ML21245A442
| ML21245A442 | |
| Person / Time | |
|---|---|
| Issue date: | 09/08/2021 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | John Segala NRC/NRR/DANU/UARP |
| Sebrosky J | |
| References | |
| Download: ML21245A442 (6) | |
Text
September 8, 2021 MEMORANDUM TO: John P. Segala, Chief Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Signed by Sebrosky, Joseph on 09/08/21 FROM: Joseph M. Sebrosky, Senior Project Manager Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF AUGUST 17, 2021, PUBLIC MEETING TO DISCUSS TECHNOLOGY INCLUSIVE CONTENT OF APPLICATION PROJECT On August 17, 2021, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting with stakeholders, to discuss the technology inclusive content of application project (TICAP). The meeting notice is available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML21228A117, and the presentation slides are available at ADAMS Accession No. ML21228A039. The enclosure to this summary provides the attendees for the meeting as captured by Microsoft Teams.
The purpose of this meeting was to discuss with the nuclear industry issues related to the draft TICAP guidance document dated August 3, 2021, for Safety Analysis Report content for an advanced reactor application based on the licensing modernization project. The August 3, 2021, draft TICAP guidance document is available in ADAMS at Accession No. ML21215A577. The August 17, 2021, meeting was a follow-on meeting to public TICAP meetings held on:
May 11, 2021 (meeting summary available in ADAMS at Accession No. ML21132A295)
May 19, 2021 (meeting summary available in ADAMS at Accession No. ML21154A290)
May 26, 2021 (meeting summary available in ADAMS at Accession No. ML21158A223)
June 23, 2021 (meeting summary available in ADAMS at Accession No. ML21181A335)
The four TICAP meetings described above led to industry revising the previous version of the TICAP guidance document and providing the NRC staff with the August 3, 2021, version of the document. Prior to the August 17, 2021, meeting, the NRC staff provided industry with a marked-up version of the August 3, 2021, industry TICAP guidance document that identified questions and comments associated with industrys document. The NRC staffs marked-up CONTACT: Joseph Sebrosky, NRR/DANU
J. Segala 2 301-4151132 version of industrys TICAP guidance document is available in ADAMS at Accession No. ML21225A565. The NRC staff identified more significant comments by highlighting them in yellow in the marked-up version of the document.
The meeting was broken into two parts: a discussion of guidance associated with principal design criteria (PDC), and a discussion of NRC staff significant comments other than those associated with principal design criteria.
Principal Design Criteria Guidance associated with developing PDC using an LMP-based approach was a topic of discussion during previous TICAP meetings. Prior to the August 17, 2021, meeting, industry provided a paper dated July 30, 2021, titled, Technology Inclusive Content of Application Project (TICAP) Proposal for Non-LWR Principal Design Criteria White Paper, (ADAMS Accession No. ML21214A008).
The staff reiterated some of its concerns stated in previous meetings including the underlying concern that industrys approach may not identify PDC associated with normal operations and areas associated with proposed special treatments (e.g., quality assurance, protection from external hazards, testability, inspectability). The staff questioned whether industry would consider adjusting their proposed guidance to reference complimentary design criteria (CDC) to address these areas.
Industrys position remained the same as stated in previous meetings. That is, that the LMP-based safety case provides a more focused performance basis for a facilitys safety based on the specifics of the unique design and that it will provide the same type of information included in the description of PDC in the introductory text of Title 10 of the Code of Federal Regulations (CFR) Part 50 Appendix A in other elements of a SAR developed using the LMP. Industry stated that it did not intend to make changes to the PDC guidance in the next update to the TICAP guidance document.
The staff stated that it would consider industrys position and noted that it would document its position in the next update to the draft TICAP RG white paper. The staff indicated that the possible options included:
The LMP-based approach provides an acceptable approach for identifying PDC associated with off-normal conditions.
The staff will review the proposed treatment of areas such as normal operations and identify if PDCs, as well as proposed CDCs are appropriate to address the staffs concerns.
The LMP-based approach cannot be reconciled with the current PDC framework und 10 CFR Part 50 and 52, and an exemption may be required.
Other Comments The NRC staff and industry then discussed the comments that were identified in the marked-up version of the document provided to industry prior to the meeting. In some cases, industry
J. Segala 3 indicated that it would be making changes to address the underlying comment. In other cases, industry indicated it would not be making changes. The staff stated that it would review industrys revised guidance and determine whether to identify exceptions or clarifications in the staffs draft guidance referencing industrys guidance document. The staff noted that in two areas (i.e., amount of defense-in-depth analysis that is captured in the safety analysis report, and the treatment of internal hazards such as fire or flood) industrys guidance appeared to deviate from the guidance found in NEI 18-04, Revision 1, Risk-Informed Performance-Based Technology Inclusive Guidance for Non-Light Water Reactor Licensing Basis Development, (ADAMS Accession No. ML19241A472) as endorsed by the NRC in Regulatory Guide 1.233.
After the meeting industry stated that it did not intend for the TICAP guidance to deviate from the LMP process described in NEI 18-04, revision 1 as endorsed by the NRC.
The meeting concluded with a discussion of the schedule for development of TICAP guidance documents. Highlights of this discussion included industry providing a revision to the August 3, 2021, TICAP guidance document by the end of August 2021 in an NEI Revision 0 format. The staff stated that it would review NEI Revision 0 of the guidance document and update the July 8, 2021, version of its draft TICAP regulatory guide white paper (ADAMS Accession No. ML21190A014) sometime in the October 2021 time frame with a proposed briefing of the Advisory Committee on Reactor Safeguards Future Plant Designs Subcommittee possibly sometime in the November time frame. The NRC staff and industry agreed that a public meeting in late September 2021, on industrys TICAP guidance document may be appropriate.
Enclosure:
Attendance List
ML21245A442 NRC-001 OFFICE NRR/DANU/UARP/PM NRR/DANU/UARP/BC NRR/DANU/UARP/PM NAME JSebrosky JSegala JSebrosky DATE 09/3/2021 09/7/2021 09/8/2021 August 17, 2021, Public Meeting to Discuss Technology Inclusive Content of Application Project Attendance List*
NAME AFFILIATION NAME AFFILIATION Robert Taylor NRC/NRR Amir Afzali Southern Company Mo Shams NRC/NRR/DANU Brandon Chisholm Southern Company Brian Smith NRC/NRR/DANU Mike Tschiltz Nuclear Energy Institute (NEI)
Nathan Sanfilippo NRC/NRR/DANU Benjamin Holtzman NEI Martin Stutzke NRC/NRR/DANU Steve Vaughn X-energy Dayna Dority NRC/NRR/DANU Ed Wallace GNBC Associates John Segala NRC/NRR/DANU/UARP Cyril Draffin US Nuclear Industry Council William Reckley NRC/NRR/DANU/UARP Steven Nesbit LMNT Consulting Maryam Khan NRC/NRR/DANU/UARP George Wilson TerraPower Eric Oesterle NRC/NRR/DANU/UARP Frank Akstulewicz A to Z Reactor Consulting Services Juan Uribe NRC/NRR/DANU/UARP Dennis Henneke GE Power Beth Reed NRC/NRR/DANU/UARP Tom King Idaho National Lab (INL)
Joe Sebrosky NRC/NRR/DANU/UARP Jim Kinsey INL Prosanta NRC/NRR/DANU/UARP Chris Chwasz INL Chowdhury Jordan Hoellman NRC/NRR/DANU/UARP Tom Hicks INL Stephen Philpott NRC/NRR/DANU/UARP Daniel Gardner Kairos Power Margaret OBanion NRC/NRR/DANU/UARP Raymond Wang X-energy Jan Mazza NRC/NRR/DANU/UARL Pete Gaillard TerraPower Mallecia Sutton NRC/NRR/DANU/UARL Scott Ingalls GE Power Ben Adams NRC/NRR/DANU/UART Amanada Westinghouse Spalding Alexandra Siwy NRC/NRR/DANU/UART Farshid Not Available (NA)
Shahrokhi Michael Orenak NRC/NRR/DANU/UART Paul Loza NA Imtiaz Madni NRC/NRR/DANU/UART Michael Mayfield NA Michelle Hart NRC/NRR/DANU/UART Karl Fleming NA Timothy Lupold NRC/NRR/DANU/UART Jana Bergman NA Hanh Phan NRC/NRR/DANU/UART Rob Burg NA Alexander NRC/NRR/DANU/UART Maxine Keefe NA Chereskin Boyce Travis NRC/NRR/DANU/UART Parthasarathy NA Chandran Ian Jung NRC/NRR/DANU/UART Charlotte Geiger NA Margaret Audrain NRC/NRR/DANU/UART Ben Chen NA Carolyn Lauron NRC/NRR/DNRL/NRLB David Holcomb NA David Desaulniers NRC/NRR/DRO Ewa Muzikova NA Weijun Wang NRC/RES/DE/SGSEB Alan Levin NA Johari Moore NRC/ NSIR/DPCP/MSB Jim von Suskil NA Enclosure
NAME AFFILIATION NAME AFFILIATION Steve Bajorek NRC/RES/DSA Mike Keller NA Shakur Walker NRC/COMM/DW Jason Andrus NA Bob Weisman NRC/OGC Jon Facemire NA Marcia Carpentier NRC/OGC Ross Moore NA Derek NRC/ACRS Scott Ferrara NA Widmayer Scott Bussey NRC/OCHCO/ADHRTD/ Kurt Harris NA RTTB Tom Braudt NA Steven Pope NA
- Attendance list based on Microsoft Teams Participant list. List does not include 5 individuals that connected via phone.
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