ML22054A238

February 1, 2022, Summary of Public Meeting to Discuss a Proposed Method for Leveraging Risk Insights in 10 CFR 50.59 Evaluations with the Nuclear Energy Institute

ML22054A238
Person / Time
Issue date:	02/23/2022
From:	Tekia Govan NRC/NRR/DRO
To:	Philip Mckenna NRC/NRR/DRO
Govan T
References
Download: ML22054A238 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 23, 2022 MEMORANDUM TO: Philip McKenna, Chief Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM: Tekia V. Govan, Project Manager /RA Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

SUMMARY

OF THE PUBLIC MEETING TO DISCUSS A PROPOSED METHOD FOR LEVERAGING RISK INSIGHTS IN 10 CFR 50.59 EVAULATIONS WITH THE NUCLEAR ENERGY INSTITUTE HELD ON FEBRUARY 1, 2022 On February 1, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting with the Nuclear Energy Institute (NEI) to discuss their proposal for leveraging risk insights in 10 CFR 50.59 evaluations. During this meeting, NEI provided a presentation where they proposed that the evaluation approach developed for the Risk Informed Process for Evaluations (RIPE) could be used by licensees to evaluate 10 CFR 50.59 criteria by applying risk insights to determine if a proposed change results in a more than minimal increase (Agencywide Document Access Management System (ADAMS) Accession No. ML22027A392).

The presentation described how the NRC staff has taken steps to becoming a more risk informed regulator by holding public meetings to discuss the idea on how risk insights may be employed during the 10 CFR 50.59 process, the issuance of the RIPE, and the issuance of Inspection Manual Chapter 0335, Changes, Test and Experiments. NEI requested that, with the steps that the NRC has taken regarding risk insight, the NRC staff provide feedback on the concept of using the risk evaluation techniques that are described in the RIPE process for 10 CFR 50.59 evaluation and continue the dialogue with industry in this area as they prepare to develop guidance to support the use of risk evaluation techniques for 10 CFR 50.59 evaluations.

The NRC staff provided comments for NEI to consider, while stressing that no decisions will be made, or any agency position taken as a result of this informational meeting. Some of the staffs comments for NEI consideration are captured below:

• The RIPE process is not intended to be used independently and is based solely on the use of Probabilistic Risk Assessment (PRA) modeling and PRA output limits from CONTACT: Tekia V. Govan, NRR/DRO 301-415-6197

P. McKenna Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk Informed Decisions on Plant-Specific Changes to the Licensing Basis."

• RG 1.174 was developed for the purpose of guiding changes to the licensing basis where the staff was reviewing and approving the change, not for changes made under 10 CFR 50.59.

• In the statements of consideration for 10 CFR 50.59, the staff noted the following:

o The Commission concludes that if use is to be made of PRA in 10 CFR 50.59, more fundamental changes to the rule would be necessary to provide a coherent set of requirements, in that 10 CFR 50.59 deals with design basis events, and RG 1.174 deals with risk including that from severe accidents beyond the design basis. In addition, RG 1.174 is specifically dealing with operating power reactors.

o The Commission acknowledges that it may be possible to develop more guidance that could be used in a quantitative sense to judge minimal increases.

As part of development of the guidance, the NRC will consider using the values developed as part of the revised oversight process (SECY-9907), so that if the resultant likelihood of occurrence remains well within the acceptable ranges given for initiating events, that the increase is "minimal." (64 FR 53590) o The Commission agrees that the effect of the change on the frequency of the accident must be discernible and attributable to the change in order to exceed the "more than minimal" increase standard, as compared to uncertainty about the existing frequency value and how it might be quantified. (64 FR 53590)

Meeting Action Items There were no action items identified during this meeting.

Conclusion At the end of the meeting, NRC, and industry management gave closing remarks. The industry representatives expressed appreciation for the open dialogue and willingness of NRC staff to hear industry views. The NRC staff stressed the importance of the NRC being focused on providing reasonable assurance of public health and safety when considering changes.

The NRC staff is willing to meet with NEI to further discuss this topic and they develop guidance for industry use.

The enclosure provides the attendance list for this meeting.

Enclosure:

As stated

ML22054A238 * = via email OFFICE NRR/DRO/IRAB/PM NRR/DRO/IRAB/BC NRR/DRO/IRAB/PM NAME TGovan* PMcKenna* TGovan*

DATE 02/22/2022 02/23/2022 02/23/2022 LIST OF ATTENDEES MEETING TO DISCUSS A PROPOSED METHOD FOR LEVERAGING RISK INSIGHTS IN 10 CFR 50.59 EVAULATIONS WITH THE NUCLEAR ENERGY INSTITUTE February 1, 2022, 1:00 PM to 2:30 PM ATTENDEE ORGANIZATION1

1. Carol Moyer NRC

2. Antonios Zoulis NRC

3. Marlone Davis NRC

4. Shakur Walker NRC

5. David Beaulieu NRC

6. Tekia Govan NRC

7. Patricia Jehle NRC

8. Angelo Stubbs NRC

9. David Garmon-Candelaria NRC

10. James Chang NRC

11. Michael Benson NRC

12. Jeffrey Josey NRC

13. Gerond George NRC

14. Philip McKenna NRC

15. Michelle Kichline NRC

16. Dustin Reinert NRC

17. Justin Braisted NRC

18. Derek Scully NRC

19. Mel Holmberg NRC 1

Unknown organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.

Enclosure

20. Mahesh Chawla NRC

21. Gordon Curran NRC

22. Ed Miller NRC

23. Carolyn Fairbanks NRC

24. John Tsao NRC

25. David Aird NRC

26. Raul Hernandez NRC

27. Matthew Euten NRC

28. Daneira Melendex-Colon NRC

29. Jorge Corujo-Sandin NRC

30. Geoffrey Ottenberg NRC

31. Kristy Bucholtz NRC

32. Bill Rogers NRC

33. Isaac Anchondo-Lopez NRC

34. Dan Widrevitz NRC

35. Michael Markley NRC

36. Alex Garmoe NRC

37. David Gullott Exelon Energy

38. Douglas Pollock Unknown

39. Christian Williams Exelon Energy

40. Phil Couture Entergy

41. Darani Reddick Exelon

42. Peter LeBlond LeBlond & Associates, LLC

43. James Polickoski Unknown

44. Brett Titus NEI

45. David Bajumpaa Dominion Energy

46. Walter Boatwright Comanche Peak Nuclear

47. Steve Pope Unknown

48. Kyle Kriesel Unknown

49. Fred Madden Certrec Corporation

50. Neil Archambo Duke Energy

51. Robert Budnitz Unknown

52. Brian Mount Dominion Energy

53. Brian Thomas Unknown

54. DeLisa Pournaras Unknown

55. Susan Hoxie-Key Member of the Public

56. R. Briggs Energy Harbor

57. Jana Bergman Unknown

58. Wayne Lunceford EPRI

59. Darin Jensen Xcel Energy

60. Sara Scott Unknown

61. Tony Brown NEI

62. Joseph Rivers Unknown

63. Michael Ellett Indiana Michigan Power

64. Roy Linthicum Exelon Nuclear

65. Bradley Dolan TVA

66. Joe Cole Entergy

67. Warren Odess-Gillett Unknown

68. Andrew Mauer NEI

69. Hossein Hamzehee Unknown

70. Jordon Hagaman Unknown

71. John Richards Unknown

72. Tony Zimmerman Duke Energy

73. Jim Slider NEI

74. Rob Burg Unknown

75. Robin Armistead Unknown

76. Steve Vaughn X-Energy

77. Mohamed Talaat Unknown

78. Lee Grzeck Unknown

79. Alan Campbell NEI

80. Lon Dawson SNL