with this satisfy the design-specific PDC necessary to control occupational position as it provides a predictable regulatory framework. exposure, including ensuring occupational radiation exposures are ALARA, such as shielding, ventilation, area radiation and airborne radioactivity monitoring instrumentation, and dose assessment for expected occupancy.
To further clarify the relationship between radiation protection programs and the Chapter 10 ISG, the staff added reference to NEI 07-03A, Generic FSAR Template Guidance for Radiation Protection Program Description, to acceptance criteria g. NEI 07-03A may be used in conjunction with the template NEI-07-08A, Generic FSAR Template Guidance for Ensuring that Occupational Radiation Exposures are as Low as is Reasonably Achievable (ALARA),
which is referenced in this ISG. The NEI guidance documents and related NRC safety evaluations discuss the relationships between various design features, some of which might be in a design-centered application (e.g., design certification) and some of which might be deferred to a combined license application, and programmatic controls developed for plant operations.