ML22013B243

NRC Slides for January 18, 2022, Technology Inclusive Content of Application Project Public Meeting

ML22013B243
Person / Time
Issue date:	01/18/2022
From:	Joseph Sebrosky NRC/NRR/DANU/UARP
To:
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Download: ML22013B243 (18)

Text

Technology Inclusive Content of Application Project (TICAP) Public Meeting January 18, 2022 Microsoft Teams Meeting Bridgeline: 301-576-2978 Conference ID: 580 886 714#

Agenda Time Topic Speaker 10:00 - 10:10 am Opening Remarks NRC/Industry 10:10 - 11:10 am Discussion of TICAP* guidance related to Principal Design Industry Criteria 11:10 - 11:40 am Discussion of TICAP guidance related to safety analysis report NRC/Industry content for anticipated operational occurrences, design-basis events, and beyond-design-basis events 11:40 - 12:00 pm Stakeholder Questions All 12:00 - 1:00 pm Break All 1:00 - 2:30 pm Discussion of preliminary exceptions, clarifications and NRC/Industry additions 2:30 - 2:45 pm Stakeholder Questions All 2:45 - 3:00 pm Break (if needed) All 3:00 - 3:50 pm Continuation of discussion on TICAP guidance including staff NRC/Industry proposed changes to address industry comments 3:50 - 4:00 pm Next Steps and Closing Remarks NRC/Industry

• Note that Industry's TICAP guidance document Revision 0-B is available at:

https://www.nrc.gov/docs/ML2134/ML21343A292.pdf 2

TICAP Public Meeting

Purpose:

to discuss draft guidance for advanced reactor application safety analysis reports (SARs) using Nuclear Energy Institute (NEI) 18-04s Licensing Modernization Project (LMP)

• Key documents:

• NEI 21-07, Revision 0-B, Technology Inclusive Guidance for Non-Light Water Reactors; Safety Analysis Report Content for Applicants Using the NEI 18-04 Methodology (ML21343A292)

• NRC staff feedback on level of detail in the safety analysis report (SAR) for anticipated operational occurrences (AOOs), design-basis events (DBEs), beyond-design-basis events (BDBEs) with radiological consequences (ML22012A274)

• NRC preliminary exceptions, clarifications, and additions (ML22013B183)

• Additional background available on the NRC Advanced Reactor Content of Application Project (ARCAP)/TICAP public webpage (see:

https://www.nrc.gov/reactors/new-reactors/advanced/details.html#advRxContentAppProj) 3

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

• Technical Specifications

1. General Plant Information, Site

• Technical Requirements Manual Description, and Overview of the Safety

• Quality Assurance Plan (design)

Case

• Fire Protection Program (design)

2. Methodologies and Analyses

• Quality Assurance Plan

3. Licensing Basis Events (construction and operations)

4. Integrated Evaluations

• Emergency Plan

5. Safety Functions, Design Criteria, and

• Physical Security Plan Audit/inspection of Applicant Records SSC Safety Classification

• SNM physical protection program

• Calculations

6. Safety-Related SSC Criteria and

• SNM material control and

• Analyses Capabilities accounting plan

• P&IDs

7. Non-safety related with special treatment

• Cyber Security Plan

• System Descriptions SSC Criteria and Capabilities

• Design Drawings

• Fire Protection Program

8. Plant Programs

• Design Specs (operational)

• Procurement Specs

• Radiation Protection Program Additional SAR Content -Outside the Scope

• Probabilistic Risk Assessment

• Offsite Dose Calculation Manual of TICAP

• Inservice inspection/Inservice

9. Control of Routine Plant Radioactive testing (ISI/IST) Program Effluents, Plant Contamination, and Solid

• Environmental Report Waste

• Site Redress Plan

10. Control of Occupational Doses

• Exemptions, Departures, and

11. Organization and Human-System Variances Considerations

• Facility Safety Program (under

12. Post-construction Inspection, Testing and consideration for Part 53 Analysis Programs applications)

• Safety Analysis Report (SAR) structure based on clean sheet approach

• Additional contents of application outside of SAR are still under discussion. The above list is draft and for illustration purposes only. 4

Principal Design Criteria Industry Slides 5

Level of Detail in the SAR for AOOs, DBEs, and BDBEs

• Recent Discussions

• Issue is TICAP guidance for level of detail in the SAR for AOOs, DBEs, and BDBEs with radiological consequences

• Detailed discussions held during following meetings:

• October 5, 2021, public meeting (meeting summary ADAMS Accession No. ML21301A189)

• Staff provided preliminary exception and basis for exception

• November 9, 2021, public meeting (meeting summary ADAMS Accession No. ML21328A233)

• Industry provided response to staff proposed exception

• December 14, 2021, public meeting (meeting summary ADAMS Accession No. ML21354A833)

• Staff revised draft guidance, including additional thoughts on the issue (see attachment to Appendix B of December 2, 2021, TICAP draft RG white paper (ADAMS Accession No. ML21336A697) 6

Level of Detail in the SAR for AOOs, DBEs, and BDBEs

• Current Status

• Staff provided additional feedback in document dated January 12, 2022 (see ADAMS Accession No. ML22012A274) identifying two primary areas for further clarification:

1) Feedback regarding whether there is inconsistency between the Chapter 2 and Chapter 3 guidance of NEI 21-07, Revision 0 (ADAMS Accession No. ML21250A378)

2) Industry feedback relative to Chapter 3 guidance on SAR content for AOOs, DBEs, and BDBEs.

7

Level of Detail in the SAR for AOOs, DBEs, and BDBEs NEI 21-07 content consistency:

• NEI 21-07, Revision 0-B, Chapter 2 provides guidance on source term information to be included in the SAR that is generally consistent with the above position. However, Chapter 3 guidance appears to provide conflicting and inconsistent guidance, for instance:

• Details on the models, site characteristics, and supporting data associated with the calculation of mechanistic source terms and radiological consequences are part of the PRA [probabilistic risk assessment] documentation that is included in the plant records.

• The technical adequacy of the non-DBA [design-basis accident]

LBE analyses is therefore not based on the SAR documentation 8

Level of Detail in the SAR for AOOs, DBEs, and BDBEs SAR Content for AOOs, DBEs, and BDBEs:

• Staff provided additional references to support position that a SAR developed using the licensing modernization project (LMP)-based approach should contain the following information for AOOs, DBEs, and BDBEs with radiological consequences:

• Description of the models, site characteristics, and important supporting data associated with the calculation of the mechanistic source terms and radiological consequences.

9

Level of Detail in the SAR for AOOs, DBEs, and BDBEs SAR Content for AOOs, DBEs, and BDBEs - additional references:

• Regulatory Guide 1.203, Transient and Accident Analysis Methods, describes the level of documentation to allow the appraisal of the evaluation model (EM), including: EM requirements, EM methodology, code description manuals, user manual and user guidelines, scaling reports, assessment reports, and uncertainty analysis reports.

• Xe-100 TICAP Tabletop exercise report dated August 2021 (ADAMS Accession No. ML21217A086)

• Section 4.1, Safety Analysis Details, references RG 1.203 and notes that elements of RG 1.203 would be best placed in TICAP Chapter 2 or other licensing basis event chapters.

10

Level of Detail in the SAR for AOOs, DBEs, and BDBEs SAR content for AOOs, DBEs, and BDBEs - additional references:

• Draft proposal on how an applicant might capture important information using a topical report

• Provides reference to mechanistic source term methodology topical report that the staff is currently reviewing

• Similar topical report approaches with a different scope and different information could also be used

• Provides an example of key analysis assumptions that staff expects to be captured in the SAR 11

Level of Detail in the SAR for AOOs, DBEs, and BDBEs SAR content for AOOs, DBEs, and BDBEs - additional references:

• Previous example of staff comments included in an August 13, 2021, email (ADAMS Accession No. ML21225A565)

• References DBE with radiological consequence SAR content found in Appendix B of draft industry TICAP guidance document

• Includes comments relative to additional SAR content:

• Settings of protection system functions, structure, system and component (SSC) performance assumed in the analysis

• Discussion of how Chapter 2 dose methodology would be captured in the SAR 12

Level of Detail in the SAR for AOOs, DBEs, and BDBEs SAR Content for AOOs, DBEs, and BDBEs - additional references:

• Highlights NEI 21-07 Chapter 3 guidance that includes references to key plant parameters being captured in the SAR

• Staff expectation that this would include such items as flow rates, temperatures, pressures and trip setpoints used in AOO, DBE and BDBE evaluations 13

Level of Detail in the SAR for AOOs, DBEs, and BDBEs SAR content for AOOs, DBEs, and BDBEs - additional references:

• Regulatory Guide 1.233, Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology To Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light-Water Reactors, page 24 provides guidance:

• Analysis of AOOs, DBE, and BDBEs plays an important role in defining safety functions, classifying SSCs, and assessing defense-in-depth

• Suggests such information could be included in old SAR structure chapter 19, chapter 15, or a new chapter created to include the analysis of AOOs, DBEs, and BDBEs 14

NRC Draft Preliminary Exceptions, Clarifications and Additions

• Original NRC preliminary exceptions, clarifications, and additions (ML21274A032) discussed in November 9, and December 14, 2021, public meetings

• Staff updated NRC preliminary exceptions, clarification and additions provided in document dated January 13, 2022 (ML22013B183)

• Includes column with proposed disposition based on:

• Changes either identified in NEI 21-07, Revision 0-B, or staff TICAP Draft RG white paper dated December 2, 2021 (ML21336A697)

• Staff position revisited based on feedback from industry during December 14, 2021, public meeting

• PDC and level of detail in the SAR for AOO, DBE, and BDBE disposition to be determined 15

NRC Draft Preliminary Exceptions, Clarifications and Additions

• Staff updated NRC preliminary exceptions, clarification and additions provided in document dated January 13, 2022

• Potential Discussion topics:

• Item 2a - pre-licensing engagement

• Industry feedback on proposed staff resolution that separate licensing documents (e.g., topical reports) submitted during pre-licensing submittals as well as during application review may reduce the information that needs to be included in the SAR if incorporated by reference

• Item 4.2.3b - defense in depth

• Industry feedback on whether changes will be made to NEI 21-07 to address issue or issue will be address in TICAP DG 16

NRC Draft Preliminary Exceptions, Clarifications and Additions

• Staff updated NRC preliminary exceptions, clarification and additions provided in document dated January 13, 2022

• Potential Discussion topics (continued):

• Items 4.2.2.2 and 4.2.2.3 - Human Factors Engineering (HFE)

• Industry feedback on staffs position to reference ARCAP Chapter 11 interim staff guidance to ensure holistic approach to HFE program

• Other Questions/Comments on January 13, 2022, updated table 17

Next Steps

• Staff reviewing Industry Feedback on December 2, 2021, Draft TICAP White Paper (see: ML21356A009 and ML21356A008)

• Expectation that NEI 21-07, Revision 1, will include changes relative to PDC issue and possibly AOO, DBE, and BDBE issue discussed in this meeting

• Timeframe for NEI 21-07, Revision 1, submittal to be determined

• Staff will update TICAP RG based on NEI 21-07, Revision 1

• Timeframe for issuance of draft TICAP RG for public comment to be determined

• Staff intends to issue draft Advanced Reactor Content of Application Project (ARCAP) interim staff guidance documents for public comment concurrent with draft TICAP RG

• Briefing of Advisory Committee on Reactor Safeguards (ACRS) on draft documents to be determined 18