ML25240B610
| ML25240B610 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 08/28/2025 |
| From: | Anderson V Nuclear Energy Institute |
| To: | Office of Administration |
| References | |
| NRC-2025-0088, 90FR278980 00001 | |
| Download: ML25240B610 (1) | |
Text
PUBLIC SUBMISSION As of: 8/28/25, 3:17 PM Received: August 28, 2025 Status: Pending_Post Tracking No. mev-o02r-6tc1 Comments Due: August 29, 2025 Submission Type: Web Docket: NRC-2025-0088 Level 3 Probabilistic Risk Assessment Project Documentation (Volume 6)
Comment On: NRC-2025-0088-0001 Level 3 Probabilistic Risk Assessment Project Documentation (Volume 6)
Document: NRC-2025-0088-DRAFT-0001 Comment on FR Doc # 2025-12017 Submitter Information Email:smp@nei.org Organization:Nuclear Energy Institute General Comment See attached file(s)
Attachments 8-28-25_Industry Comments on NRC Draft Report on the Level 3 Probabilistic Risk Assessment (PRA)
Project Docket ID NRC-2025-0088 8/28/25, 3:18 PM NRC-2025-0088-DRAFT-0001.html file:///C:/Users/BHB1/Downloads/NRC-2025-0088-DRAFT-0001.html 1/1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Alan Kuritzky, Mary Neely Comment (1)
Publication Date:
6/30/2025 Citation: 90 FR 278980
Victoria K. Anderson Technical Advisor Engineering and Risk Phone: 202.739.8101 Email: vka@nei.org August 28, 2025 Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Program Management, Announcements, and Editing Staff
Subject:
Industry Comments on NRC Draft Report on the Level 3 Probabilistic Risk Assessment (PRA)
Project; Volume 6a: Spent Fuel Pool Level 1 and Level 2 PRA, and Volume 6b: Spent Fuel Pool Level 3 PRA, Docket ID NRC-2025-0088 Project Number: 689 Submitted via regulations.gov
Dear Program Management,
Announcements, and Editing Staff, On June 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) issued a notice in the Federal Register soliciting comments on the subject draft report. The Nuclear Energy Institute (NEI)1 is pleased to provide comments on this draft report on behalf of the nuclear energy industry.
NEI previously provided comments on a draft of the Level 3 Probabilistic Risk Assessment (PRA) Project Volume 4, Overview of Reactor, At-Power, Level 1, 2, and 3 PRAs for Internal Fires, Seismic Events, and High Winds, on October 19, 2023, and on the Level 3 PRA Project Volume 7, Dry Cask Storage PRA on September 17, 2024. In both letters, NEI suggested that NRC should reconsider the value of the Level 3 PRA Project after over a decade of resource devotion with minimal developed insights relevant to nuclear safety. The comments specifically noted that substantial uncertainties remain in the Level 3 PRA portion of the study and that there does not yet appear to be any insight to be gained from spending multiple years developing a Level 3 PRA for an operating reactor, and neither industry nor NRC resources should be invested in full-scope Level 3 PRAs for the operating fleet. NEIs perspective on the relative value of the Level 3 PRA Project remains unchanged, and NEI again suggests that the NRC should strongly consider sunsetting the project absent identification of clear regulatory applicability or benefit to public safety and security. Such clear regulatory applicability has not been identified since the most recent 1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Office of Administration August 28, 2025 Page 2 Nuclear Energy Institute comment letter in September 2024, and NEI continues to suggest that this work no longer be pursued by NRC.
Additionally, NEI has several observations about the draft Volume 6a and 6b reports specifically, and suggests that Spent Fuel Pool (SFP) PRA likely provides no benefit in terms of additional safety or operational insights. NEI encourages the NRC to consider these perspectives in any future actions or plans regarding the Level 3 PRA Project.
Neither report relayed new insights on SFP operations, indicating that development of SFP PRAs would have no discernable benefit for stakeholders. The study reinforced that seismic events are likely to dominate the risk profile for SFPs, and that the risk from SFP operations is significantly lower than the already low risks from operating reactors. With no new insights to offer, an SFP PRA has no value in supporting decision making.
This report reinforced that, for SFP operations, PRA is not a particularly useful tool beyond providing a demonstration that the associated risks are very low. Volume 6a acknowledged in Section 1.2 that specific data to support an SFP PRA is largely unavailable, and that resolving this would require extremely extensive efforts to generate analogous data streams.
Volumes 6a and 6b showed substantial uncertainties in the results, with the 95th and 5th percentile spanning an order of magnitude or more. This indicates that SFP PRA data is not sufficiently advanced to support regulatory application, and that SFP PRA results are of little practical use.
Both of the reports reinforce that SFP operations are extremely low risk. Section 3.1.3 of Volume 6a state that preliminary project results suggest that the SFP fuel damage frequency may be more than an order of magnitude lower than the single-unit reactor CDF, and Section 5.7 of Volume 6b states that the risk of SFP accidentsis much lower than the already extremely low individual early fatality risk from reactor accidents. With the findings that the risks are so low, expending resources on quantifying these risks in detail offers little additional insight on SFP operations, and should not be pursued by either the NRC or the industry.
Thank you for the opportunity to provide industrys views on these draft reports. 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 C: