ML21350A423
| ML21350A423 | |
| Person / Time | |
|---|---|
| Issue date: | 02/06/2023 |
| From: | David Williams NRC/NRR/DANU/UARL |
| To: | Jessup W NRC/NRR/DANU/UNPL |
| Williams D; 301-415-1322 | |
| References | |
| Download: ML21350A423 (4) | |
Text
MEMORANDUM TO:
William Jessup, Chief Advanced Reactor Licensing Branch 1 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM:
Donna Williams, Project Manager Advanced Reactor Licensing Branch 1 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE NOVEMBER 3, 2021, PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE TO DISCUSS THE U.S. NUCLEAR REGULATORY COMMISSION STAFFS ENDORSEMENT OF THE ADVANCED NON-LIGHT-WATER REACTOR PROBABILISTIC RISK ASSESSMENT STANDARD AND RELATED PROBABILISTIC RISK ASSESSMENT PEER REVIEW GUIDANCE On November 3, 2021, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting with stakeholders to discuss the NRC staffs review and endorsement of the American Society of Mechanical Engineers (ASME) and American Nuclear Society (ANS) (ASME/ANS) advanced non-light-water reactor (NLWR) consensus probabilistic risk assessment (PRA) standard, designated as ASME/ANS RA-S-1.4-2021, Probabilistic Risk Assessment Standard for Advanced Non-Light Water Reactor Nuclear Power Plants, and Nuclear Energy Institute (NEI) 20-09, Revision 1, Performance of PRA Peer Reviews Using the ASME/ANS Advanced Non-LWR PRA Standard (Agencywide Document and Access and Management System (ADAMS) Accession No. ML21085A555). The notice for this public meeting is available in ADAMS under Accession No. ML21287A111. The participants for this meeting included representatives of the Nuclear Energy Institute (NEI) and the ASME and ANS Joint Committee on Nuclear Risk Management (JCNRM). The NRC staffs presentation slides are available at ADAMS under Accession No. ML21305B862. The enclosure to this document lists the meeting attendees.
The purpose of the meeting was to give members of the nuclear industry and other external stakeholders the opportunity to express views and perspectives on a preliminary draft of the trial Regulatory Guide (RG) 1.247, Acceptability of Probabilistic Risk Assessment Results for Advanced Non-light Water Reactor Risk Informed Activities which was made publicly available in ADAMS on September 3, 2021, under Accession No. ML21246A216. During this meeting, members of JCNRM and NEI provided presentations that contained key points on the feedback regarding RG 1.247. In particular, the presentations provided by members of the JCNRM February 6, 2023 Signed by Williams, Donn on 02/06/23
W. Jessup reflected feedback that was developed by the JCNRM regarding the preliminary draft of trial RG 1.247 and was transmitted to the NRC staff in a letter dated October 28, 2021 (ADAMS Accession No. ML21337A210).
The NRC staff issued the preliminary draft of trial RG 1.247 to support ongoing discussions with the Advisory Committee on Reactor Safeguards and external stakeholders. The content of the preliminary draft trial RG does not establish official agency positions but is intended to help foster discussions with stakeholders and to provide awareness of the NRC staffs development of the regulatory guidance.
In its remarks, the NRC staff provided background information regarding the development of trial RG 1.247, noting that trial RG 1.247 addresses consideration of all sources of radioactivity, all hazards, all plant operating states, and all levels of analysis in the development of a PRA intended to support risk-informed regulatory activities. The guidance in trial RG 1.247 includes consideration of relationships between similar requirements in the NLWR and the LWR PRA standards, given that these two types of standards are intimately related. The NRC staff provided a comparison to RG 1.200, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, the LWR PRA standard (ASME/ANS RA-Sa-2009, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications, dated February 2009) and described some of the notable guidance in RG 1.200.
Dave Grabaskas and Dennis Henneke provided remarks for the JCNRM, which are available in ADAMS under Accession No. ML21314A538. The presentation summarized the JCNRM October 28, 2021, letter to the NRC regarding a preliminary review of the preliminary draft of trial RG 1.247. The JCNRM representatives noted that trial RG 1.247 makes specific statements regarding the scope and other characteristics of PRAs and stated that these statements would be better placed within application-specific guidance, rather than in trial RG 1.247. They further noted that statements dictating PRA methods may also be better placed in application-specific guidance and provided feedback regarding specific supporting requirements and the NRC staffs exceptions. Finally, the JCNRM representatives noted that trial RG 1.247 identifies several areas where the NLWR standard could be improved and stated that such suggested changes should be transmitted to the JCNRM for review.
Victoria Anderson presented remarks on behalf of NEI. NEIs presentation is available in ADAMS under Accession No. ML21314A546. Ms. Anderson noted that the NRC staffs endorsement ofRevision 1 of NEI 20-09 without exception, is helpful, but that NEI had concerns with some of the NRC staffs exceptions related to the ASME/ANS NLWR PRA standard. For example, Ms. Anderson stated that nonmandatory appendices and notes are not requirements and should not be endorsed or clarified and that discussions regarding absolute versus relative risk significance is likewise nonmandatory and should not be part of the endorsement. NEI also noted certain information that is more appropriate in regulatory guidance and not in the supporting requirements. Ms. Anderson stated that NEI plans to provide detailed written comments to the NRC.
W. Jessup The NRC staff asked if the industry had identified any prospective applicants that planned to use trial RG 1.247. Dennis Henneke stated that General Electric-Hitachi plans to use ASME/ANS RA-S-1.4-2021 standard and the NEI 20-09 peer review guidance to support development of the TerraPower Natrium construction permit application.
Meeting participants asked about the comment process for the preliminary trial RG 1.247. The NRC staff noted that there is not a formal process for soliciting comments prior to issuing a trial RG; however, a formal comment period will be provided after the trial RG is issued and sufficient experience has been gained with its use. The NRC staff also noted that the views and perspectives expressed during the November 3, 2021, public meeting will be considered as well as other feedback that the NRC staff have received as it finalizes trial RG 1.247 for publication.
The NRC staff anticipates issuing trial RG 1.247 in March 2022.
CONTACT: Donna Williams, NRR/DANU
Enclosure:
List of attendees
W. Kennedy
SUBJECT:
SUMMARY
OF THE NOVEMBER 3, 2021, PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE TO DISCUSS THE U.S. NUCLEAR REGULATORY COMMISSION STAFFS ENDORSEMENT OF THE ADVANCED NON-LIGHT-WATER REACTOR PROBABILISTIC RISK ASSESSMENT STANDARD AND RELATED PROBABILISTIC RISK ASSESSMENT PEER REVIEW GUIDANCE DATED: FEBRUARY 26, 2023 DISTRIBUTION:
PUBLIC MOrenak, NRR MGonzales, RES DWilliams, NRR MStutzke, NRR HPhan, NRR MHumberstone, RES AGilbertson, NRR SVasavada, NRR JDeJesus, RES KTetter, NRR JHyslop, NRR KCompton, RES SCooper, RES MPohida, NRR JSebrosky, NRR HAhn, NRR DYeilding, RES ANeuhausen, NRR MHart, NRR CAraguas, RES JLane, RES MReisiFard, RES RidsNRRLACSmith Resource RidsNrrDANU Resource RidsNrrDANUUAL1 Resource RidsOgcMailCenter Resource RidsOcaMailCenter Resource RidsOcaaMailCenter Resource ADAMS Accession Number: ML21350A423 NRR-106 OFFICE NRR/DANU/UAL1:PM NRR/DANU/UAL1:L A
NRR/DANU/UAL1:BC NRR/DANU/UAL1:PM NAME DWilliams CSmith WJessup DWilliams DATE 12/17/2021 01/20/2022 02/6/2023 02/6/2023 OFFICIAL RECORD COPY
PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE TO DISCUSS THE U.S.
NUCLEAR REGULATORY COMMISSION STAFFS ENDORSEMENT OF THE ADVANCED NON-LIGHT-WATER REACTOR PROBABILISTIC RISK ASSESSMENT STANDARD AND RELATED PROBABILISTIC RISK ASSESSMENT PEER REVIEW GUIDANCE NOVEMBER 3, 2021 Name Organization Michelle Gonzales U.S. Nuclear Regulatory Commission (NRC)
Marty Stutzke NRC Hanh Phan NRC Anders Gilbertson NRC Matthew Humberstone NRC Donna Williams NRC Shilp Vasavada NRC Mehdi Reisi Fard NRC Jonathan DeJesus NRC Keith Tetter NRC Eric Oesterle NRC Eric Bowmen NRC JS Hyslop NRC Keith Compton NRC Susan Cooper NRC Marie Pohida NRC Maxwell Smith NRC Joe Sebrosky NRC Hosung Ahn NRC Maxine Keefe NRC Dale Yeilding NRC Alissa Neuhausen NRC Michelle Hart NRC Mark Thaggard NRC Christian Araguas NRC John Lane NRC Shakur Walker NRC Farshid Shahrokhi Framatome Andrea Maioli Nuclear Energy Institute (NEI)
Kati Augsten NEI Victoria Andersen NEI Dennis Henneke General Electric Power Portfolio Emma Redfoot Oklo, Inc.
Drew Peebles Kairos Power Matt Denman Kairos Power Jon Facemire X-Energy Karl Fleming JCNRM Amir Afzali Enclosure Brian Johnson TerraPower Ben Chen Binesh Tharakan Henry Marchlewski Charles Murray Kiersten Smith Shayan Shahbazi Bryan Eyers Jamal Ahmed Mohmand Rob Burg Andrew Jordan Clark Dyrk Greenhalgh DeLeah Lockridge Sudhamay Basu Fernando Ferrante EPRI Blake Bixenman Urenco SmainYalaoui Jordan Hagaman Brian J Krystek Mary Neumayr Tom Seewald Andrew Zach Committee on Energy and Public Works Mike Keller Chantal Morin (Invité)
CNSC Robert Budnitz Yolande Akl Sarah Fields Hayat Chatri