ML23352A396
| ML23352A396 | |
| Person / Time | |
|---|---|
| Issue date: | 11/16/2023 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-2627 | |
| Download: ML23352A396 (199) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Regulatory Rulemaking, Policies and Practices Subcommittee Meeting Docket Number:
(n/a)
Location:
teleconference Date:
Thursday, November 16, 2023 Work Order No.:
NRC-2627 Pages 1-139 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
(ACRS) 5
+ + + + +
6 REGULATORY RULEMAKING, POLICIES AND PRACTICES 7
SUBCOMMITTEE 8
+ + + + +
9 THURSDAY, NOVEMBER 16, 2023 10
+ + + + +
11 The Subcommittee met via Teleconference, 12 at 8:30 a.m. EST, David A. Petti, Chair, presiding.
13 COMMITTEE MEMBERS:
14 DAVID A. PETTI, Chair 15 RONALD G. BALLINGER, Member 16 CHARLES H. BROWN, JR., Member 17 VICKI M. BIER, Member 18 GREGORY H. HALNON, Member 19 JOSE A. MARCH-LEUBA, Member 20 ROBERT MARTIN, Member 21 WALTER L. KIRCHNER, Member 22 JOY L. REMPE, Member 23 THOMAS ROBERTS, Member 24 MATTHEW W. SUNSERI, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 ACRS CONSULTANT:
1 STEPHEN SCHULTZ 2
3 4
DESIGNATED FEDERAL OFFICIAL:
5 DEREK WIDMAYER 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 P-R-O-C-E-E-D-I-N-G-S 1
8:30 a.m.
2 CHAIR PETTI: Good morning, everyone. The 3
meeting will now come to order. This is a meeting of 4
the Advisory Committee on Reactor Safeguards 5
Radiological Rulemaking, Policies and Procedures 6
Subcommittee. I'm Dave Petti, chairman of the 7
subcommittee.
8 ACRS members in attendance are Ron 9
Ballinger, Tom Roberts, Joy Rempe, Vicki Bier, Bob 10 Martin, Greg Halnon, virtually I see Matt Sunseri. We 11 right now do not have Charlie Brown or Vesna, but they 12 may show up.
13 MEMBER DIMITRIJEVIC: I'm here, I'm here.
14 CHAIR PETTI: Oh good, thank you.
15 MEMBER DIMITRIJEVIC: Hi, good morning.
16 MEMBER SUNSERI: And I'm connected, Dave, 17 so.
18 CHAIR PETTI: I saw Matt Sunseri is here.
19 MEMBER MARCH-LEUBA: Yeah, and Jose's here 20 too.
21 CHAIR PETTI: Oh, sorry, Jose, yeah. Jose 22 March-Leuba is here. And our consultant Steve Schultz 23 is with us. Derek Widmayer is the ACRS staff 24 designated federal official for the meeting.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 The purpose of the subcommittee is to hear 1
from the staff concerning comment resolution and 2
status of draft final versions of the Advanced Reactor 3
Content of Application Project, ARCAP, interim staff 4
guidance document; Technology Inclusive Content of 5
Application Project, TICAP, guidance documents.
6 The subcommittee will gather information, 7
analyze relevant issues and facts, and formulate 8
proposed positions and actions as appropriate. There 9
is a session scheduled for the December 2023 full 10 committee meeting, and the committee plans on 11 preparing a letter report on this matter at the 12 meeting.
13 The ACRS was established by statutes 14 governed by the Federal Advisory Committee Act, FACA.
15 The NRC implements FACA in accordance with its 16 regulations found in Title 10 of the Code of Federal 17 Regulations, Part 7. The committee can only speak 18 through its published letter reports.
19 We hold meetings to gather information and 20 perform preparatory work that will support our 21 deliberations at a full committee meeting. The rules 22 for participation in all ACRS meetings, including 23 today's, were announced to the Federal Register on 24 June 13, 2019.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 The ACRS section of the U.S. NRC public 1
website provides our charter, bylaws, agendas, letter 2
reports, and full transcripts of all full and 3
subcommittee meetings, including slides presented at 4
the meetings. The meeting notice and agenda for this 5
meeting were posted there.
6 As stated in the Federal Register notice 7
and in the public meeting notice posted to the 8
website, members of the public who desire to provide 9
written or oral input to the subcommittee may do so, 10 and should contact the designated federal official 11 five days prior to the meeting, as practical.
12 Today's meeting is open to public 13 attendance, and we have received no request to make an 14 oral statement at the meeting. Time, though, is 15 provided in the agenda after presentations are 16 completed for spontaneous comments from members of the 17 public attending or listening to our meeting.
18 Today's meeting is being held over 19 Microsoft Teams, which includes a telephone bridge 20 line allowing participation of the public over their 21 computer using Teams or by phone. A transcript of 22 today's meeting is being kept, therefore we request 23 that meeting participants on Teams and the bridge line 24 identify themselves when they speak, and to speak with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 sufficient clarity and volume so they can be readily 1
heard.
2
- Likewise, we request that meeting 3
participants keep their computer and/or telephone 4
lines on mute when not speaking to minimize 5
disruptions.
6 At this time, I ask the team attendees to 7
make sure they are muted so we can commence the 8
meeting.
9 We will now proceed. I note that Vice 10 Chair Kirchner has joined us as well. And I call on 11 Steve Lynch, Branch Chief of the Advanced Reactor 12 Policy Branch in the Office of Nuclear Reactor 13 Regulation, for opening remarks.
14 Steve.
15 MR. LYNCH: Good morning, members. Myself 16 and my team that are in front of you are very excited 17 today to talk to you about the work that has been 18 ongoing for a number of years on both the NRC's 19 development of the regulatory guide endorsing the 20 Technology Inclusive Content of Application Project 21 and the accompanying Advanced Reactor Content of 22 Application Project.
23 We recognize that with an increasing 24 interest in advanced reactors being licensed by the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 NRC, that it is important for the staff to develop 1
guidance to support these early movers. In 2
particular, while we are still working on developing 3
a new framework in Part 53, we recognize that it is 4
important to meet developers where they are today 5
using the existing regulatory frameworks in 10 CFR 6
Parts 50 and 52.
7 These guidance documents that are 8
developed are intended to help improve the 9
predictability and efficiency of both the development 10 of advanced reactor applications, as well as the NRC 11 staff's review of these applications.
12 The NRC staff has been diligent in 13 preparing these documents for the both the preparation 14 and review of advanced reactor applications and has 15 worked extensively with stakeholders and members of 16 the public to receive feedback.
17 Today we are going to provide overviews of 18 the work that we have done to update these documents 19 to reflect our best technical, licensing, and policy 20 positions, as well as help the members understand how 21 we have carefully considered the feedback received 22 during the public comment period on these documents.
23 We look forward to good engagement today 24 as we work to finalize these documents for use 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 hopefully in the next few months. So thank you very 1
much.
2 MS. OBER: Good morning, my name is 3
Rebecca Ober, and I'm Project Manager in the Advanced 4
Reactor Policy Branch at DANU and Office of Nuclear 5
Reactor Regulation. I'm going to give the initial 6
overview, and then I'll turn it over to Anders for the 7
detailed TICAP discussion.
8 So the purpose of this briefing is to 9
provide a high-level overview of the TICAP reg guide 10 and the nine ARCAP ISGs, as well as the public 11 comments received and the NRC's disposition of these 12 comments. During this briefing, the staff will 13 provide a summary of the ARCAP and TICAP structure 14 before discussing the ten documents in more detail.
15 Then staff will wrap up with the path forward.
16 Staff has previously briefed the ACRS 17 Future Plant Design Subcommittee on this topic 18 multiple times. On March 17, 2021, staff provided a 19 high-level overview of the ARCAP and TICAP structure, 20 which was then updated on July 21 of 2021.
21 Then in December 17, 2021, staff provided 22 the draft White Paper versions of the nine ARCAP ISGs 23 and the TICAP draft reg guide.
24 In the short term, staff plan to use the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 ARCAP and TICAP guidance to support both Part 50 and 1
52 non-light water reactor applications. In the long 2
term, staff will update the guidance as appropriate to 3
support the Part 53 rulemaking.
4 Revision 0 of all ten draft documents was 5
issued in May 2023 for public comment. And Revision 6
1 of the TICAP guidance was reissued in September 2023 7
for public comment. The current list of documents and 8
how to access them can be seen on this table. In 9
addition, it also shows the number of comments 10 received on the various documents.
11 The documents with the most comments were 12 the TICAP draft guide Revision 0 and Revision 1, 13 followed by the ARCAP roadmap ISG, with 68 comments.
14 The number of comments received is consistent with the 15 importance of the documents because both the TICAP reg 16 guide and the ARCAP road map ISG are foundational 17 guidance documents.
18 During an advanced reactor stakeholder 19 public meeting on June 7, NRC staff discussed the 20 ARCAP and TICAP documents, specifically the changes 21 from the White Paper versions to the current draft 22 versions. This meeting includes presentations by both 23 NEI and NRC.
24 Since it occurred during the open comment 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 period, staff also included information on how to 1
provide comments during that discussion. This was 2
followed by another public meeting on August 22 for 3
stakeholders to discuss their comments.
4 Similarly, a public meeting was held on 5
September 26 to discuss Revision 1 of the TICAP draft 6
guide, which included additional guidance related to 7
the construction permit PRA developments. And again, 8
this meeting was held during the public comment 9
period, and guidance was provided on how to provide 10 comments.
11 All 20 of the documents we'll discuss 12 today are publicly available in ADAMS. And in 13 addition, there's a public webpage with all key 14 guidance documents and of meetings.
15 This guidance is being developed to 16 support non-light water reactors. Because there are 17 many different technologies under construction, the 18 current light water reactor focus prescriptive 19 guidance was not sufficient.
20 The NRC aims to have guidance that is 21 technology inclusive, meaning it will work for any 22 reactor technology. And we're also aiming to have 23 guidance that helps applicants identify the most risk-24 significant aspects of the design.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 Finally, this guidance aims to have the 1
end safety goals in mind instead of prescriptive paths 2
to meeting those safety goals, hence the term 3
performance-based.
4 In the near term, this guidance will 5
support licensing of non-light water reactors that 6
follows the licensing modernization project process 7
under 10 CFR Part 50 and Part 52. All ten of these 8
documents may be updated to account for final rule 9
language of Part 53.
10 MEMBER ROBERTS: Rebecca, it's Tom 11 Roberts. Can you speak briefly to advanced applicants 12 not using the LMP? Are they still on Reg Guide 1.206 13 or the 1.70, or are there parts they would pick and 14 choose from the new reg guide?
15 MR. SEBROSKY: Yeah, so this, my name's 16 Joe Sebrosky and I'm the Senior Project Manager in the 17 Advanced Reactor Policy Branch. The near term needs 18 that we have right now that have been identified are 19 for the X-Energy construction permit application 20 that's going to use the LMP process. That's coming in 21 in the spring.
22 And then the other one of the near term 23 need is the Natrium TerraPower Natrium's project.
24 That's also coming in in the spring.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 Light water reactor applicants can choose 1
to use the LMP process, but it's based on non-light 2
water reactor applications. We don't know of any 3
current light water reactor applicant that's going to 4
pursue the LMP, so they would be following Reg Guide 5
1.206 for their applications.
6 In addition, there are some non-light 7
water reactor applications that we know of that may 8
not use the LMP, like Oklo. That they may end up 9
using pieces of parts. There's for example the ARCAP 10 road map ISG has Appendix B, bravo, that talks about 11 applicability regulations to non-light water reactors.
12 They may end up using that and then use a different 13 approach.
14 But their approach would be discussed or 15 the expectation would be discussed with the staff on 16 their preapplication phase.
17 MEMBER ROBERTS: Okay, thank you. So the 18 focus really is LMP. If you don't follow the LMP 19 process, there may be parts you can pick and choose 20 from, but by and large it's a case basis. Is that 21 right?
22 MR. SEBROSKY: Right.
23 MEMBER ROBERTS: Okay, thank you.
24 MS. OBER: As you can see from the list on 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 the screen, ARCAP is broad in nature and intended to 1
cover guidance for a wide variety of non-light water 2
reactor applicants. While TICAP guidance for off-3 normal reactor states
- only, ARCAP encompasses 4
everything needed for a license application.
5 The TICAP's scope is governed by the LMP-6 based process, which is written in NEI 18-04, Revision 7
- 1. NRC reviewed this document and endorsed it in Reg 8
Guide 1.233 in June of 2020. To provide guidance on 9
how to use the LMP, industry developed NEI 21-07, and 10 Reg Guide 1.253 proposes to endorse this document with 11 clarifications and additions.
12 So here's a chart that has been shown at 13 many public meetings on ARCAP and TICAP, but it still 14 provides a great holistic view of what is needed to 15 license a non-light water reactor.
16 Please note that the Fitness for Duty 17 Program, financial qualifications and insurance, 18 aircraft impact assessment, performance demonstration 19 requirements, Nuclear Waste Policy
- Act, and 20 operational programs were added since this was last 21 shown at an ACRS meeting, and that's in the orange box 22 on the right-hand side.
23 MEMBER REMPE: I have a question. Where 24 do you find combustible gas monitoring and control 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 guidance?
1 MR. SEBROSKY: So the combustible gas 2
monitoring and control, and I'll look to folks that 3
are on the bridge line to help me out, the LMP process 4
would identify whether combustible gas and control is 5
an important safety function.
6 So when you look at this slide, you see 7
the licensing basis event analysis is in Chapter 3.
8 That analysis would identify whether combustible gas 9
and control warrants a safety-related function or is 10 a safety -- a non-safety related special treatment 11 function.
12 So depending on the outcome of the LMP 13 process, it could show up in Chapter 6 or Chapter 7 if 14 it's safety-related, or if it's non-safety related 15 special treatment.
16 MEMBER REMPE: Okay, so if someone comes 17 in and they don't identify controlled combustible gas 18 generation as a critical safety function or whatever, 19 I know we keep calling them something else. But one 20 of the higher level safety functions. It probably 21 won't show up at the licensing-basis event, and the 22 staff may not identify that.
23 And then I'm just kind of wondering, 24 because we saw one application where it just kind of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 slipped through. And I'm just wondering how do we 1
make sure the staff always is looking for that? I 2
mean, if they don't have a zircaloy-based cladding, 3
there are still ways you can have combustible gas 4
generation. It may not be hydrogen, but you can have 5
it.
6 I'm kind of wondering how one makes sure 7
that the staff looks for that carefully in the 8
guidance and the applicant knows to look for it a 9
little more carefully than what we're seeing.
10 MR. SEBROSKY: Yeah, I understand the 11 question, and it gets back to the fundamental belief 12 in the process, the licensing modernization project 13 process that it'll identify important safety-14 significant functions, both safety-related and non-15 safety related.
16 MEMBER REMPE: Well, maybe there ought to 17 be a checklist of even though the applicant doesn't 18 identify it as a critical safety function at the high 19 level, that the staff goes through maybe four or five 20 things, heat removal, heat generation, criticality, 21 etc.
22 And maybe that ought to just be a 23 checklist somewhere in the guidance. I mean, there 24 may be some other ones I'm not thinking about that the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 applicant may come up with. But it just seems like 1
there ought to be a checklist that everyone things 2
carefully about some known concerns, is where I'm 3
coming from. Just a comment.
4 MR. SEBROSKY: Understand.
5 MEMBER MARTIN: Well, and then I will --
6 break out here. My pet peeve of hazards analysis. So 7
certainly in the documentation that you all have 8
created surrounding, you know, this reg guide and 9
really the whole move towards risk-informed framework 10 mentions hazards a million times. It's great. And 11 risk a lot too.
12 But then when you look at the content of 13 an application, it's kind of buried. And certainly in 14 my experience, and I've done this for money before, 15 hazards analysis is what creates these lists, right.
16 And there are methods that are recognized in you know, 17 really all industries.
18 But there's commonality to those methods 19 that you'll find a lot of consensus among safety 20 experts on that it -- while at an early stage these 21 are qualitative type methods. That over, of course, 22 the evolution of a design they can become more 23 quantitative.
24 And they provide the evidence necessary to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 support the downstream activities of safety analysis 1
and the basis for design change and such. And rather 2
than seeing something that pops up and, say, 3
combustible gas, you know, if it showed up on, you 4
know, implicitly on a downstream list, and then you 5
think more to the example, you would say it's almost 6
becoming prescriptive.
7 But rather, elevating the role of hazards 8
analysis is -- would probably be more technology-9 inclusive with the expectation that these lists would 10 be otherwise created by the applicant.
11 So my read of the draft reg guide, I see 12 the statements. Of course I've already mentioned 13 these 18 statements of hazards analysis. But in 14 Chapter 1, there's a statement about you present the, 15 you know, the design basically or rear design.
16 And the clause in the sentence there was 17 "and its connection to safety analysis." To me that 18 is the hazards analysis. That is the connection. And 19 to not have a chapter like number 2 that is explicitly 20 the hazards analysis, that there are rules to how to 21 come up with that list, seems to miss the boat.
22 Because I
think in any kind of 23 deliberation on the integrity and safety of design, 24 you had to pull the thread. It's that connection.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
18 And everyone will say yes, the connection's there.
1 But right now, it's bring your rock.
2 And understanding that maybe outside is 3
relatively new to us, but in other industries there 4
are pathways that are accepted and have commonality.
5 And for us not to have some specificity as to what 6
that looks like seems to lead to the high potential of 7
inadequate applications.
8 And in the spirit of being inclusive, I 9
think the most important thing is for the staff to 10 receive quality applications that they can trace back 11 to decisions that go back to a qualitative assessment 12 section. And while it appears under the surface, it 13 really needs to be elevated, because we're all about 14 safety.
15 So it's a little bit of preaching. It's 16 a lot of preaching. But how do you defend not 17 elevating hazards analysis to a top-level chapter on 18 this? It really should follow that Chapter 1 in this 19 case.
20 MR. SEBROSKY: So I'll look to Marty, so 21 Marty Stutzke, Bill Reckley, or Boyce Travis to add 22 anything to what I'm about to say. So when you look 23 at the importance --
24 PARTICIPANT: Check testing one, two, one, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 two. Check, check, one, two, one two, one two. One 1
two. Mic check.
2 MEMBER REMPE: Could someone --
3 PARTICIPANT: Mic check, mic check.
4 MEMBER REMPE: That's Thomas. Tom, is 5
someone on the internet virtually like Matt or Vesna 6
or Jose, can you confirm you can still hear us?
7 PARTICIPANT: We can hear you.
8 MEMBER REMPE: You can hear us?
9 MEMBER DIMITRIJEVIC: We can hear you, but 10 we hear that track too.
11 MEMBER REMPE: Okay. That was Thomas.
12 And I just wanted to make sure that you guys can still 13 hear us.
14 Go ahead and continue with the meeting.
15 I'm not sure what's going on, but I think we're okay.
16 Go ahead.
17 MR. SEBROSKY: So what's being shown is 18 the first eight chapters of the SAR, which is the LMP-19 based process, which relies on a robust analysis of 20 the hazards.
21 And that's driven by the expectations for 22 the development of the PRA and the defense-in-depth.
23 And Reg Guide 1.247, which endorses the level 3 PRA 24 methodology, is the process by which we rely on those 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 hazards being identified as part of the level 3 PRA.
1 There is a discussion, and Anders is going 2
to be talking about in more detail about how the PRA 3
results are placed in various chapters. But I 4
understand the concern about ensuring that there is a 5
robust hazard analysis and that it be captured either 6
in the SAR or in the supporting documents for the SAR.
7 Marty, is there anything you wanted to add 8
to that?
9 MR. STUTZKE: Hi, this Marty Stutke, I'm 10 the Senior Technical Advisor for PRA in NRR DANU.
11 I would point that we had previously 12 developed and presented to the committee our draft 13 guidance DG-1413, which is the technology-inclusive 14 identification of licensing events, which lists a 15 whole number of techniques such as haz ops, FMEAs, 16 etc., for identifying hazards and was developed 17 specifically to address ACRS comments about the need 18 to start with a blank sheet of paper like that.
19 However, DG-1413 is linked to the Part 53 20 rulemaking, so we're going to decide, we'll need to 21 consider whether we want to issue it in advance of the 22 rulemaking or whatever.
23 MEMBER MARTIN: I appreciate what you said 24 there. The activity of determining licensing basis 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 events is different certainly from a hazards analysis.
1 It does heavily rely on a hazards analysis. But the 2
hazard analysis, well, just to leverage why Joy says, 3
provides this list.
4 It's, you know, analogous to like in Reg 5
Guide 1.203, right, where you have the accident safety 6
analysis. You have a PIRT to have a step prior to 7
actually doing the exercise of in that case 8
deterministic safety analysis.
9 Or you have the experts come in and assess 10 in analogous sense risk in a qualitative sense. And 11 basically score the characteristics of the problem 12 using heuristic methods.
13 And it applies here as well. It's just a 14 higher level, and it's appropriate, not just because 15 it drives requirements. But it's appropriate because 16 of the precedent and past success. And of course not 17 only I mentioned how it's being applied to other 18 industries. But the Department of Energy, and they 19 rely on it heavily.
20 And so for folks in our industry that have 21 familiarity with the Department of Energy's process, 22 I think you'll find a general appreciation for that 23 step, not just as a step along the way, but as really 24 the focal point of any kind of safety deliberation.
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22 It is something that's easy to understand and you can 1
get from there to anywhere in the safety case.
2 And I didn't criticize the fact that it's 3
not mentioned. It's just not at -- it's just not 4
given the attention. And really the attention means 5
more specificity about what that looks like. I'm 6
concerned that you'll get a light touch.
7 And of course a light touch would 8
invariably have weaknesses. You'll spend a lot of 9
time churning on the approval process. Applicant one 10 will give you something, and applicant two will look 11 completely different. Maybe in their minds, since 12 they're, you know, they think everything is there.
13 Unless you prescribe something, 14 leveraging, you know, not necessarily, not methods 15 from industry. But to some extent from academia and 16 you know. And when I say academia, something with 17 some meat on it, not the really 50,000 foot kind of 18 language you oftentimes get from industry documents.
19 Which some of the ones that we were talking about here 20 I would say fall into that category. Maybe 10,000 to 21 give us credit.
22 But nonetheless, and I'm showing my bias 23 of course, some deterministic thinking, but some 24 compromise in that direction is a better path for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 certainty in the licensing process. And that 1
certainty comes down to a consistent example.
2 Anyway, my second preach. But I'm sorry.
3 (Laughter.)
4 MEMBER ROBERTS: Yes, Tom Roberts again.
5 I have two questions, and probably this is the right 6
slide to ask them. But for that, I was wondering, 7
Marty made a great comment I think about Draft Guide 8
1413 and its applicability to 10 CFR Part 53.
9 Was there explicit consideration of that, 10 since now this ARCAP and TICAP is being decoupled from 11 Part 53 to revisiting the decision to -- when to hash 12 1413?
13 MR. SEBROSKY: So I guess the short answer 14 is that's under consideration. If you look at the 15 ARCAP road map ISG, you see that we have that draft 16 guide listed as something that's under development 17 that could potentially influence an update to the 18 document down the road.
19 But we haven't made a determination on 20 whether to put that in as part of the 50 and 52 21 update, or how we would take the ARCAP/TICAP guidance 22 and adjust it for the Part 53 language once we get a 23 Commission decision.
24 So if it's -- it's on the list and the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 appendix, but at this point, we identified it as a 1
potential update for a future revision. That's about 2
it.
3 CHAIR PETTI: So we did, in our Part 53 4
letter, recommend that that draft guide be issued 5
independently because we felt it was so important.
6 It's this exact issue coming back again.
7 MR. SEBROSKY: Understand.
8 MEMBER KIRCHNER: Yeah, I think this is a 9
good point. To the extent that a critic or a skeptic 10 would look at this and say, well, you just reordered 11 the deck from a conventional 50/52 application.
12 And yes, it's tailored to some of the 13 aspects of LMP and the referenced NEI guide. But did 14 that kind meat that Bob's talking about doesn't find 15 its way in here, then you -- then the next step is 16 then oh, okay, you -- then you put everything on that 17 PRA and that somehow is inclusive enough that it 18 identified all the hazards.
19 And if it's not, then -- completeness with 20 the PRA and so on and the quality becomes an issue for 21 some of the advanced designs that don't have the 22 maturity and such.
23 So the hazards analysis is kind of a, I 24 wouldn't call them deterministic, but it's a logical, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 systematic way of making sure you've covered the 1
waterfront, catch that combustible gas if that's a 2
potential, and incorporate the good work that was done 3
by you in that draft reg guide.
4 So I'll stop there.
5 MEMBER MARTIN: I'll try to answer. So in 6
previous conversations, you know, with staff members 7
and such and others, there is a feeling that maybe 8
it's all there. Again, I don't like the fact that 9
it's under the surface, but there's several reg guides 10 on performing different sorts of PRA, right. Maybe it 11 was eight, nine, I don't know, ten. There's quite a 12 few.
13 And one way to look at it is that well, 14 you're just going to do it all, you know. But there 15 is no screening of that, which would otherwise come 16 from your hazards analysis.
17 And in some ways, you know, an applicant 18 comes in and they're just going, applicant still likes 19 a prescription, despite what some people say. But 20 people that do the work kind of do things by 21 procedure.
22 And if they look at the list of reg guides 23 for doing PRAs, they're just going well, I got to do 24 reg guide this, this, this, this, you know, at 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 different levels. And certainly, I guess if you do 1
everything, somewhere along the line you will have 2
done the right thing.
3 But the hazards analysis, you know, it 4
will prioritize. Which again, the same purpose of 5
like a PIRT. It will screen things that are 6
unnecessary. Maybe for whatever reason we don't need 7
combustion again.
8 So you could get -- you could clear the 9
air earlier on. And in an age where there's a lot of 10 pressure to getting, you know, expedite reviews, but 11 obviously with the integrity, you want a framework to 12 support that.
13 And so, but if you're strict, you're 14 probably okay. But I worry people won't be strict.
15 And they don't, shouldn't have to be. And I think the 16 solid hazard analysis, maybe myself, will go a long 17 way towards making everyone's life easy. Not a 18 preach, I don't think that's a preach. I'm not 19 counting that one.
20 MEMBER HALNON: Just to be clear, though, 21 what your position is now is that NEI 18-04, when 22 you're going through the licensing basis event 23 selection process, which is comprehensive, you're 24 saying that that is going to look at all these 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
27 hazards.
1 If they're significant enough to the 2
plant, that they'll be part of the licensing basis 3
event selection, which will then play out later on in 4
the process.
5 Is that essentially where we're at right 6
now?
7 MR. SEBROSKY: That's correct.
8 MEMBER HALNON: Okay.
9 MR. SEBROSKY: That summarizes it. Did 10 you want to add anything?
11 MR. TRAVIS: Yeah, so this is Boyce Travis 12 with the staff. I think it's -- I think we understand 13 ACRS's comment. And I think it's important to 14 contextualize the role of what's being discussed here 15 in the sense that's guidance for what goes in the 16 application that gets submitted to the NRC, versus 17 what's being done at a level below that in the work 18 that's done on the design.
19 And so the staff's goal was to try and 20 create some performance-based, technology-neutral 21 guidance, and obviously that results in some --
22 simplifications isn't the right word. But we can't 23 cover the waterfront of all the designs that are out 24 there.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
28 And so a lot of that goes into what's in 1
the guidance in NEI 18-04 for the LMP process and 2
what's in that red box in the middle of the slide that 3
is work that's being done by the applicant and being 4
looked at by the staff but isn't necessarily being 5
reflected in the application.
6 MEMBER ROBERTS: So I guess I change the 7
subject a little, but I had two questions I thought 8
were probably worth asking on this slide. One is 9
cliff edge effects. It seems like I couldn't I find 10 any discussion of cliff edge effects in the reg guide, 11 in the NEI 21-07 document.
12 And the real -- the question I found other 13 than the LMP document itself was in one of the FAQ 14 documents that talks a little bit about what that is.
15 And it -- the way it's described is more of a 16 deterministic process even though it's characterized 17 under PRA.
18 So it just seems like that's a very 19 important aspect of the LMP process. And how that 20 gets rolled up in either the TICAP or the ARCAP wasn't 21 clear to me. I was wondering if you could comment on 22 where you'd expect to find that.
23 MR. SEBROSKY: So I'll take a crack at it.
24 So one of the things that is a cornerstone of the LMP 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
29 process is the event sequences and plotting that on 1
the frequency consequence curve. And there's an 2
expectation that the uncertainties be considered as 3
part of that process.
4 And I believe embedded in that in 5
certainties are things like looking at the cliff edge 6
effects. So I'll look to any member of the staff 7
that's on the -- in the Teams to correct if I 8
misstated anything.
9 MR. GILBERTSON: So this is Anders 10 Gilbertson, Senior Project Manager on the NRC staff.
11 I would just add that, you know, there are also as 12 part of following the non-LWR PRA standard, there are 13 attributes and supporting requirements in that 14 standard that specifically address cliff edge effects.
15 And so, in that way it's very much, 16 probably say this a lot, it's kind of baked into LMP, 17 say invoked in the LMP methodology the use of the PRA 18 standard.
19 MEMBER HALNON: Yeah, and I just, I've got 20 the 18-04 in front of me. It's very explicit. But 21 there's a question at the end that says, have you 22 assessed cliff edge effects in the PRA. So it's very 23 24 MEMBER ROBERTS: I think it's in 18-04.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
30 I think it's pretty clear there. And there's an FAQ 1
if you go search through all the supporting documents 2
that industry put out.
And it gives some 3
clarification what that means.
4 What I couldn't find is where that would 5
be. Would show up in the safety analysis reports.
6 And how that would be used. For example, the new EPZ 7
determination reg guide specifically requires 8
consideration of cliff edge effects.
9 So when you look at what facts and 10 scenarios are considered for EPZ determination, you 11 have to go look in
- the, explicitly address 12 uncertainties and cliff edge effects.
13 And it seems like the kind of the thing 14 that ought to be bubbled up into a specified 15 subsection of one of these documents so that you know 16 where to find it and it puts out a clear expectation 17 of what you expect to see in an application. That's 18 my comment.
19 I agree with you, Greg, that it's in 20 there. It's also when you get on the details of 21 exactly how you do it, it's not entirely clear. But 22 that's just that nature of, as Bob would say, hazards 23 analysis. Maybe we have to get to the point of 24 figuring out what is just outside of your expected 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 frequency of occurrence that really makes a big 1
difference.
2 And to make sure those are accounted for 3
in some of these, what I would call level 5 defense-4 in-depth type of assessments where you want to have 5
appropriate consideration for, you know, everything 6
failed, how do you protect the public. And so it just 7
seemed like that's the kind of thing that ought to be 8
more highlighted than, again, I can guess where.
9 But I would guess in the PRA discussion, 10 because that's where it shows up in 18-04. But it is 11 just a suggestion to bubble that up into something 12 that's a little easier to find.
13 MR. SEBROSKY: Yeah, like a hazards 14 analysis.
15 MEMBER ROBERTS: And my second question 16 has to do with the, I guess more the number of 17 chapters and the SSC descriptions. If a look at a 18 traditional SAR, you're probably talking five or six 19 chapters describing the fluid systems, the electrical 20 systems, the I&C systems, the auxiliary systems.
21 And this condenses it into parts of two 22 chapters, the safety-related, and what was the other 23 one, the non-safety related with special treatment 24 SSCs. And I was wondering if you've looked at what 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
32 that might lose in terms of context.
1 Because it seems like to understand why 2
particular SSCs have been bubbled up to be safety-3 related, you kind of have to understand the whole 4
plant and the types of SSCs that were not considered 5
to be safety-related or the non-safety with special 6
treatment just to have the perspective on what they 7
do.
8 And when I look at the LMP, I look at the 9
two definitions of what could be safety-related. One 10 is the obvious things that mitigate accidents. But 11 the other one is the things that prevent accidents 12 from becoming a higher classification than how they're 13 categorized.
14 So an SSC that keeps a, you know, a DBE 15 from becoming an AOO, that kind of thing is also 16 safety-related. And how the decision is made of what 17 SSCs are in that class and not in that class of things 18 that are there to operate the plant within the bounds 19 of the safety analysis is the way I usually think of 20 it.
21 It becomes clearer when you have all of 22 the important SSCs described. I was wondering if 23 you'd looked at that, because this seems like it 24 condenses it quite a bit. And you may have missed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 something in terms of the, you know, condensing.
1 So I was looking for perspective whether 2
you've table-topped this or looked at examples of what 3
comes out and what's left in the SAR by the time you 4
get done with this prescription.
5 MR. SEBROSKY: So to answer your question, 6
during the development of these documents, as part of 7
the TICAP process, we did table-top four different 8
designs.
9 The designs included the X-Energy design, 10 the VTR, which is the versatile test reactor, which is 11 a liquid sodium chloride design. A preliminary 12 version of X-Energy to look at what a micro reactor 13 portion of the SAR might look like. And then a molten 14 chloride salt fuel reactor.
15 So we did do table-tops, and those table-16 tops looked at various parts of the SAR. It wasn't 17 the complete -- each one had its focus on what it was 18 looking at. And the results of those table-tops were 19 reflected both in NEI 21-07 and in our DG-1404.
20 In addition to
- that, we've had 21 preapplication discussions, both with Natrium and with 22 X-Energy, on their table of contents, what it would 23 look like. And we've been providing feedback to them 24 during the preapplication phase.
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34 So we have looked at both via -- through 1
the table-tops and with the preapplication discussions 2
with those two applicants what the various SAR content 3
would look like using the NEI 21-07 DG 14-04 process.
4 MEMBER ROBERTS: And I suppose you would 5
work with the applicants on how they applied the reg 6
guide and the resulting opportunity to clarify or 7
expand the content from the reg guides if what you 8
find is -- is not. I was going to make sure they 9
looked at.
10 Yeah, one example that occurs to me, 11 getting specific, is like a rod control system, where 12 typically that will be non-safety because you have an 13 independent scram system. But the safety analysis may 14 have assumptions on numbers of rod and rod speeds.
15 And if your system were, your rod control 16 system were to fail such that the number of rods or 17 the speed were to be greatly above what you assume, 18 and maybe that would promote the accident from one 19 category to another. And so that would push for the 20 rocket hold system to be considered as a either safety 21 related or not safe with special treatment.
22 So without that discussion in the SAR, it 23 would be hard to see that as a potential issue. So 24 that's the kind of thing I'm thinking when I made the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 comment. It's just something that's worth looking at 1
and making sure there's enough information to be able 2
to make those informed decisions.
3 It sounds like you've looked at that as 4
part of these table-tops? It probably needs to 5
continue to look at that issue, apply this.
6 MR. SEBROSKY: Yeah, so I would say we've 7
looked at it as part of the table-tops. And then 8
we're actively engaged in pre-application discussions 9
with both Natrium and X-Energy.
10 Ian Jung is going to add some more 11 background on that.
12 MR. JUNG: Yeah, my name is Ian Jung, 13 Senior Reliability and Risk Analyst. And I'm the 14 overall technical lead for X-Energy.
15 So
- yeah, we agree that overall 16 understanding of all the systems, how they behave and 17 how they contribute to the safe operation of the 18 plant. We understand that -- for X-Energy, we are 19 undergoing readiness -- preapplication readiness 20 assessment right now. And that we are actually 21 looking at their draft preliminary safety analysis 22 board.
23 Actually on the subject of those systems 24 that may not be safety-related or non-safety related 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
36 with special treatment, we are having dialog and 1
giving some feedback how those non-safety related 2
systems are potentially needed to be understood within 3
the context of the safety analysis.
4 Also with respect to certain regulations 5
of course require describing certain SSCs to be a part 6
of the SAR, safety analysis report, because depending 7
-- regardless of the classification, you know just for 8
example.
9 One more thing to add is that for PRA, 10 when PRA does not start with a classification, right, 11 it starts with a systems as a whole. So PRA, we 12 expect the PRA to be modeling all these systems to the 13 extent that it is meaningful for the safety of the 14 plant.
15 In that regard, I'm sure there's going to 16 be some assumptions regarding some of the non-safety 17 related systems that may contribute to the overall 18 risk profile and so on.
19 So their PRA standards requirements on how 20 they screen those systems for making assumptions and 21 so on. So in our guidance documents, there's, I think 22 of our DG-1404, we expect the certain key essential 23 assumptions on PRA to be described in that assumption.
24 Even those that are non-essential 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 assumptions, I think those may not be -- those might 1
be also subject to staff's regulatory audit during the 2
license process.
3 MEMBER KIRCHNER: Just to add to Tom's 4
point, my sense is if you get an application and you 5
just get information on what's in the box in the upper 6
left corner there, and they've already screened out a 7
number of systems, I suspect, because I've been 8
watching what's going on with recent applications, 9
you're going to in the audit process ask for a lot 10 more information to backfill how you determined, you 11 the applicant, determined that you could do a light 12 touch on this. And I'm seeing it happening with the 13 applications that you're actively considering.
14 And I'll not go any further on that, but 15 I think that's what's going to happen in practice, 16 Tom. Because you'll pull the string and you'll say 17 well, how did you cut that one out and why isn't it 18 described. Or why is it not important.
19 And I think what you're doing with it, 20 recent applications with the audit process is much 21 more efficient than just letting a lot of RAIs pile 22 up.
23 So I am applauding what's going on, but I 24 think -- we'll see when you actually try it with the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
38 real applications, which is a lot more than a desktop 1
exercise. And you start pulling the thread on 2
classification systems in particular. We'll probably 3
beg for a lot more information.
4 I'm just -- that's my intuition, and it's 5
one member's opinion.
6 MEMBER ROBERTS: Yes, so I'm guessing 7
there's a tradeoff between what information is pulled 8
and therefore doesn't have to be maintained for the 9
life cycle of the plant, what information is pushed.
10 And then is definitely going to be provided and has to 11 be maintained for the life cycle. Is that really what 12 the tradeoff is?
13 MR.
SEBROSKY:
Yes.
There's an 14 expectation that the PRA needs to be continuously 15 assessed and updated based on the information that 16 you're getting from a plant.
17 But reliability and capability, if those 18 key assumptions that you made in the PRA are different 19 than what you see from the actual plant, the 20 expectation is that the PRA would be updated. And if 21 there's a change in the licensing basis events, that 22 that would be something that would be brought forward 23 to the staff.
24 So there's an effort that we have underway 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
39 independent of the application guidance called TIRICE, 1
technology inclusive risk-informed change evaluation 2
process, that after the plant receives an operating 3
license, how do you ensure that you're continuing 4
assessing the plant and reflecting that in PRA updates 5
and potential changes that would need to be brought to 6
the NRC's attention.
7 I'm looking to see if, Ian, was there 8
anything you wanted to add?
9 MR. JUNG: Yeah, this is Ian Jung again.
10 I'm looking at some of these new designs.
11 And I just want to share that overall 12 simplicity of the design and overall expected risk 13 profile of the plant, and the whole risk-informed and 14 performance-based approach we are pursuing is based on 15 our safety-focused framework that some might stay away 16 from traditional prescriptive elements and provide the 17 other performance-based framework with some 18 flexibility.
19 And but the capability and reliability 20 targets and then applied and those have to be achieved 21 and managed and maintained. That's the framework we 22 are in. Yeah, definitely it's just a balance.
23 If we wanted to be, we could be as 24 prescriptive as light water reactors. But I think we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
40 have an opportunity to help the industry applicants 1
and execute the principles of risk-informed and 2
performance-based.
3 And there's a whole set of requirements 4
and expectations regarding maintaining the PRA, use of 5
operating experience, and change management process, 6
and so on. And we have to follow the principles and 7
see how it goes. But I think our safety focus will 8
maintain all the way throughout the process.
9 MS. OBER: Okay, so back to the slide.
10 The red boxes now shown are what in ARCAP, part of 11 Chapter 2 and Chapter 9 to follow the SAR and all 12 other components necessary to license a non-light 13 water reactor are now included. ARCAP also 14 encompasses the information included in TICAP.
15 And now the red boxes are what NRC staff 16 and contractors have developed or are developing 17 guidance for. So there is certain guidance for TICAP 18 and ARCAP documents.
19 The applicability has not been constrained 20 to non-light water reactors because the major 21 document, specifically NEI 18-04, NEI 21-07, and Reg 22 Guide 1.233 are also limited to non-light water 23 reactors.
24 All ISGs have a new footnote that any 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 light water reactor applicant should engage the NRC 1
early if they desire to use LMP. There is now a clear 2
delineation between applicant guidance and review 3
guidance.
4 Finally, references to documents without 5
complete NRC staff review have been removed. For 6
those in-development documents that may result in 7
revisions to the respective ISGs, we have added an 8
appendix at the end to serve notice to that effect.
9 CHAIR PETTI: Just a question on the LWR 10 footnote.
Is it because there's additional 11 requirements that LMP doesn't touch upon?
12 MR. SEBROSKY: One of the underlying 13 concerns, first and foremost, if you look at 10 CFR 14 Part 53 notes, the Subpart A, it's thought that that's 15 an LMP-based approach, both for non-light water 16 reactors and light water reactors. So we're 17 eventually going to have to address that based on the 18 Commission basis.
19 The underlying concern right now is we 20 have a level 3 PRA endorsed for non-light water 21 reactors, Reg Guide 1.247. For light water reactors, 22 Reg Guide 1.200 doesn't go to the same extent. It's 23 a level 3 PRA that you need to support the LMP 24 process.
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42 So trying to work that into the process at 1
this stage is a little difficult. So that's one of 2
the main reasons.
3 The suggestion, or the guidance 4
essentially says if a light water reactor wants to use 5
the LMP
- process, we encourage preapplication 6
discussions. And one of the first things that we 7
would probably asking is how are you developing your 8
level 3 PRA.
9 MEMBER HALNON: One other quick question 10 before we move on. The only thing I didn't see is any 11 kind of discussion of decommissioning, and with these 12 new reactors, it could get very complex on the 13 decommissioning side. Is that later down the road, or 14 is there any thought about at least give it some 15 thought on the front end?
16 MR. SEBROSKY: Yeah, I think we deferred 17 that for developing the guidance for Part 53, the 18 decommissioning guidance, I don't know that we're, 19 like you say, we're explicit in the ARCAP guidance as 20 far as what's expected at the application stage 21 relative to decommissioning.
22 MEMBER HALNON: Because you do have I 23 think in the financial piece talking about making sure 24 there's funds set aside. But what are you setting 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
43 aside funds for if you don't have at least a high-1 level strategy of how you're going to get this cleaned 2
up?
3 So I know it's premature and it's probably 4
not relevant to the initial applications coming in, 5
but at some point there's going to be discussion 6
demand on decommissioning, and how are you going to 7
rid of some of this exotic high tech stuff that.
8 Especially the transportable stuff that you want to 9
take away and put some place.
10 MR. SEBROSKY: Understand.
11 MS. OBER: Okay, for the principal design 12
- criteria, TICAP guidance covers the criteria 13 associated with off-normal conditions while 14 appropriate ARCAP ISGs address the principal design 15 criteria associated with normal conditions. And Reg 16 Guide 1.232 provides additional guidance, and the 17 ARCAP road map recommends discussion PDCs during the 18 preapplication phase.
19 At this point, we're going to get into the 20 TICAP-specific discussion, and I'll turn it over to 21 Anders.
22 MR. GILBERTSON: Okay, thank you, Rebecca.
23 Morning, everyone. Again, my name is Anders 24 Gilbertson, I'm a Senior Project Manager in the DANU 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 Office of Nuclear Reactor Regulation. I have a 1
background in risk and reliability before coming to 2
DANU.
3 So today I'm going to be providing just a 4
high-level overview first of the TICAP guidance 5
documents. And then with a focus on getting to 6
resolution of public comments on this document. Slide 7
15, please.
8 Okay, so as was discussed a little bit 9
earlier, the overall goal of the TICAP guidance is to 10 provide a technology-inclusive approach for developing 11 the contents of applications as a matter of 12 implementing the licensing modernization project 13 methodology for LMP. And TICAP guidance is intended 14 to promote efficient development and review of an LMP-15 based application.
16 As a matter of accommodating outcomes of 17 implementing the LMP methodology, the structure of the 18 SAR resulting from these TICAP differs from the 19 traditional structure, as we've talked about earlier 20 already. And different as it relates to this SARs 21 structure for a light water reactor based on the 22 standard review plan. And I'll go into that a little 23 more detail in the next couple slides.
24 Just to sort of set the foundation here, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
45 the scope of the TICAP guidance is sort of necessarily 1
governed by the LMP methodology, which is defined by 2
the three major processes for establishing licensing 3
basis events, or the licensing basis. And that 4
includes identification of licensing-basis events, the 5
classification of SSCs, and establishment of special 6
treatments for certain SSCs, and determination of the 7
facility that's in the SSCs.
8 In addition to being risk-informed and 9
performance-based, I
wanted to note the LMP 10 methodology is a PRA-led approach. So the PRA 11 features very heavily.
12 And the optimal endpoint of the 13 development of the PRA using NEI 18-04 is a PRA logic 14 model that addresses all sources, all hazards, all 15 plant operating states. And that is comprised of the 16 full analysis of all scenarios, starting from 17 initiator and ending with radiological consequences.
18 That's all consistent with the scope of the non-LWR 19 PRA standard.
20 However, when using the LMP methodology 21 and two-step licensing process, it's understood the 22 PRA will necessarily be something less than the 23 optimal endpoints at the construction permit stage, 24 given the maturity of preliminary design information.
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46 As such, it's important to establish the 1
minimum needed for the acceptable PRA supporting an 2
LMP-based construction permit application in order to 3
help determine how the staff would make findings under 4
10 CFR 50.35(a) and other related construction permit 5
regulations.
6 So the subject of this guidance is, this 7
is developed in Appendix B to DG-1404, Revision 1.
8 CHAIR PETTI: So I had a, just a high-9 level question, and maybe you'll get to it in later 10 slides. Because it was really hard for me when I read 11 Appendix B to figure out if the PRA that, let's call 12 it the P-PRA, like the PSAR, right. And then there's 13 an FSAR and an FPRA, to keep it simple.
14 That the information that you're 15 requesting at the CP stage is commensurate with the 16 state of the design. What it looked to me like is 17 that you went into the PRA standard and kind of just 18 binned the requirements. Do I need them at the CP 19 stage, do I need them at the final, the OL stage.
20 What I didn't see was any sort of 21 discussion about why is that requirement, you know, 22 why can you put that in the CP bucket, as opposed to 23 the F bucket?
24 I mean, did you guys do something where 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 you convinced yourself that there would be the right 1
information at the CP stage? So you weren't over-2 asking.
3 That's what I was -- I couldn't get a 4
sense of that.
5 MR. GILBERTSON: Yes, we did perform that 6
process. I will talk about that in a couple of 7
slides, so, yes. If you are happy to -- Yes, I'll 8
wait till we get to there.
9 CHAIR PETTI: Okay.
10 MR. GILBERTSON: Okay. So we are on Slide 11
- 16. Okay. So this is a good diagram to show. This 12 is relevant to some of the discussions we've already 13 had.
14 Like I mentioned, given the prominent role 15 of the PRA and the LMP methodology, much of the 16 information in Chapters 1 through 8 of the SAR 17 dictated by TICAP are either directly or indirectly 18 related to or derived from the PRA in one way or 19 another.
20 So because the TICAP dictates a new 21 structure through the SAR different from the SRP we 22 developed a sort of, we call this affectionately our 23 "Where is Waldo" map, if you will, graphic to help us 24 understand where the risk information and PRA-related 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
48 information can be found in the first eight chapters 1
of the SAR.
2 So we have already been talking about more 3
generally where other information can be found, but 4
this was focused primarily on PRA information and was 5
a graphic that the staff showed at some earlier public 6
interactions on development of this guidance. Member 7
Martin?
8 MEMBER MARTIN: I wanted to comment on 9
this. I have always had a problem with the shuffle of 10 the deck and you've got to pick your battles, right.
11 I've already identified one, so -- so I 12 have rationalized that the first four chapters, all 13 right, that's the analysis, right, but once you get 14 into, you know, three, four, you incorporated content 15 and understanding of a safety function, line criteria, 16 safety classification.
17 Designs go through design cycle.
18 Invariably these things get considered. You really --
19 well, following DOE's, you know, process and other 20 processes, and I'm sure there are others, your safety 21 classification comes after your hazard though, so it 22 comes very, very early on and through the cycle, of 23 course, you iterate.
24 If you had not put that arrow between 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
49 three and five and just left it at that I probably 1
wouldn't have even spoke up, but I think it 2
communicates the wrong thing here because you cannot 3
get to three and four without already having gone to 4
five, six, seven, and eight, even though we could all 5
say, well, it's done in conceptual preliminary design.
6 Those things factor because your design 7
has -- There has already been assumptions on how it's 8
going to solve certain safety concerns and 9
incorporating, you know, you might say, you know, you 10 want to get away from deterministic as a word, but 11 deterministic design is a thing.
12 We do single failure
- analysis, 13 vulnerability, we design for diversity and redundancy.
14 That is our practice and, of course, you don't want to 15 go that way.
16 Maybe in the spirit of, you know, risk-17 informed and PRA in some elegant manner, you know, you 18 want to say it just falls out of, you know, the 19 function of form, exercise, design. The engineering 20 of a design that captures five, six, seven, and eight 21 and gets that into your licensing basis, that matters.
22 So I wanted to ignore it and just say, all 23 right, one, two, three, four, that's your op-level 24 safety analysis and everything is in the appendix, you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
50 know, or you do it the other way around and you put 1
five, six, seven, eight and all that and then you put 2
your license, you know, all the other stuff in the 3
back, but the top of the deck is less of a, you have 4
less passion for.
5 I worry that there is this idea that 6
things just fall out of, you know, the design process 7
and I just distinguish design and engineering as two 8
separate things.
9 You design for form and function and you 10 engineer for a purpose. Five, six, seven, and eight 11 is your purpose that matter. Before that it is a 12 design process.
13 So it confuses me outside of my one 14 rationalization why it's ordered in this way because 15 you cannot get to three and four without spending a 16 lot of time in all the other chapters.
17 CHAIR PETTI: But, Bob, this is how the 18 application goes. You're reflecting it off through 19 the designer lens.
20 MEMBER MARTIN: I know.
21 CHAIR PETTI: The fact that iterates 22 behind the scenes is really not the NRC's concern, 23 right. I mean what I liked about this is that it 24 allowed a focus.
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51 This is too much information that has to 1
be presented and I would argue that the old content of 2
application, the traditional way, it can be very 3
opaque depending on how it's written and who writes it 4
and that this would allow a greater safety focus to 5
get you to what NRC really cares about.
6 We understand that it doesn't flow 7
lineally in terms of how it's done. Behind the 8
scenes, you're right, there's huge iterations, but how 9
do you best present it so that the reviewer can get 10 the information they need in the most efficient 11 manner.
12 MEMBER MARTIN: Right.
13 CHAIR PETTI:
- And, okay, I
am 14 pontificating because it's in my draft letter, but I 15 think this does this better than perhaps the 16 historical approach.
17 MEMBER MARTIN: Sure.
18 CHAIR PETTI: So I understand, you know, 19 your --
20 MEMBER MARTIN: Invariably though aren't 21 you in say drafting the application in these chapters 22 saying, all right, this decision was made because of 23 something that you'll see discussed in Chapter 5, 6, 24 or 7.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
52 When we talked about it the other day at 1
the A&S conference and, you know, I was picking on the 2
use of defense in depth and uncertainties and its role 3
in addressing uncertainty, and I could go on, yes, but 4
presenting defense in depth aspects of design and its 5
addressing of various uncertainties and safety 6
analysis and your answer was basically, oh, you know, 7
you wanted to see, you know, the content in the 8
discussion of the design that addressed the safety 9
issue and I said, well, you know, oftentimes you begin 10 with the analysis and then you have to then go the 11 other direction, you know, from the analysis into 12 design.
13 It seems like the design discussion is 14 getting pushed back. Like I said, maybe I could live 15 with it if that line wasn't there and that when you 16 have --
17 (Simultaneous speaking.)
18 CHAIR PETTI: Well, again, that line is 19 not there in the application. That's a graphic.
20 MEMBER MARTIN: That is a graphic, but in 21 the write-up for section, you know, three and four and 22 probably in the other ones it's invariably going to 23 say, you know, look at Chapter 3, or Chapter 5, 24 Section such and such for, you know, more information 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
53 or, you know, and on and on and on.
1 There is going to be a lot of cross 2
reference, or there should be a lot of cross 3
reference.
4 CHAIR PETTI: I think of it as kind of an 5
unfolding, right, like a fault tree, right, you're 6
coming down and you're into three, okay, and then 7
you've got to, there is going to be a path that's 8
going to take you into five and six or into seven and 9
eight as it unfolds and it has more detail.
10 I mean, yes, to put it all in one chapter 11 would be horrendous, so --
12 MEMBER HALNON: Dave, your point, this is 13 not the design process. This is the location of 14 information in the SAR.
15 MEMBER MARTIN: Thanks.
16 MEMBER HALNON: So I agree with you. I am 17 sitting close to him so he can slap me, but it worked 18 for me because I can see where if I had a licensing 19 basis event and I wanted to see how the systems were 20 going to work it I would go to the right and not 21 iterate back, so --
22 MEMBER MARTIN: So I come with a 23 deterministic link here. From the standpoint of your 24 PRA it lays out, but once you go to the step of doing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
54 your licensing events, identify your AOOs and DBEs and 1
beyond design basis, et cetera.
2 You have brought in, you know, more of, 3
you know, more of the deterministic thinking that 4
shapes the safety case or that aspect of the safety 5
case and that is the guardrails that are your safety 6
class SSEs and your design criteria.
7 You've shaped it, because, of course, it 8
appears, you know, through that interim process. I 9
find it would be confusing. Again, without that line 10 there and thinking five, six, and everything else is 11 an appendix, I would know as a professional, you know, 12 that in an AOO the basis for, you know, whatever, you 13 know, whatever event that you put in there probably 14 has been influenced by the statements that probably 15 appear somewhere else in the SAR related to safety 16 classification, et cetera, et cetera, et cetera.
17 But if I am a reviewer it would be really 18 hard to pull a thread, you know. So I just see it, 19 you know, again, bias on the deterministic side of, 20 you know, my experience.
21 I do find a lot of value, a lot of value, 22 in the tool sets that, you know, the risk-informed 23 performance-based approaches offer, but I really see 24 there is more about the synergy of the two that's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
55 going to be effective and ultimately expedite, you 1
know, progress with the new reactor.
2 Yes, I am getting philosophical, but like 3
I said I think what's going, what you will want to 4
have, you want to have a lot of cross reference here 5
to understand, but I don't see how three and four 6
happen without all the other ones, which is why you 7
have Chapter 15 and Chapter 19 where they sit, you 8
know, they come at the end.
9 It's safety analysis, you know, and Part 10 50 and Part 52 has been a design verification 11 activity, right. We present chapters, you know, you 12 address it by the critical safety function, right, or 13 at least the barriers, the fission product barriers, 14 right.
15 You have your payment, you know, 2.3, you 16 have fuel, four, RCS, five, you know, engineering is 17 Function 6, I&C, you know, I can, I'll say testing, 18 but I don't remember all these sort of things, but you 19 get the whole design story up front with the old model 20 and then, of course, then you lead into 15 with safety 21 and tech specs, you know, 16 which naturally follows 22 from that, and then 19 covers all the -- of course, it 23 was after the fact, you know, in the history of this 24 thing. It lays out in a very deterministic world --
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56 MS. CUBBAGE: Bob, this is Amy Cubbage, 1
NRC staff. I work for Steve Lynch. I would just like 2
to reiterate that, you know, the staff is going to do 3
a holistic team approach to this review.
4 We are not going to be diving up these 5
little piece parts, so the team is going to be looking 6
holistically at the whole application and not little 7
pieces at one time.
8 I do think in the interest of time we 9
probably do need to move on because these issues have 10 previously been adjudicated before the ACRS and we 11 need to get to the resolution of comments.
12 MEMBER MARTIN: Doesn't a statement like 13 that kind of short circuit the independent role of the 14 ACRS? Anyway --
15 (Simultaneous speaking.)
16 MS. CUBBAGE: I mean feel free to keep 17 discussing it, I am just looking at the time.
18 MEMBER MARTIN: I appreciate that comment, 19 but, like I said, it's a secondary issue for me but I 20 do think it does create misconception about where 21 things are in the process. I think it's important to 22 the staff on the review of these things.
23 So I appreciate what you're saying. If 24 you are all professionals and you all have, you know, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
57 30 years' experience it won't be a problem, but the 1
reality is you don't have that.
2 CHAIR PETTI: I'm sure they cross, Rob, 3
the old application of contents against this to make 4
sure everything is covered from a completeness 5
perspective.
6 MEMBER MARTIN: I won't say it's not 7
covered, it's just that it doesn't flow.
8 CHAIR PETTI: It's in a different way.
9 MEMBER MARTIN: It just doesn't flow.
10 CHAIR PETTI: Well it doesn't flow in your 11 sense, but from an LMP sense I look at this and go I 12 understand why it is the way it is --
13 (Simultaneous speaking.)
14 MEMBER MARTIN: -- of the reactors that 15 have been produced and gone the old way, so, I don't 16 know.
17 CHAIR PETTI: And we have two going this 18 way.
19 MEMBER REMPE: Safety-related SCCs do flow 20 out of the analysis with LBE, the old GA way is where 21 I was coming from. I have a different question, to 22 change the subject, which maybe might be good.
23 Anyhow, I am confused about the term of 24 "fundamental safety functions" and "required safety 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
58 functions," and so I actually went back to the NEI 1
document and to me it looks like the required safety 2
functions are kind of like a subset of the fundamental 3
safety functions. Is that your perception?
4 MR. GILBERTSON: Yes. I mean I think 5
that's a way of looking at it. It's these are, the 6
required safety functions are what are sort of 7
materially implemented through the PRA to achieve this 8
higher level fundamental safety function.
9 MEMBER REMPE: So if I am a reviewer is 10 there some sort of guidance that says for every 11 fundamental safety function there better be a required 12 safety function, at least one or two that support that 13 fundamental, because I was confused why you needed the 14 two terms, but, okay, if NEI wants to do that that's 15 fine, but it seems like from the NRC staff's 16 perception you ought to be cross checking to make sure 17 that there is consistency because it's kind of 18 puzzling.
19 If it's a fundamental safety function it 20 seems like it ought to be required, too, you know, or 21 vice versa. I don't know, it was kind of interesting 22 that it was kind of just skipped over like everybody 23 should know and check to make sure.
24 MR. GILBERTSON: One way that I would look 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
59 at that personally is that I think maybe the 1
fundamental safety functions are more to address the 2
entire spectrum of the design process.
3 So it's that notion that you are starting 4
from the conceptual aspects of the design and the 5
facility. So the clean sheet respected, I have to do 6
these things, these fundamental safety functions, 7
contain, cool, and control.
8 MEMBER REMPE: There also ought to be 9
control chemical reactions, not just reactivity 10 control. That's again -- I guess I'm hung up on that 11 topic and all.
12 There is not a list, so you're kind of 13 telling me, oh, fundamental safety functions are 14 everything we always need to think about but you have 15 limited it to the traditional four --
16 MR. GILBERTSON: Right.
17 MEMBER REMPE: -- not things that might 18 come up with non-LWRs. So, again, I just want to make 19 sure that, it seems to me that the designer can say, 20 oh, this doesn't apply to me, but maybe they need to 21 have that list or has an analysis to keep up or 22 something, but you're saying, oh, it's a higher level 23 fundamental list that everybody must do.
24 I don't see that anywhere. I think that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
60 the applicant gets to propose their critical safety 1
functions or fundamental ones and then they have 2
required safety functions to meet those fundamental 3
ones.
4 MR. GILBERTSON: Yes.
5 MEMBER REMPE: So I think there needs to 6
be a cross --
7 CHAIR PETTI: So what struck me when we 8
have the X-Energy briefing is chemical reactivity, 9
which has been in every HTGR sort of LMP thought 10 process from the beginning, isn't one of their 11 required safety functions.
12 That is because in their mind it is 13 outside of the licensing basis, at least as they see 14 it down to their cutoff frequency. So the fundamental 15 may be sort of in the abstract and then they go 16 through the process and if it falls below the cutoff 17 frequency then I guess it's not a required a safety 18 function. It surprised me because I didn't anticipate 19 that.
20 MEMBER REMPE: The connection is not well 21 documented and --
22 CHAIR PETTI: I didn't anticipate it.
23 MEMBER REMPE: -- so I think somebody 24 needs to write something down to say, you know, what 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
61 is expected here and how to coordinate, and I didn't 1
see that.
2 Maybe it's there and I missed it. There 3
was a lot of material we were supposed to read for 4
this meeting.
5 MR. GILBERTSON: Okay. That's -- We 6
appreciate the point, really conductive, and I will 7
take that back.
8 MEMBER REMPE: Thank you.
9 MEMBER KIRCHNER: Anders, just a minor 10 point, I find that your color coding is somewhat 11 confusing and I'm not sure it adds a lot of value to 12 this.
13 I am looking at it, like source term, 14 description of the PRA, well the source term doesn't 15 come out of the PRA. That's a quasi-deterministic 16 derived source of fission products, et cetera, et 17 cetera, or it comes out of, you know, a MELCOR 18 calculation or however you choose to define the source 19 term.
20 So saying that's a part of the description 21 of the PRA seems to me -- It's a minor point, but, you 22 know, the results of the PRA, well, to me the results 23 of the PRA are not just the LBE summary but things 24 like beyond design basis accidents and so on and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
62 events.
1 I don't know. So if there is some intent 2
to that color coding I've lost the bubble, but that's 3
a minor point.
4 MR. GILBERTSON: Okay. Yes, as far as the 5
source term is concerned I think, I mean I would 6
relate that more to the mechanistic source term 7
aspects of the PRA.
8 MEMBER KIRCHNER: Yes.
9 MR. GILBERTSON: So at which, you know, 10 there is a whole set of analysis and requirements, so 11 I think that's why we designated it in that regard.
12 Okay.
13 Okay, so moving on. So just to kind of 14 get back to the overall point. This diagram was meant 15 to assist the staff and starting to lay this out.
16 It's a bit of a -- I wouldn't say this is a final sort 17 of set in concrete, you know, characterization of 18 these items, but at least it served to facilitate 19 discussions earlier in that process and really it was 20 also to help us just organize our thinking and how we 21 were developing the guidance.
22 Okay, Slide 17, please. Okay, so along 23 the same lines, this diagram was sort of very much the 24 same function. This was a diagram that we had 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
63 developed where we wanted to really get a high-level 1
view of the overall implementation of the LMP 2
methodology as it relates to the two-stage licensing 3
process under Part 50.
4 Again, this helps, you know, organize the 5
staff's thinking about what is needed for the 6
minimally acceptable PRA for the construction permit 7
stage and how that is informed by the LMP methodology.
8 And like it's been discussed before, the 9
LMP methodology is very iterative and so there are 10 feedback loops, aspects of those feedback loops that 11 are not necessarily represented here, but, again, this 12 is a much higher level overview.
13 One of the main sorts, or takeaways I 14 guess you could say from this diagram was helping the 15 staff to understand the substance of boxes "golf" and 16 "hotel" and those relate to the items that we would 17 expect to see in the construction permit application 18 and generally what might go along with the issuance of 19 the construction permit itself as a matter, again, of 20 understanding what does the PRA need to do, 21 understanding that LMP is a PRA-lead approach, and 22 that the information at the construction permit stage 23 is preliminary in nature. Okay, Slide 18.
24 MEMBER KIRCHNER: Anders, before you go 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
64 on, just quickly, I am trying to implement your 1
guidance here based on the viewgraphs. Maybe that's 2
not the right way to do it, but it's a nice diagram 3
that you've put up.
4 Why wouldn't you have a description of the 5
PRA in the CP issuance? I am just -- I am not trying 6
to nitpick and do viewgraphs, but if indeed you 7
fundamentally are building this on the PRA, you had a 8
preliminary description of the PRA at the CP stage.
9 I don't understand it.
10 MEMBER HALNON: That's the first bullet 11 response. The first bullet in the description of the 12 PRA and results.
13 MEMBER KIRCHNER: Right. I am misreading 14 it. I'll get new glasses. I just need new glasses.
15 Sorry, go on. Oh, I was looking at L versus --
16 MEMBER HALNON: It said CP application.
17 That's G.
18 MEMBER KIRCHNER: Okay.
19 MEMBER HALNON: Raised at CP issuance.
20 MEMBER KIRCHNER: Yes.
21 MEMBER REMPE: Yes.
22 MEMBER KIRCHNER: Okay, go on. Go on, 23 Anders.
24 (Simultaneous speaking.)
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65 MEMBER KIRCHNER: It's there. Thanks, 1
yes.
2 MEMBER HALNON: You can read that?
3 MEMBER KIRCHNER: That I can read. Okay, 4
thanks. Sorry, Anders.
5 MR. GILBERTSON: Okay. No, not a problem 6
at all. Okay, so the next couple of slides I really 7
just want to kind of hit on some of the key points of 8
the guidance in DG-1404, Revision 1.
9 This really is going to more specifically 10 relate to the guidance in Appendix Bravo because 11 that's the new material since Revision 0 of DG-1404.
12 The first point I just wanted to focus on 13 was that, you know, the guidance in DG-1404, Revision 14 1, is meant to compliment the guidance in NEI-2107, 15 Revision 1, to provide additional information on how 16 to demonstrate the acceptability of this construction 17 permit PRA.
18 It's not intended to increase the burden 19 on or create any new requirements for the content of 20 application. I will get into a little bit later as 21 well as a matter of some of the comments in making 22 this distinction between guidance on achieving the 23 acceptability of the construction permit PRA and 24 what's needed for the content of applications.
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66 So the first point, major point, that I 1
wanted to make is, again, the guidance in DG-1404, 2
Revision 1, this is Appendix Bravo, it addresses all 3
sources, all hazards, plant operating states, and 4
those should all be addressed in the construction 5
permit application like we showed in the previous 6
diagram and they need to be dispositioned.
7 Now what we mean by that, dispositioned, 8
is that it's one of the four items essentially shown 9
in this sub-list here, sub-bullet list, it's either 10 modeled directly after the PRA logic model, it's 11 addressed via a screening analysis, so it's excluded 12 from the PRA logic model with some justification, it's 13 accounted for using risk-informed supplemental 14 evaluations, or they are accounted for using design 15 basis hazard levels for those hazards other than the 16 internal events.
17 So that's what we mean as a matter of 18 addressing what the scope of the construction permit 19 application itself and how one might meet the 20 requirements under 10 CFR 50.34(a), this is what we 21 are thinking about as a matter of implementing the LMP 22 methodology.
23 As far as the PRA logic model itself, the 24 expectation is that to implement the LMP methodology 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
67 at a minimum that model needs to represent the 1
internal events at power reactor PRA logic model 2
because that is really what serves as the foundation 3
of the overall PRA that would be developed for the 4
further implementation of the LMP methodology.
5 Looking at this and setting this as our 6
threshold, it was understood that this would help 7
demonstrate the applicant's ability to develop an 8
acceptable PRA logic model.
9 Again, it establishes this foundation upon 10 which all of the other PRA models are expected to be 11 built for all of the other hazards.
12 The last point here that I wanted to make 13 is that having internal events at power for the 14 reactor in your PRA logic model, that may be 15 acceptable for what we are trying to achieve at the 16 construction permit stage, but we want to note that 17 only achieving that minimum scope for the PRA logic 18 model there may be benefits of the LMP methodology 19 that are not yet fully realized at that point.
20 So we recognize that, that there is a 21 difference between those two objectives, but as a 22 matter of understanding how the staff arrived at their 23 findings for 50.35(a), this was the guidance and this 24 was our purpose of developing this guidance so we can 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
68 provide this to applicants.
1 Slide 19, please. Okay, and the other 2
points I just wanted to make are that the importance 3
of performing a self-assessment for the PRA logic 4
model, the screening analyses, and the risk-informed 5
supplementary evaluations is quite high.
6 These, you know, performing the self-7 assessment helps reduce the need for an in-depth staff 8
review of those items so that they can focus on the 9
assumptions and other sources of uncertainty 10 associated with those analyses.
11 Now a self-assessment does not need to be 12 a peer review per se at the construction permit stage, 13 we fully acknowledge that, but if a peer review were 14 performed there is guidance in NEI 20-09 and that's 15 been endorsed in Reg Guide 1.247 by the NRC staff.
16 So the overall point is that some sort of 17 self-assessment would be highly beneficial for us to 18 understand that there was essentially some sort of 19 check on the applicant's work. Now --
20 DR. SCHULTZ: So how do you anticipate 21 evaluating the peer review which in itself reviews a 22 person's -- an external peer review?
23 MR. GILBERTSON: Okay. So --
24 DR. SCHULTZ: Because an organization has 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 just amazing PRA capability and they're going to be 1
peer reviewed, or has it been done?
2 MR. GILBERTSON: So I think ultimately 3
that is going to, that's going to be on a case-by-case 4
basis. You know, a self-assessment can essentially be 5
-- the applicant can define for themselves what their 6
self-assessment is.
7 There is some guidance in NEI 20-09. That 8
is really more set in the context of preparing for a 9
peer review, so there are insights to be gained from 10 that guidance probably, but we would be, you know, 11 interested to know things about, you know, was there 12 some sort independence associated with the self-13 assessment, for example.
14 DR. SCHULTZ: Yes. Do you anticipate to 15 establish early on what that peer review is going to 16 entail? In other words, you would not like to see an 17 applicant come in and have you find that more peer 18 review or a different review is going to be required.
19 I think it should be established up front and how it's 20 going to be done.
21 MR. GILBERTSON: Yes. I don't know that 22 we are, that we were necessarily planning to do that.
23 I think that understanding that at the construction 24 permit stage it's one more aspect to help the staff 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
70 understand what they've done.
1 So if they -- that we would -- the staff 2
would ask for more of a peer review or a more in-3 depth, I don't know that that is, that's really the 4
ultimate purpose of the construction permit stage.
5 As a matter of helping the staff establish 6
their confidence to make the 50.35 findings, looking 7
at how an applicant has performed the LMP process and 8
gaining confidence in their ability to perform that 9
process versus, you know, how absolutely correct the 10 answers may or may not be at the construction permit 11 stage, that understanding of how it was done and our 12 confidence in their ability to do it is perhaps a 13 little more important to us.
14 So I think that's where the self-15 assessment helps to provide that confidence, but we're 16 not -- I wouldn't see the staff as looking at that and 17 making a
judgement of,
- well, this was done 18 incorrectly, your self-assessment that you propose, we 19 don't think that's correct or that's, you know, it's 20 what we received, it's a piece of information and we 21 look at that to evaluate.
22 DR. SCHULTZ: That's fair. Thank you.
23 MR. GILBERTSON: Okay.
24 MEMBER KIRCHNER: Well, as Steve is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
71 probing you on this, I think it's a good point.
1 Because you don't want this to be a confident theme in 2
the sense of how confident you are there are good PRA 3
practitioners. You really want to have confidence in 4
the design. And the PRA should flesh out important 5
safety aspects of the design. I think Steve's point 6
is a good one here.
7 DR. SCHULTZ: Well, you stated it right, 8
Anders, what you want to is understand and validate 9
the capability that's being performed. And obviously 10 that has a lot to do with the results of the overall 11 evaluation of the design. But given that the PRA is 12 fundamental here --
13 MEMBER KIRCHNER: Right.
14 DR. SCHULTZ: -- it's really important to 15 have all of those discussions early on in this as it 16 can be. So it's the group of reviewers that are going 17 to be engaged in the review process. Everyone has a 18 good feeling about what's happening on both sides of 19 this.
20 MEMBER KIRCHNER: Yes.
21 DR. SCHULTZ: -- both the applicant and 22 the reviewers.
23 MR. GILBERTSON: And I think that's a fair 24 point, something we can take back. I think developing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
72 guidance for what the staff would look for in that 1
self-assessment, that could be challenging for sure, 2
understanding that we get close to a suggestion of 3
what is correct or not correct.
4 I understand that the desire to get to 5
that point, that offers certainty for sure. But 6
that's a difficult point to get to, I think.
7 DR. SCHULTZ: I'm not so much interested 8
in providing
- guidance, having the early on 9
interactions --
10 MR. GILBERTSON: Okay.
11 DR. SCHULTZ: -- knowing that level of 12 competency we spoke about.
13 MR. GILBERTSON: Yes, understood. Okay.
14 MEMBER REMPE: Just a little nit, one 15 question that is helpful when I've looked at these 16 things over the years is to say, can you tell me how 17 the design changed based on your PRA and how the risk 18 profile changed? I remember one of the applications 19 we reviewed in the past that show how the risk profile 20 was going down based on design changes.
21 And again, I worked for a company many, 22 many years ago where I used to laugh about the 23 transient design because of the PRA and all of it. So 24 yes, those kind of questions ought to be probed. And 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
73 I don't know, it seems like something to think about.
1 MR. GILBERTSON: Understood, yes. And we 2
have put some thought into that, understanding the 3
iterative nature, how much we need to understand about 4
how that was constructed but ultimately, you know, 5
getting to the end point of what does that mean to 6
inform how we're reviewing what they actually 7
submitted, and as a matter of arriving at our finding.
8 So yes, I agree that that's important.
9 There are any number of ways they could do 10 it. Like we were talking about earlier, the LMP 11 process is very iterative if you lay the processes, 12 the three main processes side by side at the table.
13 You try and map things across, and when somebody might 14 be doing this, and then they're doing this, and 15 jumping back and forth, what their starting point is.
16 That is important to know. Obviously, at the end of 17 the day we're looking at what they submit. Thank you.
18 Okay.
19 MEMBER DIMITRIJEVIC: Sorry, I just want 20 to add something important. You also have, you know, 21 the requirement for acceptability of probabilistic 22 risk assessment, you know, as defined now in Appendix 23 A which is like an equivalent for your support of what 24 is in Reg Guide 1247.
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74 So there is a
requirement for 1
acceptability, the applicants have to prove that their 2
PRA is acceptable, right. And now the only question 3
for you is how do they do that. You know, how do they 4
satisfy Appendix A of your, you know, 1253?
5 MR. GILBERTSON: Yes, I would agree with 6
that, how do they do that? And beyond that, how do 7
they implement that tool as part of their decision 8
process in implementing LMP?
9 Okay. I'll go ahead and move on. So 10 understanding -- so the outcome of following the 11 guidance developed in Appendix Bravo to DG-1404, 12 Revision 1, should be a preliminary, complete set of 13 licensing-based events and SSC classifications 14 provided in support of the construction permit 15 application.
16 Now I just wanted to also note that 17 completeness of these items relates to, again, 18 consistency with the preliminary design information 19 which may have varying degrees of maturity in the 20 construction permit stage and will help inform, among 21 other things, the applicant's determination of the 22 risk metrics and comparisons with the QHOs.
23 And understanding that the PRA, at the 24 construction permit stage, subsequently will continue 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 to mature leading up to the operating license stage, 1
the guidance addresses the need to provide a plan for 2
maintaining and upgrading the PRA during construction 3
and finalization of the facility design.
4 So the staff, you know, gaining and 5
understanding of how an applicant tends to do that is 6
certainly important. And one of the examples here 7
that we note is, for example, a seismic design basis 8
hazard level that is ultimately to be replaced, or 9
expected to be replaced with a seismic PRA at the 10 operating license stage.
11 Understanding how they would make that 12 transition as it relates to actually performing 13 construction, when is the, for example, when is the 14 PRA updated, what thresholds need to be crossed to 15 require, in their minds, that the PRA be updated, that 16 would be important for us to understand.
17 And of course, CP holders are always 18 encouraged to keep the NRC staff advised of changes to 19 the completion plan for the PRA that wouldn't be 20 expected to significantly affect the design of the 21 facility.
22 Slide 20, please. Okay, so now what we're 23 here to discuss, the comments received in the staff's 24 resolution thereof on DG-1404, as Rebecca previously 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
76 mentioned, the staff conducted two separate comment 1
periods wherein 73 comments were received on Revision 2
0, 30 comments were received on Revision 1 of DG-1404, 3
and just a light was shown in that larger table on a 4
previous slide.
5 The majority of the comments that were 6
received were on the ARCAP and TICAP guidance 7
documents. So again, that sort of impresses some of 8
the greater interests in those documents.
9 So the next few slides, I'm going to 10 provide a summary of just some of the notable comments 11 and staff responses to those comments. Obviously the 12 details of these comments and responses can be found 13 in the documentation that was supplied in advance of 14 this meeting.
15 The first item I wanted to talk about was 16 removal of some clarifications and additions related 17 to principal design criteria. So this was based on 18 a comment noting that the staff position, c.6.a-1, it 19 doesn't appear to provide any new guidance beyond 20 what's in NEI 2107. And the staff agreed that there 21 was some duplication. It's really the overall point of 22 mentioning this.
23 And so in that example and other places we 24 looked to find where we could eliminate some of that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
77 duplication. And we found some places.
1 We removed a staff position addressing 2
these risk informed performance based approaches other 3
than the LMP methodology. This was based on a comment 4
noting that the related staff position that was cited 5
is not needed, because it's outside the scope of NEI 6
2107, because NEI 2107 doesn't address non-LMP 7
applications. So again, we agreed that was out of 8
scope, really just wanted to focus on the LMP 9
applications.
10 Slide 20, oh, 21. Sorry. Okay. So 11 another, I guess, a series of comments that we 12 received related to guidance for manufacturing 13 licenses and standard design approvals. So this is --
14 the comments noted that the guidance really only 15 provides two options for demonstrating how a facility 16 would meet certain construction permit regulations 17 under Part 50.
18 So the staff acknowledged that the scope 19 of NEI 2107 was just limited to COLs, combined 20 licenses, design certifications, construction permits, 21 and operating licenses. So accordingly, we revised 22 Reg Guide 1.253 to remove the direct references to 23 manufacturing licenses and standard design approvals 24 processes.
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78 And, you know, so ML and SDA applicants 1
are always encouraged to engage in pre-application 2
interactions with the staff if they seek to use NEI 3
2107, Provision 1.
4 Consistent with the staff's resolution of 5
these comments, we did not adopt any of the 6
recommended changes related to manufacturing 7
licenses and SDAs.
8 Slide 22, please.
9 MEMBER DIMITRIJEVIC: This is the one 10 thing that I didn't really understand. What is 11 special about an SDA that they couldn't be included in 12 this guidance? I mean, why there are exceptions?
13 MR. GILBERTSON: Joe?
14 MR. SEBROSKY: So the concern is, when you 15 look at NEI 2107, it does not address manufacturing 16 licenses and standard design approvals. So there's a 17 gap there in that the underlying reg guide doesn't 18 address manufacturing licenses and SDAs.
19 We were asked to provide additional 20 guidance in the draft guide or in the reg guide when 21 it comes to manufacturing licenses and SDAs. And we 22 felt it was somewhat inappropriate to provide that 23 guidance without the endorsement document, you know, 24 2107, providing that information.
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79 We think there is a potential to revise, 1
in the future, the guidance, both NEI 2107 and Reg 2
Guide
- 1253, to include a
discussion about 3
manufacturing licenses and SDAs. For now, the thought 4
is that if a manufacturing license, or an applicant, 5
or an SDA applicant, wants to use the process, we urge 6
them to come in and talk to us.
7 We believe at a high level that the 8
design certification guidance is something that can 9
be used to help with those pre-application 10 discussions. So the short answer to your question is 11 we didn't want to get out and fine 2107 for now.
12 MEMBER DIMITRIJEVIC: Okay, understand, 13 thanks.
14 MR. GILBERTSON: Okay. So Slide 22, 15 additional changes, we removed or we moved some of the 16 references to supporting guidance from Reg Guide 17 1.253 into the ARCAP roadmap ISG. This is based on 18 comments noting that informing to secondary 19 references, that is not directly related to the 20 endorsement of NEI 2107 and could substantially expand 21 the documentation needed in the SAR.
22 So while we understand the point there, 23 and the references may be useful information, the 24 staff agreed they're not directly related to the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
80 endorsement of 2107. So since the ARCAP roadmap ISG 1
already provides similar types of references, and is 2
really the more appropriate document for that, that's 3
why those references were moved over into that ISG.
4 Another notable change, the entirety of 5
what was Appendix Alpha in DG-1404 was removed. So 6
this was related to resolution of the previous item 7
relating that the purpose of Appendix A in DG-1404, 8
Version 1, essentially became obsolete.
9 So again, the references to documentation 10 and guidance that's being developed was more 11 appropriately put into the ARCAP roadmap ISG. And as 12 a result of that, Appendix Bravo to DG-1404, Revision 13 1, was promoted to Appendix Alpha in Reg Guide 1.253.
14 Slide 23, okay, so some changes resulting 15 from comments on Revision 1, so again, this is really 16 primarily going to relate to the guidance on PRA 17 acceptability for the LMP-based construction permit 18 applications.
19 The staff added language to indicate when 20 a
position relates either to achieving PRA 21 acceptability, PSAR documentation on PRA 22 acceptability, or archival documentation on PRA 23 acceptability.
24 And this was in response to a comment 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
81 noting that the scope of the guidance in Appendix B, 1
the DG-1404 was one, is inconsistent with the content 2
of the scope of NEI 2107.
3 The staff considered
- this, and we 4
acknowledge that there was a potential to create 5
confusion regarding what needs to be done for the PSAR 6
as it relates to PRA acceptability. And the guidance 7
on PRA acceptability was not intended to convey any 8
additional requirements on PSAR documentation that are 9
already provided for NEI 2107.
10 To that point, the staff do consider that 11 documentation needed to demonstrate the acceptability 12 of the PRA and how PRA acceptability is achieved.
13 Those two items are really intimately related in the 14 same way that NEI 2107 addresses what is needed in the 15 content of applications as well as how to develop that 16 content.
17 So the next point, the staff revised 18 Position Bravo.2.2 in Appendix B to DG-1404, Revision 19 1 to align with language used in NEI 2107. And this 20 relates to a comment that the proposed staff position 21 regarding documenting key assumptions, that that 22 should be deleted. Because it's not necessary and 23 goes beyond NEI 2107.
24 So the staff included this position as a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
82 matter of emphasizing guidance in NEI 2107, Revision 1
- 1. And we ended up revising it to -- or we plan to 2
revise it to state that such assumptions will be 3
identified in the section of the SAR to which they 4
apply.
5 So this staff position is meant to provide 6
additional detail on identifying assumptions made in 7
performing the PRA expected to be essential to the LMP 8
-based safety analysis. And again, it's not to be 9
construed as imposing additional requirements on the 10 documentation of what are referred to as essential 11 assumptions in the PSAR.
12 Additionally, the staff added some 13 language to clarify the use of the term PRA. This was 14 based on a comment expressing that the guidance 15 contradicts itself regarding the use of this term. We 16 saw that and recognized that there was some ambiguity 17 there, and we rectified that.
18 And like a few slides ago, I think it's 19 Slide 18, there was this box that I provided that sort 20 of provides a little curly bracket showing those first 21 three sub-bullet items. That's what we're generally 22 referring to when we say the PRA. And that's 23 consistent with how it's referred to in NEI 2107. And 24 in cases where we specifically mean to refer to PRA 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
83 logic model, we've indicated as much in the guidance.
1 And then we reviewed some of the -- or the 2
tables of applicability of supporting requirements, 3
and we revised some of the designation for those 4
supporting requirements. This was based on comments 5
identifying that some of the designations potentially 6
go beyond what can be accomplished at the construction 7
permit stage.
8 So Member Petti, to your earlier question, 9
the staff did provide -- or we performed the process 10 in the PRA standard for identifying the applicability 11 of supporting requirements that are tailored to your 12 application. We did this with an understanding that 13 we would expect to see a range of design maturities at 14 the construction permit stage.
15 So while it's fair that one applicant or 16 another may have more or less design maturity, and 17 they may or may not be able to meet the requirements 18 as we've designated them in the table, that's okay.
19 And the point was really more for those 20 tables to just help facilitate, maybe do some of the 21 legwork a little bit for applicants and say, look, 22 this is where the staff are at right now. But this is 23 not concrete, they're not acceptance criteria.
24 They're not for conformance, or they're not required.
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84 Slide 24, please. Okay, so now I'll just 1
go over some of the comments that resulted in no 2
changes. Regarding not expanding the scope of the 3
guidance to accommodate light water reactors, we 4
received comments that the guidance in DG-1404 should 5
be extended to LWRs because NEI 1804 and 2107 are 6
technology-inclusive.
7 And we've touched on this a little bit 8
earlier. Because of the nature of the PRA standard 9
that is invoked through NEI 1804, and the fact that 10 there is sort of a dichotomy between PRA standards for 11 light water reactors and non-LWRs, we felt that it was 12 appropriate to maintain our scope just looking at non-13 LWRs.
14 And of course, like Joe had mentioned 15 earlier, LWR applicants that would seek to use the LMP 16 methodology, they're always encouraged to discuss 17 their plans with the staff so that we could understand 18 how they might attempt to adopt the non-LWR PRA 19 standard, if that were the case, or some other 20 process, some other guidance documents.
21 Which it's notable that the LWR PRA 22 standards, while they're not fully developed to 23 address the same scope as the non-LWR PRA standards, 24 they are in the process of completing that work and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
85 will soon have that.
1 Let's see, okay, Slide 25, please. Okay, 2
so finally, this will be my last slide. We received 3
some comments that certain staff positions, the Bravo 4
3.1.1 and 3.1.2 that relate to the risk metrics that 5
should be determined, that this is already essentially 6
covered in NEI 2107.
7 The staff chose to retain the staff 8
position as it is, because of the potential for the 9
language in NEI 2107 to be interpreted as only 10 requiring perhaps a narrative description of the 11 subject risk metrics.
12 So in that regard, the act of determining 13 these risk metrics is meant to imply there's a broader 14 set of information that should be provided about those 15 risk metrics and that would be considered, such as 16 preliminary quantitative or qualitative determinations 17 of those values, of their risk metrics, as well as how 18 they compare to the QHOs at the construction permit 19 stage, and how they would meet the QHOs at the 20 operating license stage.
21 The next point, regarding the meaning of 22 addressing all sources, hazards, and plant operating 23 states, we received a comment that, in part, indicates 24 the idea that a PRA would address or include all 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
86 sources, hazards, and plant operating states is 1
incorrect. Because some of the items may be screened 2
out deterministically.
3 So the staff's response to this 4
emphasizing, again, addressing all sources, hazards, 5
and plant operating states, means identifying and 6
somehow dispositioning them. So that includes 7
potentially screening items out from inclusion in the 8
PRA logic model. So we felt that was effectively 9
already addressed in our guidance.
10 Regarding the notion that the LMP is risk 11 informed, not risk-based, there was -- the same 12 comment that I just referred to, it also talks about 13 the LMP methodology being risk informed, not risk-14 based.
15 But together, there were a couple of other 16 parts of the comment that, when you read it together, 17 it can be construed to imply that addressing all 18 sources, hazards, and plant operating states would 19 make the LMP methodology risk-based somehow.
20 We wanted to -- we didn't make any changes 21 to our guidance, but we offered a clarification on 22 this in our response, that we disagreed with that 23 characterization. LMP is never risk-based.
24 The PRA features heavily, but it is not a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
87 primary tool for making decisions. There's always the 1
other processes, especially for a defense in depth 2
adequacy evaluation. So that's much more along the 3
lines of a risk informed decision making process and 4
consideration of many elements.
5 And then there was a comment that related 6
to the staff's use of this phrase, full LMP 7
implementation. So the comment expresses that the 8
phrasing is inappropriate. There's no criteria for 9
characterizing what full implementation of the LMP 10 methodology means. And we do agree with that, there 11 are no criteria.
12 However, the staff's purpose of using that 13 phrase has emphasized that while the minimally 14 acceptable PRA logic model described in the guidance 15 may be acceptable for the construction permits 16 application, like I mentioned before, there may be 17 benefits of the LMP methodology that aren't being 18 realized.
19 So it's really just an acknowledgment also 20 that this sort of -- the optimized end point for the 21 PRA logic model, as discussed in NEI 1804, is full 22 scope, addressing all hazards, sources, and plant 23 operating states.
24 And there was another comment that related 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
88 to the notion of meeting high level requirements, 1
supporting requirements, and related staff positions 2
on PRA acceptability. And the comment really just 3
points out that the peer reviews generally don't 4
involve meeting specifically the high level 5
requirements from the consensus PRA standard.
6 The staff's response emphasizes that, as 7
a matter of determining acceptability of the PRA, we'd 8
look for whether the related staff positions are met, 9
as in Reg Guide 1.247.
10 And those staff positions in Reg Guide 11 1.247 are written to be analogous to the high level 12 requirements in the ASME/ANS non-LWR PRA standard 13 which is, of course, only one way to meet the staff 14 positions. And so the high level requirements in the 15 standard are effectively met by virtue of meeting the 16 underlying supporting requirements for them.
17 And finally, there were some scopes that 18 the staff deemed to be out of -- some comments, I'm 19 sorry, that were deemed to be out of scope. And these 20 included a request to develop tables for light-water 21 reactors analogous to the supporting requirement 22 applicability tables. So that's clearly out of scope, 23 but the staff did take that for broader internal 24 deliberation.
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89 And again, another comment making the 1
guidance applicable to LWRs in general, there was a 2
request for an extension to the comment period and 3
another comment that related to the use and 4
endorsement of consensus codes and standards as it 5
relates to legal requirements.
6 So again, the details of all of that are 7
provided in the documentation. So with that, that 8
concludes my portion of the presentation. And I will 9
hand it off to Joe Sebrosky.
10 CHAIR PETTI: At this point, we need to 11 have our break. So I propose that we take a 15-minute 12 break and go into recess. We're going to have to move 13 faster. We only have -- so, ten minutes, 10:45.
14 MR. SEBROSKY: When we did the dry run on 15 this, it was about two minutes per slide on the TICAP.
16 It's about one minute per slide on the ARCAP. So it 17 should go ---
18 CHAIR PETTI: We're hoping the ARCAP will 19 go faster, yes, based on that.
20 (Whereupon, the above-entitled matter went 21 off the record at 10:34 a.m. and resumed at 10:45 22 a.m.)
23 CHAIR PETTI: Okay, we're back in session, 24 folks, 10:45. Joe, it's yours.
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90 MR. SEBROSKY: My name again is Joe 1
Sebrosky. I work in the Advanced Reactor Policy 2
Branch. So the purpose of this portion of the 3
presentation is to provide a high level overview of 4
the nine ARCAP ISGs, and also discuss the comments 5
that we received that led to changes in the document 6
and comments that we received that we determined that 7
a change was not needed.
8 This slide is consistent with a previous 9
slide that Rebecca showed. If you look to the right 10 where it says additional portions of the application, 11 I know it's kind of an eye chart, but the reason I 12 brought it up is this is essentially the table of 13 contents for the ARCAP Roadmap ISG.
14 So you would see the first full chapters 15 of the SAR with pointers to various ISGs. And then 16 after the SAR discussion, the first full chapters of 17 the SAR, the first thing you're going to see is tech 18 specs, technical specification or guidance, which is 19 going to point to an ISG. But the flow of this is 20 consistent with the flow in the ARCAP roadmap ISG.
21 The other thing I wanted to mention that's 22 in this slide is there's four appendices that are in 23 the ARCAP roadmap ISG, Appendix A, Alpha, which is the 24 pre-application guidance. This is something that was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
91 previously included in the ARCAP roadmap ISG that we 1
previously briefed the committee on.
2 There have been some adjustments as a 3
result of both management and our legal reviews, and 4
also as a result of the comments that we received.
5 But the main portion of the document is something that 6
was previously briefed to the ACRS.
7 Applicability of regulations to non-light 8
water reactors, this Appendix Bravo, the last time we 9
briefed the ACRS we only referenced a white paper. We 10 had a place holder for Appendix Bravo. And we 11 essentially said that we intend to take the white 12 paper that was publicly available and place it in 13 Appendix Bravo. So if you compare the white paper to 14 what's in Appendix Bravo, there's not many changes.
15 But it is a new appendix from what we previously 16 briefed the ACRS on.
17 Appendix Charlie, the construction permit 18 guidance, that was included in the previous document 19 that we briefed the ACRS on.
20 Appendix Delta is new. It's the draft 21 documents under development that may lead to future 22 changes to the guidance documents. That's where 23 you'll find a reference to DG-1413 that we talked 24 about earlier.
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92 So this slide went into the ARCAP roadmap 1
comments. There were 68 comments that were received.
2 It represents the second-most comments that we 3
received, as Anders mentioned, the ARCAP roadmap ISG 4
and the TICAP Reg Guide or foundational documents. So 5
it's expected, it wasn't a surprise to us that this 6
received the second-most comments.
7 Changes that were made because of the 8
comments, we expanded the applicability of Appendix B 9
to manufacturing license applications. So it 10 previously talked about the requirements for design 11 certs, as an example, combined licenses. But it left 12 out, in some of the tables, manufacturing licenses.
13 As a result of the comment, we added applicability of 14 regulations for manufacturing license, non-light water 15 applications.
16 We deleted a reference to the Facility 17 Safety Program. That is not a requirement in 10 CFR 18 Part 50 or 52. It was a placeholder for guidance for 19 10 CFR Part 53 which has, in the proposed rule, a 20 Facility Safety Program. We removed it. We believe 21 it's premature at this time. We're waiting for a 22 Commission direction on 10 CFR Part 53.
23 We expanded the guidance on leaks from 24 coolant systems to specifically address leaks from low 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
93 pressure systems. So when you look at the ARCAP 1
roadmap ISG, it had references in it to high pressure 2
leaks that you see from a standard review plan, 3
Chapter 3.
4 One of the questions or the comments that 5
we received was some of the non-light water reactor 6
designs don't operate at high pressures. We need to 7
provide guidance for low pressure systems.
8 So what you see in the guidance now is, 9
you know, there's an expectation that, for such 10 designs that are low pressure, environmental effects 11 of fluid leaks on structure systems and components in 12 the vicinity of the leak should consider factors such 13 as fluid temperatures, corrosive
- effects, 14 flammability, and radioactivity.
15 When it comes to principle design criteria 16 the guidance for the principle design criteria was 17 expanded to include a statement that each applicant is 18 responsible for identifying the need for additional 19 principle design criteria that are not informed by the 20 LMP process. LMP process is for off normal 21 conditions. There's principle design criteria 22 associated with things like normal effluence that 23 wouldn't come from the LMP process.
24 In this slide, we added a discussion on 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
94 operational programs. There was additional guidance 1
that was provided to supplement the guidance 2
associated with plant programs that are derived from 3
the Licensing Modernization Project. So you'll see in 4
the diagram that Rebecca showed earlier, that Chapter 5
8 includes plant programs that are relied on to 6
support the LMP outcome.
7 What we did as a result of the comment is 8
we provided additional guidance that applicants should 9
review Appendix B of the ARCAP Roadmap ISG which is 10 the applicability regulations. And if there are 11 operational programs that are required because a 12 particular regulation is applicable, and it's not 13 picked up by the LMP, the expectation is that 14 applicant would identify those.
15 Several
- items, as Anders mentioned 16 earlier, several items were transferred from the TICAP 17 regulatory guide to the ARCAP Roadmap ISG, because 18 they're not part of the LMP process. For example, 19 consideration of generic safety issues was an 20 expectation that that be provided in the SAR. Our 21 discussions are that's not something that the LMP 22 would pick up. So we moved it out of the TICAP 23 guidance and the ARCAP guidance.
24 (Audio interference.)
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95 MR. SEBROSKY: Okay, sorry. Is this any 1
better?
2 Okay. So that's the discussion of the 3
changes that we made to the document as a result of 4
comments that we received. Requested changes that 5
were not incorporated we talk about on this slide and 6
the next slide.
7 The staff did not add a statement that 8
consensus codes and standards take precedence over the 9
regulations. The NRC has not adopted a process for 10 automatic endorsement of consensus codes and standards 11 as suggested by the comments that we received.
12 The staff did not remove the guidance that 13 the design information related to items such as 14 translation of design basis hazard levels to loads on 15 structure, systems, and components and the evaluations 16 of those loads be included in the SAR.
17 The NRC did not agree with the comment and 18 believes that -- does not believe that it's sufficient 19 for an applicant to simply identify the hazard for 20 which design measures have been implemented as 21 suggested by the comment.
22 Slide 30, additional discussion of 23 comments that were not incorporated, we did receive a 24 comment on the ARCAP Roadmap ISG to remove Chapter 11 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
96 in its entirety, because the commenter believes that 1
the information is not needed to support an NRC staff 2
finding of reasonable assurance of adequate 3
protection. We did not agree with that.
4 The NRC did not agree with the expanding 5
the guidance for all the ISGs for light water 6
reactors. That's an issue that we all touched on, as 7
Anders mentioned previously. So that's the ARCAP 8
roadmap overview and discussion of the comments.
9 I'll move on to Chapter 2 which is site 10 information. So the LMP process does not provide 11 guidance on evaluation sites. So ARCAP ISG Chapter 2 12 is very similar to the structure that you would find 13 in SRP Chapter 2 for light water reactors. It 14 provides guidance on the scope and approach for 15 selecting the external hazards which must be 16 considered.
17 The selection of the external hazards is 18 to be informed by a probabilistic external hazard 19 analysis when supported by available method status, 20 standards, and guidance. So there's a discussion that 21 if it is not supported, then a deterministic 22 evaluation is appropriate.
23 Chapter 2 limits the amount of information 24 that needs to be provided in the SAR to that necessary 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
97 to establish the design basis external hazards. If 1
you look at SARs for operating reactors, you'll see 2
that some of the key information in Chapter 2 is 3
retained, but most of the information is labeled as 4
historical, because it's only done once.
5 So there is an expectation that the 6
information in Chapter 2 of the SAR will be limited in 7
nature with the supporting information either 8
submitted on the docket or available by audit 9
(phonetic).
10 Chapter 2
refers to existing site 11 evaluation guidance reg guides where appropriate. And 12 it's fundamentally based on 10 CFR Part 100, Subpart 13 B requirements. There were 12 comments received on 14 Chapter 2.
15 Changes made because of the comments, we 16 revised the frequency of occurrence of nearby 17 industrial transportation material, military facility 18 hazards to be considered in the design to be 19 consistent with the existing guidance, and you will 20 see it in redline strike out in the documents. There 21 is a section that talks about -- that was removed that 22 discusses event sequences of five in ten million 23 initiating event frequencies.
24 We removed that and retained the guidance 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
98 that one in a million is appropriate if the data 1
supports that, which gets to the second bullet to 2
allow the use of a combination of probabilistic and 3
deterministic methods to select external hazards.
4 There was a discussion in Section 2.6 5
about the need to perform a comparative, competitive, 6
process for information on slope stability. That was 7
thought to be unnecessary and was eliminated as a 8
result of the comment.
9 The requested changes that were not 10 incorporated include the development of a standardized 11 process for screening out external hazards. There is 12 two guidance documents, one that's draft, and one 13 that's finished as final, that do lay out a process 14 for screening out external hazards.
15 The one that's been listed that has been 16 issued as final is guidance on volcanic hazards.
17 There's a discussion in there about how an applicant 18 may be able to screen out volcanic hazards for its 19 site.
20 And then in a draft guide for flooding 21 hazard assessments, there's an Appendix K in the draft 22 guide that discusses the process for potentially 23 screening out a hazard, the flooding hazard. So in 24 our comment we, comment resolution, we referenced 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
99 those two documents. But we did not adopt the 1
standardized approach for all hazards.
2 The next --
3 MEMBER DIMITRIJEVIC: I'd like to just ask 4
you about the Chapter 2. So on the parts of Chapter 5
2, you know, that the methodology summarizes, because 6
now chapter 2, it actually has everything in, you 7
know, that will be put separately for comments?
8 MR. SEBROSKY: I'm sorry, I'm not sure I 9
quite understand the comment. So there's a Chapter 2 10 that comes out of the LMP process --
11 MEMBER DIMITRIJEVIC: Okay, so it's --
12 MR. SEBROSKY: -- and that's different.
13 (Simultaneous speaking.)
14 MEMBER DIMITRIJEVIC: -- Chapter 2 which 15 is the SR, right?
16 MR. SEBROSKY: Yes. So there's a Chapter 17 2, if you go back to the previous figure that Rebecca 18 showed you'll see, coming out of NEI 2107, a 19 designation of the chapters that are based on the LMP 20 approach. And I think Chapter 2 is methodologies out 21 of the LMP approach.
22 MEMBER DIMITRIJEVIC: Right.
23 MR. SEBROSKY: What we determined is we 24 needed a chapter on site information, because the LMP 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
100 process does not address the site characterization.
1 So Chapter 2 of the ISG is very consistent with 2
Chapter 2 of the light water reactor standard review 3
point. So if you look at Chapter 2 out of the LMP 4
process, it's titled methodologies, and analysis, and 5
site information.
6 MEMBER DIMITRIJEVIC: Right.
7 MR. SEBROSKY: But it doesn't -- you see 8
that, if you went back to that slide, you'll see site 9
information as an asterisk. And the asterisk points 10 to ARCAP ISG Chapter 2. And I hope that makes sense.
11 MEMBER DIMITRIJEVIC: Well, I have to 12 think about that again. So okay. All right, I can 13 look at that differently.
14 MR. SEBROSKY: So the next chapter to talk 15 about is Chapter 9. So when you look at the ISGs that 16 we developed, for the most part they're outside of the 17 LMP process. This is an example, Chapter 9, control 18 of normal effluent site contamination and solid waste.
19 The LMP process is for off-normal 20 conditions. So Chapter 9 is analogous. If you look 21 at the light water reactors in the review plan you 22 would see the same type of information in Chapter 11.
23 We, for Chapter 9, applied a performance-based 24 approach for the level of detailed information 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
101 provided in the SAR related to control of routine 1
plant effluence, and plant contamination, and solid 2
waste.
3 When it comes to changes that were made 4
because of comments, we provided additional discussion 5
for Chapter 9 on content for design certification, 6
standard design approvals, and manufacturing licenses 7
to identify the kinds and quantities of radioactive 8
materials to be produced, and means for controlling 9
and limiting radioactive effluence, and how the design 10 will minimize contamination and control gaseous and 11 liquid effluence produced during normal operations.
12 So we added that discussion.
13 And we also provided a caveat that 14 programmatic information may be addressed in the COL 15 application and not addressed in design certs, 16 standard design approvals, and manufacturing licenses.
17 The guidance also allows for an 18 alternative approach for providing detailed system 19 descriptions by requesting exemption requirements if 20 it can be demonstrated that compliance with 10 CFR 21 Part 20 can be established through a performance 22 monitoring program.
23 Additional discussion was added on what 24 information would be needed to support such an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
102 exemption to confirm that the design features and 1
programmatic controls effectively limit the release of 2
radioactive effluents.
3 So when it comes to the changes that were 4
not incorporated, these were all recommendations. So 5
I believe the guidance, the commenter interpreted as 6
related to Draft, Part 53. We believe it's clear that 7
for now the ISG is for 1552 applications.
8 We did not delete the guidance directing 9
applicants to provide a summary of estimated doses.
10 We believe that's important. There was a comment to 11 remove what was perceived to be prescriptiveness and 12 only referenced industry standards. We do not agree 13 with that comment.
14 And we did not remove references to the 15 NEI template documents that the commenter suggested.
16 We believe those NEI template documents that were 17 approved by a SECY evaluation are important when 18 considering development of the content for Chapter 9.
19 Chapter 10, similar to Chapter 9, is for 20 normal operations.
It provides guidance on 21 occupational doses. Again, if you look for an 22 analogous section in the SRP you would find this in 23 Chapter 12 of the light water reactor standard review 24 plan.
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103 For Chapter 10 it implies a performance-1 based approach for level of detail in the information 2
provided in SAR. There were no changes that we made 3
to the document because of comments. We only received 4
two comments on the document, one of which requested 5
that the guidance be expanded to include light water 6
reactors which, again, we don't intend to do at this 7
time.
8 The other comment included a statement, 9
without requesting a change, that as low as reasonably 10 achievable concepts would, from their perspective, 11 they don't believe that was included in the guidance 12 that we have in Chapter 10.
13 We believe it is. The NRC staff doesn't 14 agree with the interpretation that Chapter 10 does not 15 include an expectation that the design include as low 16 as reasonably achievable. We believe it's pretty 17 straight forward to us.
18 Chapter 11 on organization and human 19 systems interaction, I'd like to turn it over to Jesse 20 Seymour to go through these slides.
21 MR. SEYMOUR: Okay Thank you, Joe. My 22 name is Jesse Seymour. And I am an operating 23 licensing examiner, human factors, technical reviewer 24 in the NRR Office of Licensing Human Factors Branch.
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104 I was one of the NRC staff that worked on the 1
development of ARCAP Chapter 11 and more recently on 2
the resolution of public comments, which I worked on 3
in concert with Dr. David Desaulniers, who is our 4
senior technical advisor for human factors in NRR.
5 I will be providing a brief overview of 6
the scope of Chapter 11 along with the changes that 7
we've made and related comments that we took into 8
consideration.
9 Next slide, please. As an overview, ARCAP 10 Chapter 11 draws upon the existing standard review 11 plan where it's appropriate to do so. But where it is 12 appropriate, it also adapts that guidance to make it 13 technology inclusive versus it being light-water 14 reactor centric.
15 A portion of Chapter 11 provides guidance 16 regarding the construction and management of operating 17 organizations in a manner that parallels that of NUREG 18 800, Chapter 13, but in general it does so at a higher 19 level that still covers a comparable scope in areas 20 like staffing, training, qualifications across the 21 organization.
22 There is also an underlying assumption 23 that advanced non-light-water reactor applicants 24 coming in under Parts 50 and 52 will need to navigate 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
105 applicability issues from some regulations while also 1
needing exemptions from others. So this is addressed 2
as relevance within the scope of those requirements.
3 A key example of this is licensed operator 4
staffing where the exemption process of NUREG 1791 is 5
explicitly called out.
6 Importantly though, there is no treatment 7
of either remote or autonomous operations within this 8
guidance. And in that sense Chapter 11 remains geared 9
towards what we would typically consider to be more 10 traditional concepts of operations, and those that we 11 are more likely to encounter in the near-term.
12 Additionally, a number of lessons learned 13 from recent staff experiences in both the Vogtle 14 combined license and NuScale design certification are 15 incorporated also. This includes staff takeaways 16 concerning the cold licensing of operators under 17 plants under design certifications, context and also 18 COL context, and those are incorporated into the 19 guidance.
20
`
Finally, the guidance also includes means 21 for evaluating the adequacy of human factors 22 considerations within an application as well as 23 whether human factors engineering related post-TMI 24 requirements have been appropriately addressed.
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106 Next
- slide, please.
We carefully 1
considered the public comments that we received for 2
Chapter 11 and coordinated with both INL and the 3
Division of Advanced and Non-Power Reactor staff to 4
disposition those.
5 In some cases, we determined that changes 6
were warranted. The changes made in response to 7
comments included primarily adding references and 8
clarifications for the areas that are, you know, 9
summarized here on the slide. So, again, pointing 10 back to existing guidance that could be used within 11 the existing SRP where it was appropriate to do so.
12 Again, some of this is at the higher level 13 organization for construction management in the 14 operating organization, things that would typically 15 hold true in a technology neutral manner and providing 16 some additional regulatory clarifications there as 17 well.
18 The changes made in response to comments, 19 again, primarily referenced clarifications. We 20 determined that changes weren't warranted in response 21 to the remaining comments beyond that. And those are 22 listed on the bottom out there. And I will talk about 23 that.
24 In general, we assess that the material in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
107 question in some cases was already adequately clear.
1 Where some comments were suggesting the removal of 2
material, we assessed that removing the material 3
wouldn't be consistent with fulfilling any needs to 4
provide regulatory guidance. So, again, by taking 5
some material out, you actually make things less clear 6
and more difficult to navigate in our assessment or 7
because separate processes already exist to address 8
the given issue that was covered by comments. And I 9
want to highlight that last bulleted item, in 10 particular, which is in that vein.
11 Within the context of our proposed Part 53 12 work, we did develop a revised approach to on-shift 13 engineering expertise that offered some enhanced 14 flexibility over the traditional shift technical 15 advisor.
16 For the purposes of ARCAP, more broadly, 17 Part 50 and 52 facilities, we have not engaged the 18 Commission regarding any proposal to make generic 19 changes to the existing shift technical advisor 20 framework. However, that being said, on a case by 21 case basis, Part 50 and 52 applicants and licensees 22 could certainly propose different approaches to the 23 shift technical advisor. And we would continue to 24 consider those proposals on their individual merits.
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108 In some cases, this may involve the need 1
for us to engage the Commission due to policy 2
implications, as was the case with NuScale and the 3
revised plant topical that we discussed before the 4
committee a few years ago.
5 So, again, you know, that's a matter that 6
we intend to continue to address on a case by case 7
basis as it comes up within Parts 50 and 52. But we 8
are not proposing any type of a generic modification 9
to that traditional STA approach. And that's all 10 within the context of that final comment that's there.
11 So I wanted to pause and just see if 12 there's any questions before I turn it back over to 13 Joe. Yes?
14 MEMBER BIER: Yeah. I do have a couple of 15 quick questions or comments, one that's really more 16 kind of editorial than substantive. In the discussion 17 of the process for exemptions, there is kind of a 18 heavy reliance on the NuScale example to illustrate 19 that.
20 And, you know, if this document is still 21 in effect 10 or 15 years from now, NuScale may not be 22 top of mind for the people who are reading it. So I 23 would just recommend that we change -- that that gets 24 changed to say something like, you know, if you want 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
109 to have, you know, more reactors per operator or, you 1
know, fewer people in the control room or whatever as 2
concrete examples rather than you could do what 3
NuScale did kind of.
4 So that's just an editorial suggestion 5
that may, you know, help for clarity of the document.
6 The other question -- I mean, you 7
mentioned that this is currently tied to 50 and 52, 8
but that there is kind of some thought or what would 9
happen if and when Part 53 is in effect. Have you 10 thought about how generally licensed reactor operators 11 would be covered here and would it be by exemption or 12 would your revise the document to officially allow it 13 or how would that be treated?
14 MR. SEYMOUR: So with regard to general 15 licensed reactor operators, and this is a really 16 fascinating, you know, discussion just from a kind of 17 procedural standpoint, what we proposed within Part 53 18 was to create a separate class of reactor facility 19 where that would apply. And that was done largely for 20 staff support reasons because under the Atomic Energy 21 Act, you have to have uniform conditions of licensing 22 operators across the various classes of reactors.
23 For the general licensed reactor operator, 24 as the name would imply, it's a much different form of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
110 licensing, again, general. And when you compare that 1
to the specific licensing that is used for ROs and 2
SROs, it would be legally very challenging to try to 3
create a carve-out that lives within Part 50, 52 and 4
55, where that could exist.
5 Now that being said, and this is something 6
that we've shared with, you know, stakeholders we have 7
in the pre-application space, you can take a senior 8
reactor operator, and you can request modifications 9
via exemption to the licensing process into some of 10 the scope of an existing senior reactor operator and 11 still individually license them. And that flexibility 12 is there.
13 You know, hypothetically, you could have 14 a senior reactor operator power a reactor whose 15 licensure and training program more closely resembles 16 a research and test reactor. I mean, that's within 17 the realm of possibility if, you know, the safety case 18 was there for that, you know, again, their role in the 19 fulfillment of safety.
20 So through our mechanisms that are there 21 that are viable within 50 and 52 and 55, they get you 22 almost the way there. But, again, you know, having 23 that difference in licensing is difficult, unless you 24 have a distinct class of reactor.
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111 MEMBER BEIER: Thank you. That's helpful.
1 MR. SEYMOUR: If there's nothing else, I'm 2
going to turn it over to Joe.
3 MR. SEBROSKY: Thanks, Jesse. And this is 4
Joe Sebrosky. The next item to talk about is ARCAP 5
ISG Chapter 12 on -- it should say post-manufacturing 6
construction inspection testing and analysis program.
7 So Chapter 12, if you looked in the 8
standard review plan for Part 52 applications, you 9
would find this material in SRP Section 14. But the 10 difference is for Chapter 12, it covers both 11 construction permits and operating licenses as well as 12 Part 52 concepts like ITAAC, inspection staff's 13 analysis of acceptance criteria.
14 It's broken into two phases. So there is 15 a Phase 1, which is pre-fuel load. And if you looked 16 at the Part 50 construct, you would see that that 17 covers up through the construction permit, but prior 18 to the operating license. But Part 52 construct, it 19 would go up to the fuel load or the 52.103(g) finding.
20
- And, again, the 52.0103(g)
- finding, if you 21 demonstrated the ITAAC had been met under 10 CFR Part 22 52, you could receive the fuel load.
23 So the construct of Chapter 12 as a Phase 24 1 approach, which is prior to fuel load and then it 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
112 talks about the expectations for SAR content to cover 1
that area and then post-fuel load, which includes 2
after the operating license is issued or the 52.103(g) 3 finding is made.
4 So the idea when you look at the pre-fuel 5
load test program, that's expected to be discussed in 6
the SAR. It would support the issuance of an 7
operating license if the initial test program is 8
unsatisfactory under 10 CFR Part 50 or the 9
authorization load fuel SAR includes ITAAC.
10 The second bullet differentiates, as 11 indicated, it differentiates between Part 52 and Part 12 50 applications that aren't required to include ITAAC.
13 The third bullet just is a bullet that 14 shows where the requirements that describe pre-15 operational testing can be found for both Part 50 and 16
- 52. It provides guidance as I indicated earlier prior 17 to fuel load and then provides guidance under Phase 2 18 on what should be described in the SAR when it comes 19 to initial start-up testing up to and including power 20 accession testing.
21 MEMBER HALNON: So, Joe, before we get 22 into the comments, I just had one as I was reading 23 through this. I'm trying to go down the work of these 24 reactors be placed in this world. And the thing that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
113 it's a high probability that they will be placed in 1
very harsh environments, either deserts or places that 2
could be dark for two hours a day or those types of 3
things.
4 I didn't see any real pointers to making sure 5
that the mission, that the support system's heating, 6
ventilation, lighting, those types of things critical 7
to the mission of the operators and potentially 8
security and other areas is looked at to make sure 9
that where it is being placed is compatible with those 10 support systems.
11 That was the only thing I could find that 12 I really was wanting after all of these.
13 MR. SEBROSKY: I understand. So just to 14 repeat back, the guidance to the extent that the 15 reactor is placed in a harsh environment, we would 16 want to see a test program that ensures prior to fuel 17 load or after fuel load as part of the initial start-18 up testing that it's going to work in that harsh 19 environment.
20 MEMBER HALNON: Yeah. The support systems 21 are adequate for those areas that -- because a reactor 22 in Central Ohio will be different than the support 23 systems needed for Northern Alaska and taking a 24 standard design and say I think I'm going to put it 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
114 from here to there may not be adequate. I know you 1
see that other places in the application process in 2
making sure support systems are able to support 3
whatever safety functions they're doing.
4 But when I got through all of this, I 5
thought about, well, how will those work? Is there 6
enough lighting? Is there enough HVAC to support the 7
mission? And I don't know if it has to be a test 8
program or at least a mention that just ensure that 9
the support systems are adequate for your testing, 10 something to that effect.
11 So think about it. I'm not saying that 12 it's a deficiency. I'm just saying that's what I felt 13 like I was -- if I was a reviewer I would want to have 14 some push to look at that portion of the plant.
15 MR. SEBROSKY: I understand. Thank you.
16 So on this slide, Slide 45, the changes that we made 17 because of the comments, we changed the title from 18 post-construction to post-manufacturing and 19 construction to reflect in some aspects of the initial 20 test program and/or the ITAAC inspections test 21 analysis and acceptance criteria could be completed at 22 the manufacturing facility.
23 We clarified that the COL holder has the 24 responsibility for verifying the completion of ITAAC 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
115 including verifying the ITAAC that were completed at 1
the manufacturing facility have been maintained.
2 We clarified that for a construction 3
permit application, the content of the initial test 4
program descriptions can be limited in scope to the 5
Phase 1 or pre-fuel load inspections testing and 6
verification that would be required under 10 CFR Part 7
50, Appendix B. Such content would include a 8
description of the scope objectives and programmatic 9
controls associated with the pre-operational test 10 program.
11 We removed a reference to review committee 12 and replaced it with guidance that the application 13 should include a discussion for establishing a defined 14 set of qualified operating and technical plant 15 personnel to review, evaluate and disposition the 16 inspections test and verification results.
17 The changes that were not incorporated 18 included the staff disagreed that additional 19 information regarding ISG Sections that applies to 20 construction permits is needed because from the 21 staff's perspective, we believe there is sufficient 22 guidance for construction permit applications.
23 The next ISG to talk about -- so you'll 24 see there are three ISGs that are outside the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
116 construct of the SAR. This one is one of them, in-1 service inspection, in-service testing. The next one 2
I'll be talking about is an ISG on technical 3
specifications and the last one, fire protection for 4
operations.
5 So the ARCAP in-service inspection and in-6 service testing, ISG is based on the use of a plant 7
specific PRA to identify the structures, systems, and 8
components to be included in the programs.
9 The ISI guidance is based on the use of 10 these two ASME Boiler Pressure Vessel Code sections 11 that are provided on this slide in the sub-bullets, 12 Section 11, Division 2, on the requirements for 13 reliability and integrity management and then Section 14 3, Division 5, for high temperature reactors.
15 The IST guidance is based on the existing 16 in-service testing program approach with additional 17 guidance for passive components and notes that ASME is 18 developing a new OM-2 code for in-service testing of 19 components in new and advanced reactors, including 20 non-light-water reactors.
21 So one of the things that the IST 22 discusses when it comes to passive components provides 23 guidance for things like heat pipes that you don't see 24 in the light-water reactor operating fleet. It again 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
117 uses plant specific risk information to determine the 1
scope of the IST.
2 There were 43 comments received on the 3
ISI/ISG so it's the third most comment we received on 4
the documents.
5 So changes that were made because of 6
comments we noted or we added that applicants can use 7
ASME in QA1, quality assurance requirements for 8
nuclear facility applications implementing Section XI, 9
Division 2, guidance. This is consistent with the Reg 10 Guide that was recently issued, Reg Guide 1.246, which 11 endorses ASME Code Section XI, Division 2.
12 We allowed the use of unissued consensus 13 codes at the construction permit stage provided they 14 are officially issued prior to submitting the 15 operating license application and provided design 16 finality is not being requested on any portion of the 17 design affected by the OM-2 codes. And we allow 18 applicants for multi-module plants to provide standard 19 ISI and ISG programs to each module without having to 20 develop separate program approvals, provided the 21 modules are identified.
22 MEMBER BALLINGER: This is Ron Ballinger.
23 I think -- while this OM-2 code is being developed, 24 there's another code call Fitness for Service-1, which 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
118 is an ASME extensive code, at least mention it.
1 MR. SEBROSKY: I understand the comment.
2 I will take that back and talk to ISI and ISG folks in 3
our group.
4 Of the requested changes that were not 5
incorporated, the staff did not want to make a 6
discussion of the process to be followed when the in-7 service inspection program identifies that degradation 8
has occurred.
9 The NRC staff believes that the guidance 10 in the ISG supplements, the guidance found in ASME 11 Section X1, Division 2. The NRC staff disagreed with 12 removing the discussion on passive components because 13 the staff believes the topic is not specifically 14 addressed by ASME and the topic is important for some 15 of the designs like the heat pipe example that I 16 provided earlier.
17 The NRC staff did not believe additional 18 guidance for graphite and composite materials are 19 needed to be included in the scope of the in-service 20 inspection guidance because the staff believes that is 21 an implicit part of the licensing modernization 22 project process which should identify whether the 23 graphite and certain materials in their design 24 warrants an in-service inspection program.
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119 So the next ISG to talk about is the one 1
for technical specifications. The reason that we 2
developed the ISG for technical specifications is when 3
you look at the 5036 criteria for tech specs, it needs 4
adaption to correlate to the analysis and output from 5
the LMP-based approach described in 18-04.
6 So when you look at this guidance, you 7
will see tables in it that talk about the requirement 8
from 50.36. And then it maps it to the outcome from 9
the LMP process.
10 The guidance also addresses content for 11 the tech spec administrative control section and 12 recommended tech spec format.
13 So changes that remain because of the 14 comments, we added reference to NEI 18-04, the section 15 that addresses risk metrics that are different from 16
-- excuse me, core damage frequency and large early 17 release frequency metrics for use in developing 18 limiting conditions for operation and completion 19 times. Molten salt fuel reactor or damage frequency 20 doesn't mean much.
21 We added guidance for technical 22 specification information. That should be included in 23 the preliminary safety analysis report based on the 24 requirements found in 10 CFR 5034(a)(5).
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120 If you look at that requirement, there is 1
an expectation that the probable subjects of technical 2
specifications should be included in the PSAR with 3
attention to information which may significantly 4
influence the final design or form the basis for the 5
preliminary limiting conditions for operations.
6 We added that discussion and exemption may 7
be needed based on the correlation between the 8
language in 50.36 to the analysis and outputs of the 9
risk informed LMP approach.
10 The changes that were not incorporated, 11 the staff did not revise the guidance -- revise Reg 12 Guide 1.177 -- the title of that Reg Guide is Plan 13 Specific Risk-Informed Decision-Making -- to align 14 with NEI 18-04 risk metrics because the NRC staff 15 believes the guidance in the technical specific ISG is 16 sufficient at this time without having to revise that 17 Reg Guide.
18 The staff noted in response to the comment 19 that there are no near-term plans to revise 50.36 to 20 include criteria from all of the factors. That's the 21 technical specification.
22 This is the last ISG, and it's for fire 23 protection for operations. So the reason fire 24 protection for operations was developed is the LMP 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
121 process is expected to address fire protection for the 1
design, but it doesn't. The LMP process is not going 2
to include the programmatic controls.
3 So 10 CFR 50.48 requires each operating 4
plant have a fire protection plan that meets the 5
requirements of 10 CFR Part 50, Appendix A, Criteria 6
3, for light-water reactors or the applicant's 7
proposed design criteria that have been deemed 8
acceptable by the NRC.
9 So we do expect the principal design 10 criteria for non-light-water reactors that's analogous 11 to the general design criteria, Appendix A, Criterion 12 3.
13 When you look at the guidance that's in 14 this ISG, it includes concepts from NFPA 805. NFPA 15 805, which is included in Requirement 10 CFR 50.48(c) 16 is not applicable to a non-light-water reactors. But 17 we believe the concepts in NFPA 805 that are 18 fundamentally a risk-informed approach are appropriate 19 for guidance for non-light-water reactors.
20 The scope of the ISG addresses the review 21 and application content regarding the fire protection 22 program for operations, including application 23 descriptions of the management and policy program 24 direction and the integrated combination of procedures 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
122 of personnel that implement fire protection 1
activities.
2 MEMBER HALNON: So a quick question, and 3
correct me if I didn't read it correctly. But it 4
appears the ISG makes an overall overriding assumption 5
that there is a classic fire brigade available. Is 6
that true?
7 MR. SEBROSKY: I believe that is the going 8
in position.
9 MEMBER HALNON: Okay.
10 MR. SEBROSKY: There is the potential that 11 a classic fire brigade may not be needed for some of 12 the designs if it can be demonstrated that it is not 13 necessary.
14 MEMBER HALNON: Yeah. So that branch, 15 looking at a non-fire brigade plant may be incipient 16 detection type relying on the offsite is -- it didn't 17 seem to have a tie or a push to look that way in case.
18 And I didn't know if there was something that I was 19 missing.
20 We have already done one, I guess, 21 perceived non-light-water type Part 50, and they 22 didn't have a fire brigade. And they relied on 23 offsite. So we had to go to the emergency plan and 24 have it tied in the emergency plan to make sure that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
123 the offsite was ready to fight fires onsite.
1 So that branch, tied to the emergency plan 2
and the presumption that there's a fire brigade always 3
didn't match up to me. So I would suggest maybe take 4
a look at it and maybe figure some way to make sure 5
that the reviewers first asking the question fire 6
brigade, yes/no. If no, where do you go? If yes, 7
then the rest of the ISG works great. And then the if 8
no, we will need to have it tied to the emergency plan 9
to follow that trail to make sure that everything is 10 copacetic and covered.
11 MR. SEBROSKY: Thank you for the comment.
12 So we received many comments on fire protection. As 13 a result of the comments, the changes that you see 14 here are editorial in nature. And this is a listing 15 of the comments that were received that we did not 16 incorporate.
17 Many of the comments requested deletion of 18 guidance material, like removing references to general 19 design criteria, deleting clarifying text regarding 20 acceptability of NFPA 805. The staff provides a basis 21 in the comment resolution tables for why such 22 information is sought to be appropriate to be kept in 23 the guidance document.
24 So this ends the presentation on the nine 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
124 ISGs. The next two slides are just acronyms and 1
initial lists.
2 CHAIR PETTI: Thank you, Joe. At this 3
point, given the late hour, we do have some public 4
comments that I would like to take and then we can 5
talk about the comments and next steps.
6 So if anyone has a public comment, please 7
identify yourself and your comment.
8 I see Brandon. I can't read your last 9
name easily.
10 MR. CHISHOLM: Yes, hello. And thank you 11 for the opportunity to address the subcommittee. I am 12 Brandon Chisholm of Southern Company. And today I am 13 speaking on behalf of the industry-led TICAP team 14 concerning the important guidance documents that have 15 been discussed today.
16 So in particular, I
highlight the 17 technology inclusive content application project for 18 the TCAP guidance document, that is NEI 21-07 and the 19 NRC's draft Regulatory Guide DG-1404, Revision 1, 20 which addresses it.
21 As you know, TICAP built on the licensing 22 modernization project, or LMP, which is documented in 23 NEI 18-04 and endorsed by the NRC in Reg Guide 1.233.
24 Together NEI 18-04 and NEI 21-07 and the associated 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
125 NRC guidance documents form a workable basis for a 1
risk-informed and performance-based advanced reactor 2
license application that is submitted under the 3
existing regulatory framework.
4 In fact, as discussed earlier today, both 5
advanced reactor program, or ARDP, vendors, those 6
being X-energy and TerraPower's Natrium, are among the 7
multiple near-term applicants using LMP and TICAP for 8
their applications.
9 Both LMP and TICAP were initiated by 10 Southern Company on behalf of the industry and were 11 carried out through cost share and supported by the 12 Department of Energy's Office of Nuclear Energy.
13 There were many industry partners and 14 participants playing key roles, including Idaho 15 National Laboratory, the Nuclear Energy Institute, 16 reactor vendors and private consultants.
17 Most importantly, the guidance was 18 developed with extensive interaction with the Nuclear 19 Regulatory Commission staff generally in public 20 meetings. Perhaps the most significant example of 21 such interaction was the inclusion of staff 22 observation and multiple tabletop exercises to 23 illustrate the application of the guidance on a 24 variety of advanced reactor technologies during the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
126 development of NEI 21-07.
1 As evident from the discussion of the 2
public comments today, industry and the NRC did not, 3
and still do not, have complete alignment on every 4
single point that is associated with the guidance.
5 Nevertheless, all parties share the goal of developing 6
a risk-informed and performance-based approach to 7
regulation of advanced reactors that would provide a 8
reasonable assurance of adequate protection of public 9
health and safety and also be usable, transparent and 10 implementable for all reactor technologies.
11 Through extensive cooperative efforts in 12 full view of stakeholders and the public, we believe 13 that the parties have overwhelmingly succeeded in 14 achieving that goal.
15 One topic of conversation that I would 16 like to make a quick note about is the documentation 17 of hazard analysis in the safety analysis report.
18 As was mentioned, there are multiple 19 requirements in the NEI 18-04 methodology, where 20 analyses using tools like checklists, what if 21 assessments, hazard and operability studies, failure 22 modes and affect analyses and others would be used and 23 incorporated into a risk-informed and performance-24 based process.
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127 Two such examples will be the requirements 1
for hazard identification and screening in the non-LWR 2
PRA standard and the comprehensive evaluation of 3
defense-in-depth adequacy.
4 While the LMP and TICAP reflects the 5
perspective offered by Member Martin, that hazard 6
analysis is a key piece of understanding the safety 7
and design of any system, I would just like to note 8
that the requirement to explicitly document the 9
results of the hazard analysis in the SAR will be a 10 new and potentially unbounded requirement for an 11 applicant.
12 However, as mentioned earlier, the hazard 13 analysis documentation does exist in the documentation 14 that supports the development of the SAR.
15 So to conclude my comments here today, the 16 ARDP projects are continuing apace. It is of 17 paramount importance to Southern Company as well as 18 the mission of the industry-led and DOE supported 19 project for the NRC to complete its guidance documents 20 in an expeditious manner.
21 There are additional initiatives underway 22 and plans to further develop the risk-informed 23 performance-based advanced reactor regulatory 24 framework by NEI 21-07 and the associated NRC guidance 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
128 documents need to be put in place as soon as possible.
1 We urge the ACRS to act promptly on DG-2 1404 and the associated Reg Guide 1.253 and the other 3
ARCAP guidance documents. Thank you again. And 4
that's the end of my comment.
5 CHAIR PETTI: Thank you. I see Benjamin 6
Holtzman.
7 MR. HOLTZMAN: Yes. Thank you. Can you 8
guys hear me okay?
9 CHAIR PETTI: Yes.
10 MR. HOLTZMAN: Okay. Thank you. This is 11 Ben Holtzman from the Nuclear Energy Institute. I 12 would echo a lot of what Brandon just said so I won't 13 specifically do that. But I will encourage you as 14 well to move forward as judiciously and expeditiously 15 as possible in the finalization of these guidance 16 documents.
17 Industry is very interested. And there 18 are companies, as we've been discussing, who are 19 planning on using them. And generally industry 20 believes that the documents are very good. There's 21 always room for improvement, of course, but these 22 documents are a great step forward in terms of 23 providing a
predictable and usable regulatory 24 guidance.
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129 And so I would just like to just again 1
reiterate our support of not only industry, but NRC 2
staff's efforts in the development of these guidance 3
documents. Thank you very much.
4 CHAIR PETTI: Thank you. Any other public 5
comments? Any other comments? Okay. So, members, 6
any broad comments? I've been taking notes so I've 7
noted maybe two or three things that I can put into 8
the letter.
9 I want to thank the members who provided 10 input. I've got good input from Matt and Greg and 11 Vicki. And so I've got a pretty good draft together.
12 And I will go and put some more -- sprinkle some of 13 these comments I heard today in there.
14 MEMBER HALNON: Dave, can I ask one more 15 question of this panel?
16 CHAIR PETTI: Mm-hmm. Sure.
17 MEMBER HALNON: And I was just curious on 18 the fire protection comments. I mean, they were 19 probably made by very experienced fire protection 20 industry folks. Is that why most of them -- all of 21 them were rejected that they just didn't come in an 22 informed set of comments? I mean, it struck me that 23 100 percent of the comments were rejected.
24 MR. SEBROSKY: The majority of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
130 comments -- I'm trying to say this. A majority of the 1
comments --
2 MEMBER HALNON: They were trying to get 3
you to draw back on the guidance and requirements.
4 MR. SEBROSKY: Right.
5 MEMBER HALNON: I get that.
6 MR. SEBROSKY: So there was a particular 7
individual that across the ISGs believed that we 8
didn't need them. That we could rely on --
9 (Simultaneous speaking.)
10 MEMBER HALNON: That got reflected.
11 MR. SEBROSKY: And that person also 12 provided multiple comments along those same lines for 13 the fire protection.
14 MEMBER HALNON: Okay. So you say you have 15 general fire protection staff in the industry so ISG.
16 I don't want to speak for industry, but, I mean, from 17 your perspective you feel relatively okay about --
18 MR. SEBROSKY: Yes.
19 MEMBER HALNON: Okay. That's fine.
20 Thanks. I just wanted to -- I probably would have 21 struck them too when we got them.
22 MR. SEBROSKY: Yes.
23 MEMBER HALNON: Okay. Thanks.
24 MEMBER BROWN: Yes. Just a question.
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131 Back in our prior discussion when we were going 1
through all of this stuff in detail, comments were 2
made relative to some of the documents that were 3
referred to, like, in my areas, as a design review 4
guy, for instance, issue a control that says for non-5 light-water reactors. And we talked about that guide 6
because it was virtually identical in those 7
circumstances to the one we developed for some of the 8
past projects.
9 And we suggested that somehow it ought to 10 not be known as just non-light-water reactors. I 11 noticed when I went through it that the references to 12 it still had parentheses as non-light-water reactors.
13 And it came down to that there was a comment by 14 somebody that said, hey, you didn't need it at all.
15 You all said no. We took it out of, I think, the Reg 16 Guide 1.253 or something and put it in a roadmap.
17 It's pretty sparse, the whole thing, 18 relative to the INC world. So that's why I was 19 interested in seeing what the perception was.
20 MR. SEBROSKY: Yes. So just to clarify 21 and the I'm going to turn it over to Ian Jung. I was 22 looking past you because Ian can help on this.
23 MEMBER BROWN: He's not going to yell at 24 me, is he?
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132 MR. SEBROSKY: We believe that DRG is very 1
important. The fact that we moved it from DG-1404 Reg 2
Guide 1.2 (audio interference). I believe that the LMP 3
process is found in the I21-07. And DG-1404 Reg Guide 4
1253 is going to identify safety-related INC systems 5
and non-safety-related special treatment INC systems.
6 And when it comes to reviewing those INC systems that 7
DRG is important.
8 I would turn it over to Ian to talk about 9
the plans to broaden potentially applicability to 10 light-water reactors.
11 MR. JUNG: Ian Jung again. The 12 committee's recommendation to DRG related to light-13 water reactors led to a footnote within the DRG that 14 the DRG design refuel guide for INC is technology 15 inclusive from INC perspective so it can be used for 16 light-water reactors.
17 MEMBER BROWN: So you did incorporate the 18 thought process over which when you say it's a 19 footnote?
20 MR. JUNG: Right. I mean, there was some 21 negotiation on that. But in reality, actually just 22 moved the light-water reactors, like BWXY. They are 23 planning to use DRG as a guidance. They are engaged 24 with light-water reactor divisions for INC. So 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
133 practically, the guidance is being used, and your 1
emphasis on your committee's emphasis on 2
fundamental INC design principles are cornerstones of 3
those guidance. And I think those are going to be 4
executed in all non-light-water reactor and light-5 water design as a safety focus.
6 MEMBER BROWN: I was just concerned that, 7
you know, it has been obviously in a sense an issue of 8
considerable discussion over the last 15 years of my 9
participation. And that was kind of the crown jewel 10 of bringing everything together as we moved through 11 various projects. And then the DRG was developed, I 12 think, it was for -- I have forgotten which one of the 13 boiling water reactors it was in there. EBWR or 14 something like that.
15 MR. JUNG: The mPower design at the 16 beginning of NuScale.
17 MEMBER BROWN: And it was really complete.
18 And now to just see it subsumed into a footnote 19 somewhere even though theoretically it's going to be 20 recognized. Because a lot of the stuff we're going to 21 be seeing, it's not going to be all advanced reactors.
22 People are going to be using conventional light-water 23
-- just regular light-water reactors. We're going to 24 be involved in a lot of the work that's being done.
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134 So I'm kind of worry about having the 1
ability to carry that whole 15 years' worth of effort 2
developing the details and now it's kind of relegated 3
into a footnote in the --
4 (Simultaneous speaking.)
5 MR. JUNG: -- to make sure that for non-6 LWR entities, like x-Energy and Natrium reactors, and 7
those plants are all using designer review guides for 8
SDR guidance.
9 MEMBER BROWN: It is in the references.
10 And I did check out where it was used or brought up in 11 the entire -- in the documents supplied to us. So 12 just curious. All right. I'm not going to be around 13 forever. I'm getting long in the tooth to phrase it.
14 MR. JUNG: DRG, it's a great guidance.
15 MEMBER BROWN: As long as you guys are 16 maintaining that emphasis even though I may be pushing 17 up daisies in a few years, it's nice to have that 18 emphasis still there. I'm finished.
19 CHAIR PETTI: I wanted to ask Joe to be 20 sure. You would like a letter from us?
21 MR. SEBROSKY: I'll defer to my boss, 22 Steven.
23 MR. LYNCH: Hey, good morning, still, for 24 a few more minutes. This is Steve Lynch, chief of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
135 Advanced Reactor Policy Branch. So the NRC staff met 1
with the committee today to provide an update on the 2
status of the development of the TICAP and ARCAP 3
documents with a focus on how we plan on addressing 4
the public comments received.
5 While we were not explicitly expecting the 6
committee to prepare a letter for this effort, the 7
staff, as always, is prepared to engaged with the ACRS 8
full committee and receive any recommendations and 9
conclusions that the committee may want to provide in 10 a letter.
11 MEMBER BROWN: Can I ask one other 12 question relative to that? I don't want to drag this 13 out, but was there a reason for doing that as a 14 footnote as opposed to a more direct reference? Did 15 you all have that discussion? You can see this 16 bothers me a little bit.
17 (Simultaneous speaking.)
18 CHAIR PETTI: Charlie, there's some really 19 important footnotes in the regulation we can go point 20 out to you.
21 MEMBER BROWN: So I'm not the only one 22 that's been relegated to a footnote?
23 CHAIR PETTI: Correct. Correct.
24 MR. JUNG: A footnote for light-water 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
136 reactors is very similar to non-LWR discussion we had 1
on overall --
2 (Simultaneous speaking.)
3 MR. JUNG: -- framework. Bringing light-4 water reactor framework into it potentially can delay 5
the issuance of DRG. That was one of the reasons.
6 Because we have a whole set of organizations to review 7
and concur on, potentially addressing different 8
opinions.
9 MEMBER BROWN: Okay. Well, I 'm bringing 10 this up since somebody supposedly is going to be 11 around after me. I'm not going to live forever. And 12 he's about 20 years younger than me. So you're going 13 to get stressed using that I suspect --
14 CHAIR PETTI: And I got one other thing 15 I'd like to --
16 MEMBER BROWN: -- his participation. I'm 17 done. Thank you.
18 CHAIR PETTI: We have four minutes.
19 MEMBER HALNON: I just want to mention 20 throughout these guidances, you put a lot of sort of 21 the parking lot as the pre-application engagement in 22 the process without a lot of structure around what 23 that looks like. Many of those pre-application 24 engagements are proprietary so they're not public and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
137 available to other companies to see how they did.
1 As you get through that, I would recommend 2
you keeping some lessons that could be generically 3
applied to other pre-application processes so that 4
you're not getting a new ROC every time you come in.
5 I think there is some pre-application guidance for the 6
light-water reactors out there that is in some kind of 7
8 CHAIR PETTI: There is the Appendix A. I 9
really like it.
10 MR. SEBROSKY: Yeah. So Appendix A in the 11 ARCAP roadmap ISG is the pre-application guidance that 12 13 MEMBER HALNON: Okay. I missed that. I 14 didn't see that.
15 CHAIR PETTI: No, it's in the letter.
16 Because we talked this ad nauseam as a committee --
17 MEMBER HALNON: Yeah, because it is --
18 CHAIR PETTI: -- about the need and the 19 timeliness.
20 MEMBER HALNON: -- important now.
21 CHAIR PETTI: You guys hid it.
22 MEMBER BROWN: I'd like to just follow-up 23 on your comment. We developed an ISG in the INC world 24 for pre-application processes. We did this 10 or 12 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
138 years ago. And is that part of this overall ISG so 1
there's still that available for the pre-application 2
review? Because that really gets a lot of the 3
complications. What should he expect? What should 4
the applicant expect?
And that was pretty 5
comprehensive back then. So is that still part of 6
this -- in play also?
7 MR. JUNG: This Appendix A is for all 8
disciplines. It covers very critical elements. So 9
that in INC area pre-applications are in a sense are 10 actually --
11 MEMBER BROWN: Are a part of that? Okay.
12 All right. Thank you.
13 CHAIR PETTI: Okay. And remember, you 14 guys, we can talk about this at full committee. We 15 have a hard stop in two minutes because we have a 16 lunch meeting. I just want to --
17 MEMBER BROWN: I can't be ignored 18 CHAIR PETTI: -- I just want to thank the 19 staff for their time today, and we'll see you in full 20 committee. We have finished this session.
21 MEMBER REMPE: So I want to remind the 22 virtually attending members that they have a different 23 24 PARTICIPANT: You're not on, Joy.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
139 MEMBER REMPE: I think I am. Okay.
1 There's no speaker up there so I don't worry about it 2
as much. But anyway, I want to remind those members 3
who are here virtually that there is a different 4
invitation and the meeting will start at 12:15.
5 And also there is a third invitation at 1 6
o'clock for a different meeting. So just kind of look 7
at your calendar. If you've got a problem, talk to 8
Larry, and he'll figure out what needs to be said.
9 But I think we're good. Thank you. I'm going to log 10 off of this one right now. Okay?
11 (Whereupon, the above-entitled matter went 12 off the record at 11:59 a.m.)
13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
Advanced Reactor Content of Application Project (ARCAP) Interim Staff Guidance (ISG) Documents and Technology Inclusive Content of Application Project (TICAP) Guidance Documents Status ACRS Regulatory Rulemaking, Policies and Practices Subcommittee November 16, 2023
Purpose and Agenda 2
- 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
- Agenda High-level overview of ARCAP and TICAP structure Discussion of Regulatory Guide 1.253 (TICAP Guidance)
Discussion of ARCAP interim staff guidance documents Path forward
=
Background===
3
- 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
=
Background===
4
- 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
Background - How to Access Draft Documents and Comments 5
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 All of the documents are available in Table 2 of the public ARCAP/TICAP webpage https://www.nrc.gov/reactors/new-reactors/advanced/rulemaking-and-guidance/advanced-reactor-content-of-application-project.html ARCAP ISG Title ADAMS Accession #
Regulations.gov Docket ID
- of Comments Draft DANU-ISG-2022-01, Review of Risk-Informed, Technology-Inclusive Advanced Reactor Applications -
Roadmap ML22048B546 NRC-2022-0074 68 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 Waste ML22048B543 NRC-2022-0076 13 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 Specifications ML22048B548 NRC-2022-0081 8
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 Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Advanced Reactors ML22076A003 NRC-2022-0073 73 Draft Regulatory Guide 1404, Revision 1 - added Appendix B to provide additional guidance for expectations for a probabilistic risk assessment (PRA) at the construction permit (CP) stage ML23194A194 NRC-2022-0073 30
ARCAP/TICAP Background 6
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
ARCAP/TICAP Background 7
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 Public Webpage provides links to key meetings and documents associated with the development of these documents (see: https://www.nrc.gov/reactors/new-reactors/advanced/rulemaking-and-guidance/advanced-reactor-content-of-application-project.html)
ARCAP/TICAP Background 8
- 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
ARCAP Background 9
- 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.
TICAP Background 10
- 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
ARCAP and TICAP - Nexus 11 Outline Safety Analysis Report (SAR) -
Based on TICAP Guidance 1.
General Plant Information, Site Description, and Overview 2.
Methodologies and Analyses and Site Information*
- 3. Licensing Basis Event (LBE) Analysis
- 4. Integrated Evaluations
- 5. Safety Functions, Design Criteria, and SSC Safety Classification
- 6. Safety Related SSC Criteria and Capabilities
- 7. Non-safety related with special treatment SSC Criteria and Capabilities
- 8. Plant Programs Additional Portions of Application
- Technical Specifications
- Technical Requirements Manual
- Quality Assurance Plan (design)
- Fire Protection Program (design)
- Quality Assurance Plan (construction and operations)
- Security Plan
- Cyber Security Plan
- SNM physical protection program
- SNM material control and accounting
- Fire Protection Program (operational)
- Radiation Protection Program
- Inservice inspection/Inservice testing (ISI/IST) Program
- Environmental Report and Site Redress Plan
- Financial Qualification and Insurance and Liability
- Fitness for Duty Program
- Aircraft Impact Assessment
- Performance Demonstration Requirements
- Nuclear Waste Policy Act
- Operational Programs
- Exemptions, Departures, and Variances )
Audit/inspection of Applicant Records Calculations Analyses P&IDs System Descriptions Design Drawings Design Specs Procurement Specs Probabilistic Risk Assessment
- SAR Chapter 2 derived from TICAP guidance as supplemented by ARCAP interim staff guidance Chapter 2, Site Information Safety Analysis Report (SAR) structure based on clean sheet approach 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.
The above list is for illustration purposes only.
Additional SAR Content -Outside the Scope of TICAP
- 9. Control of Routine Plant Radioactive Effluents, Plant Contamination, and Solid Waste
- 10. Control of Occupational Doses
- 11. Organization and Human-System Considerations
- 12. Post-construction Inspection, Testing and Analysis Programs
TICAP and ARCAP Roadmap Common Guidance 12
- 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
TICAP and ARCAP Roadmap Common Guidance 13 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
TICAP - High Level Overview 15
- 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
- The LMP methodology is based on a full-scope probabilistic risk assessment (PRA)
All sources of radiological material, all hazards, all plant operating states, full analysis of scenario progressions (i.e., analyzed from initiator to radiological consequence)
TICAP Guidance 16
TICAP Construction Permit/Operating License Guidance 17
18 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,*
Screened out of the PRA logic model with justification,*
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.
Construction Permit PRA Acceptability NOTE: Generally referring to the PRA implies these three items
19 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
- 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.
Construction Permit PRA Acceptability
TICAP Comments 20
- 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 an addition related to information applicants need to supply when using a risk-informed, performance-based approach other than LMP o Agreed with commenter that this approach is outside the scope of RG 1.253
TICAP Comments 21
- 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
TICAP Comments 22
- Changes resulting from comments on Revision 0 (continued):
Moved references to supporting guidance from RG 1.253 to the 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
TICAP Comments 23
- Changes resulting from comments on Revision 1:
Affiliated staff positions with one of the following:
o PRA acceptability o Documentation needed in the SAR to demonstrate the acceptability of the CP PRA o Archival documentation needed to demonstrate the acceptability of the CP PRA Documenting essential assumptions in the PSAR Clarified the use of the term PRA Clarified that tables on supporting requirement applicability are not required Revised applicability of some supporting requirements
TICAP Comments 24
- 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
TICAP Comments 25
- Comments related to Revision 1 that are resolved with no changes:
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 the meaning 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 Out-of-scope comments
26 Advanced Reactor Content of Application Project Roadmap -
Overview and Discussion of Comments
ARCAP Roadmap Overview 27
- Provides guidance for other portions of the application outside of ISGs including emergency plan, security, financial qualification and insurance and liability
- Includes four appendices Appendix A - Preapplication Guidance Appendix B - Applicability of Regulations to non-light water reactors Appendix C - Construction Permit Guidance Appendix D - Draft Documents Under Development Additional Portions of Application
- Technical Specifications
- Technical Requirements Manual
- Quality Assurance Plan (design)
- Fire Protection Program (design)
- Quality Assurance Plan (construction and operations)
- Security Plan
- Cyber Security Plan
- SNM physical protection program
- SNM material control and accounting
- Fire Protection Program (operational)
- Radiation Protection Program
- Inservice inspection/Inservice testing (ISI/IST) Program
- Environmental Report and Site Redress Plan
- Financial Qualification and Insurance and Liability
- Fitness for Duty Program
- Aircraft Impact Assessment
- Performance Demonstration Requirements
- Nuclear Waste Policy Act
- Operational Programs
ARCAP Roadmap Comments 28
- 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.
ARCAP Roadmap Comments 29
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.
ARCAP Roadmap Comments 30 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.)
31 Advanced Reactor Content of Application Project Chapter 2 Site Information Overview and Discussion of Comments
Chapter 2 Overview 32
- 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.
Chapter 2 Comments 33
- Changes made because of comments:
Revised the frequency of occurrence of nearby industrial, transportation and military facility 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 comparative information on slope stability.
- Requested changes not incorporated:
Development of a standardized process for screening out external hazards
34 Advanced Reactor Content of Application Project Chapter 9 - Control of Effluents, Plant Contamination and Solid Waste Overview and Discussion of Comments
Chapter 9 Overview 35
- 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
Chapter 9 Comments 36 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
- Remove prescriptiveness; only reference industry standards
- Remove references to NEI template documents not previously formally endorsed but previously approved via safety evaluation
37 Advanced Reactor Content of Application Project Chapter 10 -
Occupational Dose Overview and Discussion of Comments
Chapter 10 Overview 38
- Applies a performance-based approach for level of detail of information provided in the SAR regarding the control of occupational dose
Chapter 10 Comments 39 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
40 Advanced Reactor Content of Application Project Chapter 11 Organization and Human Systems Interaction Overview and Discussion of Comments
Chapter 11 Overview 41
- 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
Chapter 11 Comments 42 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
43 Advanced Reactor Content of Application Project Chapter 12 - Post Construction Inspection Testing and Analysis Program Overview and Discussion of Comments
Chapter 12 Overview 44
- Intended to provide guidance to the NRC staff regarding application content that would support making the finding that the constructed plant has met the applicable Part 50 and Part 52 regulations to support issuance of an operating license or authorization to load fuel, respectively
- ISG differentiates between 10 CFR Part 52 applicants that must include inspections, tests, analyses and acceptance criteria (ITAAC) and 10 CFR Part 50 applications that are not required to include ITAAC.
- 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-manufacturing and 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).
Chapter 12 Comments 45 Changes made because of comments:
- Changed post-construction.. text to post-manufacturing and construction or just post-manufacturing if applicable
- Clarified text regarding pre-operational testing under a CP
- Removed specific reference to test review committee Requested changes not incorporated:
- Remove acceptance criteria that the commenter interpreted to go beyond 10 CFR Part 50
46 Advanced Reactor Content of Application Project Inservice Inspection/Inservice Testing Overview and Discussion of Comments
ARCAP ISI/IST Overview 47
- 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.
ARCAP ISI/IST Overview (continued) 48
- 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.
ARCAP ISI/IST Comments 49 Changes made because of comments:
- Allow the use of NQA-1 when implementing ASME BPV Code,Section XI, Division 2.
- 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.
ARCAP ISI/IST Comments 50 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.
51 Advanced Reactor Content of Application Project Technical Specifications Overview and Discussion of Comments
ARCAP Technical Specifications -
Overview 52 The text in the 10 CFR 50.36 regulations for TS content needs 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
ARCAP Technical Specifications Comments 53 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:
- Revise 10 CFR 50.36 to include criteria for non-LWRs
54 Advanced Reactor Content of Application Project Fire Protection for Operations Overview and Discussion of Comments
ARCAP Fire Protection for Operations-Overview 55
- 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.
ARCAP Fire Protection for Operations Comments 56 Changes made because of comments:
None Requested changes not incorporated:
Add reference to NEI 21-07 Remove statements that the commenter interpreted to be from draft Part 53 (planned) requirements Remove references to general design criteria Remove prescriptive guidance regarding fire protection program Delete clarifying text regarding acceptability of NFPA 805 Clarify relationship between PDC 3 and RG 1.232 Delete reference to RG 1.189 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 Add expectations for fire protection programs in CP applications Add endorsement of NFPA 804 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
Acronyms and Initialisms 57 ADAMS Agencywide Documents Access and Management System ANS American Nuclear Society AOO abnormal operating occurrence ASME American Society of Mechanical Engineers ARCAP Advanced Reactor Content of Applications ARCOP Advanced Reactor Construction Oversite Process BDBE beyond design-basis event CDC complementary design criteria CFR Code of Federal Regulations COL combined license CP construction permit DBA design-basis accident DBE design-basis event DBEHL design-basis event hazard level (NEI 18-04)
DBHL design-basis hazard level (NEI 21-07)
DC design certification DG draft regulatory guide DID defense in depth EAB exclusion area boundary FOAK first-of-a-kind FR Federal Register FSAR final safety analysis report GSI generic safety issue HFE human factors engineering ISG interim staff guidance ISI inservice inspection ISG inservice testing ITAAC inspections, tests, analyses and acceptance criteria LBE licensing basis event LCO limiting condition for operation LMP Licensing Modernization Project LPSD low-power and shutdown
Acronyms and Initialisms (continued) 58 ML manufacturing license NEI Nuclear Energy Institute NEIMA Nuclear Energy Innovation and Modernization Act NFPA National Fire Protection Association NLWR non-light-water reactor NPUF non-power utilization facility NSRST non-safety-related special treatment NST no special treatment OL operating license PDC principal design criteria POS plant operating state PRA probabilistic risk assessment PSAR preliminary safety analysis report RFDC required functional design criteria RG regulatory guide RSF required safety function SAR safety analysis report SDA standard design approval SE supplemental evaluation SR safety related SRM staff requirements memorandum SSC structure, system, and component TEDE total effective dose equivalent TICAP Technology-Inclusive Content of Applications TIRICE Technology-Inclusive, Risk Informed Change Evaluation TIMaSC Technology-Inclusive Management of Safety Case TS Technical Specification