ML24054A006
| ML24054A006 | |
| Person / Time | |
|---|---|
| Site: | Electric Power Research Institute |
| Issue date: | 03/29/2024 |
| From: | Lois James Licensing Processes Branch |
| To: | Gerond George Licensing Processes Branch |
| References | |
| EPID L-2023-TOP-0031 pre fee exempt TR 3002025288 | |
| Download: ML24054A006 (1) | |
Text
March 29, 2024 MEMORANDUM TO:
Gerond A. George, Chief Licensing Projects Branch (LLPB)
Division of Operating Reactor Licensing (DORL)
Office of Nuclear Reactor Regulation (NRR)
FROM:
Lois M. James, Senior Project Manager /RA/
Licensing Projects Branch (LLPB)
Division of Operating Reactor Licensing (DORL)
Office of Nuclear Reactor Regulation (NRR)
SUBJECT:
SUMMARY
OF MEETING TO DISCUSS THE STATUS OF THE U.S. NUCLEAR REGULATORY COMMISSION STAFF'S REVIEW OF TECHNICAL REPORT 3002025288, ENHANCED RISK-INFORMED CATEGORIZATION METHODOLOGY FOR PRESSURE BOUNDARY COMPONENTS (EPID NO. L-2023-TOP-0045)
On February 12, 2024, the U.S. Nuclear Commission (NRC) staff met with Electric Power Research Institute (EPRI) representatives to discuss the status of the NRC staffs acceptance review of EPRI Technical Report 3002025288, Enhanced Risk-Informed Categorization Methodology for Pressure Boundary Components (Risk-Informed CMPBC). The meeting summary is Enclosure 1 and the list of attendees is Enclosure 2.
If you have any questions or comments, please contact me via e-mail at Lois.James@nrc.gov.
Docket No. 99902021
Enclosures:
- 1. Meeting Summary
- 2. List of Attendees CONTACT: Lois M. James, NRR/DORL/LLPB 301-415-3306
U.S. NUCLEAR REGULATORY COMMISSION PUBLIC MEETING
SUMMARY
Title:
Status of the U.S. Nuclear Regulatory Commission Staff's Review of Electric Power Research Institute Technical Report 3002025288, Enhanced Risk-Informed Categorization Methodology for Pressure Boundary Components (Risk-Informed CMPBC)
Date of Meeting: February 12, 2024, 2:00 pm - 5:00 pm Location:
Hybrid Type of Meeting: This was an Observation Meeting. This was a meeting in which attendees had the opportunity to observe the U.S. Nuclear Regulatory Commission (NRC) performing its regulatory function or discussing regulatory issues. Attendees had an opportunity to ask questions of the NRC staff or make comments about the issues discussed following the business portion of the meeting; however, the NRC was not actively soliciting comments toward regulatory decisions at this meeting.
Purpose of the Meeting:
To discuss the status of the NRC staff's review of Electric Power Research Institute (EPRI)
Technical Report 3002025288, Risk-Informed CMPBC.
General Details:
The NRC staff held a public, observational meeting with EPRI to discuss the status of the NRC staff acceptance review EPRI TR 3002025288, Risk-Informed CMPBC. The meeting began at 2:00 pm and ended at 5:15 pm. There were 31 NRC staff members, 7 EPRI staff, 3 Nuclear Energy Institute members, 17 member of industry, and 13 members of the public or individuals who did not identify themselves. The meeting began with introductions of the NRC staff and EPRI staff in the conference room.
Summary of Meeting:
The NRC staff provided key messages. First, the NRC staff explained that this technical report appears written as a guidance document and not a topical report, not as detailed as other EPRI topical reports. Second, the NRC staff stated, based on the information in the technical report, that the deterministic aspects (Criteria 1-10) are not complete at this time. Finally, the NRC staff acknowledged that EPRI had revised the technical report based on staffs previous comments on probabilistic risk assessment (PRA) aspects.
EPRI staff began their presentation by stressing that there are no PRA or deterministic criteria.
Rather, there are holistic, risk-informed criteria. EPRI staff also stated that they did not intend to weaken or change Class 1 structures, systems, and components (SSCs). EPRI staff explained that industry has identified efficiencies that could greatly improve plant activities, specifically:
Streamline NRCs and Licensees resource utilization Full plant evaluation (safety and non-safety systems)
Provide concrete safety improvements Reduce worker exposure Reduce Radwaste The NRC staff asked if a pre-application meeting specific to this technical report was requested or held. EPRI staff stated that no such meeting was requested or held specifically for this technical report, but a pre-application meeting was held for the Limerick Generating Station, Units 1 and 2 (Limerick) license amendment request (LAR), numerous meetings during Limerick LAR review, and a meeting associated with the partial denial of the Limerick LAR.
EPRI staff acknowledged the NRC staffs concern that SSCs are currently identified as Class 1 will be downgraded. EPRI staff stated that Class 1 SSCs should be high safety significance and any changes to the SSC classification would be accomplished outside of Technical Report 3002025288 methodology.
EPRI staff stepped through the supporting the risk-informed categorization methodology, identifying the prerequisites and guardrails to ensure the appropriate designation of high and low safety significant.
The NRC staff expressed that the criteria or guardrails describe the what but not the why.
Further, the NRC staff explained this is why the document reads more like a guidance document than a topical report.
The NRC staff also explained that the tables in Chapter 5 has caused concern because a lot of the SSCs are identified as low safety significance based on a methodology that provides the what and not the why.
EPRI staff explained that industry has gained substantial experience with numerous pressure boundary categorization efforts and this approach to categorize passive components is there result and implementation of the experience.
The NRC staff is concerned that this risk-informed categorization methodology for pressure boundary components is less robust than the current process without a justification and basis to support the reduction in rigor.
Public Participation Themes:
No member of the public spoke on the webinar.
Action Items/Next Steps:
The NRC staff will prepare and issue a meeting summary.
The NRC staff will caucus and discuss the information discussion and its impact on the completion review of EPRIs technical report. The NRC staff needs to conclude the completion review and provide feedback to EPRI.
Attachments:
Meeting description and agenda - ADAMS Accession No. ML24040A007 NRC slide presentation - ADAMS Accession No. ML24039A109 Vendor slide presentation - ADAMS Accession No. ML24044A000
U.S. Nuclear Regulatory Commission Public Meeting - Attendees List February 12, 2024
Title:
Status of the NRC Staff's Review of Electric Power Research Institute (EPRI) Technical Report (TR) 3002025288 Enhanced Risk-Informed Categorization Methodology for Pressure Boundary Components (Risk-Informed CMPBC)
Name NRC Participants Jana Bergman NRC Mihaela Biro NRC Billy Blaney NRC Adrienne Brown NRC Jeff Circle NRC Phyllis Clark NRC Stephen Cumblidge NRC Mike Franovich NRC Stephanie Garza NRC David Gennardo NRC Gerond George NRC Jo Jacobs NRC Lois James NRC Meena Khanna NRC Daniel King NRC Andrea Kock NRC Sam Lee NRC Matthew Mitchell NRC Carol Moyer NRC Ching Ng NRC Robert Pascarelli NRC Jigar Patel (HQ)
NRC Bo Pham NRC April Pulvirenti NRC Aida Rivera NRC Anthony Rossi NRC David Rudland NRC Alexander Schwab NRC Zach Turner NRC Shilp Vasavada NRC Sunil Weerakkody NRC Name EPRI Participants Robert Austin EPRI Fernando Ferrante EPRI
Name EPRI Participants Rick Fougerousse EPRI Carl Latiolais EPRI Jim Moody EPRI Patrick O'Regan EPRI Michael Riszkowski EPRI Industry Participants Name Affiliation Roy Linthicum Constellation Nuclear Suzanne Loyd Constellation Nuclear Jeffrey Stone Constellation Nuclear Sean Franklin Duke Energy Robert Isbell Duke Energy Heather Davis Szews Duke Energy Jennifer Varnedoe Duke Energy Robert Burrell Enercon Jeff Gromatzky Enercon Bob Post Enercon Tim Sande Enercon Rob Burg Engineering Planning and Management (EPM), Inc.
David Bidwell Jensen Hughes David Passehl Jensen Hughes Hunter Young Jensen Hughes Jim Chapman Jim Chapman, LLC Victoria Anderson Nuclear Energy Institute (NEI)
Thomas Basso Nuclear Energy Institute (NEI)
Jon Facemire Nuclear Energy Institute (NEI)
Carrie Gilbreath Southern Nuclear Public Participants Name Affiliation Dr. Jeffrey Guey Member of the Public Shane Jured Member of the Public Brian Nolan Member of the Public 10 Unidentified Member of the Public
ML24054A006 (NRC and vendor slides are listed in summary)
^via eConcurrence
- via e-mail NRR-106 OFFICE DORL/LLPB/PM DORL/LLPB/LA DNRL/NPHP/BC DRA/ALPA/BC NAME LJames*
DHarrison^
MMitchell^
BPascarelli^
DATE 02/23/2024 2/28/2024 02/29/2024 03/21/2024 OFFICE DORL/LLPB/BC DORL/LLPB/PM NAME GGeorge^
LJames*
DATE 03/22/2024 03/29/2024