memorandum to: john p. segala, chief from: eric r ...contact: oesterle eric uarp/danu (301) 415-1014...
TRANSCRIPT
CONTACT: Oesterle Eric UARP/DANU (301) 415-1014
June 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 FROM: Eric R. Oesterle, 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 MAY 26, 2021, PUBLIC MEETING TO DISCUSS
TECHNOLOGY INCLUSIVE CONTENT OF APPLICATION PROJECT
On May 26, 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 NRC’s Agencywide Documents Access and Management System (ADAMS) at Accession No. ML21144A002, and the presentation slides are available at ADAMS Accession No. ML21146A088. The Enclosure 1 to this summary provides the attendees for the meeting as captured by Microsoft Teams. Meeting Highlights The meeting was in the form of a workshop. The purpose of the workshop was to discuss industry’s draft TICAP guidance document found at ADAMS Accession No. ML21106A013. Prior to the workshop the NRC staff identified a list of 23 items that were identified as topics to be discussed during this workshop and remaining TICAP workshop scheduled for May 26, 2021. The list of issues can be found at ADAMS Accession No. ML21120A057. Thirteen of the 23 items were discussed during the May 11, 2021 workshop (see meeting summary at ADAMS Accession No. ML21132A295) and seven of the 23 items were discussed during the May 19, 2021 workshop (see meeting summary at ADAMS Accession No. ML21154A290). A path forward for several of the issues discussed during workshop was identified. Enclosure 2 documents the results of the workshop in the disposition column.
J .Segala - 2 -
Two topical areas were identified during this workshop for further focused discussion towards resolution of the content of the TICAP guidance discussions needed for these topics:
Topic 9, “reliability and capability targets,” from the list found in Enclosure 2. This issue was originally identified as an outcome of the TICAP tabletop exercises that were held in the February through March 2021 time frame. The observations from these TICAP tabletop exercises can be found at ADAMS Accession No. ML21125A139.
The NRC staff noted that industry’s draft TICAP guidance document does not appear to be consistent with NEI 18-04, Rev 1, “Risk-Informed Performance-Based Technology Guidance for Non-Light Water Reactors,” (ADAMS Accession No. ML19241A336) in that the reliability and capability targets are not proposed to be captured in the safety analysis report (SAR). From the staff’s perspective the SAR should describe reliability targets and performance requirements used as input to the probabilistic risk assessment and for structures, systems and components that were used to develop the selection of special treatment requirements (i.e., programmatic actions used to maintain performance within the design reliability targets). The staff noted this information is important to capture in the SAR and in some cases could also be captured as part of technical specification requirements. From the industry’s perspective, there is a concern that placing such information in the SAR is unnecessary and would potentially create a burden from a change control process standpoint. The staff and industry agreed to discuss this issue further in a future focused meeting.
Topic 6 from the list found in Enclosure 2 associated with the development of principal design criteria (PDC). The staff believes the TICAP approach to establishing the RFDC as the PDC is too narrow. The staff believes the following statement is not correct “For plants that use the NEI 18-04 methodology, the PDC that flows from the LMP methodology and are needed to support the LMP-based safety case are based on the RSFs and the Required Functional Design Criteria (RFDC).” RFDCs are used to “supplement or modify” ARDCs in developing PDCs. RG 1.232 should be referenced since there are other PDCs that are not tied to RFDCs (e.g., ARDCs 1 through 4). NEI 18-04 4.1 Task 7 states: “RFDCs are defined to capture design-specific criteria that may be used to supplement or modify the applicable General Design Criteria or Advanced Reactor Design Criteria in the formulation of Principal Design Criteria.” Industry does not believe the intent of NEI 18-04 was to impose deterministic PDC on a risk-informed, performance-based process. The TICAP methodologies are trying to adapt the PDC concept to the affirmative safety case approach and equate the PDC to those associated with RSFs. In that approach, considering non-reactor sources could have associated RSFs and PDCs if high-consequence events might be associated with such inventories. Other issues associated with the LWR GDC or ARDC may be addressed by other parts of an application. The issue will be considered further by the staff and industry and discussed again at Workshop #3. Aspects for consideration include cross-cutting GDC/ARDC; areas outside the TICAP scope such as releases during normal operation (GDC 60); and implications of GDC imposing requirements beyond those that might be established by LMP (e.g., GDC 17 and single failure).
J .Segala - 3 -
At the end of the workshop the staff noted the dates for the remaining workshop and the target date of early June 2021 for the NRC staff to provide a complete set of comments on the industry’s draft TICAP guidance document and industry’s target of late July for providing a revision to the document. The staff noted that the list provided in Enclosure 2 are the high-level issues associated with industry’s draft guidance document. The staff informed industry that it was also developing comments embedded within the draft document that did not rise to a level to be discussed during the workshops. The staff and industry also discussed the need for a future meeting focused on resolution of Topics 6 and 9, as discussed above, and agreed to coordinate on scheduling of this during the June 2021 timeframe. Enclosure:
1. Attendance List 2. List of Topics of Discussion for TICAP Workshops
J. Segala 4
SUBJECT: SUMMARY OF MAY 26, 2021, PUBLIC MEETING TO DISCUSS TECHNOLOGY INCLUSIVE CONTENT OF APPLICATION PROJECT DATED: June 8, 2021
DISTRIBUTION: PUBLIC RidsNrrDanu Resource RidsNrrDanuUarp Resource JSegala EOesterle JSebrosky ADAMS Accession No.:ML21158A223 NRC-001
OFFICE NRR/DANU/UARP/PM NRR/DANU/UARP/BC NRR/DANU/UARP/PM NAME EOesterle JSegala EOesterle DATE 6/7/2021 6/8/2021 6/8/2021
OFFICIAL RECORD COPY
Enclosure 1
May 26, 2021, Public Meeting to Discuss Technology Inclusive Content of Application Project
Attendance List*
NAME AFFILIATION NAME AFFILIATION Nathan Sanfilippo NRC/NRR/DANU Amir Afzali Southern Company Martin Stutzke NRC/NRR/DANU Jason Redd Southern Nuclear William Reckley NRC/NRR/DANU/UARP Brandon Chisholm Southern Company John Segala NRC/NRR/DANU/UARP Mike Tschiltz NEI Prosanta Chowdhury
NRC/NRR/DANU/UARP Cyril Draffin US Nuclear Industry Council
Maryam Khan NRC/NRR/DANU/UARP George Flanagan Oak Ridge National Lab Eric Oesterle NRC/NRR/DANU/UARP Ed Wallace GNBC Associates Arlon Costa NRC/NRR/DANU/UARP Steven Nesbit LMNT Consulting Juan Uribe NRC/NRR/DANU/UARP Frank Akstulewicz A to Z Reactor Consulting
Services Amy Cubbage NRC/NRR/DANU/UARP Steve Vaughn X-energy Joe Sebrosky NRC/NRR/DANU/UARP Travis
Chapman X-Energy
Nan Valliere NRC/NRR/DANU/UARP Jim Kinsey Idaho National Laboratory (INL)
Jordan Hoellman NRC/NRR/DANU/UARP Tom King INL Stephen Philpott NRC/NRR/DANU/UARP Christopher Chwasz INL Alex Chereskin NRC/NRR/DANU/UART Tom Hicks INL Margaret O’Banion NRC/NRR/DANU/UARP Ricardo Davis-Zapata GE Power Jan Mazza NRC/NRR/DANU/UARL Dennis Henneke GE Power Mallecia Sutton NRC/NRR/DANU/UARL George
Wadkins GE Power
Hanh Phan NRC/NRR/DANU/UART Archana Manoharan
Not Available (NA)
Alexandra Siwy NRC/NRR/DANU/UARL Farshid Shahrokhi NA Michelle Hayes NRC/NRR/DANU/UART Lance Sterling NA Michelle Hart NRC/NRR/DANU/UART Bill Fowler NA Timothy Lupold NRC/NRR/DANU/UART Michael Mayfield NA Ian Jung NRC/NRR/DANU/UART Alan Levin NA Chris Van Wert NRC/NRR/DANU/UART Tom Braudt NA Boyce Travis NRC/NRR/DANU/UART Karl Fleming NA Tim Drzewiecki NRC/NRR/DANU/UART Jana Bergman NA Carolyn Lauron NRC/NRR/DNRL/NLRB Rob Burg NA Eric Bowman NRC/COMM/CS Barton Landon Pate NA Yuan Cheng NRR/NRC/DEX/EXHB Amanda Spalding NA Julie Ezell NRC/OGC Narasimha Kadambi NA Marcia Carpentier NRC/OGC Stephen Burns NA David Heeszel NRC/NRR/DEX/EXHB Parthasarathy
Chandran NA
Barbara Hayes NRC/NRR/DEX/EXHB Steven Pope NA Baindur Satyen NA Alan Jelalian NA Kamal Manoly NRC/NRR/DEX Jason Andrus NA Andrew Zach EPW Anthony Schoedel NA
2
NAME AFFILIATION NAME AFFILIATION Caroline Cochran Oklo Rachel Turney NA Chantal Morin NA
* Attendance list based on Microsoft Teams Participant list. List does not include 5 unidentified individuals that connected via phone.
Enc
losu
re 2
List
of T
opic
s of
Dis
cuss
ion
for
Tec
hnol
ogy
Incl
usiv
e C
onte
nt o
f App
licat
ion
Pro
ject
Wor
ksho
ps
Worksho
p 1
Cell color d
enotes
worksho
p in which issue
was first d
iscussed
Red font indicates
Worksho
p #3
upd
ates on
topics disc
ussed in prio
r worksho
ps
Worksho
p 2
Worksho
p 3
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 1
The constructio
n pe
rmit (CP) guidance
containe
d in th
e tw
o‐step
Licen
sing
section is no
t sufficiently detailed to
ensure con
sistent im
plem
entatio
n.
Hi
For S
ectio
ns 1.2, 1.3, 1.4, 2.4 th
ere is no
CP guidance. For
Section 2.3, simplified
and
/or q
ualitative analyses sh
ould be
available to su
pport reasonable assurance fin
dings
(examples are provide
d in App
endix C of NRC
’s Con
struction
Perm
it White Paper fo
und at ADA
MS Accession No.
ML21043A3
39)
Chapter 3
– Use of term “prelim
inary assessmen
ts.” W
hat
does th
at m
ean?
Sho
uld reference bo
unding
assum
ptions
and conservative mod
eling to accou
nt fo
r the
uncertainty in
final design de
tails. Sho
uld reference discussio
n of th
e major SSCs o
f the
facility that are intend
ed to
mitigate th
e radiological con
sequ
ences o
f a design basis
acciden
t (DB
A).
For C
hapter 4, the
staff w
ould like to
und
erstand be
tter th
e use of te
rm “prelim
inary de
scrip
tion of th
e integrated
plant
performance.”
For C
hapter 6, guidance for first o
f a kind (FOAK
) structures,
system
s and
com
pone
nts (SSCs) d
oes n
ot app
ear to be
sufficien
tly detailed to ensure consisten
t implem
entatio
n.
The CP
guidance shou
ld con
sider includ
ing a de
scrip
tion of
the research and
develop
men
t (R&
D) plans su
pportin
g the
desig
n.
The minim
um level of d
etail to supp
ort a
CP application
shou
ld be considered
for d
iscussio
n. The
CP white paper
provides th
oughts re
garding minim
um level of d
etail.
The no
n‐light water re
actor p
robabilistic
risk assessm
ent
(NLW
R PR
A) standard (A
SME/AN
S RA
‐S‐1‐4‐2021) con
tains
Worksho
p #2
Co
mmen
t 4: TICAP
reite
rated its intention to
take ano
ther look
at h
ow/if TICAP
guidance
need
s to address 5
0.43(e) (see Issue 7 from
Worksho
p 1).
Commen
t 5: TICAP
will expand guidance on
R&D plans. Currently th
is is in Sectio
n 2.3, but it
could be
expande
d to SSC
system
descriptio
ns
in Chapters 6
and
7.
Commen
t 7: TICAP
will re
vise Sectio
n 2.1.1 to
clarify
that th
e PR
A assumptions sh
ould be
available for N
RC aud
it bu
t are not re
quire
d to
be provide
d in th
e PSAR
. TICA
P will con
sider add
ing CP
guidance for
Section 2.4 as well, recognizing
that it will
necessarily be gene
ral.
TICA
P will con
sider NRC
expectatio
ns in th
e draft T
ICAP
Guidance Do
cumen
t Reg Guide
for
incorporation into th
e Guidance Do
cumen
t.
This includ
es PRA
docum
entatio
n at th
e CP
stage.
TICA
P will look
at e
arly site permit (ESP)
guidance in
Reg Guide
1.206
for p
oten
tial
application to CP guidance, but noted
that th
e inhe
rent differen
ces b
etween ESPs and
CPs m
ay
2
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n nu
merou
s sup
porting requ
iremen
ts to
docum
ent the
assumptions m
ade in lieu
of d
etailed de
sign inform
ation.
Will th
ese assumptions be iden
tified in th
e prelim
inary
safety analysis
repo
rt (P
SAR) or w
ill th
ey be provided
in th
e de
tailed PR
A inform
ation (which is only available to th
e staff via an on
site audit)? This c
ommen
t is related
to Issue
#8 below
. The staff e
xpects th
at th
e TICA
P guidance docum
ent w
ill be
used
to su
pport n
ear‐term
non
‐LWR CP
app
lications.
Discussio
ns of h
ow th
e TICA
P guidance docum
ent m
ight be
used
along
with
preapplication discussio
ns to
aid th
e ne
ar‐
term
review
s cou
ld be a topic of a worksho
p. Such an
approach cou
ld poten
tially be used
to develop
near‐term
guidance with
revised up
dated guidance being
issued
at a
later d
ate. The
revised guidance cou
ld be based on
lesson
s learne
d from
the initial con
struction pe
rmit review
s.
limit applicability. N
RC also
noted
the Clinch
River E
SP as a
possib
le re
source.
2 Source te
rm guidance might need to be
expand
ed.
Med
The source te
rm disc
ussio
n shou
ld re
quire
the attenu
ation
mechanism
s be de
scrib
ed. The
se are just as impo
rtant in
limiting
radion
uclide release as is fu
el perform
ance.
Source te
rms sho
uld be
detailed for e
ach licen
sing basis
even
t (LBE), but no confirm
atory analyses is don
e to ensure
inclusion of all source te
rms.
Worksho
p #1
TICA
P to clarify in guidance that atten
uatio
n mechanism
s are to
be de
scrib
ed.
3 The guidance in se
veral areas is to
o gene
ral to en
sure con
sistent and
adeq
uate im
plem
entatio
n, su
ch as the
use of te
rms like “relevant
phen
omen
a,” “initia
l ope
ratin
g cond
ition
s,” and “ide
ntify
treatm
ents.”
Additio
nal examples in
this area are
provided
in item
s 3a through 3d
below
.
Worksho
p #1
TICA
P acknow
ledges th
at so
me guidance can
be
made more specific bu
t the
re are limita
tions on
how sp
ecific for techn
ology inclusive guidance.
NRC
to provide
add
ition
al examples as p
art o
f written commen
ts.
3
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 3a
The guidance sh
ould be more specific
in sp
ecifying initial plant param
eters,
settings of p
rotection system
functio
ns,
meteo
rological assum
ptions,
uncertainty assumptions, and
characteristics o
f fission prod
uct
releases assum
ed in
the LBE analysis.
For m
odular nuclear pow
er re
actor d
esign; describe and
analyze the po
ssible ope
ratin
g configurations of the
reactor
mod
ules with
com
mon
system
s, interface requ
iremen
ts,
and system
interactions.
TICA
P be
lieves m
ultip
le m
odules are add
ressed
in LBE
descriptio
ns (C
hapter 3) and
interface
requ
iremen
ts and
system
interactions are
addressed in sy
stem
descriptio
ns (C
hapters 6
and 7). H
owever, TICAP
will re
view
the curren
t wording
to se
e if en
hancem
ents are warranted
.
3b
The guidance re
garding the de
fense in
depth (DID) con
tent sh
ould be
expand
ed to
add
ress th
e areas
discussed in th
e staff’s April 2020
anno
tated ou
tline
in Chapter 7 (see:
ADAM
S Accession No. M
L20107
J565)
which were de
rived
from
NEI 18‐04
Section 4.2 (DID) states that the
scop
e and conten
t of the
fin
al sa
fety analysis
repo
rt (FSA
R) are fo
cused on
presenting
results, not details of th
e process. It goe
s on to sa
y that th
e topics to
be addressed in th
e evaluatio
n of DID are fo
r backgrou
nd and
there is no
requ
iremen
t to address e
ach
topic in th
e FSAR
. Why isn’t d
iscussio
n of th
e evaluatio
n topics im
portant e
nough to be placed
in th
e FSAR
? This
provides th
e technical basis for the
DID ade
quacy
determ
ination. Other se
ctions (4
.2.1, 5.4) m
ake sim
ilar
statem
ents with
no basis.
NEI 18‐04
(Sectio
n 5.9.3) states th
at th
e adeq
uacy of D
ID is
confirm
ed whe
n the actio
ns and
decision
s (listed in 5.9.3)
are completed
by the Integrated
Decision
‐Making Process
(IDP). The
re is hardly any men
tion of th
e IDP in th
e TICA
P guidance, yet NEI 18‐04
emph
asize
s it.
Section 5.4 (Safety‐Re
lated SSCs) states in the introd
uctio
n that in iden
tifying
safety‐related
SSCs, th
e SSCs not se
lected
as sa
fety‐related
con
stitu
te one
elemen
t of P
lant Capability
DID. How
ever, the
introd
uctio
n goes on to sa
y that th
ese
DID SSCs are not design basis
inform
ation. W
hy aren't D
ID
SSCs in th
e de
sign basis? W
hat is the
basis for e
xcluding
the
inform
ation used
to se
lect th
e safety‐related
SSCs from th
e SA
R?"
TICA
P discussed de
sire to fo
cus S
AR con
tent on
results ra
ther th
an process.
NRC
to provide
specific recommen
datio
ns
whe
re add
ition
al DID con
tent is desire
d in th
e SA
R, along
with
the ratio
nale.
NRC
provide
d additio
nal com
men
ts on DID on
May 17, 2021. Respo
nse to th
ose several
commen
ts fo
llow; n
ote that th
ese issue
s were
cross‐cutting for T
opics 3
b, 10, 12.
4
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 3.b
Additio
nal N
RC DID Com
men
ts dated
May 17, 2021
TICA
P guidance docum
ent S
ectio
n 4.2 addresses d
efen
se‐in
‐de
pth (DID). It is un
clear from th
e guidance th
at an
adeq
uate level of d
etail w
ould be includ
ed in th
e SA
R regarding the evaluatio
n of DID.
Gen
eral Com
men
t Respo
nse:
‐ Multip
le com
men
ts have overlapp
ing them
es
and conten
t. TICA
P reconciliation of th
e basic
commen
ts re
quire
d to extract individu
al
points fo
r inclusio
n in TICAP
guidance
updates.
‐ TICA
P plans to up
date th
e DID guidance with
the following common
und
erstanding:
o
TICA
P DID conten
t will fo
cus o
n the fin
al
results of the
Integrated
Review Process.
o
Supp
ortin
g records w
ill con
tain add
ition
al
details of the
IDP de
liberations.
o
DID baseline conten
t, i.e. that n
ecessary
to se
t the
fram
ework for future DID
change evaluations sh
ould be provided
in
the SA
R.
o
DID topic discussio
n ou
tline
d in NEI 18‐04
will be parsed
amon
g multip
le TICAP
chapters, i.e, 3, 4, 5, 6, 7
and
8 as
approp
riate to
supp
ort the
specific topic
discussio
ns in th
ose chapters.
‐ The revised DID guidance will also
refle
ct th
e disposition
s associated with
Com
men
ts 1‐7
below.
5
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 3.b
Additio
nal N
RC DID Com
men
ts dated
May 17, 2021
Co
mmen
t 1
Add the following to Sectio
n 4.2: “Ba
seline Evaluatio
n of
Defense in Dep
th
This section shou
ld describe the “baseline” level of d
efen
se
in dep
th provide
d by th
e prop
osed
facility. This b
aseline is
establish
ed whe
n the recurring evaluatio
n of plant
capability and programmatic capability associated with
de
sign and PR
A up
date cycles n
o longer iden
tifies risk
‐sig
nificant v
ulne
rabilities w
here poten
tial com
pensatory
actio
ns can
make a practical, significant improvem
ent to the
LBE risk profiles o
r risk
‐significant red
uctio
ns in
the level of
uncertainty in characterizing
the LBE freq
uencies a
nd
conseq
uences. This b
aseline DID evaluatio
n and its outcome
are to be do
cumen
ted in su
fficien
t detail to assure th
at
future changes to
physic
al, fun
ctional, op
erational, or
programmatic fe
atures of the
facility can be
effe
ctively
evaluated for the
ir po
tential for re
duction of DID before
proceeding.”
See Gen
eral Com
men
t Respo
nse above
6
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 3.b
Additio
nal N
RC DID Com
men
ts dated
May 17, 2021
Co
mmen
t 2
Section 4.2.1 de
scrib
es SAR
con
tent guidance for p
lant
capability DID evaluatio
ns. Suggest th
e following changes to
Section 4.2.1:
“The
purpo
se of this sectio
n is to provide
a descriptio
n of
the SSCs and
the layers of d
efen
se th
ey re
presen
t in the
overall achievemen
t of an acceptable level of D
ID. The
application shou
ld describe ho
w th
e de
sign meets th
e guidelines fo
r plant capability attrib
utes provide
d in NEI 18‐
04 Table 5‐2 [“Guide
lines fo
r Establishing
the Ad
equacy of
Overall Plant C
apability Defen
se‐in
‐Dep
th”]. Sep
arate
discussio
ns of p
lant capabilitie
s that a
re re
lied up
on to
meet
these plant capability attrib
utes sh
ould be provided
in th
is section. For example, describe ho
w th
e de
sign minim
izes
the freq
uency of challenges to
safety‐related
SSCs including
controlling
abn
ormal ope
ratio
n, detectin
g failures a
nd
preven
ting de
sign basis
acciden
ts.”
Respon
se 2.1‐ See
Gen
eral Com
men
t Respo
nse
above.
Respon
se 2.2 – re
“minim
izatio
n”
The parties a
greed that m
inim
izatio
n was not
the ob
jective.
TICA
P agreed
to re
view
the “chain of e
vide
nce”
requ
ired across th
e chapters to
make sure th
e DID Attributes in NEI 18‐04
are captured in th
e vario
us guidance sections.
7
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 3.b
Additio
nal N
RC DID Com
men
ts dated
May 17, 2021
Co
mmen
t 3
Mod
ify TICAP
text in
Sectio
n 4.2.1.2 as fo
llows:
“This sectio
n shou
ld describe ho
w th
e de
sign addresses
each qualitative guideline in NEI 18‐04
Table 5‐2 fo
r each
LBE and de
scrib
e any de
partures from
the stated
criteria.
The applicant sho
uld provide a summary iden
tification of
the layers of d
efen
se fo
r each risk‐sig
nificant LBE
and
de
scrib
e the extent of ind
epen
dence be
tween diffe
rent LBE
layers of d
efen
se. The applicant sho
uld de
scrib
e for e
ach
risk‐sig
nificant LBE
how
the de
sign do
es not have an
over
reliance on
a single design feature, barrie
r, or ope
ratio
nal
feature relied up
on to
meet q
uantita
tive ob
jectives. The
crite
ria used to decide whe
ther or n
ot an over re
liance
exists sho
uld be
provide
d. The
app
lication shou
ld describe
how th
e process ide
ntifies th
e po
tential for com
mon
cause
failures a
nd how
those vulnerabilitie
s were elim
inated
. De
scrib
e ho
w th
e de
sign provides an approp
riate balance
betw
een even
t prevention and mitigatio
n in th
e layers of
defense for risk
‐significant LBE
s. The
criteria used to decide
whe
ther or n
ot th
ere is an
app
ropriate balance between
preven
tion and mitigatio
n shou
ld be provided
.”
Respon
se 3.1‐ See
Gen
eral Com
men
t Respo
nse
above.
Respon
se 3.2 – TICAP
clarified that “sin
gle
feature” evaluation wou
ld be summarize
d in
Chapter 4
. TICA
P also emph
asize
d that th
e SA
R conten
t for DID ade
quacy focused on
results
and shou
ld not have to docum
ent n
egative
findings o
f the
review
that had
no im
pact on
the de
sign or ope
ratio
nal program
s. Such
“negative fin
dings” sh
ould be available in
supp
ortin
g records o
f the
IDP.
Respon
se 3.3 – TICAP
clarified its position
on
the term
“ over‐reliance” as u
sed in th
e TICA
P guidance and
NEI 18‐04
and
the adeq
uacy of
NEI 18‐04
to deal w
ith th
is qu
alita
tive ob
jective.
Respon
se 3.4 – TICAP
iden
tified the PR
A standard and
resulting
records a
s the
source of
inform
ation for “common
cause” evaluatio
ns.
The ne
cessary conten
t is p
art o
f the
Plant
Capability evaluatio
n of LBE
s.
Respon
se 3.5 – TICAP
clarified that its a
pproach
to prevention‐mitigatio
n balance is containe
d in
the exam
ination of layers of d
efen
se. The ne
ed
for a
ddition
al guidance on
layers of d
efen
se in
Ch
apter 3
and
4 will be review
ed.
8
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 3.b
Additio
nal N
RC DID Com
men
ts dated
May 17, 2021
Co
mmen
t 4
Add ne
w te
xt to
section 4.2.1.2 as fo
llows:
“For SSCs that p
erform
prevention and mitigatio
n functio
ns
for risk
‐significant LBE
s, describe the set o
f req
uiremen
ts
related to th
e pe
rformance, reliability, and
availability of
the SSC functio
ns th
at are re
lied up
on to
ensure the
accomplish
men
t of the
ir tasks, as d
efined
by the PR
A or
determ
inistic analysis. This sectio
n shou
ld also
describe the
capability of th
ose SSCs re
lied up
on fo
r DID. This sho
uld
includ
e ho
w th
at capability is ensured
through testing,
mainten
ance, inspe
ction and pe
rformance m
onito
ring. If
this inform
ation is provided
in other se
ctions it need no
t be
repe
ated
here.”
Respon
se 4.1‐ see
related discussio
n in
Respon
se 3.5.
Respon
se 4.2‐ P
erform
ance ta
rgets a
re being
addressed un
der T
opic 9.
Respon
se 4.3 – TICAP
clarified that sp
ecial
treatm
ents are disc
ussed in Chapters 5
, 6 and
7.
9
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 3.b
Additio
nal N
RC DID Com
men
ts dated
May 17, 2021
Co
mmen
t 5
Section 4.2.2 de
scrib
es SAR
con
tent guidance for
programmatic DID evaluations. Suggest m
odifying the text
in Sectio
n 4.2.2 as fo
llows:
“Program
matic DID sh
ould be used
to add
ress uncertaintie
s whe
n evaluatin
g plant capability DID as w
ell as u
ncertaintie
s in program
matic m
easures. It sh
ould provide
the basis
for
defin
ing special treatmen
t req
uiremen
ts to
ensure there is
reason
able assurance th
at th
e pred
icted pe
rformance of
SSCs and
program
matic m
easures c
an be achieved
througho
ut th
e life of th
e plant. The
app
lication shou
ld
describ
e ho
w th
e de
sign incorporates th
e programmatic
capability attributes provide
d in NEI 18‐04
Table 5‐6 to
provide adeq
uate assurance th
at th
e risk, re
liability, and
pe
rformance ta
rgets w
ill be met and
maintaine
d througho
ut th
e life of th
e plant w
ith ade
quate
consideration of so
urces o
f significant u
ncertaintie
s. This
descrip
tion shou
ld su
pport the
disc
ussio
n of sp
ecial
treatm
ent p
rogram
s selected for safety‐sig
nificant S
SCs
describ
ed in
Chapters 6
and
7. Special treatmen
ts described
in NEI 18‐04
Table 5‐7 sh
ould be considered
, alth
ough
the
application do
es not need to add
ress item
s that a
re not
applicable. The
app
lication shou
ld describe ho
w uncertainty
in program
matic DID is add
ressed
and
how
add
ition
al
measures a
re in place to
add
ress unkno
wns.”
Respon
se 5.1‐ See
Gen
eral Com
men
t Respo
nse
above.
Respon
se 5.2‐ T
ICAP
clarified that th
e discussio
n on
uncertaintie
s related
to
evaluatin
g plant capability uncertaintie
s, not
programmatic uncertaintie
s. The
TICAP
guidance in
Chapter 4 is being
revised and will
contain additio
nal guidance on
the topic of
uncertainties.
Respon
se 5.3‐ N
RC clarified that th
e commen
t on
“un
know
ns” was re
ferring to th
e DID
attributes in NEI 18‐04
Table 5‐6.
10
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 3.b
Additio
nal N
RC DID Com
men
ts dated
May 17, 2021
Co
mmen
t 6
Add a requ
iremen
t to summarize
the integrated
decision
‐making process (IDP) which NEI 18‐04
emph
asize
s (in
Section 5.6) as “
respon
sible fo
r making the de
liberate,
affirmative de
cisio
n that DID ade
quacy has b
een achieved”.
Suggest the
following be
add
ed to
the TICA
P guidance
documen
t: “The
app
lication shou
ld su
mmarize
how
the IDP process
was app
lied in evaluating the overall ade
quacy of DID. The
de
scrip
tion shou
ld add
ress how
each of th
e de
cisio
n guidelines listed
in NEI 18‐04, Sectio
n 5.9.3, was evaluated
and the basis
for a
n affirmative respon
se. The
criteria used
in m
aking the de
cisio
ns (e
.g., risk margins are su
fficien
t, preven
tion/mitigatio
n balance is sufficien
t, etc.) sho
uld be
provided
. If q
uantita
tive measures w
ere used
as p
art o
f the
crite
ria, the
y shou
ld be provided
. A descriptio
n of how
the
results of the
IDP process a
re docum
ented and available for
future DID decision
‐making and op
erations su
pport sho
uld
also be provided
.”
Respon
se 6.1‐ T
ICAP
noted
that Chapter 4 will
focus o
n the integrated
DID re
sults not
containe
d in other chapters.
Respon
se 6.2‐ reaffirm
ed th
at th
e DID SA
R conten
t is focused
on results fo
r the
DID
baseline and that th
e results will be distrib
uted
across m
ultip
le chapters.
3.b
Additio
nal N
RC DID Com
men
ts dated
May 17, 2021
Co
mmen
t 7
Add the following to th
e en
d of se
ction 4.2:
“Evaluation and Incorporation of Changes to
Defen
se in
De
pth
The change con
trol process sh
ould be de
scrib
ed add
ressing
how th
e baseline DID evaluatio
n will be re‐evaluated
, based
on
propo
sed changes, to
determine which program
matic or
plant capability attrib
utes have be
en affe
cted
for e
ach layer
of defen
se. Changes th
at im
pact th
e de
finition
and
evaluatio
n of LBE
s, sa
fety classificatio
n of SSCs, or risk
sig
nificance of LBE
s or S
SCs m
ust b
e assessed
. This section
shou
ld also
describe ho
w any changes to
the baseline DID
evaluatio
n will be do
cumen
ted and im
plem
ented.”
Respon
se 7.1‐ T
ICAP
observed that th
e gene
ral
topic of SAR
change control w
as com
mon
to
othe
r portio
ns of the
licensing. TICAP
confirm
ed th
at th
e discussio
n of “baseline” DID
inform
ation in NEI 18‐04
was in re
cognition
of
this ne
ed.
The parties a
greed that th
e change con
trol
topic is broade
r than TICA
P.
Furthe
r disc
ussio
n of change control outsid
e of
TICA
P are anticipated
.
11
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 3c
In add
ressing the special treatmen
ts
the guidance sh
ould sp
ecify
that th
e application address the
special
treatm
ent req
uiremen
ts from
NEI 18‐
04, Table 4‐1, on a case‐by‐case basis
and in th
e context o
f the
SSC
functio
ns
in th
e preven
tion and mitigatio
n of
applicable LBE
s.
De
scrib
e safety re
lated (SR) SSC
reliability targets a
nd
performance re
quire
men
ts used as inpu
t to the PR
A for
SSCs th
at were used
to develop
the selection of sp
ecial
treatm
ent req
uiremen
ts (i.e., programmatic actions used to
maintain pe
rformance with
in th
e de
sign reliability targets).
Guidance shou
ld point to
NEI 18‐04
Table 4‐1 and
have the
applicant a
ddress th
e ite
ms in that list:
(from
NEI 18‐04, Table 4‐1, as a
pplicable)
i. Eq
uipm
ent q
ualification
ii. S
eism
ic qualification
iii. M
aterials qu
alificatio
n iv. P
re‐service and
risk‐in
form
ed in
‐service inspectio
ns
v. P
re‐op and startup testing requ
iremen
ts
vi. S
urveillance te
sting requ
iremen
ts
TICA
P will enh
ance th
e linkages b
etween special
treatm
ents in Chapters 6
and
7 and
the
programs in Ch
apter 8
. TICA
P stated
that th
e SA
R conten
t for th
e LM
P‐based affirmative safety case shou
ld fo
cus o
f the special treatmen
ts th
at were selected
through the LM
P process, vs. docum
entin
g why
special treatmen
ts were no
t selected.
3d
Similarly
, guidance discussio
n of
"optional" program
s sho
uld instead
make a clearer tie between iden
tified
special treatmen
ts and
the programs
that im
plem
ent tho
se treatm
ents
The programmatic actions used to m
aintain pe
rformance
with
in th
e de
sign reliability targets sho
uld includ
e a
descrip
tion of how
actual SSC
reliability is de
term
ined
and
compared against the
design reliability target (e
.g., as part
of th
e Mainten
ance Rule program).
TICA
P will re
visit th
e linkages b
etween special
treatm
ents and
program
s (see 3c).
NRC
clarified that optional refers to whe
ther or
not the
special treatmen
t invoking the program
was se
lected
. 4
The guidance re
ferences th
e mod
ular
high
tempe
rature gas coo
led reactor
prelim
inary safety inform
ation
documen
t (PSID) as g
uidance bu
t doe
s no
t referen
ce th
e staff’s sa
fety
evaluatio
n repo
rt on that PSID which
iden
tified gaps in
necessary con
tent.
Discuss w
hether actual guidance that is
referenced
shou
ld be placed
in th
e TICA
P guidance docum
ent instead
of
referencing the do
cumen
t
Hi
An example discussio
n from
the staff’s sa
fety evaluation
foun
d at ADA
MS Accession No. M
L052780497
is as follows:
“Som
e even
ts were no
t defined
explicitly en
ough
to
quantify prop
erly. Com
mon
‐mod
e and common
‐cause
even
ts were no
t present explicitly in th
e mod
els. Hum
an
failure events w
ere too vaguely de
scrib
ed to
determine
whe
ther th
ey were assumed
to occur before the even
t initiation or after…Most restrictive in tracing the results of
the PR
A was th
e fact th
at th
ere is no
list of b
asic events that
includ
es th
e occurren
ce probability associated
with
each
even
t.”
Worksho
p #1
The PSID re
ferences were for the
purpo
ses o
f guidance docum
entatio
n on
ly; the
safety
evaluatio
n is therefore no
t relevant to the
guidance.
TICA
P will re
visit th
e PSID examples to
upd
ate
them
or, if ne
cessary, re
place them
with
TICAP
exam
ples.
TICA
P will end
eavor to includ
e the exam
ples
directly in
the guidance ra
ther th
an re
ferencing
them
.
12
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 5
The do
cumen
t describes a m
ove aw
ay
from
com
pliance‐based applications to
a more pe
rformance‐based
app
roach.
It's n
ot clear from
these statem
ents
whe
ther app
licants will be expe
cted
to
describ
e ho
w th
ey com
ply with
the
regulatio
ns th
at are associated with
the
performance‐based
scop
e and
outcom
es of the
affirm
ative safety case
approach. regulations is an expe
ctation
for a
pplication conten
t.
Hi
The TICA
P guidance doe
s not re
quire
the NRC
regulatio
ns
applicable to
the de
sign be
iden
tified or disc
ussed. Isn’t the
pu
rpose of th
e FSAR
to dem
onstrate com
pliance with
the
applicable re
gulatio
ns?
LMP prim
arily add
resses th
e 50
.34 requ
iremen
ts to
iden
tify
even
ts, plant re
spon
se to
those even
ts, and
associated
safety m
argins. This provides an alternative to th
e LW
R‐based regulatio
ns th
at dire
ctly con
nect to
this part of 5
0.34
(50.46
requ
iremen
ts fo
r ECC
S, fo
r example). Is th
is the
basic
pop
ulation of re
gulatio
ns indu
stry is re
ferring to in
its
prop
osed
change from
“compliance‐based”?
Does th
e conten
t of this T
ICAP
guidance align with
the
NRC
’s re
gulatory app
licability assessm
ents in
“NRC
Staff
Draft W
hite Pap
er ‐ An
alysis of App
licab
ility of N
RC
Regu
latio
ns fo
r Non
‐Light W
ater Reactors”, as d
iscussed in
recent non
‐LWR stakeh
olde
r meetin
gs?
Potentially ano
ther way to
con
sider th
e affirmative safety
case app
roach is stated
in RG 1.233
as “
… sa
fety evaluations
may dem
onstrate com
pliance with
or justify exem
ptions
from
specific NRC
regulatio
ns and
iden
tify whe
re design‐
specific regulatory con
trols a
re warranted
.” A
n application
will need to add
ress th
e results from
the safety case in
term
s of w
here current re
gulatio
ns do no
t con
tribute to
safety (e
xemptions) o
r whe
re current re
gulatio
ns are
lacking (add
ition
al re
quire
men
ts). W
hereas th
e safety case
shou
ld fo
cus o
n satisfying subject fun
ctions, it w
ould be
useful to
agree
on a form
at fo
r com
pliance/exem
ption
discussio
ns, be they embe
dded
, in a table, or o
ther fo
rmat.
Worksho
p #2
TICA
P will re
visit wording
of “compliance‐
based” in
the Guidance Do
cumen
t (p. 4 und
er
“Scope
”) to
ensure there is no
uninten
ded
implication that a TICAP
app
lication is no
t requ
ired to com
ply with
regulatio
ns.
13
6 The guidance fo
r inclusio
n of prin
cipal
desig
n crite
ria (P
DC) m
ay be
incomplete, since on
ly "LM
P ou
tcom
es"
are addressed, and
other to
pics from
Part 50 Ap
p. A (like Mon
itorin
g Fuel &
Waste Storage) are not clearly includ
ed
for con
sideration
Hi
This statem
ent is n
ot correct “For p
lants that u
se th
e NEI
18‐04 metho
dology, the
PDC
that flow
s from th
e LM
P metho
dology and
are neede
d to su
pport the
LMP‐based
safety case are based on
the RSFs and
the Re
quire
d Functio
nal D
esign Crite
ria (R
FDC).” RFD
Cs are used to
“sup
plem
ent o
r mod
ify” AR
DCs in de
veloping
PDC
s. RG
1.232 shou
ld be referenced
since there are othe
r PDC
s that
are no
t tied to RFD
Cs (e
.g., AR
DCs 1
through 4).
Section 5.3 seem
s to im
ply that PDC
s are only for D
BEs a
nd
DBAs. W
hat d
esign crite
ria are app
lied to add
ress BDB
Es?
Section 5.3: “For p
lants that u
se th
e NEI 18‐04
metho
dology, the
PDC
that flow
s from th
e LM
P metho
dology and
are neede
d to su
pport the
LMP‐based
safety case are based on
the RSFs and
the Re
quire
d Functio
nal D
esign Crite
ria (R
FDC)”
Section 5.6: “Thus, the
PSA
R conten
t for Chapter 5 sh
ould
includ
e functio
nal decom
position of FSFs to RSFs, a
prelim
inary set o
f RFD
C/PD
C with
perform
ance‐based
crite
ria”
From
NEI 18‐04
4.1 Task 7: “RFDC
s are defined
to capture
desig
n‐specific crite
ria th
at m
ay be used
to su
pplemen
t or
mod
ify th
e applicable Gen
eral Design Crite
ria or A
dvanced
Reactor D
esign Crite
ria in
the form
ulation of Prin
cipal
Desig
n Crite
ria.”
The TICA
P metho
dologies are trying
to adapt th
e PD
C concep
t to the affirmative safety case approach and
equ
ate
the PD
C to th
ose associated
with
RSFs. In that app
roach,
considering no
n‐reactor sou
rces cou
ld have associated
RSFs
and PD
Cs if high‐conseq
uence even
ts m
ight be associated
with
such inventories. O
ther issues associated with
the
LWR GD
C or ARD
C may be addressed by other parts of an
application.
Worksho
p #2
NRC
believes the
TICAP
app
roach to
establish
ing the RFDC
as the
PDC
is to
o narrow
. TICA
P do
es not believe th
e intent of N
EI 18‐04
was to
impo
se deterministic PDC
on a risk‐
inform
ed, perform
ance‐based
process.
The issue
will be considered
furthe
r by TICA
P and NRC
and
disc
ussed again at W
orksho
p #3.
Aspe
cts for con
sideration includ
e cross‐cutting
GDC
/ARD
C; areas outsid
e TICA
P scop
e such as
releases during no
rmal ope
ratio
n (GDC
60); and
im
plications of G
DC im
posin
g requ
iremen
ts
beyond
those that m
ight be establish
ed by LM
P (e.g., GDC
17 and sin
gle failure).
A future con
versation will be he
ld between
TICA
P and NRC
/INL staff regarding
the
defin
ition
of P
rincipal D
esign Crite
ria (P
DC) in
Appe
ndix A of 1
0 CFR Part 50 and the most
efficient way fo
r TICAP
PDC
to com
ply with
existing regulatio
ns while not losin
g the
advantages provide
d by an RIPB
app
roach. One
specific aspe
ct to
disc
uss is the
amou
nt of
specificity (i.e., ho
w detailed a PD
C must b
e)
that is app
ropriate and
/or req
uired for the
set
of PDC
(e.g., are de
rived
requ
iremen
ts
necessary to be iden
tified as PDC
?).
14
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 7
The guidance includ
es a re
quire
men
t to
includ
e testing/qu
alificatio
n plans for
first‐of‐a
kind (FOAK
) safety‐related
SSCs fo
r CP applications. This
requ
iremen
t is reflected
in 50.43
(e),
and also app
lies to the othe
r types of
applications covered
in th
e guidance
(COL, DC, OL) but is not disc
ussed in th
e guidance fo
r tho
se other app
lication
type
s.
Hi
50.34(e)(1)(i): “The pe
rformance of e
ach safety fe
ature of
the de
sign has b
een de
mon
strated through either analysis,
approp
riate te
st program
s, experience, or a
com
binatio
n thereo
f”
50.43(e) re
quire
s app
licants to
provide
the collection of
analyses, tests, O
E, etc. necessary to
assure the expe
cted
pe
rformance of “safety fe
atures”. D
oes this “
safety
feature” re
quire
men
t app
ly to
both SR
and
NSRST SSCs?
Chapters 6 & 7 of the
SAR
in an application wou
ld re
flect
the requ
ired capabilities o
f SR and NSRST SSCs. W
here
wou
ld th
e proo
f of tho
se capabilitie
s be provided
to add
ress
50.43(e)? (It’s noted
that th
is topic is called ou
t for FOAK
SR
SSCs re
flected
in tw
o‐step
CP applications, but th
e do
cumen
t seems to be
silent on the issue
for D
C, COL, M
L).
Worksho
p #1
NRC
believes that 5
0.43(e) testin
g is inhe
rently
fund
amen
tal to the safety case and shou
ld
therefore be
includ
ed und
er TICAP
guidance.
TICA
P be
lieves that the
NEI 18‐04
metho
dology
does not encom
pass th
e 50
.43(e) re
gulatio
n,
but that results of 5
0.43(e) testin
g wou
ld likely
appe
ar in
the technical justifications su
pportin
g the safety case (e.g., be
nchm
ark data fo
r compu
ter cod
es used to analyze DBA
s).
This is an
example of disa
greemen
t on the
scop
e of th
e TICA
P guidance. Ad
ditio
nal clarity
with
respect to scop
e and NRC
expectatio
ns will
be neede
d.
Nevertheless, TICAP
will ta
ke ano
ther look
at
whe
ther and
, if so, how
the 50.43(e) te
sting
could be
add
ressed
by TICA
P.
TICA
P will m
odify
its g
uidance to re
flect th
at it
is no
t just C
Ps but DCs and
COLs th
at m
ay
invoke FOAK
testing as sp
ecial treatmen
ts.
Disposition
is as d
iscussed on
the slide
s for
worksho
p #3
‐ mod
ificatio
n of guidance for
Chapters 2, 6, and
7 as ind
icated
. If the
NRC
de
sires a sp
ecific section in th
e SA
R coverin
g a
50.43(e) te
st program
, NRC
will develop
guidance fo
r that sectio
n. TICAP
believes the
approp
riate locatio
n for such a section wou
ld
be SAR
Chapter 2.
15
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 8
The level of d
etail in the SA
R,
supp
ortin
g inform
ation placed
on the
docket, and
inform
ation that is
available for a
udit were iden
tified as
potential items for fu
rthe
r disc
ussio
n du
ring the TICA
P tabletop
exercise
s.
Durin
g the TICA
P tabletop
exercise
s it
was also
noted
that th
ere is a
distinction be
tween ite
ms incorpo
rated
by re
ference (IB
R) into th
e SA
R and
references to
the SA
R. IBR
’d item
is
considered
to be part of the
licensing
basis
for the
plant.
Hi
Discuss that if the
staff relies o
n something
they re
view
as
part of an audit to make their safety fin
ding, that the
specifics of that item th
en need to be elevated
into th
e FSAR
or a
n IBR do
cumen
t?
Make clear that rep
orts th
at are IB
R’d are part of the
licen
sing basis
and
change control process.
Section 1.2 states th
at th
e site attributes re
levant to
the
safety case are in Chapter 2. The
re is no site inform
ation in
Chapter 2
. There is no
men
tion of fu
el qualification.
RG 1.233
provide
d clarificatio
ns in
certain areas. D
oes the
TICA
P guidance docum
ent inten
d to includ
e these?
Worksho
p #1
TICA
P un
derstand
s that N
RC citing
an ite
m in
an
audit rep
ort d
oes n
ot put th
at in
the licen
sing
basis.
TICA
P confirm
ed th
at IB
R in th
e SA
R makes th
e inform
ation in th
e IBR reference part of the
licen
sing basis
and
subject to the NRC
change
control processes.
TICA
P explaine
d that th
e reference to site
inform
ation in Chapter 2 is based
on the
unde
rstand
ing that ARC
AP will add
ress site
inform
ation there.
The treatm
ent o
f fue
l qualification will be
discussed in ARC
AP/TICAP
disc
ussio
ns in
Worksho
p #3.
16
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 9
Durin
g the discussio
n of non
‐safety
related with
special treatmen
t (NSRST)
structures, systems, and
com
pone
nts
(SSC) SAR
con
tent, the
NRC
staff raised
a qu
estio
n regarding whe
re th
e reliability inform
ation for the
se SSCs
wou
ld be located (e.g., PR
A or SAR
) and
what this information might entail. The
NRC
staff b
elieves further disc
ussio
n on
this topic wou
ld be be
neficial.
TICA
P stated
that th
e applicant is
respon
sible fo
r ensuring it is addressin
g Re
g Gu
ide 1.233 includ
ing clarificatio
ns
and lim
itatio
ns th
erein. TICAP
doe
s not
see much daylight between NEI 18‐04
and Re
g Guide
1.233
.
Hi
SAR shou
ld describe reliability targets a
nd perform
ance
requ
iremen
ts used as inpu
t to the PR
A for S
SCs that w
ere
used
to develop
the selection of sp
ecial treatmen
t requ
iremen
ts (i.e., programmatic actions used to m
aintain
performance with
in th
e de
sign reliability targets).
Section 6.2 states th
at th
e SSC reliability and availability
inform
ation will not be in th
e FSAR
. This is d
esign basis
inform
ation that is neede
d for d
etermining the
effectiven
ess o
f the
mainten
ance program
, the
reliability
assurance program and
the ISI/IST programs. W
hat is the
basis
for e
xcluding
it from
the FSAR
? Section 7.1 de
fines NSRST sp
ecial treatmen
t req
uiremen
ts,
no tie to perform
ance ta
rgets
Section 8 plant p
rogram
s has “special treatmen
ts fo
r SR
SSCs and
NSRST SSCs m
ay involve programs relied up
on to
provide reason
able assurance”
The introd
uctio
n to Chapter 6 sa
ys “ This further detail
[Chapter 6] include
s SRD
C, re
liability and capability
performance‐based
targets, and
special treatmen
t requ
iremen
ts to
provide
sufficien
t con
fiden
ce th
at th
e pe
rformance‐based
targets inten
ded in th
e de
sign will be
achieved
in th
e constructio
n of th
e plant a
nd m
aintaine
d througho
ut th
e licen
sed plant life
. This statem
ent a
ppears
to su
pport that the
se ta
rgets sho
uld be
in SAR
. It may be acceptable to
point to
whe
re th
e inform
ation
resid
es (e
.g., reliability assurance program) versus p
uttin
g actual re
liability assumptions in th
e SA
R.
Worksho
p #1
NRC
believes the
reliability targets sho
uld be
provided
in th
e SA
R. N
RC notes th
at NEI 18‐04
stated
“…the reliability and capability targets
for S
R and NSRST SSCs, and
special treatmen
t requ
iremen
ts fo
r SR and NSRST SSCs d
efine
safety‐significant a
spects of the
descriptio
ns of
SSCs th
at sh
ould be includ
ed in sa
fety analysis
repo
rts.” NRC
furthe
r believes the
inform
ation
shou
ld be in th
e SA
R.
TICA
P be
lieves the
targets sho
uld be
owne
r‐controlled inform
ation, not m
aintaine
d in th
e SA
R. TICAP
ackno
wledges th
e NEI 18‐04
statem
ent b
ut believes T
ICAP
guidance
specifically fo
r the
SAR
can
supe
rsed
e NEI 18‐04
statem
ents on SA
R conten
t. TICAP
acknow
ledges th
at one
in th
e draft g
uidance
(introd
uctio
n to Chapter 6) is n
ot aligne
d with
the TICA
P po
sition, but th
at statem
ent w
as
mistaken
ly includ
ed in
the Ap
ril 15, 2021 draft
guidance.
TICA
P and NRC
will con
sider th
e issue
furthe
r and revisit it at W
orksho
p 3.
TICA
P acknow
ledges th
e ne
ed to
be consisten
t with
the guidance in NEI 18‐04. The NRC
and
the TICA
P Team
plan to have a focused follow‐
up m
eetin
g on
the topic, probably in th
e mid‐
June
time fram
e.
17
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 10
The SA
R conten
t sho
uld focus o
n presen
ting the results of implem
entin
g the LM
P process. For disc
ussio
n pu
rposes, it m
ay be be
neficial to
discuss w
hat type of docum
entatio
n may exist from
implem
entin
g the LM
P process b
y the applicant, includ
ing
narrative on
the ite
ratio
ns in th
e process, and
the de
liberations and
de
cisio
ns of the
integrated
de
cisio
nmaking process (IDP) and
whe
ther th
is do
cumen
tatio
n may be
something
that is aud
ited by th
e NRC
staff.
Hi
The de
scrip
tion shou
ld add
ress each of th
e de
cisio
n guidelines described
in Sectio
n 5.9.3 of NEI 18‐04, including
the basis
for con
clud
ing the guideline has b
een met. For
those guidelines whe
re a quantita
tive measure can
be
provided
, tho
se m
easures u
sed in th
e de
cisio
n‐making
shou
ld be provided
. Num
erou
s places in 18
‐04 de
tail do
cumen
tatio
n ne
eds for
bases o
r decision
s. The
TICAP
repo
rt sh
ould highlight what
is do
cumen
ted in a TR, and
what is in the SA
R
Related to item
8
Worksho
p #1
See disposition
of add
ition
al NRC
DID
commen
ts und
er Issue 3b
.
18
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 11
NEI 18‐04
(Sectio
n 3.2.2 – Task 6) states
that, w
here possib
le, external events
are to be analyzed
in th
e PR
A bu
t, in
some cases, m
ay be selected
and
treated de
term
inistically. The
re is no
discussio
n in th
e TICA
P guidance
documen
t abo
ut how
to se
lect and
treat e
xternal events selected using a
determ
inistic app
roach. Accordingly,
the VT
R repo
rt did not add
ress th
is topic.
Hi
There is Note on
Page 51
that re
ads “
Note: The
de
velopm
ent o
f the
DBE
HLs is a
ddressed
by AR
CAP and
summarize
d in SAR
Chapter 2.
Section 6.1.1 states th
at th
e de
sign on
ly needs to
protect
against e
xternal hazards with
a freq
uency greater than 1 E‐
4/yr. D
oes this e
xclude
BDB
E external hazards from
consideration?
Section 2.2 includ
es external events in the PR
A. How
are
determ
inistically se
lected
external events a
ddressed
in th
e PR
A?
Additio
nally, incorpo
ratio
n of external hazards into th
e LBE
determ
ination process lacks basis and de
tail in 18‐04
and
the TICA
P do
cumen
t. Prop
osed
10 CFR 53
.510(a) sets the
design basis
external
hazard levels (DBH
ELs) at 1
E‐5/plant‐year. RG
1.208
(seism
ic) e
stablishe
s the
site‐spe
cific groun
d motion
respon
se sp
ectrum
(GMRS) such that th
e freq
uency of
significant ine
lastic deformation (FOSID) is 1E‐5/y. RG 1.76
(tornado
s) and
RG 1.221
(hurricanes) set DBH
ELs a
t 1E‐7/y.
Worksho
p #2
TICA
P will con
sider add
ition
al guidance in
Section 6.1.1 to clarify the de
term
inistic
selection of DBE
HLs.
TICA
P will con
sider add
ition
al guidance in
Chapter 3
abo
ut incorporation of external
hazards into the LBE de
term
ination process.
TICA
P will con
sider ty
pical information in
Chapter 3
of LWR SA
Rs and
determine if the
level of d
etail in Section 6.1.1 shou
ld be
enhanced
.
12
The discussio
n of DID in
Sectio
n 4.2 of a
SAR de
velope
d using the TICA
P guidance is a goo
d cand
idate for
discussio
n as part o
f the
upcom
ing
worksho
ps with
the NRC
/INL staff.
Hi
Section 4.2 it states “Note that th
e above inform
ation
[top
ics listed
in NEI 18‐04
Table 5‐1] is p
rovide
d for
backgrou
nd, and
there is no
requ
iremen
t to address e
ach
topic in th
e SA
R material.” How
doe
s an applicant a
ddress
this?
Related to one
of the
sub‐bu
llets in
item
3 –
Worksho
p #1
See disposition
of add
ition
al NRC
DID
commen
ts und
er Issue 3b
. 13
Ba
sed on
internal disc
ussio
n with
the
staff –
believe a disc
ussio
n of prin
cipal
desig
n crite
ria guidance em
bedd
ed in
draft ind
ustry do
cumen
t is a
ppropriate
in accordance with
eVinci TICAP
tabletop
exercise
com
men
ts
HI
Note that th
e guidance m
ore accurately re
flects the
NEI 18‐
04 PDC
develop
men
t than was perform
ed by eV
inci.
Worksho
p #2
No ite
ms ide
ntified
for d
isposition
specific to
this issue
. PD
C issue
s are being
covered
und
er
Issue 6.
19
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 14
Cu
rren
tly th
e scop
e of th
e TICA
P guidance docum
ent covers o
nly CO
Ls.
The scop
e of th
e TICA
P guidance
documen
t sho
uld be
expande
d to
includ
e applicability fo
r OL applicants
unde
r Part 5
0 and the supp
lemen
tal
guidance fo
r the
two‐step
licensing
process sho
uld be
limite
d to just CP
applicants.
Hi
The guidance docum
ent n
eeds to
also
add
ress sc
opeo
f ESP,
DC and
ML applications. Re
garding ESPs, the
staff b
elieves
an app
licant u
sing the TICA
P guidance m
ight leverage
inform
ation from
an ESP in develop
ing their a
pplication
(e.g., inform
ing the DB
EHL de
term
ination).
The level of d
etail and
design maturity
for a
n OL application
is expe
cted
to be the same as fo
r a COL applicant. By
incorporating this commen
t the
guidance for C
P applicants
can be
made more clear a
nd sp
ecific – curren
tly th
e en
tries
unde
r the
Two Part Licen
sing Process a
re con
fusin
g,
inaccurate in so
me places, and
lack sp
ecificity in others.
On 4/2/2021, N
EI su
bmitted
com
men
ts (M
L21092A1
15) o
n the draft C
P ISG. One
com
men
t stated that “… th
e NRC
shou
ld not be requ
iring
that th
e de
sign and analysis for a
CP
A be
at the
same level of com
pletion as fo
r a COLA.” This
diffe
rs from
the TICA
P statem
ent.
Worksho
p #1
TICA
P to con
sider changes to
clarify that
alternative licen
sing paths two‐step
licensing
guidance is app
licable to
the CP
, not to
the OL,
and that th
e baseline TICA
P guidance is
applicable to
the OL.
NRC
to provide
details of examples of T
ICAP
guidance dep
artin
g from
NEI position
s as stated
in NEI com
men
ts on the draft con
struction
perm
it Interim
Staff Guidance.
15
For sup
plem
ental guidance for D
esign
Certificatio
ns th
ere are no
entrie
s for
several sectio
ns. Need to clarify intent
for the
se no en
tries (I.e., guidance
provided
for C
OLs app
lies) or if
additio
nal disc
ussio
n is intend
ed
Med
Similar to #14, all licen
ses sho
uld be
covered
Worksho
p #1
TICA
P clarified
that no en
try for D
C means no
adjustmen
ts to
the baseline guidance fo
r DCs.
16
For sup
plem
ental guidance for D
esign
Certificatio
ns, it a
ppears th
at perhaps
only limite
d DID adeq
uacy assessm
ents
might be able to
be pe
rformed
due
to
the fact th
at th
e expe
ctations on
operational program
descriptio
ns fo
r DC
app
licants is not equ
ivalen
t to CO
L applicants. May also
have some im
pact
on iden
tification of sp
ecial treatmen
ts.
DC
s sho
uld address D
ID as p
art o
f the
design includ
ing
iden
tification of neede
d special treatmen
ts. The
only
diffe
rence from
a COL is the de
velopm
ent o
f the
op
erational program
descriptio
n which wou
ld not be
expe
cted
in a DC.
Worksho
p #1
TICA
P will re
vise guidance as neede
d to re
flect
DC adjustm
ents due
to th
e fact th
at DC do
es
not a
ddress ope
ratin
g plant‐specific topics.
17
The TICA
P guidance docum
ent refers to
“licen
sing basis”, how
ever, the
re is a
Med
The staff n
otes th
at th
is issue
cou
ld be considered
as P
art
53 language is develop
ed fo
r Sub
part H and
I.
Worksho
p #3
20
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n de
finition
of “curren
t licen
sing basis”
containe
d in 10 CFR 54
.3 which was
necessita
ted by license rene
wal.
Shou
ld a re
ference to th
at definition
be
includ
ed in th
e guidance or sho
uld that
defin
ition
be revisited
and
rede
fined
for the
purpo
ses o
f use of the
LMP
approach or for inclusion in Part 5
3 for
that m
atter. Que
stion for d
iscussio
n is
whe
ther or n
ot th
e de
finition
needs to
be
mod
ified
for the
purpo
ses o
f this
guidance docum
ent o
r other advanced
reactor g
uidance do
cumen
ts?
TICA
P did no
t take issue
with
the basic
de
finition
of current licensing basis
in
10CFR5
4.3. TICAP
doe
s not plan to includ
e a
licen
sing basis
definition
or referen
ce in
the
TICA
P Guidance.
[Note: TICAP
indicated that it wou
ld ta
ke a
furthe
r loo
k at th
e use of th
at definition
more
broadly and its basis wou
ld have any
unintend
ed con
sequ
ences if the
definition
was
used
outsid
e the scop
e of Part 5
4. This review
was ta
rgeted
for com
pletion by
mid‐Ju
ne.]
18
There shou
ld be alignm
ent o
n the
prop
osal to
not includ
e licen
sing basis
inform
ation in Chapter 1. The pu
rpose,
I think, is to also exclude
Chapter 1 fo
r the change process and
redu
ce fu
ture
regulatory burde
n. H
owever, our
curren
t con
cept of the
change process
is 10
CFR
50.59
and
it is not clear as to
what the
change process u
nder Part 5
3 might be.
Need to align on
the prop
osal th
at Chapter 1 is not licensing
basis
inform
ation w/o having a clear d
efinition
of “licen
sing
basis” for LMP‐based SA
Rs or e
ven what the
change process
wou
ld entail.
Worksho
p #3
TICA
P to re
view
chapter 1 and
the use of
“licen
sing Ba
sis” term
inology to se
e ho
w it can
clarify
that Chapter 1 is not so
meh
ow exclude
d from
the 50
.59 change process since it is a part
of th
e FSAR
. This sho
uld be
don
e in th
e context
of our re
view
of Issue
17 which is also
focused
on “licen
sing basis” and the de
finition
in
10CFR5
4.3.
19
Several sectio
ns re
fer to tables in
the
LMP Tabletop
Exercise
Rep
ort o
r to
useful guidance in th
e MHT
GR PSID
documen
t. (ERO
)
Hi
It wou
ld be more useful to
includ
e the tables and
useful
guidance re
ferred
to with
in th
e TICA
P guidance docum
ent.
Worksho
p #1
See Disposition
of Issue
#4
21
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 20
Arou
nd W
orksho
p #3, the
staff is
considering discussio
n of a draft TICAP
RG
and
an AR
CAP roadmap
ISG to
start
the discussio
n on
how
indu
stry’s
guidance is envision
ed to
fit w
ithin
TICA
P and the staff’s initial th
inking
on
whe
re indu
stry’s TICAP
guidance is
envisio
ned to be supp
lemen
ted (e.g.,
fuel qualification, ASM
E Section III
Divisio
n 5, design review
guide
for I&C)
Med
Worksho
p #3
The NRC
will con
sider th
e TICA
P commen
ts as
provided
on the Worksho
p #3
TICAP
slides as it
continue
s to de
velop its ARC
AP ISG and
TICAP
Re
g Gu
ide.
21
The term
“safety case” is not currently
used
in NRC
licensing processes.
Hi
TICA
P page 4 states “The term
safety case is a collection of
statem
ents th
at, if con
firmed
to be true
by supp
ortin
g technical information, establishe
s reasonable assurance of
adeq
uate protection for o
peratio
n of th
e nu
clear p
ower
plant d
escribed
in th
e application.” TICAP
Figure 1 on
page
6 show
s the
relatio
n be
tween TICA
P and an
advanced
reactor licen
se app
lication; sp
ecifically, the
affirm
ative
safety case addressed by TICAP
is necessary, but not
sufficien
t, to establish reason
able assurance of ade
quate
protectio
n. N
eed alignm
ent o
n what a
safety is and
, equ
ally
impo
rtant, what it is n
ot.
No ite
ms ide
ntified
for d
isposition
specific to
this issue
.
22
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 22
The staff h
as provide
d indu
stry with
a
list o
f NRC
observatio
ns from
the TICA
P tabletop
exercise
s. To date, ind
ustry’s
feed
back on these ob
servations has
been
limite
d to th
e first tw
o TICA
P tabletop
exercise
observatio
ns. The
NRC
staff w
ould be interested
in
indu
stry’s fe
edback on the NRC
ob
servations fo
r the
last tw
o TICA
P tabletop
exercise
s (i.e., the eV
inci
microreactor, and the molten chlorid
e reactor e
xperim
ent (MCR
E)). In
particular, the
NRC
staff w
ould be
interested
in whe
ther indu
stry
iden
tifies p
oten
tial w
orksho
p ite
ms
from
eVinci and
MCR
E TICA
P tabletop
exercises that a
re not captured in th
e ite
ms ide
ntified
abo
ve.
Hi
Worksho
p #3
TICA
P has n
ot iden
tified additio
nal items for
discussio
n which have no
t alre
ady be
en covered
by
other Issues.
23
Issue
# To
pic
Priority
Commen
ts
Dispo
sitio
n 23
The NRC
staff finds th
at add
ition
al
inform
ation and clarity
on PR
A is
need
ed in
the TICA
P guidance.
Hi
In Sectio
n 2.1.1, th
e overview
of P
RA needs add
ition
al
clarity
regarding pe
er re
view
, the
use of “technically
adeq
uate PRA
’, the level of d
etails, and
so on. In add
ition
, PR
A for con
struction pe
rmit applications needs disc
ussio
n with
the NRC
staff since th
ere is on
going discussio
ns on the
subject a
s part o
f the
NRC
staff’s ongoing
develop
men
t of
guidance on constructio
n pe
rmit.
In Sectio
n 2.1.2, th
e summary of key PRA
results sh
ould
includ
e othe
r information such as k
ey assum
ptions, the
results and
insig
hts from im
portance, sen
sitivity
, and
un
certainty analyses, and
so on.
Althou
gh other Chapters (i.e., Ch
apter 3
and
4) include
some of th
e PR
A results or insights (such as risk
‐significant
SSCs, hum
an actions, etc.), it m
ay be useful to
have these
key results und
er Sectio
n 2.1.2 to have the compreh
ensiv
e PR
A results in
one
place. Alte
rnatively, a se
t of p
ointers
(not at the
Chapter level) at th
e individu
al to
pic areas m
ay
be includ
ed in Sectio
n 2.1.2.
No ite
ms ide
ntified
for d
isposition
specific to
this issue
.
The NRC
may provide
specific written
commen
ts re
lated to th
is issue
.
It is no
ted that th
e NRC
recently upd
ated
CP
guidance re
garding no
n‐LW
R de
signs and
PRA
s;
the CP
angle is add
ressed
und
er Issue #1.