ML23283A121
| ML23283A121 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/2023 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | |
| Shared Package | |
| ML23283A092 | List: |
| References | |
| DANU-ISG-2022-08 | |
| Download: ML23283A121 (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 DANU-ISG-2022-08 Advanced Reactor Content of Application Project Risk-Informed Technical Specifications 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-2022-0081-DRAFT-0001 ML23167A480 Hybrid Power Technologies LLC Michael Keller NRC-2022-0074- DRAFT-0006 ML23229A120 Nuclear Energy Institute Ben Holtzman NRC-2022-0075-DRAFT-0004 ML23234A052 X-Energy, LLC Travis Chapman Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document NRC-2022- General Not The NRC is issuing a large number of complicated A similar comment was received by 0081- Applicable documents while expecting comments in a short period of the commenter on other interim DRAFT- time. There is little question that the NRC is attempting to staff guidance (ISG) dockets. The 0001-1 simply short circuit the process of conducting meaningful NRC staff responded to the request reviews and providing comments. I seriously doubt the as documented in ML23174A004.
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Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document NRC's actions comply with the Nuclear Modernization As a result of this comment and Act which makes the NRC's actions of doubtful legality. request from the Nuclear Energy Stagger the documents out over a reasonable time frame. Institute (ML23171B098) the NRC staff extended the comment period for nine interim staff guidance documents and draft guide (DG) 1404, revision 0, from July 10, 2023, to August 10, 2023.
NRC-2022 General General Please rephrase to indicate the guidance is technology- The NRC staff disagrees with this 0074- inclusive and is equally applicable to comment.
DRAFT- both LWR and non-LWR designs.
0006- 1 The NRC staff is considering Throughout all the documents of the package, there are expanding the applicability of statements that this guidance is applicable to nonLight advanced reactor content of Water Reactors (LWRs). However, all the guidance is application project (ARCAP) technology-inclusive and is equally applicable to LWRs. guidance documents beyond non-ARCAP is supposed to be applicable for any technology light water reactors (non-LWRs).
(non-LWR and LWR), any licensing approach (LMP, However, expansion of the classical, etc.), and any licensing path (CP, COL, DC etc.). guidance beyond non-LWRs at this time is premature.
For the ARCAP guidance, industry specifically requested the NRC develop guidance applicable to both non-LWRs The final ISG continues to note that and LWR SMRs, and we were informed in various the NRC staff is developing an meetings that this would be the NRCs approach. While optional performance-based, NEI 18-04 and NEI 21-07 were developed specifically for technology-inclusive regulatory advanced non-LWRs, applicants with LWR designs should framework for licensing nuclear also be able to use the Licensing Modernization Project power plants designated as 10 CFR (LMP) methodology if they elect to do so (e.g., NEI 18-04 Part 53, Licensing and Regulation and NEI 21-07). It would be up to the applicants to justify of Advanced Nuclear Reactors, the use of the guidance documents and associated (RIN 3150-AK31). It is envisioned regulatory guides. 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 2
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document 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 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.
NRC-2022 Completion p.13 NRC should consider providing additional clarification The NRC staff partially agrees with 0074- times about how the acceptance criteria for CDF and LERF this comment.
DRAFT- metrics in RG 1.177 should be interpreted with respect to 0006- 2 the NEI 18-04 integrated risk metrics. For example, In the near term, the NRC staff has should a licensee interpret the incremental conditional no plans to revise RG 1.177 to core damage probability (ICCDP) metric in RG 1.177 as address licensing modernization directly interchangeable with an incremental conditional project (LMP) (QHO) criteria.
latent cancer fatality risk metric? However, to provide additional clarity, this ISG is revised to add the The text states: "RG 1.177, position 2.3.4, references the following text at the end of item (3) risk metrics of core damage frequency and large early in the section titled Limiting release frequency based on LWRs as factors in Condition for Operation Format:
determining completion times. Advanced reactor applicants should use other risk metrics, such as those NEI 18-04, Section 3.3.5, described in NEI 18-04, for determining completion Selection of Risk Metrics for PRA times." Model Development, describes several possible risk metrics (that The NEI 18-04 approach involves direct quantification of are different from CDF and LERF risk metrics for comparison to the Quantitative Health metrics developed for LWRs).
Objectives (QHOs): latent cancer fatalities and early These metrics could be used by an fatalities. RG 1.177, Section 2.4, "Acceptance Guidelines applicant to develop LCO for Technical Specification Changes," provides completion times. Applicants quantitative acceptance criteria for technical specification should discuss their proposed risk changes in terms of CDF and LERF. There is interest in metrics for developing LCO NRC development of similar acceptance criteria for the completion times with NRC staff NEI 18-04 latent cancer fatality and early fatality during preapplication discussions.
integrated risk metrics.
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Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document NRC-2022 PSAR p. 13-16 Please provide clarification on the level of detail expected, The NRC staff agrees with this 0074- scope based on the discussion in this draft guidance, for the comment.
DRAFT- surveillance requirements, design features, and 0006- 3 administrative controls sections of the preliminary safety The construction permit (CP) analysis report (PSAR) technical specification (TS). discussion in the Application Guidance section of this ISG is 10 CFR 50.34(a)(5) requires An identification and revised to add the following text:
justification for the selection of those variables, conditions, or other items which are determined as the For preliminary safety analysis result of preliminary safety analysis and evaluation to be reports (PSARs), probable subjects probable subjects of technical specifications for the of technical specifications, with facility, with special attention given to those items which attention to information which may may significantly influence the final design. significantly influence the final design should be provided in the For the surveillance requirements, design features, and form of preliminary LCOs [limiting administrative controls sections of the PSAR TS; what condition for operations], a level of detail does the NRC staff expect to see in the preliminary list of the types of PSAR? surveillance tests being considered, and a preliminary description of important design features. It is not necessary that PSAR technical specifications provide surveillance requirement frequencies or administrative controls.
Furthermore, the PSAR should include a preliminary Technical Specification Bases document that addresses information in the PSAR technical specifications.
NRC-2022 Exemption p. 17 Please clarify whether there is a plan to minimize the need As present, the NRC staff does not 0074- for lengthy and costly exemptions for all non-LWR plan to revise 10 CFR 50.36 to DRAFT- applicants. Either by revising 50.36 or otherwise. address non-LWR applications. In 0006- 4 the Federal Register Notice related Item (8) mentions that TS are to meet 50.36, which were to this ISG, the staff requested developed for LWRs. The draft ARCAP Roadmap DANU public comment on whether the ISG202201 denotes that this regulation is applicable for correlation in the ISG between the 50.36 text and the outputs described 4
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document non-LWRs but that in some cases, exemptions are in NEI 18-04 can be interpreted as a expected to be taken. departure from the regulation text and whether the NRC staff will need to consider whether exemptions are necessary. The staff received no public input on this question. Therefore, the last paragraph of the "Contents of Technical Specifications" section is revised as follows:
To provide suitable guidance on risk-informed TS for advanced reactors, this ISG correlates the text in 10 CFR 50.36 with the analysis and outputs of the risk-informed approach described in NEI 18-04.In some cases, this correlation may be interpreted as a significant departure from the regulation text, in which case the applicant should include an exemption request as part of its application.
Given that this ISG provides guidance to non-LWR applicants regarding the correlation between 50.36 and NEI 18-04, the development of an exemption consistent with this ISG should not present a significant burden on applicants.
NRC-2022- PSAR Pages 13-16 Please provide clarification on the level of detail expected Refer to the response to comment 0075- scope of 20 for the PSAR technical specifications. NRC-2022-0074- DRAFT-0006- 3.
DRAFT-0004- 34 5
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document For the surveillance requirements, design features, and administrative controls sections of the Preliminary Safety Analysis Report (PSAR) technical specifications, what level of detail does the NRC staff expect to see in the PSAR?
NRC-2022- Exemption Page 17 of 20 Please clarify if exemptions will be needed from 50.36 or Refer to the response to comment 0075- s provide a revision to 50.36 to reflect this ISG and NEI 18- NRC-2022-0074- DRAFT-0006- 4.
DRAFT- 04 to avoid lengthy and costly exemptions.
0004- 35 Item (8) mentions that Technical Specifications (TS) are to meet the regulations in 10 CFR 50.36, which are the TS requirements for LWRs. Is 50.36 going to be revised to reflect NEI 18-04 methodology, or will every advanced reactor applicant require exemptions from 50.36?
NRC-2022- Completion Page 13 of 20 Please provide additional clarification about how the Refer to the response to comment 0075- times acceptance criteria for CDF and LERF metrics in RG NRC-2022-0074- DRAFT-0006- 2.
DRAFT- 1.177 should be interpreted with respect to the NEI 18-04 0004- 36 integrated risk metrics. For example, should a licensee interpret the incremental conditional core damage probability (ICCDP) metric in RG 1.177 as directly interchangeable with an incremental conditional latent cancer fatality risk metric?
The guidance states, "RG 1.177, position 2.3.4, references the risk metrics of core damage frequency and large early release frequency based on LWRs as factors in determining completion times. Advanced reactor applicants should use other risk metrics, such as those described in NEI 18-04, for determining completion times." The NEI 18-04 approach involves direct quantification of risk metrics for comparison to the Quantitative Health Objectives (QHOs): latent cancer fatalities and early fatalities. RG 1.177, Section 2.4, "Acceptance Guidelines for Technical Specification Changes" provides quantitative acceptance criteria for technical specification changes in terms of CDF and LERF. X-energy is interested in NRC development of 6
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document similar acceptance criteria for the NEI 18-04 latent cancer fatality and early fatality integrated risk metrics.
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