ML23292A025

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Advanced Reactor Content of Application Project (Arcap) Interim Staff Guidance (ISG) Documents and Technology Inclusive Content of Application Project (Ticap) Guidance Documents Status ACRS Future Plant Designs Subcommittee November 16, 202
ML23292A025
Person / Time
Issue date: 10/31/2023
From: Joseph Sebrosky
NRC/NRR/DANU/UARP
To:
Shared Package
ML23283A092 List:
References
Download: ML23292A025 (1)
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Text

The NRC staff has publicly released these draft slides to support interactions with the Advisory Committee on Reactor Safeguards (ACRS).

These slides have not been subject to complete NRC management or legal reviews and are subject to change prior to the ACRS Subcommittee meeting.

Advanced Reactor Content of Application Project (ARCAP) Interim Staff Guidance (ISG) Documents and Technology Inclusive Content of Application Project (TICAP) Guidance Documents Status ACRS Future Plant Designs Subcommittee November 16, 2023

Purpose and Agenda

  • Provide a high-level overview of the Technology Inclusive Content of Application Project (TICAP) Regulatory Guide 1.253 and the nine Advanced Reactor Content of Application Project (ARCAP) Interim Staff Guidance Documents Include overview of the comments received and the NRCs disposition of these comments

Discussion of ARCAP interim staff guidance documents Path forward 3

Background

  • ACRS Future Plant Designs Subcommittee Previous Briefings
  • March 17, 2021 Provided a high-level overview of the structure of ARCAP and TICAP
  • July 21, 2021 Updated overview of structure of ARCAP and TICAP
  • December 17, 2021 Provided a high-level overview of the draft white paper versions of the nine ARCAP ISGs and the TICAP draft regulatory guide 4

Background

  • ACRS Future Plant Designs Subcommittee Previous Briefings (continued)

After these briefing the NRC staffs near-term focus is that the ARCAP and TICAP guidance is being issued to support near term 10 CFR Part 50 and 52 non-light water reactor applications Longer term the NRC staff will update the guidance as appropriate to support the 10 CFR Part 53 rulemaking effort 5

Background - How to Access Draft Documents and Comments

  • Revision 0 of ten draft documents were reissued in May of 2023 (ADAMS Package No. ML23044A038).
  • Revision 1 of the TICAP guidance was issued is September of 2023

ML22048B546 NRC-2022-0074 68 Roadmap Draft DANU-ISG-2022-02, Chapter 2, Site Information ML22048B541 NRC-2022-0075 12 Draft DANU-ISG-2022-03, Chapter 9, Control of Routine Plant Radioactive Effluents, Plant Contamination and Solid ML22048B543 NRC-2022-0076 13 Waste Draft DANU-ISG-2022-04, Chapter 10, Control of Occupational Doses ML22048B544 NRC-2022-0077 2 Draft DANU-ISG-2022-05, Chapter 11, Organization and Human-System Consideration ML22048B542 NRC-2022-0078 12 Draft DANU-ISG-2022-06, Chapter 12, Post Construction Inspection, Testing and Analysis Program ML22048B545 NRC-2022-0079 9 Draft DANU-ISG-2022-07, Risk-Informed ISI/IST Programs ML22048B549 NRC-2022-0080 43 Draft DANU-ISG-2022-08, Licensing Modernization Project-based Approach for Developing Technical ML22048B548 NRC-2022-0081 8 Specifications Draft DANU-ISG-2022-09, Risk-Informed, Performance-Based Fire Protection Program (for Operations) ML22048B547 NRC-2022-0082 23 Draft Regulatory Guide 1404, Guidance for a Technology Inclusive Content of Application Methodology to Inform the ML22076A003 NRC-2022-0073 73 Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Advanced Reactors Draft Regulatory Guide 1404, Revision 1 - added Appendix B to provide additional guidance for expectations for a ML23194A194 NRC-2022-0073 30 probabilistic risk assessment (PRA) at the construction permit (CP) stage 6

ARCAP/TICAP Background

  • Overview of ARCAP/TICAP draft guidance documents provided during an advanced reactor stakeholder public meeting on June 7, 2023 Overview included a discussion of changes to draft guidance documents from white paper versions of the documents See slides 96 through 144 at ML23157A018 o Includes both NRC staff slides and Nuclear Energy Institute Slides Meeting occurred during the open comment period for the documents o Included information on how to provide comments on documents
  • Public meeting held on August 22, 2023 (after public comment period ended) to provide commenters an opportunity to discuss their comments Meeting summary available at: ML23236A481 7

ARCAP/TICAP Background

  • Public meeting held on September 26, 2023, to discuss DG-1404, Revision 1 DG-1404 Revision 1 included additional guidance related to construction permit probabilistic risk assessment development Meeting held during public comment period o Purpose was to facilitate stakeholder understanding of guidance and to provide information on how to provide comments on the draft guidance Meeting slides available at: ML23265A185
  • Material to support todays meeting available at: ML23283A092 Includes ten comment resolution tables and ten guidance documents Guidance documents provide a comment identification that provides a reason for the change

ARCAP/TICAP Background

  • Guidance for developing and reviewing technology-inclusive, risk-informed, and performance-based non-light water (non-LWR) applications
  • Being developed to support 10 CFR Part 50 and 10 CFR Part 52 applications Needed to support expected near-term non-LWR Part 50/52 applications using the licensing modernization project (LMP) process in NEI 18-04, Revision 1
  • The NRC staff intends to revise the guidance per the final Part 53 rulemaking language 9

ARCAP Background

  • Broad in nature and intended to cover guidance for non-LWR applications for:

combined licenses construction permits operating licenses design certifications standard design approvals manufacturing licenses

  • Encompasses TICAP TICAP is guidance for off-normal reactor states only.

o ARCAP encompasses everything needed for a license application.

10

TICAP Background

  • TICAP scope is governed by the LMP-based process LMP uses risk-informed, performance-based approach to select licensing basis events, develop structures, systems, and components (SSC) categorization, and ensure that defense-in-depth is considered
  • Industry developed key portions of TICAP guidance See NEI 21-07, Revision 1, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Utilizing NEI 18-04 Methodology, (ADAMS Accession No. ML22060A190)
  • RG 1.253 (issued as DG-1404) proposes to endorse NEI 21-07, Revision 1, with clarifications and additions There are no proposed exceptions 11

ARCAP and TICAP - Nexus Outline Safety Analysis Report (SAR) - Additional Portions of Application Based on TICAP Guidance

  • Technical Specifications
1. General Plant Information, Site Description,
  • Technical Requirements Manual and Overview
  • Quality Assurance Plan (design)
2. Methodologies and Analyses and Site

Information*

  • Quality Assurance Plan (construction
3. Licensing Basis Event (LBE) Analysis and operations)
4. Integrated Evaluations
5. Safety Functions, Design Criteria, and SSC
  • Security Plan Safety Classification Audit/inspection of Applicant Records
6. Safety Related SSC Criteria and Capabilities
  • Calculations
7. Non-safety related with special treatment
  • Analyses
  • SNM material control and accounting SSC Criteria and Capabilities
8. Plant Programs
  • System Descriptions
  • Radiation Protection Program
  • Design Drawings
  • Design Specs
  • Inservice inspection/Inservice testing Scope of TICAP
  • Procurement Specs (ISI/IST) Program
9. Control of Routine Plant Radioactive
  • Environmental Report and Site Effluents, Plant Contamination, and Solid Redress Plan Waste
  • Financial Qualification and Insurance
10. Control of Occupational Doses and Liability
11. Organization and Human-System
  • Aircraft Impact Assessment
12. Post-construction Inspection, Testing and
  • Performance Demonstration Analysis Programs Requirements
  • Nuclear Waste Policy Act
  • SAR Chapter 2 derived from TICAP guidance as supplemented by ARCAP interim
  • Operational Programs staff guidance Chapter 2, Site Information
  • Exemptions, Departures, and
  • Safety Analysis Report (SAR) structure based on clean sheet approach Variances )
  • Additional contents of application may exist only in the SAR, may be in a separate document incorporated into the SAR, or may exist only outside the SAR. 12
  • The above list is for illustration purposes only.

TICAP and ARCAP Roadmap Common Guidance

  • Applicability is now only for non-LWRs Recommends that light-water reactor applicants wanting to use ARCAP/TICAP guidance engage in pre-application discussions
  • All ISGs provide applicant guidance and NRC staff review guidance in separate sections
  • Removed references that did not have complete NRC staff review Appendices added to several ISGs to list in-development guidance documents that could affect future revision of those ISGs 13

TICAP and ARCAP Roadmap Common Guidance

  • Importance of Principal Design Criteria (PDC)

TICAP guidance covers PDCs associated with the licensing modernization project (i.e., those associated with off-normal conditions)

ARCAP roadmap ISG and associated ISGs (e.g., ARCAP Chapter 9) contains PDC guidance for normal operations RG 1.232, Guidance For Developing Principal Design Criteria For Non-light-water Reactors, (ML17325A611) provides additional guidance for reviewer consideration ARCAP roadmap ISG recommends discussion of PDC during preapplication phase 14

Technology Inclusive Content of Application Project - Overview and Discussion of Comments on DG-1404 15

TICAP - High Level Overview

  • Goal is to develop technology-inclusive guidance that proposes an optional formulation of advanced reactor application content that is based on a risk-informed, performance-based approach for demonstrating that plant safety meets the underlying intent of the current requirements
  • Guidance is intended to increase efficiency of developing and reviewing an application
  • Scope is governed by the LMP methodology to facilitate a systematic, technically acceptable, and predictable approach for developing key portions of a designs SAR The LMP methodology provides processes for identifying LBEs, classifying and establishing special treatments for certain SSCs, and ensuring DID adequacy

All sources of radiological material, all hazards, all plant operating states, full analysis of scenario progressions (i.e., analyzed from initiator to radiological consequence) 16

TICAP Guidance 17

TICAP Construction Permit/Operating License Guidance 18

Construction Permit PRA Acceptability Key Points from DG-1404, Revision 1:

  • All sources, hazards, and plant operating states (POSs) should be addressed (i.e., identified and dispositioned) in the CP application, where dispositioned means each item is either:

Modeled in the PRA logic model,*

NOTE: Generally referring to the PRA Screened out of the PRA logic model with justification,* implies these three items Accounted for using risk-informed supplemental evaluations, or Accounted for using design-basis hazard levels (DBHLs) for hazards other than internal events

  • As a minimum, the LMP-based CP application should be supported by an internal events, at-power, reactor PRA logic model, which represents the fundamental plant response model that:

helps demonstrate the applicants ability to develop an acceptable PRA logic model and establishes an acceptable foundation for upgrading the PRA logic model as the design progresses while acceptable for the CP stage of licensing, achieving only the minimum scope of the PRA logic model may not realize the full benefit of the LMP methodology

  • The ASME/ANS non-LWR PRA consensus standard, ASME/ANS RA-S-1.4-2021, provides requirements and processes for defining the scope of the CP PRA logic model.

19

Construction Permit PRA Acceptability Key Points from DG-1404, Revision 1 (continued):

  • A self-assessment of the PRA logic model, screening analyses, and risk-informed supplementary evaluations helps reduce the need for in-depth NRC review This could be a peer review but is not required as such
  • The CP application should provide a preliminary, yet complete**, set of LBEs
  • The CP application should provide a preliminary, yet complete**, SSC classifications
  • Further expectations The CP application should provide a plan for maintaining and upgrading the PRA during construction.

o Example: Replacing a seismic DBHL with a seismic PRA o CP holders are encouraged to keep the staff advised of changes to the PRA completion plan that significantly affect the design.

    • Consistent with the maturity of design information and relative to the scope of the PRA logic model, screening analyses, and risk-informed supplementary evaluations supporting the CP application.

20

TICAP Comments

  • Seventy-three comments received on DG-1404, Revision 0
  • Thirty comments received on DG-1404, Revision 1
  • Most comments related to the ARCAP/TICAP guidance documents
  • Changes resulting from comments on Revision 0:

Removed clarifications and additions related to principal design criteria (PDC) o NRC staff determined that the PDC guidance found in NEI 21-07, Revision 1, is sufficient such that RG 1.253 clarifications and additions are not needed Removed note regarding need to engage NRC for applicants using risk-informed performance based approached other than LMP o Agreed with commenter that this approach is outside the scope of RG 1.253 21

TICAP Comments

  • Changes resulting from comments on Revision 0 (continued):

Provided clarification regarding use of guidance for a manufacturing license (ML) or standard design approval (SDA) o NEI 21-07, Revision 1, provides guidance for combined licenses, design certifications, construction permits and operating licenses but not MLs or SDAs o Removed RG 1.253 applicability of guidance to MLs and SDAs Added discussion that ML and SDA applicants should consider the design certification guidance and make appropriate modifications ML and SDA applicants are encouraged to discuss their intended use of the guidance with NRC staff during preapplication interactions Other suggested additions related to MLs not accepted by the NRC staff 22

TICAP Comments

  • Changes resulting from comments on Revision 0 (continued):

Moved references to supporting guidance from RG 1.253 to ARCAP roadmap ISG o Examples include reference to design review guide for instrumentation and control and ASME Section III Division 5 guidance NRC staff agreed with commenter that such references are outside the scope of RG 1.253 and more properly belong in ARCAP roadmap ISG o As a result of this comment DG-1404, Appendix A - Guidance Documents Under Development was removed from RG 1.253 Guidance documents under development found in Appendix D of ARCAP roadmap ISG DG-1404, Appendix B (CP PRA guidance), is found in Appendix A to RG 1.253 23

TICAP Comments

  • Changes resulting from comments on Revision 1:

Added language to affiliate staff positions with one of the following:

PRA acceptability Documentation needed in the SAR to demonstrate the acceptability of the CP PRA Archival documentation needed to demonstrate the acceptability of the CP PRA Added language to clarify the use of the term PRA Explain that the tables on applicability of supporting requirements are not required and the Revised applicability of some supporting requirements 24

TICAP Comments

  • Comments related to Revision 0 that are resolved with no changes:

NRC staff did not expand the guidance to light water reactors (LWR) o The scope of NEI 18-04, Revision 1, and NEI 21-07, Revision 1, are limited to non-LWRs Based on the ASME/ANS non-LWR PRA consensus standard endorsed for trial use (i.e., full-scope PRA)

The series of PRA consensus standards needed to achieve a full-scope PRA for LWRs has not yet been endorsed o LWR applicants choosing to use LMP for their applications are encouraged to discuss their plans with the NRC staff 25

TICAP Comments

  • Comments related to Revision 1 that are resolved with no changes:

Documenting essential assumptions in the PSAR Descriptions of risk metrics used that address meeting the QHOs Emphasizing the meaning of addressing all sources, hazards, and POSs Addressing that LMP is risk-informed, not risk-based Addressing use of the phrase full LMP implementation Meeting high-level requirements and related staff positions on PRA acceptability by virtue of meeting underlying, applicable supporting requirements in ASME/ANS RA-S-1.4-2021 Comments that are out-of-scope 26

Advanced Reactor Content of Application Project Roadmap -

Overview and Discussion of Comments 27

ARCAP Roadmap Overview

  • Provides content of application guidance for all portions of an application
  • Proposes a 12-chapter SAR guidance structure Guidance for first 8 SAR chapters primarily from TICAP guidance Additional guidance for first 8 chapters of the SAR provided o Examples include reference to DANU-ISG-2022-02, Site Information o Additional references for consideration (e.g., design review guide for instrumentation and control, ASME Section III, Division 5, and structural analysis guidance)

Chapters 9, 10, 11, and 12 point to individual ISGs developed for each SAR chapter o These chapters are outside the scope of the LMP process

  • Includes pointers to Tech spec ISG, ISI/IST ISG, and fire protection for operations ISG
  • Provides guidance for other portions of the application outside of these ISGs 28

ARCAP Roadmap Overview Additional Portions of Application

  • Provides guidance for other portions of the
  • Technical Specifications
  • Technical Requirements Manual application outside of ISGs including emergency
  • Quality Assurance Plan (design)
  • Quality Assurance Plan (construction and operations) and liability
  • Security Plan
  • Includes four appendices
  • SNM material control and accounting
  • Radiation Protection Program light water reactors
  • Inservice inspection/Inservice testing Appendix C - Construction Permit Guidance (ISI/IST) Program
  • Environmental Report and Site Appendix D - Draft Documents Under Redress Plan
  • Financial Qualification and Insurance Development and Liability
  • Aircraft Impact Assessment
  • Performance Demonstration Requirements
  • Nuclear Waste Policy Act
  • Operational Programs 29

ARCAP Roadmap Comments

  • Sixty-eight comments received
  • Represents second most comments received on ARCAP/TICAP guidance documents
  • Changes made because of comments:

Expanded the applicability of Appendix B (Applicability of Regulations to Non-LWRs) to Manufacturing License applications.

Deleted reference to the Facility Safety Program.

Expanded guidance on leaks from coolant systems to specifically address leaks from low pressure systems.

Added guidance that applicants need to consider safety concerns beyond those identified by the LMP process when identifying PDCs applicable to their design.

30

ARCAP Roadmap Comments Added guidance that applicants are responsible for identifying needed programs beyond those specified in Section 8.

Transferred several items (e.g., consideration of LWR GSIs) from DG-1404 to the Roadmap, since they are not part of the LMP process.

Requested changes not incorporated:

  • Add a statement that consensus Codes and Standards have more weight and take precedence over regulations.
  • Eliminate the design detail required in the SAR. Only identify the hazards for which design measures have been implemented.

31

ARCAP Roadmap Comments Comments not incorporated (continued)

  • Delete Chapter 11, Organization and Human-System Considerations.

Commenter indicated that The relationship with safety is tenuous.

  • Extend the applicability of the documents to LWRs. (NOTE: expanding the applicability to LWRs is under consideration as a future action. The current limitation to non-LWRs is for consistency with NEI 18-04 and 21-07, whos scope is non-LWRs.)

32

Advanced Reactor Content of Application Project Chapter 2 Site Information Overview and Discussion of Comments 33

Chapter 2 Overview

  • Chapter 2 provides guidance on the scope and approach for selecting the external hazards which must be considered in the plant design.
  • The selection of external hazards is to be informed by a probabilistic external hazards analysis, when supported by available methods, data, standards and guides.
  • Chapter 2 limits the amount of information that needs to be provided in the SAR to that necessary to establish the design basis external hazards.
  • Chapter 2 refers to existing site evaluation guidance (e.g., RGs) where appropriate.
  • The guidance in Chapter 2 is based upon the requirements of 10 CFR Part 100, Subpart B.
  • 12 comments received.

34

Chapter 2 Comments

  • Changes made because of comments:

Revised the frequency of occurrence of external hazards to be considered in the design to be consistent with existing guidance.

Allow the use of a combination of probabilistic and deterministic methods to select external hazards.

Eliminated the need to submit historical information on slope stability.

  • Requested changes not incorporated:

Development of a standardized process for screening out external hazards 35

Advanced Reactor Content of Application Project Chapter 9 - Control of Effluents, Plant Contamination and Solid Waste Overview and Discussion of Comments 36

Chapter 9 Overview

  • Applies a performance-based approach for level of detail of information provided in the SAR related to control of routine plant radioactive effluents, plant contamination and solid waste 37

Chapter 9 Comments Changes made because of comments:

  • Clarified application content for design certifications, manufacturing licenses, and standard design approvals
  • Clarified what design information is necessary when an applicant requests an exemption to 10 CFR 50.34 content requirements Requested changes not incorporated:
  • Delete guidance the commenter interpreted as related to draft Part 53
  • Delete guidance directing applicants to provide a summary of estimated doses as an alternate to providing radionuclide quantity estimates
  • Remove prescriptiveness; only reference industry standards
  • Remove references to NEI template documents not previously formally endorsed but previously approved via safety evaluation 38

Advanced Reactor Content of Application Project Chapter 10 -

Occupational Dose Overview and Discussion of Comments 39

Chapter 10 Overview

  • Applies a performance-based approach for level of detail of information provided in the SAR regarding the control of occupational dose 40

Chapter 10 Comments Changes made because of comments:

  • None Requested changes not incorporated:
  • None, but staff disagreed with a comment statement that the program to control occupational exposure does not extend ALARA into the design 41

Advanced Reactor Content of Application Project Chapter 11 Organization and Human Systems Interaction Overview and Discussion of Comments 42

Chapter 11 Overview

  • Supports Part 50 and 52 non-LWR applications with relatively traditional concept of operations Does not address remote or autonomous operations
  • Guidance to applicants and NRC reviewers on:

Organizational staffing Qualifications Training Operator Licensing: staffing exemptions, licensing during plant construction (i.e., cold licensing), considerations for new programs, other exemptions

  • NRC staff also incorporated human factors engineering (HFE) guidance to supplement LMP and TICAP guidance 43

Chapter 11 Comments Changes made because of comments:

  • Added references to existing guidance covering level of detail for organizational information in CPs, OLs, and COLs (SRP Sections 13.1.1 and 13.1.2-13.1.3)
  • Added applicable regulations in the acceptance criteria section
  • Clarified acceptance criteria for addressing numbers of licensed and non-licensed operators; added reference to 10 CFR 26.205(c)

Requested changes not incorporated:

  • Delete entire ISG or major sections; rely on NEI 18-04, "Risk-Informed Performance-Based Technology Inclusive Guidance for Non-Light Water Reactor Licensing Basis Development"
  • Delete guidance related to topics the commenter interpreted as (draft) Part 53 requirements
  • Add references to 10 CFR 50.34 (post-TMI requirements) topics
  • Add clarification on technology neutral approaches for a site to meet the requirement for engineering expertise 44

Advanced Reactor Content of Application Project Chapter 12 - Post Construction Inspection Testing and Analysis Program Overview and Discussion of Comments 45

Chapter 12 Overview

  • Intended to provide guidance to the NRC staff regarding application content that would support making the finding that the applicant has met the applicable Part 50 and Part 52 regulations
  • Requirements to describe preoperational testing and initial operations in OL and COL applications are contained in 50.34(b)(6)(iii) and 52.79(a)(28), respectively.
  • Provides guidance for:

post-construction inspection, preoperational testing (i.e., tests conducted following construction and construction-related testing, but prior to initial fuel load), analysis verification, and initial startup testing (i.e., tests conducted during and after initial fuel load, up to and including initial power ascension).

46

Chapter 12 Comments Changes made because of comments:

  • Changed post-construction.. text to post-manufacturing and construction or just post-manufacturing if applicable
  • Clarified content requirements for MLs and COLs referencing MLs
  • Clarified text regarding pre-operational testing under a CP
  • Removed specific reference to test review committee Requested changes not incorporated:
  • Add additional information regarding what ISG sections apply to CPs
  • Remove acceptance criteria that the commenter interpreted to go beyond 10 CFR Part 50 47

Advanced Reactor Content of Application Project Inservice Inspection/Inservice Testing Overview and Discussion of Comments 48

ARCAP ISI/IST Overview

  • The ISG provides guidance for developing risk-informed, performance-based ISI/IST programs for non-LWRs.
  • The ISG guidance is based upon the use of a plant-specific PRA to identify the SSCs to be included in the programs.
  • The ISI guidance is based upon the use of:

ASME BPV Code,Section XI, Division 2, Requirements for Reliability and Integrity Management (RIM) Programs for NPPs, for developing the ISI program using risk information and an expert panel.

ASME BPV Code,Section III, Division 5, High Temperature Reactors, for designs using high temperature materials and notes that ASME is developing a flaw evaluation Code Case for high temperature materials.

49

ARCAP ISI/IST Overview (continued)

  • The IST guidance is based upon:

Existing IST program approach, with additional guidance for passive components, and notes that ASME is developing a new OM-2 Code for inservice testing of components in new and advanced reactors, including non-LWRs.

Using plant-specific risk information to determine the scope of the IST program and proposed testing frequencies.

  • 43 comments received.

50

ARCAP ISI/IST Comments Changes made because of comments:

  • Allow the use of unissued consensus codes at the CP stage provided they are officially issued prior to submitting the OL application and provided design finality is not being requested on any portion of the design affected by the unissued codes.
  • Allow applicants for multi-module plants to apply standard ISI and IST programs to each module, without separate program approvals, provided the modules are identical.

51

ARCAP ISI/IST Comments Requested changes not incorporated:

  • Eliminate the discussion of the process to be followed when the ISI program identifies degradation has occurred, because ASME BPV Code,Section XI, Division 2, provides guidance in this area.
  • Delete the discussion in the IST section on passive components.
  • Include graphite and ceramic composite materials in the scope of ISI, because these materials are included in ASME BPV Code,Section III, Division 5.

NOTE: The ISG does not preclude the inclusion of these materials because ASME BPV Code,Section III, Division 5, is to be used in the development of ISI for high temperature materials.

52

Advanced Reactor Content of Application Project Technical Specifications Overview and Discussion of Comments 53

ARCAP Technical Specifications -

Overview

  • The text in the 10 CFR 50.36 regulations for TS content requires adaptation to correlate to the analysis and outputs of the risk-informed LMP approach described in NEI 18-04.
  • Guidance addresses content for TS administrative controls section and recommended TS format 54

ARCAP Technical Specifications Comments Changes made because of comments:

  • Added reference to NEI 18-04 section that addresses risk metrics for use in developing LCO completion times
  • Added guidance for technical specification information in PSARs
  • Added guidance regarding the need for an exemption to 10 CFR 50.36 LCO criteria Requested changes not incorporated:

Advanced Reactor Content of Application Project Fire Protection for Operations Overview and Discussion of Comments 56

ARCAP Fire Protection for Operations-Overview

  • 10 CFR 50.48(a) requires that each operating nuclear power plant have a fire protection plan that meets the requirements of either 10 CFR Part 50, Appendix A, Criterion 3 for LWRs or the applicants proposed principal design criteria that have been deemed acceptable by the NRC.

Although 10 CFR 50.48(c) - NFPA 805 - does not apply to non-LWRs, concepts associated with this risk-informed approach are included in the draft ISG

  • The scope of this ISG addresses the review of the application content regarding the fire protection program for operations including application descriptions of:

Management policy and program direction and the responsibilities of those individuals responsible for the program/plans implementation.

The integrated combination of procedures and personnel that will implement fire protection program activities.

57

ARCAP Fire Protection for Operations Comments Changes made because of comments:

  • None Requested changes not incorporated:
  • Remove statements that the commenter interpreted to be from draft Part 53 (planned) requirements
  • Remove references to general design criteria
  • Delete clarifying text regarding acceptability of NFPA 805
  • Remove/relax guidance regarding fire brigades for advanced reactors
  • Delete references to verification and validation (V&V) of fire models
  • Delete acceptance criteria and replace with only commitments to codes and standards
  • Remove references to the term Authority Having Jurisdiction (AHJ)
  • Remove/revise criteria in the guidance that may not apply to SMRs
  • Remove references to a monitoring program for a non-NFPA 805 plant 58

Acronyms and Initialisms ADAMS Agencywide Documents Access CP construction permit FSAR final safety analysis report and Management System DBA design-basis accident GSI generic safety issue ANS American Nuclear Society DBE design-basis event HFE human factors engineering AOO abnormal operating occurrence DBEHL design-basis event hazard level ISG interim staff guidance ASME American Society of Mechanical (NEI 18-04) ISI inservice inspection Engineers DBHL design-basis hazard level ISG inservice testing ARCAP Advanced Reactor Content of (NEI 21-07) ITAAC inspections, tests, analyses and Applications acceptance criteria DC design certification ARCOP Advanced Reactor Construction LBE licensing basis event Oversite Process DG draft regulatory guide DID defense in depth LCO limiting condition for operation BDBE beyond design-basis event EAB exclusion area boundary LMP Licensing Modernization Project CDC complementary design criteria FOAK first-of-a-kind LPSD low-power and shutdown CFR Code of Federal Regulations COL combined license FR Federal Register 59

Acronyms and Initialisms (continued)

ML manufacturing license PDC principal design criteria SRM staff requirements memorandum NEI Nuclear Energy Institute POS plant operating state SSC structure, system, and component NEIMA Nuclear Energy Innovation and PRA probabilistic risk assessment TEDE total effective dose equivalent Modernization Act PSAR preliminary safety analysis report TICAP Technology-Inclusive Content of NFPA National Fire Protection RFDC required functional design criteria Applications Association TIRICE Technology-Inclusive, Risk RG regulatory guide NLWR non-light-water reactor Informed Change Evaluation RSF required safety function NPUF non-power utilization facility TIMaSC Technology-Inclusive Management SAR safety analysis report of Safety Case NSRST non-safety-related special treatment SDA standard design approval TS Technical Specification NST no special treatment SE supplemental evaluation OL operating license SR safety related 60

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