ML21244A005

Oklo Slides - Pb Mca TR Public Meeting - 9-1-21

ML21244A005
Person / Time
Site:	05200049
Issue date:	09/01/2021
From:	Oklo Inc
To:	Office of Nuclear Reactor Regulation
Mazza, Jan
References
Download: ML21244A005 (16)

Text

Public Meeting on Oklo Topical Reports September 1, 2021

MCA and Performance-based Licensing Topical Reports Why are they important?

• Articulate the methodologies used by Oklo in developing the licensing basis for its reactor designs

• Offer an alternative licensing approach to the current approaches being considered for Part 53

• Represent a technology-inclusive, risk-informed performance-based licensing methodology, available for use by any advanced reactor developer, to enable broader deployment as directed by NEIMA

MCA and Performance-based Licensing Topical Reports What do they do?

• Focus on the requirements for assuring adequate protection, rather than regulatory guidance developed for other technologies

• Utilize iterative processes to simplify the design, with preferential use of inherent features and passive systems over complex, active systems

• Clearly demonstrate safety significant functions and features of the design and how to apply the necessary controls to ensure their reliability

MCA and Performance-based Licensing Topical Reports Current status?

• Oklo submitted both topical reports to the NRC on 7/2/2021

• NRC staff performed completeness review and identified supplemental information to support review of both topical reports

• Oklo/NRC discussion through public meetings on the identified supplemental information and proposed resolution of NRC staff comments

Maximum Credible Accident Topical Report

• Certain design interfaces outlined in comment IV are comparable to the requirements imposed in 10 CFR Appendix B for design and documentation. Therefore, implementation of this topical report by an entity with an NRC approved QA plan should be sufficient to meet the comment provided.

• Proposed revision language: Application of this methodology is intended to be performed by those with an NRC approved quality assurance program for design.

Performance-based Licensing Topical Report

• Section 4.4, provides for a systematic approach to classifying functions and features.

• Section 4.6, describes how quality assurance is then specifically applied to SSCs.

• It is unclear what specific information the NRC is requesting be supplemented based on the requirements articulated in 10 CFR 50.34(f)(3) and 10 CFR Part 50, Appendix B, Criterion II.

Performance-based Licensing Topical Report

• Section 4.4, provides for a systematic approach to classifying functions and features.

Performance-based Licensing Topical Report

• Section 4.6, describes how quality assurance is then specifically applied to SSCs.

Performance-based Licensing Topical Report

• 10 CFR 50.34(f), Additional TMI-related requirements, paragraph (3)(ii) states:

• (ii) Ensure that the quality assurance (QA) list required by Criterion II, app. B, 10 CFR part 50 includes all structures, systems, and components important to safety. (I.F.1)

• It is unclear what specific information the NRC is requesting be supplemented based on the requirements articulated in 10 CFR 50.34(f)(3) and 10 CFR Part 50, Appendix B, Criterion II.

Performance-based Licensing Topical Report

• The topical report comprehensively discusses the 10 CFR 50.2 definition of safety-related and the technology-specific nature of items (1) and (2).

• Could the staff elaborate on both the technical and regulatory basis for the inclusion of the material requested in I.D.1?

Performance-based Licensing Topical Report

• Could the staff elaborate on the regulatory basis to support the supplemental material requested in I.D.2?

Performance-based Licensing Topical Report

• Can the staff clarify what is meant by uncertainty in selecting licensing basis events?

Performance-based Licensing Topical Report

• Could the staff elaborate on the specific Commission policy referenced in this comment and its associated regulatory basis?

Performance-based Licensing Topical Report

• In development of the topical report, Oklo did not identify any exemptions that must be requested to support licensing under this methodology. Could the staff clarify the comment on exemptions that might be necessary?

Performance-based Licensing Topical Report

• Oklos methodology describes a process for identifying what functions and features require programmatic controls, but does not prescribe the programmatic controls, only that they should be justified based on the safety basis of the function or feature.

• This should be a design-specific selection that allows for flexibility in demonstrating the necessary requirements for safety-related and important to safety equipment are met.

Questions?