ML24220A138
| ML24220A138 | |
| Person / Time | |
|---|---|
| Issue date: | 08/12/2024 |
| From: | Banks I NRC/NRR/DNRL/NLIB |
| To: | Hayes M NRC/NRR/DNRL/NLIB |
| Shared Package | |
| ML24220A101 | List: |
| References | |
| Download: ML24220A138 (3) | |
Text
Enclosure 3 U.S. NUCLEAR REGULATORY COMMISSION
SUMMARY
OF THE JULY 15, 2024, OBSERVATION PUBLIC MEETING WITH THE AMERICAN NUCLEAR SOCIETY TO DISCUSS ANSI/ANS-30.3-2022, LIGHT WATER REACTOR RISK-INFORMED, PERFORMANCE-BASED DESIGN Meeting Summary The U.S. Nuclear Regulatory Commission (NRC) held an observation public meeting on July 15, 2024, with the American Nuclear Society (ANS), to discuss ANSI/ANS-30.3-2022, Light Water Reactor Risk-Informed, Performance Based Design, (hereafter referred to as ANS-30.3). On August 9, 2022, ANS sent a letter to the NRC requesting review and endorsement of the standard.1 On June 27, 2023, the NRC responded to the letter and included a non-exhaustive list of general and preliminary technical observations.2 On January 31, 2024, ANS responded to the observations from the NRC and requested to have a public meeting.3 This public meeting satisfies that request. The NRC and ANS provided presentation materials for the public meeting.4, 5 This hybrid observation public meeting had attendees from ANS, NRC staff, the Nuclear Energy Institute (NEI), and members of the public.
No regulatory decisions or commitments were made during the meeting.
The following summarizes the discussion during the meeting:
After opening remarks from the NRC and ANS, the NRC staff provided an overview of the agenda and described the purpose of the meeting as to discuss ANS-30.3. They explained that after the meeting they would use the feedback from stakeholders gathered during the meeting to inform the NRCs path forward on the request for endorsement.
The staff commented that the lack of details in ANS-30.3 adds to the effort that would be required to review the standard for endorsement.
1 Letter from American Nuclear Society (ANS) to U.S. NRC, ANS Letter of Notification of ANSI Approved Standard for NRC Review and Endorsement -ANS-30.3, dated August 9, 2022, ML23111A238, part of package ML23121A270.
2 U.S. NRC, Response To American Nuclear Society Letter Of Request for NRC Endorsement Of ANSI/ANS-30.3-2022, Light Water Reactor Risk-Informed, Performance-Based Design, dated June 27, 2023, ML23121A283, part of package ML23121A270.
3 Letter from American Nuclear Society (ANS), ANS-30.3 Working Group Response to NRC Letter Dated June 27, 2023, Providing Preliminary Comments on the Request for Endorsement of ANSI/ANS-30.3-2022, dated January 31, 2024, ML24046A023, part of package ML23121A270.
4 U.S. NRC Presentation Materials, NRC Presentation Materials for the Public Meeting with ANS to Discuss ANSI/ANS-30.3-2022, Light Water Reactor Risk-Informed, Performance Based Design, dated July 15, 2024, ML24185A140, part of package ML24185A139.
5 American Nuclear Society (ANS), ANS Presentation Materials for the NRC Public Meeting to Discuss ANSI/ANS-30.3-2022, Light Water Reactor Risk-Informed, Performance Based Design, dated July 15, 2024, ML24192A265, part of package ML24185A139.
2 The staff expressed concern that given the absence of detailed implementation guidance, endorsement of ANS-30.3 would not provide the desired level of regulatory clarity and stability.
The staff noted that the NRC is not able to endorse any guidance that may be inconsistent with the regulations without Commission approval, noting that Regulatory Guide (RG) 1.233 was issued after receiving Commission approval. 6 The staff asked ANS for clarity related to its use of the word exceptions in ANS-30.3.
The staff asked ANS if users of ANS-30.3 will need to ask for exemptions, stating that the NRC cannot generically endorse an approach that would require exemptions because that is considered de facto rulemaking. Each exemption request requires special circumstances and review on a case-by-case basis.
The staff highlighted that ANS-30.3 uses the International Atomic Energy Agency glossary which has definitions that are inconsistent with how similar terms are defined in NRC policies, regulations, and other regulatory documents. The staff notes that resolving the different terminologies will increase the resources required to review the standard for endorsement.
The staff noted that while an NRC endorsement of the standard is desired, such an endorsement is not essential for a designer to use ANS-30.3 during the design process.
The staff concluded its presentation by asking how many vendors have committed to using ANS-30.3. The staff also asked if there has been any considerations for the development of implementing guidance.
ANS began its presentation by introducing ANS-30.3 as a standard that establishes a minimum set of process requirements for the designer to follow in order to combine deterministic, probabilistic, and performance-based methods for designing light-water reactors (LWRs).
ANS explained that risk informed performance based (RIPB) design is a sub-process within the overall reactor design and product development process.
ANS then described the scope and application of ANS-30.3, followed by a timeline detailing the development of the standard.
ANS stated that ANS-30.3 is a transitional, RIPB process standard which meets the technology-inclusive intent of the Nuclear Energy Innovation and Modernization Act.
ANS stated that the primary user of the standard has been NuScale Power.
Following the presentation by ANS, the NEI, provided brief remarks. NEI stated that it is unaware of anyone in the industry that is interested in using ANS-30.3 at this time.
6 U.S. NRC, RG, 1.233, Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light Water Reactors, Revision 0, June 2020.
https://www.nrc.gov/docs/ML2009/ML20091L698.pdf
3 During the open discussion period, ANS responded to a question from the NRC staff stating that it was not the intent of ANS-30.3 to create a standard that created de facto rulemaking and that users should follow the NRCs exemption process if there are exemptions.
ANS explained that ANS-30.3 fills a gap, stating that there is currently no equivalent to RG 1.233 that exists for LWRs.
During the public comment portion, ANS requested that the NRC formally provide their feedback in a response to ANS. No other members of the public provided comments.
To close the meeting, the NRC staff stated that decisions regarding how to allocate review efforts will be determined based on the resources available, placing emphasis on efficiency and expressed interest from stakeholders. The NRC staff reiterated that the staff intends to digest the comments made during the meeting discussion and consider what options are available to the NRC staff regarding endorsement of the standard.
The meeting adjourned at 11:52 am.