ML24340A255
| ML24340A255 | |
| Person / Time | |
|---|---|
| Site: | 99902028, Nuclear Energy Institute |
| Issue date: | 11/22/2024 |
| From: | Anderson V Nuclear Energy Institute |
| To: | Jonathan Evans Office of Nuclear Reactor Regulation, Office of Nuclear Regulatory Research, Document Control Desk |
| Shared Package | |
| ML24340A254 | List: |
| References | |
| Download: ML24340A255 (1) | |
Text
Victoria K. Anderson Technical Advisor Engineering and Risk Phone: 202.739.8101 Email: vka@nei.org November 22, 2024 Mr. Jonathan Evans Chief, Probabilistic Risk Assessment Branch Division of Risk Analysis Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Follow Up on Comments Regarding Trial Use Regulatory Guide 1.247, Acceptability of Probabilistic Risk Assessment Results for Non-Light-Water Reactor Risk-Informed Activities Project Number: 689
Dear Mr. Evans,
At public meetings held on May 23, 2024, and July 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) discussed plans for issuance of Trial Use Regulatory Guide 1.247, Acceptability of Probabilistic Risk Assessment Results for Non-Light-Water Reactor Risk-Informed Activities (RG 1.247). At those meetings, the NRC conveyed that they would move forward with finalization of RG 1.247 in 2025 and 2026, while reconsidering previously provided comments that had not yet been addressed, such as industry comments regarding the NRCs addition of a supporting requirement on consideration of errors of commission in human reliability analysis. Specifically, in a May 23, 2022, letter,1 NEI stated that the final trial use version of RG 1.247 did not resolve NEIs December 9, 2021, comment2 regarding the consideration of acts of commission and the inconsistency with the current state of the practice and again suggested removal of the addition from RG 1.247. In support of the NRCs consideration of removal of the added supporting requirement on errors of commission, NEI has prepared NEI 24-09, Evaluating Errors of Commission in HRA for PRA of Advanced Reactors. A copy of this report has been attached for your information and consideration.
Mr. Jonathan Evans December 22, 2024 Page 2 Nuclear Energy Institute Additionally, NEI is continuing to engage with our members working in advanced reactor activities to secure the first trial use of RG 1.247 in 2025. As stated at the May 23, 2024 and July 30, 2024 public meetings, NEI cautions that this RG 1.247 should not be finalized until a trial use has been performed to allow for comprehensive feedback.
Thank you for the opportunity to provide industrys views on this trial use regulatory guide. If you have any questions or require additional information, please do not hesitate to contact me.
Sincerely, Victoria K. Anderson, Technical Advisor Engineering and Risk Attachment C:
Michelle Gonzalez, RES/NRC Donna Williams, RES/NRC NRC Document Control Desk