NUREG-1855, Summary of 7/18/19 Public Meeting with Nuclear Energy Institute to Discuss Application of NUREG-1855, Guidance on the Treatment of Uncertainties Associated with PRAs in Risk-Informed Decision Making

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Summary of 7/18/19 Public Meeting with Nuclear Energy Institute to Discuss Application of NUREG-1855, Guidance on the Treatment of Uncertainties Associated with PRAs in Risk-Informed Decision Making
ML19203A293
Person / Time
Issue date: 08/20/2019
From: Geoffrey Miller
Special Projects and Process Branch
To: Michael Orenak
Special Projects and Process Branch
Miller G
References
Download: ML19203A293 (6)


Text

MEMORANDUM TO:

FROM:

SUBJECT:

UNITED STATES WASHINGTON, D.C. 20555-0001 August 20, 2019 Michael D. Orenak, Acting Chief Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation G. Edward Miller, Project Manager Special Projects and Process Branch Division of Operating Reactor Licens1 Office of Nuclear Reactor Regulation

SUMMARY

OF JULY 18, 2019, PUBLIC MEETING WITH NUCLEAR ENERGY INSTITUTE REGARDING NUREG-1855, "GUIDANCE ON THE TREATMENT OF UNCERTAINTIES ASSOCIATED WITH PRAS IN RISK-INFORMED DECISION MAKING" On July 18, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting1 with representatives from the Nuclear Energy Institute (NEI). The purpose of the meeting was to discuss usage and interpretation of NUREG-1855,2 "Guidance on the Treatment of Uncertainties Associated with PRAs [Probabilistic Risk Assessments] in Risk-Informed Decision Making."

During the meeting, the NRC staff presented slides that provided feedback from NRC staff to industry about the regulatory guidance that the NRC staff uses to review whether the licensee has appropriately identified and resolved key assumptions and sources of uncertainty in licensing submittals.3 In a subsequent discussion following an industry question about what specifically the NRC staff needs in a license amendment request (LAR). The NRC staff noted that a simple statement that the high level, generic guidance in NUREG-1855 was followed and that no key assumption or sources of uncertainty were identified provide insufficient information to support a conclusion that the licensee have identified all key assumptions and sources of uncertainty for a specific application. Conversely, if a reasonable application-specific discussion about how the licensee has identified and evaluated its assumptions and source of uncertainty is included in the LAR, then there is specific information that can be reviewed to support a conclusion that the licensee has appropriately addressed uncertainties. Alternatively, if the LAR includes detailed evaluations about the potential impact on the specific risk-informed application for a number of specific assumptions, then there is also specific information about the licensees process to identify and evaluate uncertainties that can be reviewed to support a conclusion that the licensee has appropriately addressed uncertainties. Industry proposed that 1 The original meeting notice is available in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML19171A282.

2 NUREG-1855 is available under ADAMS Accession No. ML17062A466.

3 The NRC slides are available under ADAMS Accession No. ML19198A342.

application-specific guidance should be developed that could be used (and referenced) in an LAR; the NRC staff agreed that application-specific guidance would be very useful.

Following the NRC staff presentation, NEI staff gave a presentation of their feedback on usage of NUREG-1855.4 This was followed by a presentation of Exelon Generation Company, LLC staff that provided lessons learned from use of NUREG-1855 in the application of the risk-informed completion times LARs for Byron and Braidwood Stations.

The Pressurized Water Reactor Owners Group (PWROG) staff provided a presentation providing the results of a pilot performed using NUREG-1855. There was additional discussion about information that should be provided by licensees who have total core damage frequencies close to or slightly over 1 E-4 per year. Lastly, a presentation was given by Xcel Energy staff5 that provided lessons learned from application of NUREG-1855 in the 10 CFR 50.69 reviews for Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant.

No regulatory decisions were made in the meeting.

Following the discussion, an opportunity was afforded to any other participants who wished to ask questions or make comments. No questions or comments were received from the public.

Enclosure:

List of Attendees 4 The NEI, Exelon, and PWROG slides are available under ADAMS Accession No. ML19198A341.

5 The Excel Energy slides are available under ADAMS Accession No. ML19198A344.

ENCLOSURE LIST OF ATTENDEES

Sign In Sheet DATE: July 18, 2019 Name Public Meeting to discuss NUREG-1855 f-,...:1,

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Sign In Sheet DATE: July 18, 2019 Public Meeting to discuss NUREG-1855

ML19203A293 OFFICE NRR/DORL/LSPB/PM NRR/DORL/LSPB/LA NAME GEMiller JBurkhardt DATE 08/12/19 07/26/19 RR/DORL/LS PB/BC NRR/DORL/LSPB/PM GEMiller 08/20/19