This month, the NRC published an early draft regulatory guide on the content of license applications for non-LWRs.  The document is designed to help license applicants apply the NRC’s movement towards a risk-informed/performance-based regulatory approach towards the drafting of an actual license application.

The document is in part the result of the Southern Company-led Licensing Modernization Project, which has resulted in the issuance of a number of informal reports discussing licensing reform for non-LWR reactors.  This draft regulatory guide is designed to more formally capture the results of those reports and follow-on discussions.   It addresses the designation of licensing basis events; safety classification and performance criteria for structures, systems, and components; and evaluation of defense in depth adequacy.  importantly, it largely adopts detailed draft industry guidance set forth in March of this year, although with certain clarifications.  One area of particular NRC focus concerns probabilistic risk analyses (“PRA”), where the agency appears to show a little hesitancy with the broad use of PRA proposed in the industry guidance.

The draft guidance is being issued to support future discussions, in particular an Advisory Committee on Reactor Safeguards meeting tentatively scheduled for October 30, 2018.

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