ML20339A566

NRC Slides for December 10, 2020, Public Meeting on Technology Inclusive Content of Application Project, Advanced Reactor Content of Application Project, and Applicability of Regulations to Non-Light Water Reactors

ML20339A566
Person / Time
Issue date:	12/10/2020
From:	Joseph Sebrosky NRC/NRR/DANU/UARP
To:
Sebrosky J,NRR/DANU/UARP,2405000614
References
Download: ML20339A566 (39)

Text

Technology Inclusive Content of Application Project (TICAP), and Advanced Reactor Content of Application Project (ARCAP) Meeting December 10, 2020 Telephone Bridgeline: (301) 576-2978 Passcode: 613 774 13#

Agenda Time Topic Presenter 10:00 -10:10 am Introduction NRC 10:10 - 10:50 amNEI Guidance Document Annotated Outline Southern/NRC update including:

• Discussion of NRC comments on NEI Guidance Document

• Initial concepts on how to integrate industry developed TICAP guidance with NRC developed ARCAP guidance 10:50 - 11:20 am Level of Detail Task Southern/ NRC 11:20 - 11:45 am Tabletop Exercises Status Southern 11:45 - 12:30 pm ARCAP Draft Chapter 2 NRC 12:30 - 1:00 pm Regulatory Analysis Review of Applicable NRC/Industry Regulations for Non-Light Water Reactors 1:00 - 1:15 pm Stakeholder questions All 1:15 - 1:30 pm Next Steps and Concluding Remarks All 2

NRC Comments on Draft Southern Company TICAP Guidance Document 3

Background

• Draft Guidance Document titled, Technology Inclusive Guidance for Non-Light Water Reactor Safety Analysis Report Content for a Licensing Modernization Project-Based Affirmative Safety Case, available at ADAMS Accession No. ML20294A382

• NRC staff comments on draft Guidance Document available at ADAMS Accession No. ML20316A013

• Comments fall into 3 general categories:

Not Clear if Included (Items not mentioned in document)

Establishing and Maintaining the Licensing Basis (Items identified as for information only)

Clarifications Needed (Items needing additional explanation) 4

Not Clear if Included

• Chapter 1 - External Hazards Evaluation

• Chapter 2 - Basis for Mechanistic Source Terms

• Chapter 2 - Baseline Parameters for Normal Operation

• Chapter 2 - SSC Performance Under Accident Conditions

• Chapter 3 - The Basis for DBA Selection

• Chapter 3 - Detailed Description of the DBE and BDBE Analysis

• Chapter 4 - Discussion of DID Evaluation (e.g. evaluation criteria, evaluation results for plant capability and programmatic DID)

• Chapter 5 - Equipment Qualification

• Chapter 5 - Description of Analytical Tools and Their V & V

• Chapter 8 - Startup Testing and ITAAC

• Chapter 8 - Plant Organization and Responsibilities

• Chapter 8 - Interfacing with Other Facility Programs 5

Establishing and Maintaining the Licensing Basis

• Chapter 1 states, without a basis, that the information in the chapter is for information only. This includes site characteristics, a general description of plant systems and their role in normal and off normal operation, key design attributes and DID. These are important to the safety case and, therefore, warrant regulatory control.

• Chapter 2 states that the summary PRA information is not considered in change control evaluations. However, the PRA information is key to many of the design and safety decisions described in the application and, thus, to the regulatory review. Therefore, they warrant regulatory control.

6

Clarifications Needed

• Chapter 1 includes general site characteristics. Will this include the characteristics typically described for sites (i.e. ARCAP Chapter 2)?

• Chapter 2 states the applicant may provide information about additional generic analysis used in subsequent subsections. What does this mean?

Provide examples to clarify the types of analysis and potential subsections.

• Chapter 3 - Where will the aircraft and loss of large area analysis be described?

• Chapter 5 states that SR and NSRST operator actions will be identified.

What is to be done with these?

• Chapter 6 includes a description of SR design criteria. How are these related to the Complementary Design Criteria and the PDCs?

• Will the TICAP chapters include acceptance criteria similar to ARCAP?

• Where will the LBE comparison to the F-C curve be described?

• Where will the design parameters for the SSCs be described?

7

Initial Concepts on How to Integrate Industry-Developed TICAP Guidance with NRC-Developed ARCAP Guidance 8

Background

• At the April 22 public meeting, the staff presented a complete NRC/INL-developed ARCAP annotated outline available at ADAMS Accession No. ML20107J565

• At the October 22 public meeting, industry presented Guidance Document (including TICAP annotated outline) available at ADAMS Accession No. ML20294A382

• NRC/INL initial concepts for integrating ARCAP annotated outline with TICAP annotated outline available at ADAMS Accession No. ML20316A013

• The items shown in the blue font were extracted from the ARCAP outline and placed in what the NRC staff believes could be the appropriate place in an integrated TICAP/ARCAP outline

• The items at the end of the outline fall outside the scope of the final safety analysis report (FSAR) but are also part of a license application 9

Proposed Integrated TICAP/ARCAP Outline Chapter 1 - General Plant and Site Description and Overview of the Safety Case

• Overview of technology (size of the reactor and planned commercial application of the designpower production, industrial application, etc.)

• General description of the plant systems and roles that they play in normal and off-normal conditions, including refueling o Baseline operating parameters

• General site characteristics o Introduction o Site Characteristics and Site Parameters o Geography and Demography o Nearby Industrial, Transportation, and Military Facilities o Regional Climatology, and Local Meteorology, and Atmospheric Dispersion (Basis for Section 2.3 below) o Hydrological Description o Geology, Seismology, and Geotechnical Engineering

• Summary of Safety Case Findings o Overview of affirmative LMP-based safety case methodology, including reference to NEI 18-04 and any deviations from the approved methodology o Summary of FSFs o Summary of LBEs with focus on DBAs o Summary of radiological consequence assessment o Summary of how the design provides that FSFs are metkey plant attributes and design features that provide reasonable assurance of adequate protection of public health and safety o Evaluation of DID capabilities 10

Proposed Integrated TICAP/ARCAP Outline (cont.)

Chapter 2 - Generic Analyses 2.1 - Probabilistic Risk Assessment o Overview of PRA o Summary of Key PRA Findings 2.2 - Source Term 2.3 - Meteorology 2.4 - Other Generic Analyses 2.5 - External Hazards Evaluation 2.6 - Analyses of Systems, Components, and Materials Performance 2.7 - Analytical Codes Chapter 3 - Licensing Basis Events 3.1 - Licensing Basis Event Selection Methodology 3.2 - Anticipated Operational Occurrences 3.3 - Design Basis Events 3.4 - Beyond Design Basis Events 3.5 - Design Basis Accidents Chapter 4Integrated Evaluations 4.1 - Evaluation of Integrated Plant Risk 4.2 - Defense-in-Depth 4.2.1 - Plant Capability DID 4.2.2 - Programmatic DID 11

Proposed Integrated TICAP/ARCAP Outline (cont.)

Chapter 5 - Safety Functions, Design Criteria, and SSC Categorization 5.1 - Principal Design Criteria and Safety-Related SSCs

• Required Safety Functions

• Required Functional Design Criteria 5.2 - Complementary Design Criteria and Non-Safety-Related with Special Treatment SSCs

• Risk Significant Safety Functions Chapter 6Safety-Related SSC Criteria and Capabilities

• Safety-Related Design Criteria Note that the draft

• Special Treatments outlines for

• Basis for Operability Requirements Chapters 5, 6, and Chapter 7NSRST SSC Criteria and Capabilities 7 do not reflect

• Special Treatments input from the

• Basis for Availability Controls level of detail discussion which Chapter 8Plant Programs is ongoing

• Human Factors

• Training

• Reliability Assurance

• Maintenance

• Change Control

• Conduct of Operations 12

Proposed Integrated TICAP/ARCAP Outline (cont.)

Chapter 9 - Control of Routine Plant Radioactive Effluents, Contamination, and Solid Waste 9.1 - Liquid and Gaseous Effluents Outlines for Chapters 9 9.2 - Contamination Control and 10 are consistent 9.3 - Solid Waste with previously issued Chapter 10 - Control of Occupational Dose draft content guidance for these topics Chapter 11 - Organization 11.1 - Description/responsibilities of key management positions 11.2 - Educational, training and experience requirements for key management positions 11.3 - Interfaces with support groups (e.g. Technical Support Center, Corporate) 11.5 - Basis/number of operating shift crews, their staffing and responsibilities Chapter 12 - Initial Startup Testing 12.1 - As-built verification program (ITAAC) 12.2 - Preoperational testing program 12.3 - Initial startup testing/operations program 13

Proposed Integrated TICAP/ARCAP Outline (cont.)

Separate Licensing Documents DC and COL Application (if not referencing a DC) COL Application only Technical Specifications Quality Assurance Plan (construction and Technical Requirements Manual (or operations)

Availability Control Manual) Emergency Plan Quality Assurance Plan (design) Physical Security Plan Fire Protection Program (design) SNM (special nuclear materials) physical protection PRA program Fuel qualification report SNM material control and accounting plan Exemptions Cyber Security Plan Environmental Report New fuel shipping plan Fire Protection Program (operational)

Radiation Protection Program Offsite Dose Calculation Manual ISI/IST Program Environmental Report Site Redress Plan Exemptions, Departures, and Variances Financial Qualification and Insurance and Liability 14

Initial Concepts Regarding Level of Detail in a Combined License or Operating License Application 15

Approach Used to Develop Initial Concepts 16

Approach Used to Develop Initial Concepts

• Initially, develop level of detail (LoD) guidance for safety-related structures, systems, and components (SSCs) section of the application content guide; available at ADAMS Accession No. ML20321A326

• Obtain stakeholder agreement

• Work with industry to develop LoD guidance for non-safety-related with special treatment SSCs and other content sections using a graded approach commensurate with the safety significance of the SSCs 17

Approach Used to Develop Initial Concepts

• Primary Inputs for the Safety-Related LoD Guidance:

o NEI 18-04, Rev 1, Risk-Informed Performance-Based Technology Inclusive Guidance for Non-Light Water Reactor Licensing Basis Development (and associated RG 1.233) o Non-Light Water Review Strategy, Staff White Paper, September 2019 o NEI 15-02, Industry Guideline for the Development of Tier 1 and ITAAC Under 10 CFR Part 52 Proportional to the safety and risk significance of the top-level design feature or performance characteristic (i.e., a graded approach)

Top-level design features and performance characteristics are attributes that are important to performing the safety-related and certain risk-significant functions of the plant o NUREG-0800 (Standard Review Plan) Section 14.3, guidance for Design Certification Document Tier 1 The top-level information selected should include the principal performance characteristics and safety functions of the SSCs 18

Level of Detail -

Areas Addressed

1. Description of Required Functional Design Criteria (RFDC)

• Defined to capture design-specific criteria that may supplement or may not be captured by the principal design criteria (PDC)

• These criteria are used within the LMP methodology to frame specific design requirements as well as special treatment requirements for SR SSCs

2. Description of Design Requirements and Relationship to PDCs

• Describe the required safety functions (RSFs) used to define a set of reactor-specific required functional design criteria (RFDC) from which safety-related design criteria (SRDC) are derived

3. Description of Design Features

• The specific design features that are responsible for meeting the SRDC

• Include features that demonstrate system capability and reliability for both prevention and mitigation of LBEs 19

Level of Detail -

Areas Addressed (cont.)

4. Description of External Hazard Levels

• Describe how the SR SSCs that are credited in the fulfillment of RSFs are capable to perform their RSFs with a high degree of confidence in response to any Design Basis External Hazard Levels (DBEHLs)

5. Description of Reliability and Capability Performance Requirements

• Describe SR SSC reliability targets and performance requirements

• Describe the performance of testing and validation of SSC performance capability

• Describe, as applicable, the special treatment requirements from NEI 18-04, Table 4-1

6. Description of Required Supporting Functions

• Describe important system interdependencies, including failure modes and effects of nonsafety-related SSCs that could directly affect safety-related functions 20

Draft ARCAP Chapter 2, Site Information 21

ARCAP Chapter 2

• Draft ARCAP Chapter 2, Site Information, available at ADAMS Accession No. ML20316A013

• 10 CFR 100, Subpart B, requires that site characteristics be determined in order to establish (1) the external hazards (man-made and natural) the plant must be designed for, (2) the hydrological radionuclide transport properties, (3) if the site poses a significant impediment to EP and (4) that the individual and societal risk of potential accidents is low.

• Much of the above information is contained in Chapter 2 of the SAR, with the result that the chapter becomes very large. For example, the SARs contain information on historical records of the site (such as floods, temperatures, seismic events, etc.) as well as the results of recent site characterization work (e.g. meteorology, core samples).

22

ARCAP Chapter 2

• What is being considered is using the guidelines in NEI 98-03 Guidelines for Updating FSARs (endorsed by RG 1.181), developed to identify areas where information can be removed from FSARs, as the starting point for determining if it was needed in the first place.

Examples include:

• Historical information (floods, storms, etc.)

• Information not expected to change with time (geological data, seismic data, etc.)

• Redundant information

• Excessive detail 23

ARCAP Chapter 2

• The intent is to limit the amount of material in SAR Chapter 2 to what is necessary for establishing safety significant design parameters and performing the safety analysis, along with its supporting bases.

• If necessary, any additional supporting information (e. g. historical records, geological data) could be documented in a separate report available for audit.

• Guidance developed to support non-LWRs, stationary micro reactors and small modular LWRs submitting applications for a construction permit (CP) or operating license (OL) under 10 CFR 50, for a combined license (COL) or an Early Site Permit (ESP) under 10 CFR 52, or for a future 10 CFR Part 53 application.

24

ARCAP Chapter 2 Discussion Topics

• Need to update Section 2.2 guidance when Commission direction is received on SECY-20-0045, Population-Related Siting Considerations for Advanced Reactors.

• Requesting feedback on Section 2.4 guidance on what to do if 2 years of onsite meteorological data are not available at the time the application is submitted

• NRC staff notes that Section 2.5 guidance to be further refined

• Regulatory Guide 1.59, Design Basis Flood Information for Nuclear Power Plants, is in the process of being updated

• Updated guidance based on lessons learned from reevaluated flood hazard reviews

• Staff also developing regulatory guide for dam safety reviews 25

ARCAP Chapter 2 Discussion Topics Section 2.6.1-2 Establish GMRS using SSHAC Guidance - NUREG 2213

1. Develop seismic source model

a. CEUS: NUREG 2115, ANS 2.27

b. WUS: ANS 2.27, 2.29

2. Develop seismic ground motion model

a. CEUS: NGA-East GMC

b. WUS: ANS 2.29

3. Perform local site response analysis: ANS 2.29

4. Perform PSHA to develop site hazard curves and response spectra: ANS 2.29

5. Select SDC: ANS 2.26

6. Develop GMRS: ASCE/SEI 43-19 26

NRC Regulatory Analysis Review of Applicable Regulations for Non-Light Water Reactors December 2020

Purpose

• Provide NRC perspectives on NEI feedback regarding NRC Staff Draft White Paper - Analysis of Applicability of NRC Regulations for Non-Light Water Reactors

• Identify areas where changes to the white paper are planned 28

Background

• NRC Staff Draft White Paper - Analysis of Applicability of NRC Regulations for Non-Light Water Reactors issued 9/2020 (ML20241A017)

- Supersedes regulatory applicability discussion in Appendix to NRC draft Non-Light Water Review Strategy Staff White Paper issued 9/2019 (ML19275F299)

- Standalone document subject to a more robust review

• NEI Input on Analysis of Applicability of NRC Regulations for Non-Light Water Reactors dated Oct 30, 2020 (ML20308A662)

- Identifies two objectives for finalization of staffs white paper

- Attachment provides industrys evaluation of 10 CFR 52.79 requirements 29

NEI Objective 1 Clearly identify all regulations that are broadly not applicable to non-LWRs (using entry conditions, as needed). In determining whether a regulation is applicable or not applicable to non-LWRs, the NRC should base its determination on the technical aspects of the design and the underlying safety purpose of the regulation, neither of which changes based on the licensing process used (i.e., 10 CFR Part 50 versus 10 CFR Part 52).

30

NRC Response to NEI Objective 1

• NEI White paper asserts if the regulation makes assumptions specific to LWRs, the regulations are not applicable to non-LWRs. In contrast, NRC determines the applicability of regulations based on the plain language of the regulation. The regulation is considered applicable unless it specifically limits applicability to LWRs.

• Staff acknowledges regulatory differences between Part 50 and Part 52 applicants. Some will be addressed in Alignment of Licensing Processes and Lessons Learned from New Reactor Licensing Rulemaking; regulatory basis expected 12/16/2020

• Table 2 Regulations are not candidates for entry conditions.

31

NEI Objective 2

• Establish a process to address the regulations that are broadly not applicable to non-LWRs in a manner that minimizes the number of exemptions. This approach would provide consistency and predictability to the application process, as compared to expecting applicants to individually assess the entire body of regulations, and to seek numerous specific exemptions 32

NRC Response to NEI Objective 2

• An exemption request may not always be required - in many cases, non-LWR designs may meet a rule through design- and application-specific implementations.

• NRC regulations already provide an exemption process to provide flexibility in cases where "[a]pplication of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

- The exemption process is not punitive and should not be perceived negatively.

- The level of detail and technical justification required for some specific exemptions will vary among applications.

- For other exemptions, the staff can minimize the burden on applicants by drafting exemptions or by providing guidance or templates on how to develop the exemptions.

- Hearing orders are an alternative to exemptions for specific applicants, but they require extensive pre-application interaction and cannot be enacted generically.

• Changing NRC regulations generically, for all non-LWR applicants, will require rulemaking.

- This is the goal of the Part 53 rulemaking.

- Other changes may be made in other rulemakings (e.g., security, emergency planning)

- White papers and individual licensing actions cannot make generic changes to regulations.

33

Table 2 - Part 52 Regulations Referencing Part 50 Regulations Limited to LWRs

• NRC regulations acknowledge and provide a path for when Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule - this is done through exemptions

• The regulations apply, but they refer to Part 50 regulations that do not apply

• The NRC has the authority to grant exemptions on its own initiative; the staff has identified regulations for which NRC-initiated exemptions may be appropriate and requests that a non-LWR Part 52 applicant identify those regulations which relate to its design

• NRC staff will then write the exemption with content as required by 50.12 and 52.7 34

Exemptions

• An example where a regulation applies, but an exemption would not be required is 10 CFR 50.46a (which the NEI white paper states industry believes does not apply). The regulation itself offers relief without a need for an exemption (emphasis added):

- Each nuclear power reactor must be provided with high point vents for the reactor coolant system, for the reactor vessel head, and for other systems required to maintain adequate core cooling if the accumulation of noncondensible gases would cause the loss of function of these systems.

• This is one instance where the regulation is written in a straightforward fashion and the vast majority of non-LWR designs will be able to meet the regulation with no additional justification beyond that required by other regulations.

35

Other NRC observations regarding NEI White Paper

• GDC Nuances

- PDCs are required by regulation

- The GDC are not requirements, but provide guidance (see 52.79(a)(4)(i) and Part 50 Appendix A) to applicants in establishing PDC; NRC staff expects applicants will consider GDC when establishing PDC (for example, as done in RG 1.232)

- Not all GDC are based on water-cooled reactor technology. For example, the concept of fire protection is not technology specific

• Not all TMI requirements are technology dependent

- Examples include plant parameter display (10 CFR 50.34(f)(2)(iv) and (v)),

quality assurance (10 CFR 50.34(f)(3)(ii) and (iii)), and administrative and management oversight of design and construction (10 CFR 50.34(f)(3)(i) and (vii))

• NRC position not always correctly captured

- Particularly the distinction between Part 50 and Part 52 and consistency with the position expressed in NRCs 2020 Draft White Paper 36

Changes to NRC Draft White Paper

• Consider adding guidance on how to develop exemptions; possibly include template or sample

• Add clarity to Table 2 description and plans for exemption request

• Further clarify Tables 3-5 to better address usability and expressly set forth NRC position

- NRC staff is evaluating specific language in 10 CFR 50.55a stating "Each manufacturing license, standard design approval, and design certification application under part 52 of this chapter and each combined license for a utilization facility is subject to the following conditions..." (e.g. 50.55a(d))

• Identify those TMI Items that may be satisfied with no additional effort by the applicant as a result of other regulations.

37

Questions/Discussion 38

Next Steps - Future Meeting Planning and Open Discussion Near-Term Advanced Reactor Public Stakeholder Meetings January 7, 2021 (Part 53 - Design and Analysis Requirements (Subpart C)

Preliminary Language to be Issued Around December 18, 2020)

January 21, 2021 (Periodic)

Next TICAP/ARCAP Meeting?

39