ML23277A151

Analysis of Public Comments on Draft DANU-ISG-2022-04, Advanced Reactor Content of Application Project Chapter 10, Control of Occupational Dose

ML23277A151
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Issue date:	03/25/2024
From:	NRC/NRR/DANU/UARP
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ML23277A105	List: ML23277A139 ML23277A140 ML23277A141 ML23277A142 ML23277A143 ML23277A144 ML23277A145 ML23277A146 ML23277A147 ML23277A148 ML23277A149 ML23277A150 ML23277A151 ML23277A152 ML23277A153 ML23277A154 ML23277A155 ML23277A156 ML23277A225 ML23277A226 ML23277A227 ML23277A228 ML23277A229 ML23277A230 ML23277A231 ML23277A232 ML23277A233 ML23297A158 ML23297A159 ML23297A160 ML23297A161 ML23297A162 ML23297A163 ML23297A164 ML23297A165 ML23297A166
References
DANU-ISG-2022-04, NRC-2022-0077, ML23277A105
Download: ML23277A151 (2)

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1 Analysis of Public Comments on Draft DANU-ISG-2022-04 Advanced Reactor Content of Application Project Chapter 10, Control of Occupational Dose Comments on the draft interim staff guidance (ISG) are available electronically at http://www.nrc.gov/reading-rm/adams.html. From this page, the public can access the Agencywide Documents Access and Management System (ADAMS), which provides text and image files of the U. S. Nuclear Regulatory Commission (NRC) public documents. The following table lists the comments the NRC received on the draft ISG.

Comment Number ADAMS Accession Number Commenter Affiliation Commenter Name NRC-2022-0074-DRAFT-0006 ML23229A120 Nuclear Energy Institute Ben Holtzman Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response RC-2022 0074-DRAFT-0006-1 General General Please rephrase to indicate the guidance is technology-inclusive and is equally applicable to both LWR and non-LWR designs.

Throughout all the documents of the package, there are statements that this guidance is applicable to nonLight Water Reactors (LWRs). However, all the guidance is technology-inclusive and is equally applicable to LWRs.

ARCAP is supposed to be applicable for any technology (non-LWR and LWR), any licensing approach (LMP, classical, etc.), and any licensing path (CP, COL, DC etc.).

For the ARCAP guidance, industry specifically requested the NRC develop guidance applicable to both non-LWRs and LWR SMRs, and we were informed in various meetings that this would be the NRCs approach. While NEI 18-04 and NEI 21-07 were developed specifically for advanced non-LWRs, applicants with LWR designs should also be able to use the Licensing Modernization Project (LMP) methodology if they elect to do so (e.g., NEI 18-04 and NEI 21-07). It would be up to the applicants to justify the use of the guidance documents and associated regulatory guides.

The NRC staff disagrees with the comment.

The NRC staff is considering expanding the applicability of ARCAP guidance documents beyond non-light water reactors (non-LWRs).

However, expansion of the guidance beyond non-LWRs at this time is considered premature.

The final ISG continues to note that the NRC is developing an optional performance-based, technology-inclusive regulatory framework for licensing nuclear power plants designated as 10 CFR Part 53, Licensing and Regulation of Advanced Nuclear Reactors, (RIN 3150-AK31). If the NRC promulgates a final 10 CFR Part 53 rule, the NRC staff plans to apply the 10 CFR Part 53 guidance to both LWRs and non-LWRs. Should the 10 CFR Part 53 rulemaking include requirements for both LWR and non-LWRs, the NRC staff envisions that the guidance documents supporting that rulemaking would provide a basis to expand the concepts found in the ARCAP ISGs guidance beyond non-LWRs. In the interim, the NRC staff notes that the applicability section of the ISG notes that applicants desiring to use the ISG for a light water reactor application should contact the NRC staff to hold pre-application discussions on their proposed approach.

No change to this ISG.

2 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response NRC-2022-0074 DRAFT -

14 As low as reasonably achievable ARCAP Roadmap ISG and ARCAP ISG Chapter 10 The following comment was submitted on the ARCAP roadmap ISG regarding ALARA. The specific comment is; The wording on ALARA in Chapter 10 indicates that the guidance will continue the well-established operational program for ALARA but not extend ALARA into the design, as a regulatory requirement. Industry agrees with this position as it provides a predictable regulatory framework.

The NRC staff disagrees with the comments characterization of the guidance in ISG Chapter 10. The guidance references design elements to control occupational exposures in several instances and includes the following acceptance criteria:

Describe important equipment and facility design features that satisfy the design-specific PDC necessary to control occupational exposure, including ensuring occupational radiation exposures are ALARA, such as shielding, ventilation, area radiation and airborne radioactivity monitoring instrumentation, and dose assessment for expected occupancy.

To further clarify the relationship between radiation protection programs and DANU-ISG-2022-04, the staff added reference to NEI 07-03A, Generic FSAR Template Guidance for Radiation Protection Program Description, which should be used in conjunction with the template in NEI-07-08A, Generic FSAR Template Guidance for Ensuring that Occupational Radiation Exposures are as Low as is Reasonably Achievable (ALARA), which is referenced in this ISG.

The NEI templates and related NRC safety evaluations discuss the relationships between various design features, some of which might be in a design-centered application (e.g., design certification) and some of which might be deferred to a combined license application, and programmatic controls developed for plant operations.