ML25003A199
| ML25003A199 | |
| Person / Time | |
|---|---|
| Issue date: | 01/13/2025 |
| From: | Michael Mahoney NRC/NRR/DORL/LPL4 |
| To: | Tony Nakanishi NRC/NRR/DORL/LPL4 |
| Shared Package | |
| ML25003A200 | List: |
| References | |
| EPID L-2023-PPM-0004 | |
| Download: ML25003A199 (1) | |
Text
January 13, 2025 MEMORANDUM TO:
Tony T. Nakanishi, Chief Licensing Projects Branch 4 Division of Operating Reactors Licensing Office of Nuclear Reactor Regulation FROM:
Michael Mahoney, Project Manager /RA/
Plant Licensing Branch 4 Division of Operating Reactors Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF NOVEMBER 14, 2024, PUBLIC MEETING WITH NUCLEAR ENERGY INSTITUTE TO DISCUSS POTENTIAL ENHANCEMENTS FOR POWER UPRATE APPLICATIONS AND REVIEWS (EPID L-2023-PPM-0004)
On November 14, 2024, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Nuclear Energy Institute (NEI) virtually. The purpose of the meeting was for the NRC and NEI to discuss potential improvements in NRC staff guidance for Power Uprate reviews. The meeting notice and agenda, dated October 23, 2024, are available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML24297A028. A list of attendees is provided in the enclosure.
NEI presented meeting slides (ML24318C453) on the industrys perspective on efficiencies with power uprate combined license applications.
NEI discussed the ADVANCE Act and potential efficiencies in NRCs review of power uprate applications. NEI provided a recap of previous public meetings, such as the September 5, 2024, public meeting where combined (bundled) power uprate licensing actions were discussed. NEI reiterated that efficiencies (overall project savings could be measured in years) may be gained in bundling licensing actions with power uprate applications. NEI discussed combining power uprate applications with accident tolerant fuel (ATF), low enriched Uranium plus (LEU+) and higher burnup (HBU) fuel transition licensing actions.
Duke Energy discussed an example of a power uprate application combined with a fuel transition, potentially using license conditions to account for fuel burnup and enrichments beyond levels allowable by current regulations and guidance. Duke Energy also discussed an example license condition used in the Title 10 of the Code of Federal Regulations (10 CFR),
Section 50.69 license amendments. indicating that the NRC has approved 10 CFR 50.69 amendments using license conditions related to implementation (based on completion of items identified during the staff review). Lastly, Duke Energy presented a timeline of potential submittal and approval of a bundled power uprate application with HBU/increased enrichment
(IE), and that full implementation would only be possible after the final increased enrichment rule is published (currently targeted in 2027).
The NRC staff presented meeting slides (ML24318C512) on the NRC power uprate working groups proposed graded approach to power uprate reviews.
The NRC staff discussed that one of the working groups preliminary recommendations was that the staff review of power uprate applications should focus on the most risk and safety significant portions of the application. This graded approach will enable the staff to evaluate the extent to which the power uprate impacts structures, systems, and components (SSCs) functions and requirements important to safety. The staff created three categories (or bins) to use to grade the expected level of effort commensurate with its safety and risk significance. The staff used areas of review from NRCs review standard (RS)-001, Review Standard for Extended Power Uprates (ML023610659). The staff also uses RS-001 for stretch power uprate reviews. The staff discussed other factors such as margin to regulatory limits, defense in depth, and precedents and use of approved methods, that could affect bin assignments.
Bin 1 is defined as power uprate review areas which are expected to have minimal NRC staff review effort. Bin 1 would include review areas (or systems) that are not subject to impact by a power uprate since the power uprate would not likely effect system design or operation.
Bin 2 is defined as review areas that are affected by a power uprate, need to be reviewed against NRC regulations, but unlikely to have a significant impact on nuclear safety. Bin 2 would include review areas (or systems) that may be impacted by a power uprate due to potential changes in system design or operating conditions but would have little to no impact on plant safety since conditions are not expected to exceed the design parameters (pressure, temperature, flow, etc.) for the SSCs.
Bin 3 is defined as review areas (or systems) that are directly impacted by operation at the uprated power and expected to require a detailed review by the NRC staff. Bin 3 includes areas that result in significant changes system design, analyses or operation; significant changes in margin that also challenge regulatory limits; risk-significant changes; or deviation from NRC-approved methodologies.
The NRC staff stated that there would be no change for the staffs review to conclude that
- 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, 2) there is reasonable assurance that such activities will be conducted in compliance with the NRC's regulations, and 3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. The NRC staff stated that the working group continues to define the graded approach/binning strategy.
Lastly, NRC staff provided a discussion of the power uprate working groups efforts. This included issuance of the working groups preliminary recommendation memorandum, a memorandum related to signature authority for extended power uprates, and updates to the power uprate public website.
No regulatory decisions were made during the meeting. No public meeting feedback or feedback forms were received.
There were 2 comments from a member of the public in attendance.
A member of the public asked that the graded approach documentation, in draft form, be made available to the public prior to issuance of future power uprate license amendments. NRC staff acknowledged this comment and agreed that a draft of the graded approach be made public when the draft is completed.
Edwin Lyman of the Union of Concern Scientists commented on slide 4 of the NRC staff presentation that other factors other than core damage frequency and large early release frequency should be considered when talking about risk amendable Standard Review Plan sections. The NRC staff acknowledged this comment.
Please direct any inquiries to me at 301-415-3867 or michael.mahoney@nrc.gov.
Enclosure:
List of Attendees
Enclosure LIST OF ATTENDEES NOVEMBER 14, 2024, PUBLIC MEETING WITH NUCLEAR ENERGY INSTITUTE TO DISCUSS POTENTIAL ENHANCEMENTS FOR POWER UPRATE APPLICATIONS AND REVIEWS Name Organization Micheal Mahoney U.S. Nuclear Regulatory Commission (NRC)
Andrea Kock NRC Bo Pham NRC Aida Rivera-Varona NRC Tony Nakanishi NRC Vic Cusumano NRC Blake Purnell NRC Angelo Stubbs NRC John Bozga NRC Robert Beaton NRC Joshua Kaizer NRC Sandra McClure NRC Kamal Manoly NRC Scott Krepel NRC Kimberly Green NRC Gurjendra Bedi NRC David Roth NRC Todd Hilsmeier NRC Jamie Pelton NRC Matthew Hamm NRC Edward Stutzcage NRC Sheila Ray NRC Scott Burnell NRC Isaac Wang NRC Stewart Bailey NRC Al Csontos Nuclear Energy Institute (NEI)
Brett Titus NEI Charlotte Shields NEI Frances Pimentel NEI Baris Sarikaya Constellation Nuclear Dennis Earp Duke Energy Phil Lashley Vistra Corporation Thomas Bartoski Sargent Lundy Christopher Wiegand Electric Power Research Institute (EPRI)
Tara Matheny Duke Energy Duane Avery Constellation Nuclear Stephen Meyer Certrec Nicole Good Star Alliance Lisa Simpson Constellation Nuclear Scott Stanchfield Entergy Joshua Duc Duke Energy Peter Gohdes Public Service Enterprise Group (PSEG) Nuclear Dawn Crytzer Westinghouse Kurshad Muftuoglu EPRI Goeff Pihl Duke Energy Jeanne Johnston Southern Company Marty Murphy Curtis Wright Julian Turner Energy Northwest Thomas Baummer Constellation Nuclear Jay Boardman Westinghouse Richard Garica Energy Northwest Ryan Treadway Duke Energy Laurene Dobrowolski Holtec Alyse Peterson New York State Energy Research and Development Authority Eric McGrew Westinghouse Bill Steelman Entergy Tammra Oldham Energy Northwest Larry Lee Jensen Hughes Russell Long Energy Northwest Ernest Bates Southern Company Erin Sims Energy Northwest James Smith Westinghouse Richard Rogalski Energy Northwest Zeses Karoutas Westinghouse Patrick Simpson Constellation Nuclear Chris Thornell Southern Company Kevin Houston Duke Energy Fred Smith EPRI Charlotte Geiger PSEG Nuclear Trupti Narielwala Constellation Nuclear Matthew Golliet Westinghouse 4123743698 6673135131 Deann Raleigh 9105122674 Edwin Lyman Union of Concerned Scientists
Package, ML25003A200 Meeting Notice, ML24297A028 Meeting Summary, ML25003A199 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME MMahoney PBlechman (KZeleznock for) TNakanishi MMahoney DATE 01/03/2025 01/06/2025 01/10/2025 01/13/2025