ML24232A148
| ML24232A148 | |
| Person / Time | |
|---|---|
| Issue date: | 09/17/2024 |
| From: | Barwell O NRC/OCFO |
| To: | Ruszkowski M Electric Power Research Institute |
| Shared Package | |
| ML24232A147 | List: |
| References | |
| 3002028939 | |
| Download: ML24232A148 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Michael Ruszkowski, Plant Support Director Electric Power Research Institute Charlotte Office 1300 West W.T. Harris Blvd Charlotte, NC 28262-8550
SUBJECT:
RESPONSE TO THE ELECTRIC POWER RESEARCH INSTITUTE'S REQUEST FOR A FEE EXEMPTION OF NRC REVIEW FEES FOR RISK-INFORMED HIGH ENERGY LINE BREAK EVALUATION REQUIREMENTS, EPRI TECHNICAL REPORT 3002028939
Dear Michael Ruszkowski:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter dated July 23, 2024, (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML24205A148), requesting a fee exemption under Title 10 of the Code of Federal Regulations (10 CFR) 170.11(a)(1)(ii) for the NRC staffs review of Risk-Informed High Energy Line Break Evaluation Requirements, Electric Power Research Institute (EPRI)
Technical Report 3002028939.
The NRC has established regulations for the granting of fee exemptions under 10 CFR 170.11 Exemptions. An interested person may apply for an exemption under 10 CFR 170.11 in accordance with 10 CFR 170.5, Communications.1 The NRC staff reviewed your request based on the regulations in 10 CFR 170.11(a)(1)(ii) and 10 CFR 170.11(d).
Section 170.11(a)(1)(ii) states:
No application fees, license fees, renewal fees, inspection fees, or special project fees shall be required for: (1) A special project that is a request/report submitted to the NRC... (ii) When the NRC, at the time the request/report is submitted, plans to use the information to assist the NRC in generic regulatory improvements or efforts (e.g., rules, regulatory guides, regulations, policy statements, generic letters, or bulletins).
Section 170.11(d) states:
All fee exemption requests must be submitted in writing to the Chief Financial Officer in accordance with § 170.5, and the Chief Financial Officer will grant or deny such requests in writing.
1 10 CFR 170.5 provides that All communications concerning the regulations in this part should be addressed to the NRCs Chief Financial Officer, either by mail to the U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; by hand delivery to the NRCs offices at 11555 Rockville Pike, Rockville, Maryland; or, where practicable, by electronic submission, for example, via Electronic Information Exchange, or CD-ROM.
September 16, 2024
M. Ruszkowski In your letter submitting EPRI Technical Report 3002028939, Risk-informed High Energy Line Break Evaluation Requirements, you requested NRC review and approval of risk-informed methodology for addressing the requirements of 10 CFR Part 50, Domestic licensing of production and utilization facilities, Appendix A, General Design Criteria for Nuclear Power Plants, General Design Criteria (GDC)-4, Environmental and Dynamic Effects Design Bases.
Your letter also states that GDC-4 requires that structures, systems, and components (SSCs) important to safety be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. These SSCs are to be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear power unit.
Further, your letter describes the current implementation guidance for meeting GDC-4 that are found in plant-specific licensing commitments in updated final safety analysis reports as well as NUREG-0800, Standard Review Plan [SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light Water Reactor] Edition Design of Structures, Components, Equipment, and Systems, sections 3.6.1, Plant Design for Protection Against Postulated Piping Failures in Fluid Systems Outside Containment, and 3.6.2, Determination of Rupture Locations and Dynamic Effects Associated with the Postulated Rupture of Piping. The criteria contained in the SRP involve differentiating between high and moderate energy systems, identifying where to postulate break locations, identifying postulated break sizes and shapes, and determining fluid/environmental effect of the postulated breaks. These criteria are deterministic and are generally known as high energy line break (HELB) programs.
Finally, your letter explains that probabilistic fracture mechanics computer codes have improved and can now evaluate piping rupture events with initial emphasis on leak-before-break considering applicable active degradation mechanisms and can be applied to HELB programs.
NRC staff review and approval of EPRI Report 3002028939 will establish how licensees can develop risk-informed HELB programs and develop future license amendment requests. The methodology in EPRI Report 3002028939 adapts and expands on the guidance for risk-informed in-service inspection programs, previously approved in topical reports2 to assess the consequences of pipe failures and better characterize the risk significance of potential HELBs.
The methodology in EPRI Report 3002028939 provides guidance on how to use risk insights to determine appropriate strategies (or treatment) to mitigate HELB risk. This approach is consistent with the NRCs 1995 Final Policy Statement on Use of Probabilistic Risk Assessment Methods in Nuclear Regulatory Activities (60 FR 42622; August 16, 1995), in that it uses probabilistic risk assessment and associated analyses to reduce unnecessary conservatism associated with current regulatory guidance.3 Additionally, this activity will assist the NRC staff in incorporating risk-informed performance-based approaches into regulatory activities, conforming with current the NRC Strategic Plan.4 The NRC staff concludes that if approved, the guidance in EPRI Report 3002028939 could be used as an alternative to the deterministic guidance currently contained in SRP 3.6.1 and 3.6.2, or to help risk inform the SRP in future updates. In addition, the safety evaluation documenting the review and approval of EPRI Report 3002028939, will help staff to efficiently review and approve individual license amendment requests to adopt risk-informed HELB strategies.
2 NRC-approved EPRI Topical Report TR-112657 Revision B-A,( ML013470102).
3 Paragraph (2) of the 1995 Final Policy Statement (60 FR 42622; August 16, 1995).
4 Strategy 1.1.1 of NRC Strategic Plan: Fiscal Years 2022-2026 (ML22067A170).
M. Ruszkowski Therefore, I am granting your request for a fee exemption for the review of the EPRI Technical Report 3002028939. However, as the review progresses, the staff will continue to assess the generic applicability of the submittal. The fee exemption granted in this letter for the review of EPRI Technical Report 3002028939 is limited to the time required for the NRC staff to complete the acceptance review of the document. Once the acceptance review is completed, the staff will re-evaluate to determine if the review activities for EPRI Technical Report 3002028939 continue to qualify for a fee exemption. The staff will make the determination to continue with a fee exemption for EPRI Technical Report 3002028939 based on the generic applicability of the approach to a broad segment of the industry.
If you have any technical questions regarding this matter, please contact Lois James at 301-415-3306. Please contact Billy Blaney, of my staff, at 301-415-5092 for any fee-related questions.
Sincerely, Owen F. Barwell Chief Financial Officer Signed by Barwell, Owen on 09/16/24
M. Ruszkowski
SUBJECT:
RESPONSE TO THE ELECTRIC POWER RESEARCH INSTITUTE'S REQUEST FOR A FEE EXEMPTION OF NRC REVIEW FEES FOR RISK-INFORMED HIGH ENERGY LINE BREAK EVALUATION REQUIREMENTS, EPRI TECHNICAL REPORT 3002028939, DATED: SEPTEMBER 16, 2024 DISTRIBUTION: OCFO-24-00144 NAridi, OCFO MVelasquez, OCFO LJames, NRR RidsNrrOd Resource EXTERNAL DISTRIBUTION:
mruszkowski@epri.com ADAMS Accession Number: ML24232A147 Package; ML24232A148 Letter OFFICE OCFO/DOB OCFO/DOB NRR/DRA NRR/DEX NAME BBlaney JJacobs BPascarelli SBailey DATE 08/19/2024 08/19/2024 08/20/2024 08/19/2024 OFFICE NRR/DORL NRR/DORL NRR/DNRL NRR/DRA NAME GGeorge ARivera-Varona SLee AZoulis DATE 08/20/2024 08/27/2024 08/26/2024 08/26/2024 OFFICE OGC OCFO/DOC OCFO/DOC OCFO/DOB NAME EDuncan*NLO RRevinzon MBlair ARossi DATE 09/04/2024 09/05/2024 09/05/2024 09/05/2024 OFFICE OCFO/DOB OCFO/DOB CFO NAME LYee MNeville OBarwell DATE 09/09/2024 09/11/2024 09/16/2024 OFFICIAL RECORD COPY