ML20091L696
| ML20091L696 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/2020 |
| From: | NRC/RES/DE |
| To: | |
| SJG1 | |
| Shared Package | |
| ML20091L620 | List: |
| References | |
| DG-1353, RG-1.233, Rev 0 | |
| Download: ML20091L696 (2) | |
Text
Response to Public Comments on Draft Regulatory Guide (DG)-1353 Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light-Water Reactors" Proposed Revision 0 of Regulatory Guide (RG) 1.233 On May 3, 2019, the NRC published a notice in the Federal Register (84 FR 19132) that Draft Regulatory Guide, DG-1353(Proposed Revision 0 of RG 1.233), was available for public comment. The Public Comment period ended on July 2, 2019. The NRC received one comment from the individual listed below. The NRC has summarized the comment and NRC staff response in the following table.
Comments were received from the following:
Richard S. Denning, PhD 2041 Hythe Road, Columbus, OH 43220 The submittal from Dr. Denning (ADAMS Accession No. ML19158A457) provided a discussion of concerns prepared by himself and Vinod Mubayi, PhD. The NRC also received an email from the Nuclear Energy Institute (NEI) (ADAMS Accession No. ML19261B955) related to the comments provided by Drs. Denning and Mubayi. A summary of the comment and the NRC staffs response is provided below:
Section of Specific Comments NRC Resolution DG-1353 General The development and interpretation of the The staff agrees that the approach described by the commenters may frequency-consequence curve1 proposed to be endorsed in be a viable alternative to the methodology described in DG-1353 and DG-1353 does not have a strong technical basis. An NEI 18-04. The alternative approach offers some advantages in terms underlying weakness of the proposed logic of assessing of supporting the assessment of cumulative risk and the contributions each candidate licensing basis event is that results could from various licensing basis events. However, the methodology in be influenced by the way an analyst chooses to define and DG-1353 and NEI 18-04 includes assessments of cumulative risks group event scenarios. A better approach would be to (e.g., a comparison to the NRCs safety goals) and supports the consider a frequency-consequence curve as not only a tool established objectives, which are the identification and assessment of for assessing individual licensing basis events but also as licensing basis events; establishing safety classifications and a bound on the complementary cumulative distribution performance criteria for plant features; and supporting evaluations of function (CCDF) of accident sequences. defense in depth. The possible concerns about analysts adjusting the results by redefining event sequences are expected to be addressed by April 2020
Section of Specific Comments NRC Resolution DG-1353 1 See Figure 3-1, Frequency-Consequence Target, in NEI 18-04, the implementation of consensus standards, integrated Revision 1, Risk-Informed Performance-Based Technology decisionmaking processes, peer reviews of probabilistic risk Inclusive Guidance for Non-Light Water Reactor Licensing Basis Development (ADAMS Accession No. ML19241A472) assessments, and the reviews performed by the NRC staff. For these reasons, the staff has determined that the methodology described in DG-1353 remains one acceptable approach for informing the licensing basis for advanced reactors and decided not to alter the guidance documents as requested.
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