ML23304A267

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Summary of October 5, 2023, Public Meeting to Provide and Discuss U.S. Nuclear Regulatory Commission Preliminary Assessment of Nuclear Energy Institute’S Recommendations on Risk Informed Process for Evaluations
ML23304A267
Person / Time
Issue date: 11/13/2023
From: Siva Lingam
NRC/NRR/DORL/LPL4
To: Jennifer Dixon-Herrity
NRC/NRR/DORL/LPL4
References
Download: ML23304A267 (1)


Text

U.S. Nuclear Regulatory Commission Public Meeting Summary

Title:

Public Meeting to Provide and Discuss U.S. Nuclear Regulatory Commission Preliminary Assessment of Nuclear Energy Institutes Recommendations on Risk-Informed Process for Evaluations

Meeting Identifier: 20231055

Date of Meeting: 10/5/2023

Location: Webinar

Type of Meeting: Comment-Gathering

Purpose of the Meeting: The purpose of this meeting between the U.S. Nuclear Regulatory Commission (NRC) staff, and representatives fr om the Nuclear Energy Institute (NEI) and industry was to discuss the staffs assessment of the recommendations by the NEI in its letter dated April 19, 2023 (Agencywide Document s Access and Management System (ADAMS)

Accession No. ML23163A048) on Risk-Informed Process for Evaluations (RIPE). Further, the purpose of this meeting was to communicate the NRCs recent issuance of temporary staff guidance (TSG), TSG-DORL-2021-01, Revision 3, Risk-Informed Process for Evaluations incorporating observations from the first application submitted using RIPE ( ML23122A014).

General Details: The meeting was a virtual meeting conducted via the Microsoft Teams platform. The meeting started at 11:15 AM eastern time (ET) and concluded at 12:00 PM ET.

There were 25 NRC staff, and 23 external participants, representing Breakthrough Institute, Constellation, Curtis Wright, Duke-Energy, Enercon Services, Inc., Energy Harbor, Information Systems Laboratories, Jensen Hughes, NextEra, NEI, RSL Safety Corporation, Spanish Nuclear Safety Council, Tennessee Valley Authority (TVA), Union of Concerned Scientists, and Westinghouse that attended the meeting. In addition, there was a member of the public present at the meeting who had the opportunity to ask questions or make comments. Comments were received from a public member, Mr. Edwin Lyman of the Union of Concerned Scientists. Details of Mr. Lymans comments are provided in section, Public Participation, below. A facilitator was not used to conduct the meeting. A list of attendees is provided below.

Summary of Presentations:

Antonios Zoulis, Chief, Probabilistic Risk Assessment Oversight Branch (APOB), Division of Risk Assessment, Office of Nuclear Reactor Regulation (NRR) and Michelle Kichline, Senior Reliability and Risk Analyst, APOB, presented information, which included the following:

Communicated issuance of NRRs RIPE TSG, TSG-DORL2021-01, Revision 3, reflecting NRC staffs observations and best practices from the first RIPE review. This revision provided additional information to the NRC staff on defense-in-depth, safety margins, performance monitoring, flexibility on schedule for the no technical objection, review with no change to the overall schedule for RIPE review, and more clarification on the validity of special circumstances for exemptions.

Addressed NRC staffs preliminary assessment of NEIs recommendations to revise the risk thresholds as discussed in NEIs Ap ril 19, 2023, letter referenced above. The NRC staff stated that the increase in risk acceptance criteria appears reasonable based on

similar thresholds established for the NRC En forcement Manual, Appendix F, Notices of Enforcement Discretion (ML19193A023), and meeti ng the five principles of Regulatory Guide (RG) 1.174, Revision 3, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis (ML17317A256).

Communicated an alternative option in lieu of NEIs recommendation to revise the risk acceptance criteria for RIPE so that they are not pass/fail criteria because this could cause complexity and delays in the staffs re view process. The NRC staff offered that for those RIPE applications where the risk acceptance criteria are slightly exceeded, the licensee could provide a supporting explanation as to why the deviation is acceptable, and the NRC staff would consider for review using RIPE on a case-by-case basis.

Public Participation: A member of the public was present and had the opportunity to ask questions or make comments. Mr. Edwin Lyman provided comments about NEIs request to increase the risk acceptance criteria. NRC staff addressed these comments.

Action Items/Next Steps:

The NRC staff conveyed two options as paths forward during the meeting. The first option was that the NRC staff could pursue updating its gui dance documents to reflect its final assessment of NEIs recommendations based on the feedback from the public meeting. The second option was that NEI may choose to revise its RIPE guidance document reflecting the higher risk thresholds and submit to NRC with the understa nding that it would be made publicly available, and that the staff would leverage COM-204, Revision 5, Informal Interfacing with and Handling Documents from Owners Groups, Vendors, Nuclear Energy Institute, Licensees, and Other External Stakeholders (ML20027A598), to conduct its review and issue a letter with its final assessment of NEIs recommendations. Andrew Mauer of NEI conveyed that NEI planned to submit their updated RIPE guidance document to the NRC and agreed to making it publicly available. NRC management conveyed that based on the feedback received from this meeting, we would determine the appropriate path forward. The NRC staff also conveyed that after several RIPE reviews, NRC will consider providing endorsement to industry guidance using the RG process.

Additional Information:

Meeting notice and agenda - ML23264A801 NRC presentation slides - ML23275A241

Meeting

Participants:

LIST OF ATTENDEES FOR OCTOBER 5, 2023, COMMENT-GATHERING PUBLIC MEETING

Name Affiliation Surinder Arora NRC Eric Benner NRC Kristy Bucholtz NRC Kevin Coyne NRC Stephen Cumblidge NRC Vic Cusumano NRC Jennifer Dixon-Herrity NRC Leslie Fields NRC Gerond George NRC John Hughey NRC Meena Khanna NRC Michelle Kichline NRC Daniel King NRC Mike King NRC Ming Li NRC Steve Koenick NRC Siva Lingam NRC Michael Mahoney NRC William Orders NRC Charley Peabody NRC Bo Pham NRC Reinaldo Rodriguez NRC Steve Smith NRC Brian Wittick NRC Antonios Zoulis NRC Leigh Lloveras Breakthrough Institute Charlyne Smith Breakthrough Institute Roy Linthicum Constellation Christian Williams Constellation Deanne Raleigh Curtis Wright Dennis Earp, Jr. Duke-Energy Chris Vera-Burgos Enercon Services, Inc.

Rob Drsek Energy Harbor Tony Mangan Energy Harbor Steven Pope Information Systems Laboratories Andy Ratchford Jensen Hughes Steve Catron NextEra Jarrett Mack NextEra Kenneth Mack NextEra Keith Vincent NextEra Janet Schlueter NEI Brett Titus NEI Michael Miller RSL Safety Corporation

LIST OF ATTENDEES FOR OCTOBER 5, 2023, COMMENT-GATHERING PUBLIC MEETING

Name Affiliation Enrique Melendez Asensio Spanish Nuclear Safety Council Beau Eckermann TVA Stuart Rymer TVA Edwin Lyman Union of Concerned Scientists Andrea Maioli Westinghouse

Package: ML23304A269 Meeting Notice: ML23264A801 Meeting Slides: ML23275A241 Meeting Summary: ML23304A267 *by email NRC-001 OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DRA/APOB/BC (A)*

NAME SLingam PBlechman RRodriguez DATE 10/25/2023 11/1/2023 11/1/2023 OFFICE NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*

NAME JDixon-Herrity SLingam DATE 11/13/2023 11/13/2023