ML23207A194
| ML23207A194 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/2023 |
| From: | Michael Orenak NRC/NRR/DANU/UAL1 |
| To: | Steven Lynch NRC/NRR/DANU/UARP |
| References | |
| EPID N-2022-ADV-0004 | |
| Download: ML23207A194 (5) | |
Text
September 13, 2023 MEMORANDUM TO:
Steven T. Lynch, Chief Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM:
Michael Orenak, Project Manager /RA/
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 MAY 9, 2023, OBSERVATION MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND THE NUCLEAR INDUSTRY REGARDING NRC COMMENTS ON NEI 22-05, REVISION A, "TECHNOLOGY INCLUSIVE RISK INFORMED CHANGE EVALUATION (TIRICE):
GUIDANCE FOR THE EVALUATION OF CHANGES TO FACILITIES UTILIZING NEI 18-04 AND NEI 21-07."
Meeting Information:
Applicant: N/A Docket/Project No. N/A EPID: N-2022-ADV-0004 Meeting
Title:
Discussion of NRC Comments on NEI 22-05, Revision A, "Technology Inclusive Risk Informed Change Evaluation (TIRICE): Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07."
Meeting Date: May 9, 2023 Meeting Type: Observation Public Meeting Notice Agencywide Documents Access and Management System (ADAMS):
ML23128A095 Industry Slides: ML23125A319 NRC Comments on NEI 22-05, Revision A: ML23107A257 Industry Response to NRC Comments on NEI 22-05, Revision A: ML23125A320
Meeting Attendees: See Enclosure for list of meeting attendees.
Meeting Summary:
The U.S. Nuclear Regulatory Commission (NRC) staff held a virtual observation meeting with representatives from the nuclear industry regarding the industrys response to NRC comments on NEI 22-05, Revision A. The meeting was conducted in accordance with NRC Management Directive 3.5, Attendance at NRC Staff-Sponsored Meetings (ML21180A271).
During the meeting, representatives of the nuclear industry presented their slides that described the changes to be made to NEI 22-05 as a result of the April 17, 2023, NRC comments.
The first discussion occurred on Slide 7 where the NRC staff noted that the term affirmative safety case was not used in the NRC-endorsed NEI 18-04, Revision 1, Risk-Informed Performance-Based Guidance for Non-Light Water Reactor Licensing Basis Development, (ML19241A336). The industry acknowledged this fact.
The NRC staff and contractors had several comments on Slide 10. The NRC staff noted that emergency planning zone (EPZ) size analysis is different than normal licensing modernization project (LMP) program changes. Changes to the design of the facility may be picked up by LMP, but the effect of changes to the design on the basis for the plume exposure pathway EPZ size (e.g., 1 rem TEDE at the site boundary) may not be captured. The NRC staff stated that industry may want to consider an EPZ size change process because the EPZ size is now more clearly dependent on the design of the specific facility, instead of the EPZ being a standard 10 miles radius that is for currently operating power reactors. The industry responded that the proposed emergency preparedness (EP) rule currently up with the Commission (ML21200A055) would result in the licensee not being able to change the EPZ anyway. If industry wanted to create a new process, they could not because of the revised EP rule. Industry stated that addressing EP and EPZ size would be more appropriate in projects outside of TIRICE. The NRC staff noted that the proposed EP rule does not have a change process and there needs to be a process somewhere to ensure that a plant change does not undercut the assumptions for the EPZ analysis. The industry responded that they have a project ongoing with Argonne National Labs to develop a change control process for EPZ sizes. The NRC staff asked that this issue just be noted in NEI 22-05, but no solution needs to be provided.
For Slide 11, the NRC contractors noted that the most recent plant operating licenses issued under Title 10 of the Code of Federal Regulations (10 CFR) Part 52 do not have a fire protection license condition because they were designed with fire protection in mind and the change requirements in the design certification rule and 10 CFR 50.59, Changes, tests and experiments, were considered sufficient. The NRC staff noted that the standard fire protection license condition is not a regulation. An applicant may choose to apply for a fire protection license condition that lays out a proposed change control process. If the applicant chooses to rely solely on the 10 CFR Part 52 rule-based change process and the 10 CFR 50.59 process for fire protection, then no license condition is necessary. The NRC staff also noted that the standard fire protection license condition may not be the only possible proposed license condition for fire protection change control process, so NEI 22-05 should account for that fact.
Industry members acknowledged that more thought is need for the contents of the fire protection section. The NRC contractors recommended that industry consult NEI 96-07, Appendix C, Guideline for Implementation of Change Processes for New Nuclear Power Plants Licensed Under 10 CFR Part 52, (ML14084A113) for guidance in this area.
The discussions regarding comments on Slides 13, 16, and 17 are related.
For Slide 13, an NRC contractor noted that input parameters could constitute elements of a methodology, so there is not a clear-cut separation of what does and does not require NRC approval before implementation. The industry members responded that there are four tests which determine if the change is a method of evaluation or an input parameter.
For Slide 16, the NRC contractor noted that the second bullet in Section 3.9 of NEI 22-05 does not limit changes to only aspects related to design basis accidents (DBAs), but in Section 4.3, the text indicates that changes are limited to those that only impact DBAs. It was further noted that Section 4.3 appeared to conflict with text in Section 3.9 that states that an input parameter is considered to be an element of the methodology if the development or approval of the methodology was predicated on the degree of conservatism in a particular input parameter or set of input parameters. Therefore, a change to such an input parameter would constitute a change in an element of a methodology.
As an example, the question was asked, If a change was made to dose rate conversion factor, would that meet the screening criteria? The industry responded that it would screen out due to criterion (i) of Section 4.3. Industry members stated they were trying to make a separation between deterministic analysis and probabilistic risk assessment (PRA). Industry stated that according to Sections 3.7 and 3.9, if the change involved an input parameter, it would screen out; if the change was to a method, it may not screen out. If the change was to a method, it would be processed by Criterion (i) of Section 4.3; if it was a change to an input parameter, it would go through Criteria (a)-(h).
For Slide 17, industry stated that this subject will be more closely looked at by the Technology-inclusive Management of Safety Case (TIMaSC) project that is just starting up. The NRC staff commented that in Example 2 of Section 4.3.9.2, the change would only need approval if it supports a DBA. Industry responded that, correct, this decision is made in Section 4.2.1.5 where the screening is completed.
There were no public comments during the public comment period.
CONTACT: Michael Orenak, NRR/DANU (301) 415-3229
SUBJECT:
SUMMARY
OF THE MAY 9, 2023, OBSERVATION MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND THE NUCLEAR INDUSTRY REGARDING NRC COMMENTS ON NEI 22-05, REVISION A, "TECHNOLOGY INCLUSIVE RISK INFORMED CHANGE EVALUATION (TIRICE): GUIDANCE FOR THE EVALUATION OF CHANGES TO FACILITIES UTILIZING NEI 18-04 AND NEI 21-07."
DATED: SEPTEMBER 13, 2023 DISTRIBUTION:
Public RidsOgcMailCenter RidsOpaMail Resource RidsNrrDanu Resource RidsNrrDanuUarp Resource JSebrosky, NRR MOrenak, NRR WReckley, NRR JSegala, NRR ACubbage, NRR IJung, NRR MHart, NRR SLynch NRR STonsfeldt, NRR MBiro, NRR ADAMS Accession Number: ML23207A194 NRR-052 OFFICIAL RECORD COPY OFFICE NRR/DANU/UAL1/PM NRR/DANU/UARP/BC NRR/DANU/UAL1/PM NAME MOrenak SLynch MOrenak DATE 7/26/2023 9/13/2023 9/13/2023
Enclosure List of Attendees Observation meeting between the U.S. Nuclear Regulatory Commission Staff and the Nuclear Industry Regarding NRC comments on NEI 22-05, Revision A Tuesday, May 9, 2023 Name Organization Mike Orenak U.S. Nuclear Regulatory Commission (NRC)
Bill Reckley NRC Steve Lynch NRC Scott Tonsfeldt NRC Mihaela Biro NRC Michelle Hart NRC John Segala NRC Jim ODriscoll NRC Ian Jung NRC Amy Cubbage NRC Jim Kinsey Idaho National Labs (INL)
Tom Hicks INL Tom King INL Chris Chwasz INL Brandon Chisolm Southern Company Michael Tschiltz Southern Company Ben Holtzman Nuclear Energy Institute Pete LeBlond LeBlond & Associates, LLC Karl Fleming KNF Consulting Services, LLC Steve Nesbit LMNT Consulting Barton Landon Pate Barry Shirley Farsheet Shahrolchi Jana Bergman Curtis Wright Rob Burg Dave Grabaskas Greg Meinweiser Ingrid Nordby X Energy, LLC (X-energy)
Justin Hawkins Amanda Spalding Steve Pope Travis Chapman X-energy