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{{#Wiki_filter:J. Segala                                            1 September 16, 2020 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 FROM:                            Joseph M. Sebrosky, Senior Project Manager /RA/
Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
 
==SUBJECT:==
 
==SUMMARY==
OF AUGUST 27, 2020, PUBLIC MEETING TO DISCUSS TECHNOLOGY INCLUSIVE CONTENT OF APPLICATION PROJECT, ADVANCED REACTOR CONTENT OF APPLICATION PROJECT, AND CONSTRUCTION PERMIT GUIDANCE On August 27, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a Category 2 public meeting with stakeholders, to discuss the technology inclusive content of application project (TICAP), the advanced reactor content of application project (ARCAP), and construction permit (CP) guidance. The meeting notice is available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML20239B034, and the presentation slides are available at ADAMS Accession No. ML20239A957. This was a teleconference meeting, and an attempt was made to capture a list of the attendees as they called into the meeting. The Enclosure to this summary provides the attendees for the meeting as captured by the operator that helped to facilitate the meeting.
Meeting Highlights Technology Inclusive Content of Application Project The meeting began with a discussion of the industry-developed fundamental safety function1 (FSF) mapping report (ADAMS Accession No. ML20219A650), and the NRC staffs feedback on the report (ADAMS Accession No. ML20233A510). The objective of the industry developed FSF mapping report was to demonstrate that the existing design requirements contained in Title 10 of the Code of Federal Regulations (10 CFR) Parts 50 and 52 (and regulations referenced by those parts) are in place to substantiate that one or more FSFs are met.
The NRC noted that the overall conclusions of the industrys report align with the NRC staffs expectations that the NRCs existing regulations for light-water reactors ensure that the FSFs are fulfilled. As described in industrys report, the regulations provide that assurance by defining various high-level performance requirements as well as prescriptive requirements for some 1
Fundamental safety functions are defined as: 1) limiting the release of radioactive material, 2) removing decay heat from the reactor and waste stores, and 3) controlling reactivity.
 
J. Segala                                          2 structures systems, and components and related programmatic controls. The NRC staff noted that it was not endorsing the industrys report for use as guidance, but the NRC staff is comfortable with an approach based on developing an affirmative safety case based on the FSFs and other elements of Revision 1 of NEI 18-04, Risk-Informed Performance-Based Guidance for Non-Light Water Reactor Licensing Basis Development (ADAMS Accession No. ML19241A336). The industry and NRC staff agreed that the objective of the mapping report had been met and that no further revisions or discussions associated with the report were needed.
Industry then provided the current status of the TICAP effort including the development of the structure for the safety analysis report (SAR), and the status of the tabletop exercises that would be used to demonstrate aspects of the TICAP process. There was a discussion of the principle design criteria (PDC) and complimentary design criteria (CDC). Industry defined PDCs as supporting demonstration of the performance objectives for the FSFs. The CDCs support plant functions related to risk significance or defense-in-depth. Industry provided examples of PDCs and CDCs. The NRC staff noted that while it understood the steps to develop PDCs and CDCs and that such work was insightful, the NRC staff questioned whether the concept of PDCs and CDCs was necessary for TICAP since the licensing modernization project (LMP) did not include these terms. Industry stated that it would consider the NRC staff feedback on PDCs and CDCs and whether there was a need to use these concepts in the TICAP guidance document that is under development.
Regarding the status of tabletop exercises to demonstrate aspects of the TICAP process, industry noted that it was still working on the logistics for the exercises. Both industry and the NRC staff agreed that it would be beneficial to have NRC staff observe portions of the exercises and the NRC staff noted that its observation of the exercises should not impede the ability to perform the exercises. Industry noted that publicly available reports would be developed and provided to the NRC staff highlighting the results of the exercises.
Light Water Small Modular Reactor Construction Permit Guidance The NRC staff noted that it was continuing to develop light water small modular reactor (SMR) construction permit guidance based on industrys identification that such guidance would be useful. Both the Nuclear Energy Institute (NEI) and U.S. Nuclear Industry Council (USNIC) supported the development of such guidance. NEI stated that it was developing a position paper on the topic that it hoped to provide to the NRC staff in December of 2020.
Advanced Reactor Content of Application Project The NRC staff noted that as a result of feedback from the July 31, 2020, ARCAP meeting, the NRC ARCAP team met and developed a roadmap document describing that ARCAP will provide high-level guidance that will provide pointers to advanced reactor guidance that is under development (e.g., TICAP, security and emergency planning rulemaking) and provide guidance for areas that are not being addressed under an advanced reactor activity. Details regarding the ARCAP guidance document proposal can be found in ADAMS at Accession No. ML20231A563. A fundamental assumption is that it has never been the intention of ARCAP to develop an approach similar to the guidance found in the standard review plan (NUREG-0800) for large light water reactors or the guidance found in thousands of regulatory documents (e.g., regulatory guides, NUREGs, etc.) that have been developed over the last 50 plus years for large light-water reactors. The proposed structure of the ARCAP guidance document would be in the form of a roadmap that would list various parts of an application and
 
J. Segala                                          3 point to where guidance is being developed outside of ARCAP (e.g., TICAP, emergency planning and security rulemaking) and would contain appendices for portions of the application for which ARCAP is providing standalone guidance.
The NRC staff provided a table that listed the portions of the application (using the INL-developed annotated structure available at ADAMS Accession No. ML20107J565) and how the ARCAP would address the guidance. Industry and the NRC staff agreed that the approach would be discussed further in future ARCAP meetings.
The NRC staff and Idaho National Laboratory (INL) staff2 provided an update on the status of developing a performance-based approach for portions of an advance reactor application. The INL staff noted that it had previously provided proposed guidance for the liquid and gaseous effluent portions of Chapter 8, Control of Routine Plant Radioactive Effluents and Solid Waste.
Stakeholders were informed that the NRC and INL staff are developing a performance-based approach for other portions of an advanced reactor application including:
* Chapter 2, Site Information,
* Chapter 8, Section 8.3, Solid Waste, and
* Chapter 9, Control of Occupational Dose.
The NRC staff noted that it was targeting discussing this additional guidance in more detail at the next ARCAP meeting that is tentatively scheduled for September 24, 2020.
 
==Enclosure:==
 
Attendance List 2
Idaho National Laboratory staff are supporting development of ARCAP guidance through an NRC contract.
 
ML20253A307          *via e-mail            NRC-001 OFFICE NRR/DANU/UARP/PM
* NRR/DANU/UARP/BC
* NRR/DANU/UARP/PM
* NAME    JSebrosky                    JSegala              JSebrosky DATE    9/9/2020                      9/15/20              9/16/20 August 27, 2020, Public Meeting to Discuss Technology Inclusive Content of Application Project, Advanced Reactor Content of Application Project, and Construction Permit Guidance Attendance List NAME                    AFFILIATION                NAME                  AFFILIATION Anna Bradford            NRC/NRR/DNRL              Marc Nichol          Nuclear Energy Institute (NEI)
Bob Caldwell            NRC/NRR/DNRL              Kati Austgen          NEI Mike Dudek              NRC//NRR/DNRL/NRLB        Mike Tschiltz        NEI Carolyn Lauron          NRC/NRR/DNRL/NRLB          Martin ONeill        NEI John Segala              NRC/NRR/DANU/UARP          Jeff Merrifield      Pillsbury Law Firm Maryam Khan              NRC/NRR/DANU/UARP          Cyril Draffin        US Nuclear Industry Council Eric Oesterle            NRC/NRR/DANU/UARP          Denis Henneke        GE Hitachi Bill Reckley            NRC/NRR/DANU/UARP          Steven Nesbit        LMNT Consulting Amy Cubbage              NRC/NRR/DANU/UARP          Karl Fleming          KNF Consulting Joe Sebrosky            NRC/NRR/DANU/UARP          Frank Akstulewicz    A to Z Reactor Consulting Services Nan Valliere            NRC/NRR/DANU/UARP          George Wadkins        GE Hitachi Jordan Hoellman          NRC/NRR/DANU/UARP          Martin Owens          GE Hitachi Chris Van Wert          NRC/NRR/DANU/UART          Farshid Shahrokhi    Framatome Jim Kinsey              Idaho National Laboratory  Darrell Gardner      Kairos Power (INL)
Wayne Moe                INL                        James Tomkins        Kairos Power Tom Hicks                INL                        Caroline Cochran      Oklo Tom King                INL                        Jacob Gabcwitez      Oklo Amir Afzali              Southern Company          Tammy Morin          Holtec International Brandon Chisholm        Southern Nuclear          Gary Becker          NuScale Jason Redd              Southern Nuclear          Steve Schilthelm      BWXT Ben Carmichael          Southern Company          Pete Dillard          Terra Power Ryan Henderson          Southern Company          John Bolan            General Atomics Clint Medlock            Southern Company          Jill Monahan          Westinghouse Gracen Ray              Southern                  Tim Lucas            X Energy Stu Magruder            NRC/NRR/DANU/UARL          Bill Horak            Brookhaven National Laboratory Adrian Muniz            NRC/NRR/DANU/UARL          Christopher Chwasz    INL Michelle Hart            NRC/NRR/DANU/UART          Jason Christensen    INL Ian Jung                NRC/NRR/DANU/UART          David Holcomb        Oak Ridge National Lab (ORNL)
Michelle Hayes          NRC/NRR/DANU/UART          Mike Poore            ORNL Bob Fitzpatrick          NRC/NRR/DEX/EENB          Jason Andrus          INL Nadim Khan              NRC/NRR/DEX/EENB          Rory Stanley          US Senate Environment and Public Works (EPW)
Eric Bowman              NRC/COMM/OCMKS            Brad Williams        US Senate EPW Enclosure
 
NAME            AFFILIATION                NAME          AFFILIATION Shakur Walker  NRC/COMM/OCMDW            Ed Wallace    GNBC Valerie Gray    NRC/OCHCO/ADHRTD/          Prasad Kadambi Consultant NRANB Hayden Brundage NRC/OCHCO/ADHRTD/          Jenna Bergman  Curtiss-Wright NRANB Derek Widmayer  NRC/ACRS                  Donald Helton  NASA Casper Sun      NRC/RES/DSA/RPB            Alan Levin    Public Donald Palmrose NRC/NMSS/RESS              Karen Cochran  Public Scott Bussey    NRC/OCHCO/ADHRTD/          Alex Hashemian AMS RTTB Rob Burg        Engineering Planning and  Alice Reener  Hopewell Inc.
Management Inc.
Bruce Weir      Dubose National Energy    April Rice    PLS Stacey Wheeler  Public                    Don Hulting    NBS National Labs 2}}

Revision as of 23:55, 24 September 2020

August 27, 2020, Summary of Public Meeting to Discuss Technology Inclusive Content of Application Project, Advanced Reactor Content of Application Project, and Construction Permit Guidance
ML20253A307
Person / Time
Issue date: 09/16/2020
From: Joseph Sebrosky
NRC/NRR/DANU/UARP
To: John Segala
NRC/NRR/DANU/UARL
Sebrosky J,NRR/DANU/UARL,(240)500-0614
References
Download: ML20253A307 (6)


Text

J. Segala 1 September 16, 2020 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 FROM: Joseph M. Sebrosky, Senior Project Manager /RA/

Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF AUGUST 27, 2020, PUBLIC MEETING TO DISCUSS TECHNOLOGY INCLUSIVE CONTENT OF APPLICATION PROJECT, ADVANCED REACTOR CONTENT OF APPLICATION PROJECT, AND CONSTRUCTION PERMIT GUIDANCE On August 27, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a Category 2 public meeting with stakeholders, to discuss the technology inclusive content of application project (TICAP), the advanced reactor content of application project (ARCAP), and construction permit (CP) guidance. The meeting notice is available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML20239B034, and the presentation slides are available at ADAMS Accession No. ML20239A957. This was a teleconference meeting, and an attempt was made to capture a list of the attendees as they called into the meeting. The Enclosure to this summary provides the attendees for the meeting as captured by the operator that helped to facilitate the meeting.

Meeting Highlights Technology Inclusive Content of Application Project The meeting began with a discussion of the industry-developed fundamental safety function1 (FSF) mapping report (ADAMS Accession No. ML20219A650), and the NRC staffs feedback on the report (ADAMS Accession No. ML20233A510). The objective of the industry developed FSF mapping report was to demonstrate that the existing design requirements contained in Title 10 of the Code of Federal Regulations (10 CFR) Parts 50 and 52 (and regulations referenced by those parts) are in place to substantiate that one or more FSFs are met.

The NRC noted that the overall conclusions of the industrys report align with the NRC staffs expectations that the NRCs existing regulations for light-water reactors ensure that the FSFs are fulfilled. As described in industrys report, the regulations provide that assurance by defining various high-level performance requirements as well as prescriptive requirements for some 1

Fundamental safety functions are defined as: 1) limiting the release of radioactive material, 2) removing decay heat from the reactor and waste stores, and 3) controlling reactivity.

J. Segala 2 structures systems, and components and related programmatic controls. The NRC staff noted that it was not endorsing the industrys report for use as guidance, but the NRC staff is comfortable with an approach based on developing an affirmative safety case based on the FSFs and other elements of Revision 1 of NEI 18-04, Risk-Informed Performance-Based Guidance for Non-Light Water Reactor Licensing Basis Development (ADAMS Accession No. ML19241A336). The industry and NRC staff agreed that the objective of the mapping report had been met and that no further revisions or discussions associated with the report were needed.

Industry then provided the current status of the TICAP effort including the development of the structure for the safety analysis report (SAR), and the status of the tabletop exercises that would be used to demonstrate aspects of the TICAP process. There was a discussion of the principle design criteria (PDC) and complimentary design criteria (CDC). Industry defined PDCs as supporting demonstration of the performance objectives for the FSFs. The CDCs support plant functions related to risk significance or defense-in-depth. Industry provided examples of PDCs and CDCs. The NRC staff noted that while it understood the steps to develop PDCs and CDCs and that such work was insightful, the NRC staff questioned whether the concept of PDCs and CDCs was necessary for TICAP since the licensing modernization project (LMP) did not include these terms. Industry stated that it would consider the NRC staff feedback on PDCs and CDCs and whether there was a need to use these concepts in the TICAP guidance document that is under development.

Regarding the status of tabletop exercises to demonstrate aspects of the TICAP process, industry noted that it was still working on the logistics for the exercises. Both industry and the NRC staff agreed that it would be beneficial to have NRC staff observe portions of the exercises and the NRC staff noted that its observation of the exercises should not impede the ability to perform the exercises. Industry noted that publicly available reports would be developed and provided to the NRC staff highlighting the results of the exercises.

Light Water Small Modular Reactor Construction Permit Guidance The NRC staff noted that it was continuing to develop light water small modular reactor (SMR) construction permit guidance based on industrys identification that such guidance would be useful. Both the Nuclear Energy Institute (NEI) and U.S. Nuclear Industry Council (USNIC) supported the development of such guidance. NEI stated that it was developing a position paper on the topic that it hoped to provide to the NRC staff in December of 2020.

Advanced Reactor Content of Application Project The NRC staff noted that as a result of feedback from the July 31, 2020, ARCAP meeting, the NRC ARCAP team met and developed a roadmap document describing that ARCAP will provide high-level guidance that will provide pointers to advanced reactor guidance that is under development (e.g., TICAP, security and emergency planning rulemaking) and provide guidance for areas that are not being addressed under an advanced reactor activity. Details regarding the ARCAP guidance document proposal can be found in ADAMS at Accession No. ML20231A563. A fundamental assumption is that it has never been the intention of ARCAP to develop an approach similar to the guidance found in the standard review plan (NUREG-0800) for large light water reactors or the guidance found in thousands of regulatory documents (e.g., regulatory guides, NUREGs, etc.) that have been developed over the last 50 plus years for large light-water reactors. The proposed structure of the ARCAP guidance document would be in the form of a roadmap that would list various parts of an application and

J. Segala 3 point to where guidance is being developed outside of ARCAP (e.g., TICAP, emergency planning and security rulemaking) and would contain appendices for portions of the application for which ARCAP is providing standalone guidance.

The NRC staff provided a table that listed the portions of the application (using the INL-developed annotated structure available at ADAMS Accession No. ML20107J565) and how the ARCAP would address the guidance. Industry and the NRC staff agreed that the approach would be discussed further in future ARCAP meetings.

The NRC staff and Idaho National Laboratory (INL) staff2 provided an update on the status of developing a performance-based approach for portions of an advance reactor application. The INL staff noted that it had previously provided proposed guidance for the liquid and gaseous effluent portions of Chapter 8, Control of Routine Plant Radioactive Effluents and Solid Waste.

Stakeholders were informed that the NRC and INL staff are developing a performance-based approach for other portions of an advanced reactor application including:

  • Chapter 2, Site Information,
  • Chapter 8, Section 8.3, Solid Waste, and
  • Chapter 9, Control of Occupational Dose.

The NRC staff noted that it was targeting discussing this additional guidance in more detail at the next ARCAP meeting that is tentatively scheduled for September 24, 2020.

Enclosure:

Attendance List 2

Idaho National Laboratory staff are supporting development of ARCAP guidance through an NRC contract.

ML20253A307 *via e-mail NRC-001 OFFICE NRR/DANU/UARP/PM

  • NRR/DANU/UARP/BC
  • NRR/DANU/UARP/PM
  • NAME JSebrosky JSegala JSebrosky DATE 9/9/2020 9/15/20 9/16/20 August 27, 2020, Public Meeting to Discuss Technology Inclusive Content of Application Project, Advanced Reactor Content of Application Project, and Construction Permit Guidance Attendance List NAME AFFILIATION NAME AFFILIATION Anna Bradford NRC/NRR/DNRL Marc Nichol Nuclear Energy Institute (NEI)

Bob Caldwell NRC/NRR/DNRL Kati Austgen NEI Mike Dudek NRC//NRR/DNRL/NRLB Mike Tschiltz NEI Carolyn Lauron NRC/NRR/DNRL/NRLB Martin ONeill NEI John Segala NRC/NRR/DANU/UARP Jeff Merrifield Pillsbury Law Firm Maryam Khan NRC/NRR/DANU/UARP Cyril Draffin US Nuclear Industry Council Eric Oesterle NRC/NRR/DANU/UARP Denis Henneke GE Hitachi Bill Reckley NRC/NRR/DANU/UARP Steven Nesbit LMNT Consulting Amy Cubbage NRC/NRR/DANU/UARP Karl Fleming KNF Consulting Joe Sebrosky NRC/NRR/DANU/UARP Frank Akstulewicz A to Z Reactor Consulting Services Nan Valliere NRC/NRR/DANU/UARP George Wadkins GE Hitachi Jordan Hoellman NRC/NRR/DANU/UARP Martin Owens GE Hitachi Chris Van Wert NRC/NRR/DANU/UART Farshid Shahrokhi Framatome Jim Kinsey Idaho National Laboratory Darrell Gardner Kairos Power (INL)

Wayne Moe INL James Tomkins Kairos Power Tom Hicks INL Caroline Cochran Oklo Tom King INL Jacob Gabcwitez Oklo Amir Afzali Southern Company Tammy Morin Holtec International Brandon Chisholm Southern Nuclear Gary Becker NuScale Jason Redd Southern Nuclear Steve Schilthelm BWXT Ben Carmichael Southern Company Pete Dillard Terra Power Ryan Henderson Southern Company John Bolan General Atomics Clint Medlock Southern Company Jill Monahan Westinghouse Gracen Ray Southern Tim Lucas X Energy Stu Magruder NRC/NRR/DANU/UARL Bill Horak Brookhaven National Laboratory Adrian Muniz NRC/NRR/DANU/UARL Christopher Chwasz INL Michelle Hart NRC/NRR/DANU/UART Jason Christensen INL Ian Jung NRC/NRR/DANU/UART David Holcomb Oak Ridge National Lab (ORNL)

Michelle Hayes NRC/NRR/DANU/UART Mike Poore ORNL Bob Fitzpatrick NRC/NRR/DEX/EENB Jason Andrus INL Nadim Khan NRC/NRR/DEX/EENB Rory Stanley US Senate Environment and Public Works (EPW)

Eric Bowman NRC/COMM/OCMKS Brad Williams US Senate EPW Enclosure

NAME AFFILIATION NAME AFFILIATION Shakur Walker NRC/COMM/OCMDW Ed Wallace GNBC Valerie Gray NRC/OCHCO/ADHRTD/ Prasad Kadambi Consultant NRANB Hayden Brundage NRC/OCHCO/ADHRTD/ Jenna Bergman Curtiss-Wright NRANB Derek Widmayer NRC/ACRS Donald Helton NASA Casper Sun NRC/RES/DSA/RPB Alan Levin Public Donald Palmrose NRC/NMSS/RESS Karen Cochran Public Scott Bussey NRC/OCHCO/ADHRTD/ Alex Hashemian AMS RTTB Rob Burg Engineering Planning and Alice Reener Hopewell Inc.

Management Inc.

Bruce Weir Dubose National Energy April Rice PLS Stacey Wheeler Public Don Hulting NBS National Labs 2