ML25231A013
| ML25231A013 | |
| Person / Time | |
|---|---|
| Site: | 99902049 |
| Issue date: | 08/21/2025 |
| From: | Victoria Huckabay, Jardaneh M NRC/NRR/DNRL/NLIB |
| To: | Fleming J Holtec |
| References | |
| Download: ML25231A013 (1) | |
Text
Jean Fleming, Vice President Licensing, Regulatory Affairs, & PSA Holtec International 1 Holtec Boulevard Camden, NJ 08104
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION STAFFS FEEDBACK ON SMR, LLC (A HOLTEC INTERNATIONAL COMPANY) PLANNED LIMITED WORK AUTHORIZATION APPLICATION CONTENTS
Dear Ms. Fleming:
By letter dated September 6, 2024, SMR, LLC (SMR), a Holtec International Company (Holtec),
submitted a letter and enclosure describing its planned limited work authorization (LWA) application contents and exemption requests.1, 2 The U.S. Nuclear Regulatory Commission (NRC) staff has previously provided feedback on the planned LWA requests by letter dated August 1, 2025.3 This letter provides feedback on the LWA application contents as discussed in Section 5 of Enclosure 1 to SMR (Holtec)s letter.
In Enclosure 1 to the letter, SMR (Holtec) stated that it developed a plan for the preliminary safety analysis report (PSAR) content that is consistent with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.10(d)(3)(i) and 10 CFR 50.34(a) and meets the guidance in Regulatory Guide (RG) 1.70, Revision 3, NUREG-0800, and DNRL-ISG-2022-01. SMR (Holtec) stated that it plans to develop the LWA PSAR content to reflect only those portions of the facility that will be included in the LWA and identified the specific sections that will be included in the PSAR.
SMR (Holtec) provided a listing of the PSAR sections that it plans to include in the LWA PSAR in Table II, to include the following:
1 Letter from J. Flemming to US NRC, Planned SMR-300 LWA Exemption Requests and LWA Application Contents (Project No. 99902049), dated September 6, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24250A155, part of package ML24250A154).
2 SMR, LLC, Enclosure 1, Planned SMR-300 LWA Exemption Requests and LWA Application Contents, dated September 6, 2024 (ML24250A160, part of package ML24250A154). (Non-publicly available).
3 Letter from NRC to J. Fleming, U.S. Nuclear Regulatory Commission Staffs Feedback on SMR, LLC (A Holtec International Company) Letter Regarding Its Planned SMR-300 LWA Exemption Requests and LWA Application Contents, dated August 1, 2025 (ML25168A028).
August 21, 2025
J. Fleming 2
Chapter 1, Introduction Chapter 2, Site Characteristics and Site Parameters Chapter 3, Design of Structures, Systems, and Components (SSCs)
Chapter 8, Electrical Power Chapter 9, Auxiliary Systems Chapter 10, Steam and Power Conversion System Chapter 11, Radiological Waste Management Chapter 13, Conduct of Operations Chapter 17, Quality Assurance The NRC staff is offering the following observations regarding the planned LWA PSAR contents:
In Section 5.2.1.1 of Enclosure 1 to the letter, SMR (Holtec) acknowledged that loading from supported structures within the scope of the LWA is an important part of the planned LWA Chapter 3 information for the design of foundations, it expressed a view that a description and analysis of the supported structures would not be appropriate in a PSAR for an LWA submitted as the first part of a two-part CP application. SMR (Holtec) further states it plans to provide a description of the load combinations that will be considered and specify the acceptance criteria that will be used in the evaluation. However, SMR (Holtec) does not plan to provide results of evaluation of each of the loadings in the LWA PSAR or make them available to the NRC during the LWA application review. It is not clear how SMR (Holtec) plans to demonstrate that all loadings on the foundations within the scope of the LWA were appropriately considered and included, and the foundation design including the subsurface (LWA PSAR Section 2.5) would be able to sustain the loads applied without undergoing undesirable (beyond allowable) settlements, absent the results of the evaluation being included in the application. Absent sufficient information, the staff may not be able to make findings that the design of the foundations within the scope of the LWA meets the relevant requirements on Appendix A to 10 CFR Part 50 and 10 CFR 50.55a.
In Section 5.2.2 of Enclosure 1 to the letter, SMR (Holtec) stated that it commits to performing geologic mapping of the excavations consistent with the recommendations of RG 1.132. The NRC staff points out that this mapping should be completed before any foundation-related activities starts (e.g., before placing any mudmat or concrete, etc.)
covering the geologic features exposed in the excavation. The NRC staff assumes that the excavation will reach the competent rock layers beneath the foundation and geologic features (e.g., joints and bedding planes) to be mapped that are part of the existing rock mass. Consequently, the selected method(s) to estimate the bearing capacity of the foundation and the associated settlement should be appropriate for the fractured rock mass.
In Section 5.4 of Enclosure 1 to the letter, SMR (Holtec) states that the general approach described in Section 5.1 would be used for describing the contents of the LWA PSAR applicable to the planned Exemption Request #2 (construction of containment structure walls to the grade). The NRC staff points out that the estimation of loads on the walls should include lateral pressure exerted by the surrounding media and seismicity.
The selected method(s) to estimate the lateral pressure should be appropriate for the site subsurface conditions.
J. Fleming 3
In Table III of Enclosure 1 to the letter, SMR (Holtec) indicated within Chapter 2 of the LWA PSAR, it plans to include Sections 2.1, Geography and Demography, and 2.5, Geology, Seismology, and Geotechnical Engineering. The NRC staff observed that the planned contents for Chapter 2 of the LWA PSAR do not include Section 2.3 (addressing the discussion of climatology and meteorology) and Section 2.4 (hydrology).
However, in Section 5.2.2 of Enclosure 1 to the letter, SMR (Holtec) stated that it plans to include a description of the stability of subsurface materials and foundations and a discussion of groundwater conditions as they affect the loading, stability, and durability of foundation materials in PSAR Section 2.5.4. The NRC staff notes that, for example, major hydrological features in the site vicinity may have significant impacts on the safety of foundations of buildings that SMR (Holtec) plans to include in the scope of the LWA.
Similarly, extreme climatic conditions and regional meteorological phenomena that could affect the site may need to be considered within the scope of the LWA. The NRC staff emphasizes the importance of appropriately addressing these topics within the scope of the LWA PSAR to the extent that they apply to the scope of the LWA and associated exemptions.
In addition to the PSAR, SMR (Holtec) identified other portions of the planned LWA application, which would include an environmental report, a Quality Assurance Program Description, and a site redress plan. SMR (Holtec) indicated that it does not plan to include technical specifications, an emergency plan, and security plans in the LWA application. The NRC staff has not identified any major issues with the proposed approach to structuring the LWA application as shown in Table II of Enclosure 1 to SMR (Holtec)s letter.
If you have questions regarding this matter, please contact Victoria Huckabay at (301) 415-5183 or via email at Victoria.Huckabay@nrc.gov.
Sincerely, Mahmoud Jardaneh, Chief Licensing and Regulatory Infrastructure Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket No. 99902049 cc: K. Trice (SMR, LLC)
Signed by Jardaneh, Mahmoud on 08/21/25
ML25231A013 NRR-106 OFFICE NRR/DNRL/NLIB: PM NRR/DNRL/NLIB: LA NRR/DNRL/NLIB: BC NAME VHuckabay SGreen MJardaneh DATE 08/20/2025 08/20/2025