ML24162A245
| ML24162A245 | |
| Person / Time | |
|---|---|
| Issue date: | 06/12/2024 |
| From: | Mike Franovich NRC/NRR/DRA |
| To: | |
| References | |
| Download: ML24162A245 (1) | |
Text
Information Sharing Public Meeting Draft Guide (DG) 1425 Update to Regulatory Guide 1.183, Revision 1, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors June 12, 2024 ADAMS Accession No. ML24162A245
Introductions
Please ensure to identify yourself before speaking throughout the meeting.
3 ADAMS ML24162A245 NRC Opening Remarks Michael Franovich, Director Division of Risk Assessment Office of Nuclear Reactor Regulation
Agenda
- Background
- Methods of Stakeholder Involvement
- Schedule
- Overview of Early Public Engagement Efforts
- Priorities
- Selected Topics for Discussion
- Review of Public Draft Language File 4
Background - What/Why Revision 0 - Implementing guidance for 10 CFR 50.67, Accident Source Term Identified the significant attributes of an acceptable accident AST based largely on NUREG-1465, Accident Sources Terms for Light-Water Nuclear Power Plants (1995) provides assumptions and methods that are acceptable to the NRC staff for performing design basis radiological analyses using an AST Revision 1 - Incorporated improved understanding of source term behavior and expanded applicability to higher burnups Revision 2 -
Safely enable applicability to higher burnups and increased enrichments Address implementation issues Refine conservatisms and allow flexibility in analysis approaches Maintain adequate protection and reflect NRC commitments to Principles of Good Regulations See supplementary slides for additional information on RG process.
Background (Contd)
Increased Enrichment Rulemaking
- Docket ID NRC-2020-0034, www.regulations.gov
- Regulatory Basis comment period ended on January 22, 2024
- Alternative 2 for Control Room Dose Criteria proposed changes to criteria
- Staff has been developing draft guidance in case this alternative is selected
- Per NRC policy to reduce the cumulative effects of regulation, implementing guidance should be developed with proposed rules
- Important Point - Development of rule language is related to but separate from guidance development 6
ADAMS ML24162A245 Stakeholder engagement for the rulemaking is through Regulations.gov.
Stakeholder Involvement
- Staff aiming to be responsive to feedback
- Public Workshops and Information Meetings
- 3 Workshops (1/9/24, 2/13/24 and 3/8/24)
- 2 Information Sharing Meetings (5/1/24 and 6/12/24)
- Contact Project Leads
- Meeting Feedback
- ACRS Briefings - approximately Spring 2025
- Draft Guide Comment Period
- Aligned with Proposed Increased Enrichment Rulemaking
- Docket ID NRC-2020-0034, www.regulations.gov
- Comment period on Proposed Increased Enrichment Rulemaking Regulatory Basis ended on January 22, 2024 7
8 ADAMS ML24162A245 Project Schedule Milestone Tentative Completion Public Workshops* and Information Meetings**
January 2024 - June 2024 DG Internal Review begins June 2024 DG Internal Review completed October 2024 Pre-Decisional DG Publicly Available to Support ACRS Briefings Spring 2025 ACRS Briefings (Staff to respond as needed)
Spring 2025 Increased Enrichment Proposed Rule package to Commission (will include DG referenced in SECY paper)
June 2025 ***
- 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)
Overview of Early Public Engagement Efforts 5 Total Public Meetings 3 Workshops, 2 Information Sharing About 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> of public meeting time (not inclusive of preparation time)
Responsive to request for opportunities for early stakeholder engagement Benefits Generate shared understanding Incorporate stakeholder perspective in final positions recommended by staff Enables sharing stakeholder perspective in staff communications with the Commission Additional Considerations Early engagement efforts are complementary of the agency processes for public engagement 9
Priority Mapping NRC Priorities Adequate protection/POGR Changes to enable Increased Enrichment Rulemaking Develop implementing guidance for BWR pathway specific source terms Address potential guidance implementation issues Select DPO Items Version consolidation/backfit?
Non-LOCA Release Fractions Non-LOCA FFRD EQ Process improvements Refine Conservatisms Flexibility 10 ADAMS ML24162A245
Insight into Guidance Development Process
- Process
- Staff makes technically sound recommendations to management
- Management approves recommendations to Commission
- Commission can approve/deny/set different course
- Diversity in thought and positions among staff
- Free and open exchange of views and ideas
- NRC Policy on Differing Views (ML17065A327) provides multiple options for Staff 11 ADAMS ML24162A245
Priorities Addressed Enable implementation of near-term, advance reactor fuels including increased enrichments and high burnup fuels Up to 8 weight-percent (wt%) Uranium-235 (U-235) for PWRs and (10 wt% U-235 for BWRs)
Up to a maximum rod average 80 gigawatt days per metric ton uranium (GWd/MTU)
Implementing graded, risk-informed, performance-based approach to determining applicable control room design criterion Enable crediting BWR suppression pool for radionuclide transport calculations through implementation of a pathway-specific source term approach Implementation Issues Select DPO items Version consolidation/backfit - Revs 0, 1 and 2 will coexist with applicability statements as described in each version. No information has been discovered that would challenge the staffs conclusions of the adequacy of each revision when limited to the applicability statements in each revision Updated non-LOCA release fractions, guidance for developing fuel-design/plant-specific release fractions and guidance for non-LOCA FFRD Process Improvements:
Guidance for conducting margins analyses and increasing risk-informed considerations in submittals Guidance for best-estimate plus uncertainty approaches to calculations 12 ADAMS ML24162A245
Selected Topics for Discussion 13 ADAMS ML24162A245
Topics
- Control Room Design Criteria
- Pathway-Specific Source Term Guidance
- Non-LOCA Gap Release Fractions and Changes to Appendix I
- Best Estimate Plus Uncertainty Guidance
- Additional Changes
- Additional background information (e.g., EP, licensing basis information needed for applications, regulatory source terms)
- KM Appendix 14 ADAMS ML24162A245
- Docket ID NRC-2020-0034, www.regulations.gov
Public Draft Guide Excerpts File ML24162A323 Disclaimer:
Draft language being considered by staff, does not have the benefit of full internal review Purpose -
Continued opportunity for early public engagement in the regulatory process Support discussions during this meeting Enable decision-making Support comprehensive communications with the Commission Staff does not intend to formally respond to comments or accept additional comments pertaining to this document, after this meeting Public comment period for the DG will be aligned with the Increased Enrichment Rulemaking (Docket ID NRC-2020-0034, www.regulations.gov) 15 ADAMS ML24162A245
Feedback and Discussion 16 ADAMS ML24162A245
Comments and Input from the Public 17 ADAMS ML24162A245
Adjourn 18 ADAMS ML24162A245
ADAMS ML24162A245 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 19
20 ADAMS ML24162A245 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
21 ADAMS ML24162A245
- 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