ML23093A099
| ML23093A099 | |
| Person / Time | |
|---|---|
| Issue date: | 05/15/2023 |
| From: | Steven Lynch NRC/NRR/DANU/UARP |
| To: | |
| Sebrosky J | |
| Shared Package | |
| ML22048A520 | List: |
| References | |
| Download: ML23093A099 (3) | |
Text
REGULATORY ANALYSIS
ADVANCED REACTOR CONTENT OF APPLICATION PROJECT INTERIM STAFF GUIDANCE DOCUMENTS
- 1. Statement of the Problem
The U.S. Nuclear Regulatory Commission (NRC) is considering iss uing new advanced reactor content of application project (ARCAP) interim staff gu idance (ISGs) documents to provide guidance to designers, applicants, and licensees for no n-light water reactors (non-LWRs), for developing applications following the Licensing Mode rnization Project (LMP) process. The ARCAP ISGs also provide guidance to the NRC staff for the review of such applications. The proposed guidance will facilitate the develop ment and review of non-LWR applications for construction permits (CPs) or operating licens es (OLs) under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensi ng of Production and Utilization Facilities (Ref. 1), or for combined licenses (COL s), manufacturing licenses (MLs),
standard design approval (SDAs), or design certifications (DCs) under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plan ts The NRC staff intends to revise this proposed guidance as a part of the ongoing rulemaki ng for 10 CFR Part 53, Licensing and Regulation of Advanced Nuclear Reactors (RIN 31 50 AK31).
To standardize the development of content within a non-LWR appl ication, the NRC staff focused on two activities: the Advanced Reactor Content of App lication Project (ARCAP) and the Technology-Inclusive Content of Application Project (TICAP). The ARCAP is an NRC-led activity that is intended to result in guidance for a complete non-LWR application for review under 10 CFR Part 50 or 10 CFR Part 52, and which the staff wou ld update if the Commission issues a final 10 CFR Part 53 rule. As a result, the ARCAP is b road and encompasses several industry-led, and NRC-led guidanc e document development activities aimed at facilitating a consistent approach to the development of application documents.
The TICAP is an industry-led activity that is focused on provid ing guidance on the appropriate scope and depth of information related to the speci fic portions of the safety analysis report that describe the fundamental safety functions of the de sign and documents the safety analysis of the facility using the LMP-based approach. The LMP-based approach is described in RG 1.233, Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applic ations for Licenses, Certifications, and Approvals for Non-Light-Water Reactors.
The following table provides the proposed ARCAP ISGs:
Document Description ADAMS Accession No.
Draft Interim Staff Guidance DANU-ISG-2022-01 Advanced ML22048B546 Reactor Content of Application Project, Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications
- Roadmap.
Draft Interim Staff Guidance DANU-ISG-2022-02, Advanced ML22048B541 Reactor Content of Application Project Chapter 2, Site Information.
Document Description ADAMS Accession No.
Draft Interim Staff Guidance DANU-ISG-2022-03, Advanced ML22048B543 Reactor Content of Application Project Chapter 9, Control of Routine Plant Radioactive Effluents, Plant Contamination and Solid Waste.
Draft Interim Staff Guidance DANU-ISG-2022-04, Advanced ML22048B544 Reactor Content of Application Project Chapter 10, Control of Occupational Dose.
Draft Interim Staff Guidance DANU-ISG-2022-05, Advanced ML22048B542 Reactor Content of Application Project Chapter 11, Organizatio n and Human-System Considerations.
Draft Interim Staff Guidance DANU-ISG-2022-06, Advanced ML22048B545 Reactor Content of Application Project Chapter 12, Post-Construction Inspection, Testing, and Analysis Program.
Draft Interim Staff Guidance DANU-ISG-2022-07, Advanced ML22048B549 Reactor Content of Application Project, Risk-informed Inservic e Inspection/Inservice Testing.
Draft Interim Staff Guidance DANU-ISG-2022-08, Advanced ML22048B548 Reactor Content of Application Project, Risk-Informed Technica l Specifications.
Draft Interim Staff Guidance DANU-ISG-2022-09, Advanced ML22048B547 Reactor Content of Application Project, Risk-informed Performance-based Fire Protection Program (for Operations).
- 2. Objective
The objective of this regulatory action is to provide guidance on using a technology-inclusive, risk-informed, and performance-based methodology to inform the licensing basis and content of applications for licenses, certifications, and appro vals for non-LWRs required by 10 CFR Parts 50 and 52. The NRC staff intends to revise this gu idance as a part of the ongoing rulemaking for 10 CFR Part 53.
- 3. Alternative Approaches
The NRC staff considered the following alternative approaches:
- 1. Do not develop ARCAP ISGs described in the table above
- 2. Develop the ARCAP ISGs described in the table above
Alternative 1: Do not develop ARCAP ISGs described in the tabl e above
Under this alternative, the NRC staff would not develop the AR CAP ISGs, and the current guidance, which was developed for large light-water rea ctor (LWR) designs, would be retained. This alternative is considered the no-action alter native and provides a baseline condition from which any other alternatives will be assessed. T he no-action alternative would not address how the current large LWR-focused guidance could be adapted to address the unique design features related to non-LWR technologies or the L MP methodology. Each applicant for a non-LWR design or facility would prepare applic ations independent of guidance and the NRC would review each application on a case-by-case bas is, which would extend the
Page 2 time required to prepare and review each application and potent ially result in increased costs and delays in licensing non-LWRs following the LMP methodology.
Alternative 2: Develop the ARCAP ISGs described in the table a bove
Under this alternative, the NRC would develop the ARCAP ISGs de scribed in the table above. This initial issuance would provide designers, applicant s, and licensees of non-LWRs using the LMP methodology with guidance that is risk-informed, technology-inclusive and performance-based and would include guidance for identifying li censing basis events; classifying structures, systems, and components (SSCs) and thei r performance criteria; and assessing defense-in-depth to support applications submitted un der 10 CFR Parts 50 and 52.
The ARCAP ISGs would also provide guidance for the NRC staff re view of such applications and would be used to inform guidance development for the 10 CFR Part 53 rulemaking. By doing so, the NRC would ensure th at the guidance available in this area is current and accurately reflects the NRC staffs position.
The impact to the NRC would be the costs associated with preparing and issuing the new regulatory guidance for non-LWR designs using the LMP metho dology that is risk-informed, technology-inclusive, and performance-based. The impact to the public would be the voluntary costs associated with reviewing and providing comments to NRC d uring the public comment period. The value to NRC staff and its applicants would be the benefits associated with enhanced efficiency and effectiveness in using common guidance documents as the technical basis for license applications and other interactions between t he NRC and its regulated entities.
The costs to applicants and licensees of implementing the revis ed guidance are justified by the benefits accrued with the use of a guidance document that is ri sk-informed, technology-inclusive, and performance-based that can be used to develop no n-LWR applications that are different than the large LWR reactors on which the current guid ance is based. Further, the NRC staff anticipates that the revised guidance would streamline th e NRC staffs review of non-LWR applications (i.e., relative to a case-by-case basis review due to no guidance or outdated guidance) and therefore result in the least-cost alternative fo r reviewing non-LWR applications.
Conclusion
Based on this regulatory analysis, the NRC staff concludes that issuance of the ARCAP ISGs is warranted. The action will enhance the ability of non-L WR designers, applicants, and future licensees using the LMP methodology to prepare applicati ons for their new, innovative, and non-LWR based designs. The guidance could also lead to cost savings for the industry and time savings for the NRC staff, especially regarding the develo pment or review of an application for a CP, OL, DC, COL, SDA, or ML associated with an non-LWR de sign.
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