ML23355A235
| ML23355A235 | |
| Person / Time | |
|---|---|
| Site: | 99900003 |
| Issue date: | 10/02/2023 |
| From: | Stephen Philpott NRC/NRR/DANU/UAL2 |
| To: | Hayes M NRC/NRR/DNRL/NLIB |
| References | |
| Download: ML23355A235 (1) | |
Text
Readiness Assessment GEH BWRX-300 Safety Strategy Draft Topical Report NRC Staff Preliminary Feedback October 2, 2023 1
Background and Purpose GEH developed the safety strategy to systematically incorporate defense-in-depth into their safety design basis using a defense line architecture based on selected guidance from the International Atomic Energy Agency (IAEA) and to determine the safety category of Structures Systems and Components (SSCs).
GEH began engaging with the NRC staff on this approach in June 2022 o June 29, 2022, public meeting (ML22215A081) o August 5, 2022, non-public Page Turn meeting with subsequent feedback (ML22263A294) o BWRX-300 Safety Strategy white paper submitted on December 7, 2022 (ML22341A058) o December 14, 2022, public meeting - NRC feedback on the white paper (ML23023A142) o Pre-submittal meetings with GEH held on March 8 and April 5, 2023. The NRC staffs feedback is summarized in the meeting summary available at ADAMS Accession No. ML23087A077.
While the concept has remained the same, aspects of the implementation have evolved.
NRC staff began a readiness assessment of a draft topical report (TR) on July 26, 2023.
o Draft TR (GEH Proprietary) was shared with the NRC staff via electronic reading room.
Purpose of the Readiness Assessment: to identify any major issues or information gaps between the draft TR and technical content expected to be included in the submitted TR.
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Key Messages
- The NRC staff recognizes that the GEH Safety Strategy methodology uses a risk-informed approach that aligns closely with international safety standards. While the NRC staff is certainly open to efforts to align with international frameworks and believes the safety strategy could be acceptable under 10 CFR Part 50, GEH and any applicants will need to demonstrate compliance with 10 CFR Part 50 requirements or address differences between the safety strategy and those requirements.
- In several cases, it remains unclear how the safety strategy will address previous feedback from the NRC staff and meet specific 10 CFR Part 50 requirements.
- The NRC staff suggests providing clarity as to how an applicant would use the framework described in NEDC-33934P to demonstrate consistency with relevant regulatory guidance, or otherwise demonstrate compliance with the applicable regulatory requirements set forth in 10 CFR Part 50.
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