ML18177A462

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June 5-6, 2018 Summary of Meeting to Discuss Licensing Modernization Project Guidance Document
ML18177A462
Person / Time
Issue date: 07/02/2018
From: William Reckley
NRC/NRO/DSRA/ARPB
To: John Segala
NRC/NRO/DSRA/ARPB
Reckley W, NRO/DSRA, 415-7490
References
Download: ML18177A462 (6)


Text

July 2, 2018 MEMORANDUM TO:

John P. Segala, Chief Advanced Reactor and Policy Branch Division of Safety Systems, Risk Assessment and Advanced Reactors Office of New Reactors FROM:

William D. Reckley, Senior Project Manager /RA/

Advanced Reactor and Policy Branch Division of Safety Systems, Risk Assessment and Advanced Reactors Office of New Reactors

SUBJECT:

SUMMARY

OF JUNE 5-6, 2018, PUBLIC MEETING TO DISCUSS LICENSING MODERNIZATION PROJECT On June 5 and 6, 2018, the U.S. Nuclear Regulatory Commission (NRC) held a Category 2 public meeting with representatives from Southern Company, National Laboratories, Nuclear Energy Institute (NEI), and other stakeholders to discuss the development of guidance documents supporting licensing advanced reactor designs (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18151A706). Enclosure 1 contains a list of meeting attendees and participants who joined via webinar. The primary topic of discussion was Draft Report Revision M of the Licensing Modernization Project (LMP) guidance document Risk-Informed Performance-Based Guidance for Non-Light Water Reactor Licensing Basis Development (ADAMS Accession No. ML18150A344).

Mr. Jason Redd, Southern Company, led the discussions on the LMPs current draft of the guidance for the developing licensing bases for non-light water reactors. Mr. Redd used the draft report (ADAMS Accession No. ML18150A344) to support discussions with a focus on changes since a meeting on April 2018 (ADAMS Accession No. ML18113A792). Enclosure 2 provides a list of topics discussed during the meeting and areas where the LMP plans to clarify the guidance document or is awaiting additional comments and questions from the NRC staff.

The meeting ended with discussions related to LMP representatives and NRC staff preparing for a meeting of the Future Plants Designs Subcommittee of the Advisory Committee on Reactor Safeguards. The next public meeting on the guidance is tentatively planned for August 2018.

CONTACT:

William D. Reckley, NRO/DSRA 301-415-7490

Enclosures:

1. List of attendees
2. Discussion topics

ML18177A462 NRO-002 OFFICE NRO/DSRA NRO/DSRA NAME WReckley JSegala DATE 07/02/2018 07/02/2018

Attendance List - Attended at least part of meeting in person Name Organization Kevin Coyne NRC/NRO Amy Cubbage NRC/NRO Michelle Hayes NRC/NRO Jan Mazza NRC/NRO John Monninger NRC/NRO Hanh Phan NRC/NRO Bill Reckley NRC/NRO John Segala NRC/NRO Martin Stutzke NRC/NRO Lucieann Vechioli NRC/NRO Joe Williams NRC/NRO Michelle Gonzalez NRC/RES Steve Kline Bechtel Prasad Kadambi Consultant Jim Kinsey INL Hiroki Watanabe JNRA Kati Austgen NEI Mike Tschiltz NEI Amir Afzali Southern Karl Flemming Southern Jason Redd Southern Ed Wallace Southern Robin Rickman TEUSA Jim Gresham Westinghouse Doug Weaver Westinghouse

2 Attendance List - Webinar Attendees Name Organization Jana Bergman Curtiss Wright John Bolin GA Scott Bussey NRC/TTC Jim Chapman Caroline Cochran Oklo Timothy Crook Transatomic Suzanne Dennis NRC/RES Donald Dube Jensen Hughes Greg Gibson X-energy Michelle Gonzalez NRC/RES Peter Hastings Kairos Power Mark Holbrook INL Jim Kinsey INL Steve Kline Bechtel Jun Liao Westinghouse Patrick Looney GE Wayne Moe INL Tomy Nazario NRC JongSeuk PARK KINS Paul Rades NRC Pranab Samanta BNL Nanette Valliere NRC/OCMSB Doug Weaver Westinghouse Staci Wheeler Alpha Tech Research Corp Gregory White

Licensing Modernization Project Discussion Topics for Public Meeting, June 5-6. 2018

1. Ensure that Licensing Modernization Project (LMP) and Staff are aligned on the use of a Bibliography and Reference list; we want to ensure that our formatting is clear to NOT incorporate other documents by reference.
2. Complete LMP general design (GD)-specific Glossary of Terms for all the new or unique definitions and terminology needed. Coordinate terms and definitions with the U.S. Nuclear Regulatory Commission (NRO) Staff. Glossary should include an agreed upon list of items so that the Glossary definitions can be developed, agreed upon between industry and NRO Staff, and then included in the GD and updated working procedures.
3. Likewise, develop an Anti-Glossary of terms that have proven often result in misunderstandings and revise Guidance Document as required.
4. Complete review of all Figures and supporting text for implementation process detail beyond what is endorsable by Regulatory Guide. This topic requires further discussion with the NRO Staff.
5. Additional discussion with the NRO Staff is needed to address the calculation of incensing basis events (LBE) consequences. The calculation of consequences is dependent on assumptions of distance (e.g., EAB or X meters), exposure times, demographics, meteorology, and protective actions. Discussion on detail and appropriate communication vehicle may be useful regarding how a designer may make conservative assumptions or otherwise represent site characteristics prior to an actual site being selected for deployment.
6. Need to clearly explain how the LMP process is intended to be flexible in the method of implementation. Need to address Maximum Hypothetical Hazard and Robust Barrier approaches. We believe such an approach is valid and executable under the LMP process however it is not year clear how such approaches would be used to support selection of LBEs, safety classification of structures, systems and components (SSCs), SSC performance requirements, and evaluation of defense in depth adequacy. Industry and NRC should review the recent SHINE Medical Technologies precedent to further elaborate on this topic and how performance-based outcomes should be defined.
7. The SSC safety classification of SSC which protect safety related SSC from hazards such as tornado missiles, internal flooding, and external flooding needs further discussion between industry and NRC Staff.
8. External events is a topic requiring further industry and NRO discussion. For example, would assumptions for external events within design-basis events establish design basis earthquakes, flooding, wind loadings, etc. like current practices? How would mixture of methodologies between external hazard curves (e.g., for seismic) be used in combination with deterministic external hazards? In design phase, would conservative hazard curves or values be assumed and how would standardization be maintained? Seismic probabilistic risk assessment is needed for a design, but Seismic Margin Assessment does not fit within the LMP process as a stand-alone element.

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9. Multi-module and multi-source (i.e. fission gas holdup tanks) topics need further discussion between industry and NRO Staff.
10. Use and role of 10 CFR 20 limits (i.e. 100 mrem) and the U.S. Environmental Protection Agency Protective Action Guidelines in the content of the F-C chart, impact on Emergency Planning, Emergency Planning Zone distances needs to be further discussed between industry and NRO Staff; these topics will likely be split but both fall under the general topic of radiological dose to workers and the public.
11. What guidance will be needed to implement a risk informed performance based (RIPB) framework from construction through decommissioning? Industry and NRO Staff need to discuss longer term controls - into plant operation and maintaining elements of this RIPB process that is different from the operating (deterministic) fleet. This is a forward-looking topic to generate discussion about other, future guidance needed for the Staff and industry.
12. LMP has sought to clarify all references to 10 CFR 50.69 in the Guidance Document to ensure that no link between the Guidance Document and the implementation of 10 CFR 50.69 to the operating fleet is inadvertently implied; LMP would like the Staffs feedback as to whether gaps remain.
13. LMP expects the Regulatory Guide endorsing the LMP guidance document to inform ALL of the 10 CFR 50.34 / 10 CFR 52.47 application content for new non-LWR licensing applications *that choose to follow the LMP process* - specifically in guiding the amount of content and level of detail for the different chapters of the preliminary safety analysis report or updated final safety analysis report. What actions additional guidance is needed from industry or the Staff to push the ball forward on this topic? Additional discussion between the industry and NRC Staff would be beneficial.