ML24002B081

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RG 1-183 Public Workshop (1of 3) Project Plan and RG Process Slides - ML24002B081
ML24002B081
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Issue date: 01/02/2024
From: Garmon D
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Public Workshop (1 of 3)

Update to RG 1.183, Revision 1 - Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors January 9, 2023 ADAMS Accession No. ML24002B081

Introductions

2 Please ensure to identify yourself before speaking throughout the meeting.

NRC Opening Remarks Michael Franovich Director NRR/DRA USNRC 3

Workshop Agenda Workshop Format Project Plan and Overview of Regulatory Guide Process High Burnup Fuel Source Term Accident Sequence Analysis Report Follow-On Calculations for Boiling Water Reactors External Presentations (if applicable)

Discussion 4

Workshop Format 5

86 FR 14964 - NRC Policy on Enhancing Participation in NRC Public Meetings Comment-Gathering Meeting - Purpose is for the NRC to obtain feedback on regulatory issues and NRC actions - in this case for an update to RG 1.183 Focused on allowing participants opportunity to provide opinions, perspectives and feedback NRC staff will take notes during meeting and use these notes to inform decision-making Meeting summaries will include high-level summaries of notes NRC staff has taken

RG 1.183 Update Stakeholder Involvement

  • Public Workshops and Information Meetings

- 3 Workshops

- 2 Information Meetings

  • Contact Project Lead
  • Meeting Feedback
  • ACRS Meeting - approximately November 2024
  • Draft Guide Comment Period - approximately June 2025

- Relationship with Proposed Increased Enrichment Rulemaking

  • Comment period on Proposed Increased Enrichment Rulemaking Regulatory Basis ends on January 22, 2024 6

Workshop Agenda Workshop Format Project Plan and Overview of Regulatory Guide Process High Burnup Fuel Source Term Accident Sequence Analysis Report Follow-On Calculations for Boiling Water Reactors External Presentations (if applicable)

Discussion 7

Project Plan and RG Process Update to RG 1.183, Revision 1 - Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors David Garmon, Project Lead/Technical Contact david.garmon@nrc.gov Division of Risk Assessment Office of Nuclear Reactor Regulation

Project Plan and RG Process Overview

  • Background on RGs

- Purpose and benefit

- Management of updates

- Withdrawal of RGs

  • Project Schedules 9

Regulatory Guides - Background

  • Purpose

- Assist stakeholders in understanding and complying with NRC rules and regulations

- Describe methods NRC staff have determined to be acceptable (but not required) for meeting regulations

- Provide for licensing efficiency and regulatory stability

- RGs do not impose requirements 10

Regulatory Guides - Background

  • Benefit - If not required, why do we have them?

- Conserves resources and simplifies approval process because the guide describes ways the staff has already determined to be acceptable to meeting regulations

- Relieves burden of demonstrating that approved methods satisfy applicable NRC requirements

- In safety evaluations, the staff recognizes that approved methods were used by applicant/licensee and evaluates the outcome of those methods

  • Without RG, licensee must first establish that a method is acceptable 11
  • Update Process Highlights

- Identifying the need for new guidance

- Development of the technical basis

- Development of the Draft Regulatory Guide

- Development of supporting documents

- RGs that support rulemakings

- Internal and external review

- Publication (Pre-decisional Draft, DG and Final RG)

Regulatory Guides - Background 12

Regulatory Guides - Background

- NRC determines that guidance has been relocated

- NRC determines guidance is no longer an acceptable means of complying with the applicable requirements

  • If pursued, a backfit assessment should be performed and shared via Federal Register notice
  • If the NRC staff determines that withdrawing the RG would constitute backfitting but cannot justify the backfitting, then the NRC staff cannot withdraw the RG

- Withdrawal of previous versions can be done especially if guidance is no longer an acceptable means of compliance 13

Recommendations Under Consideration

  • Differing Profession Opinion DPO appeal panel recommended future consideration of withdrawing Revision 0 following issuance of Revision 1, recognizing backfitting/forward-fitting implications (ADAMS Accession No. ML23263A639)
  • Staff will follow the policy in MD 6.6 while ensuring there is appropriate consideration of these recommendations
  • Staff would engage external stakeholders when revising or withdrawing existing guidance, as applicable 14

Purposes for Updating RG 1.183, Rev. 1

  • Provide guidance that is applicable for fuel burnups greater than 68 GWd/MTU (current guidance applicable at/below this level)
  • Develop guidance to implement certain Increased Enrichment Rulemaking decisions
  • Consider other improvements to the guidance 15

Project Schedule 16 Milestone Tentative Completion Public Workshops* and Information Meetings**

January 2024 - April 2024 DG Internal Review begins June 2024 DG Internal Review completed October 2024 Pre-Decisional DG Publicly Available to Support ACRS Briefings November 2024 ACRS Briefings (Staff to respond as needed)

November 2024 Increased Enrichment Proposed Rule package to Commission (will include DG referenced in SECY paper)

December 2024 DG Available for Public Comment via Proposed IAW Increased Enrichment Rulemaking SECY June 2025 (Estimated)

  • The term Workshop means a Comment-Gathering Meeting as described in the NRCs policy statement on public meetings (see 86 FR 14964)
    • The term Information Meeting means NRC will inform attendees and allow questions (see 86 FR 14964)

Workshop Agenda Workshop Format Project Plan and Overview of Regulatory Guide Process High Burnup Fuel Source Term Accident Sequence Analysis Report Follow-On Calculations for Boiling Water Reactors External Presentations (if applicable)

Discussion 17

Workshop Agenda Workshop Format Project Plan and Overview of Regulatory Guide Process High Burnup Fuel Source Term Accident Sequence Analysis Report Follow-On Calculations for Boiling Water Reactors External Presentations (if applicable)

Discussion 18

Break 19

Workshop Agenda Workshop Format Project plan and Overview of Regulatory Guide Process High Burnup Fuel Source Term Accident Sequence Analysis Report Follow-On Calculations for Boiling Water Reactors External Presentations (if applicable)

Discussion 20

Workshop Agenda Workshop Format Project Plan and Overview of Regulatory Guide Process High Burnup Fuel Source Term Accident Sequence Analysis Report Follow-On Calculations for Boiling Water Reactors External Presentations (if applicable)

Discussion 21

Discussion 22

RG 1.183 Update Stakeholder Involvement -

Reminder -

  • Public Workshops and Information Meetings

- 3 Workshops

- 2 Information Meetings

  • Contact Project Lead
  • Meeting Feedback
  • ACRS Meeting - approximately November 2024
  • Draft Guide Comment Period - approximately June 2025

- Relationship with Proposed Increased Enrichment Rulemaking

  • Comment period on Proposed Increased Enrichment Rulemaking Regulatory Basis ends on January 22, 2024 23

Contacts David Garmon, Project Lead/

Technical Contact david.garmon@nrc.gov 301-415-3512 Chris Van Wert, Technical Contact christopher.vanwert@nrc.gov 301-415-3217 https://www.nrc.gov/pmns/mtg?do=details&Code=20231392 How did we do?

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