ML21274A032
| ML21274A032 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/2021 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Sebrosky J | |
| Shared Package | |
| ML21274A029 | List: |
| References | |
| NEI 18-04, NEI 21-07, Rev 0 | |
| Download: ML21274A032 (13) | |
Text
APPENDIX X NRC REGULATORY POSITION ON NEI 21-07, REVISION 0, TECHNOLOGY INCLUSIVE GUIDANCE FOR NON-LIGHT WATER REACTORS SAFETY ANALYSIS REPORT CONTENT FOR APPLICANTS USING THE NEI 18-04 METHODOLOGY
Introduction
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed Nuclear Energy Institute (NEI) 21-07, Revision 0, Technology Inclusive Guidance for Non -Light Water Reactors Safety Analysis Report Content for Applicants Using the NEI 18-04 Meth odology. The purpose of this appendix is to supplement the Regulatory Positions discussed in Regulatory Positions C.1 through C.8 of this RG. The staffs detailed position on that applicable portions of NEI 21-07, Revision 0 are found in the following table. The table notes a reas where the staff has identified an exception, clarification, addition, or comment/sugges ted edit. The definition of these terms is as follows:
- Exception - feedback labeled as an NRC Except ion is used to highlight statements, or portions thereof, in NEI 21-07 that are factually incorrect or guidance that would result in the need for an NRC Request for Additional Information (RAI) if fol lowed by an applicant in developing a safety analysis report (SAR).
- Clarification - feedback labeled as an NRC Clarification is used to indicate statements or guidance in NEI 21-07 that are ambiguous and would require clar ification by the NRC to limit the possible interpretations by an applicant or other stakehold er consulting NEI 21-07. An applicant relying on NEI 21-07 to develop an application in the absence of the Clarification would likely be subject to RAIs if the guidance was improperly interpreted. Similarly, stakeholders consulting NEI 21-07 in the absence of the Clarifi cation could conclude that publicly available application information is inadequate to the extent that it could form the basis for a contention.
- Addition - feedback labeled as an NRC Addition is used to indicate staf f regulatory guidance that should be followed by an applicant in addition to the guidance in NEI 21-07 in order to develop a SAR that addresses their safety case. Addit ions not related to the LMP-based affirmative safety case will be included in the ARCAP gui dance.
1