ML23291A299
| ML23291A299 | |
| Person / Time | |
|---|---|
| Issue date: | 02/21/2024 |
| From: | Patrick Raynaud NRC/RES/DE |
| To: | |
| References | |
| DG-1422 RG 1.245 Rev 1 | |
| Download: ML23291A299 (3) | |
Text
REGULATORY ANALYSIS DRAFT REGULATORY GUIDE DG-1422 PREPARING PROBABILISTIC FRACTURE MECHANICS SUBMITTALS (Proposed Revision 1 of Regulatory Guide 1.245, Revision 0, issued January 2022)
- 1.
Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) is considering revising Regulatory Guide (RG) 1.245, Revision 0, Preparing Probabilistic Fracture Mechanics Submittals, issued January 2022, to clarify the guidance for regulatory applications that contain probabilistic fracture mechanics (PFM) analyses as part of the technical basis.
The NRC staff published Revision 0 of RG 1.245 to provide applicants and licensees subject to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities; 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants; 10 CFR Part 71, Packaging and Transportation of Radioactive Material; or 10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste, with guidance on methods and procedures for preparing PFM analyses. Specifically, RG 1.245 describes a framework for developing the contents of a licensing submittal that the NRC staff considers acceptable when performing PFM analyses in support of regulatory applications.
Revision 0 of RG 1.245 presents guidance supporting justifications for the acceptability of the methods used to generate and report PFM results, but it does not describe how the results of PFM may be used to support a regulatory application. Specifically, revision 0 of RG 1.245 does not include guidance on how risk-informed decision-making principles should be applied to regulatory applications that use PFM as part of their technical basis.
- 2.
Objective The objective of this regulatory action is to assess the need to update NRC guidance to clarify that PFM analyses are only one part of a risk-informed regulatory application, and that RG 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis (which provides a framework for integrated risk-informed decision-making), is also applicable to regulatory applications that use PFM as part of their technical basis.
- 3.
Alternative Approaches The NRC staff considered the following alternative approaches:
(1)
Do not revise RG 1.245.
(2)
Withdraw RG 1.245.
2 (3)
Revise RG 1.245 to clarify the NRCs position on regulatory applications that use PFM as part of their technical basis.
Alternative 1: Do Not Revise RG 1.245 Under this alternative, the NRC would not revise RG 1.245, and the current guidance would be retained. If the NRC does not act, then there would be no changes in costs or benefits to the public, licensees, or the NRC. This alternative is considered the no action alternative and provides a baseline condition from which any other alternatives will be assessed. However, the no-action alternative would not address identified concerns with the current version of the RG, specifically the apparent lack of clarity regarding the applicability of risk-informed decision-making principles for regulatory applications that use PFM as part of their technical basis. Review inefficiencies (e.g., increased number of requests for additional information and longer review times) would remain, as well as uncertainty in regulatory outcomes.
Alternative 2: Withdraw RG 1.245 Under this alternative, the NRC would withdraw RG 1.245. This would eliminate the only readily available description of the methods the NRC staff considers acceptable for using PFM analyses as part of the technical basis for a regulatory application to demonstrate compliance with 10 CFR Part 50, 10 CFR Part 52, 10 CFR Part 71, and 10 CFR Part 72, and potentially other regulations. Although this alternative would be less costly than Alternative 3, it would impede the publics access to the most current regulatory guidance.
Alternative 3: Revise RG 1.245 to Clarify the NRCs Position on Regulatory Applications that Use PFM as Part of Their Technical Basis Under this alternative, the NRC would revise RG 1.245 to clarify guidance for regulatory applications that contain PFM analyses as part of the technical basis for the application.
Specifically, based on experience with licensee use of RG 1.245 to date, this revision would explain that PFM analyses are only one part of a risk-informed regulatory application, and that RG 1.174 (which provides a framework for integrated risk-informed decision-making) is also applicable to regulatory applications that use PFM as part of their technical basis.
The impact of Alternative 3 to the NRC would be the costs associated with preparing and issuing the revised RG. The impact to the public would be the voluntary costs associated with reviewing and providing comments to the NRC during the public comment period. The value to the NRC staff and the agencys applicants would be the benefits associated with enhanced efficiency and effectiveness in using a common guidance document as the technical basis for license applications and other interactions between the NRC and its regulated entities. In addition, applicant use of the guidance would reduce the number of requests for additional information and shorten review times, resulting in ongoing cost savings to the NRC and industry.
Conclusion Based on this regulatory analysis, the NRC staff concludes that the revision of RG 1.245, Revision 0, is warranted. The action will enhance confidence in the content and review of licensing applications that rely on PFM as part of their technical basis, which is a way to risk-inform licensing applications. It could also lead to cost savings for the NRC and industry,
3 especially with regard to more efficient NRC reviews and to the predictability of regulatory outcomes when PFM is used as part of the technical basis.