ML22054A238
ML22054A238 | |
Person / Time | |
---|---|
Issue date: | 02/23/2022 |
From: | Tekia Govan NRC/NRR/DRO |
To: | Philip Mckenna NRC/NRR/DRO |
Govan T | |
References | |
Download: ML22054A238 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 23, 2022 MEMORANDUM TO: Philip McKenna, Chief Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM: Tekia V. Govan, Project Manager /RA Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE PUBLIC MEETING TO DISCUSS A PROPOSED METHOD FOR LEVERAGING RISK INSIGHTS IN 10 CFR 50.59 EVAULATIONS WITH THE NUCLEAR ENERGY INSTITUTE HELD ON FEBRUARY 1, 2022 On February 1, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting with the Nuclear Energy Institute (NEI) to discuss their proposal for leveraging risk insights in 10 CFR 50.59 evaluations. During this meeting, NEI provided a presentation where they proposed that the evaluation approach developed for the Risk Informed Process for Evaluations (RIPE) could be used by licensees to evaluate 10 CFR 50.59 criteria by applying risk insights to determine if a proposed change results in a more than minimal increase (Agencywide Document Access Management System (ADAMS) Accession No. ML22027A392).
The presentation described how the NRC staff has taken steps to becoming a more risk informed regulator by holding public meetings to discuss the idea on how risk insights may be employed during the 10 CFR 50.59 process, the issuance of the RIPE, and the issuance of Inspection Manual Chapter 0335, Changes, Test and Experiments. NEI requested that, with the steps that the NRC has taken regarding risk insight, the NRC staff provide feedback on the concept of using the risk evaluation techniques that are described in the RIPE process for 10 CFR 50.59 evaluation and continue the dialogue with industry in this area as they prepare to develop guidance to support the use of risk evaluation techniques for 10 CFR 50.59 evaluations.
The NRC staff provided comments for NEI to consider, while stressing that no decisions will be made, or any agency position taken as a result of this informational meeting. Some of the staffs comments for NEI consideration are captured below:
- The RIPE process is not intended to be used independently and is based solely on the use of Probabilistic Risk Assessment (PRA) modeling and PRA output limits from CONTACT: Tekia V. Govan, NRR/DRO 301-415-6197
P. McKenna Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk Informed Decisions on Plant-Specific Changes to the Licensing Basis."
- RG 1.174 was developed for the purpose of guiding changes to the licensing basis where the staff was reviewing and approving the change, not for changes made under 10 CFR 50.59.
- In the statements of consideration for 10 CFR 50.59, the staff noted the following:
o The Commission concludes that if use is to be made of PRA in 10 CFR 50.59, more fundamental changes to the rule would be necessary to provide a coherent set of requirements, in that 10 CFR 50.59 deals with design basis events, and RG 1.174 deals with risk including that from severe accidents beyond the design basis. In addition, RG 1.174 is specifically dealing with operating power reactors.
o The Commission acknowledges that it may be possible to develop more guidance that could be used in a quantitative sense to judge minimal increases.
As part of development of the guidance, the NRC will consider using the values developed as part of the revised oversight process (SECY-9907), so that if the resultant likelihood of occurrence remains well within the acceptable ranges given for initiating events, that the increase is "minimal." (64 FR 53590) o The Commission agrees that the effect of the change on the frequency of the accident must be discernible and attributable to the change in order to exceed the "more than minimal" increase standard, as compared to uncertainty about the existing frequency value and how it might be quantified. (64 FR 53590)
Meeting Action Items There were no action items identified during this meeting.
Conclusion At the end of the meeting, NRC, and industry management gave closing remarks. The industry representatives expressed appreciation for the open dialogue and willingness of NRC staff to hear industry views. The NRC staff stressed the importance of the NRC being focused on providing reasonable assurance of public health and safety when considering changes.
The NRC staff is willing to meet with NEI to further discuss this topic and they develop guidance for industry use.
The enclosure provides the attendance list for this meeting.
Enclosure:
As stated
ML22054A238 * = via email OFFICE NRR/DRO/IRAB/PM NRR/DRO/IRAB/BC NRR/DRO/IRAB/PM NAME TGovan* PMcKenna* TGovan*
DATE 02/22/2022 02/23/2022 02/23/2022 LIST OF ATTENDEES MEETING TO DISCUSS A PROPOSED METHOD FOR LEVERAGING RISK INSIGHTS IN 10 CFR 50.59 EVAULATIONS WITH THE NUCLEAR ENERGY INSTITUTE February 1, 2022, 1:00 PM to 2:30 PM ATTENDEE ORGANIZATION1
- 1. Carol Moyer NRC
- 2. Antonios Zoulis NRC
- 3. Marlone Davis NRC
- 4. Shakur Walker NRC
- 5. David Beaulieu NRC
- 6. Tekia Govan NRC
- 7. Patricia Jehle NRC
- 8. Angelo Stubbs NRC
- 9. David Garmon-Candelaria NRC
- 10. James Chang NRC
- 11. Michael Benson NRC
- 12. Jeffrey Josey NRC
- 13. Gerond George NRC
- 14. Philip McKenna NRC
- 15. Michelle Kichline NRC
- 16. Dustin Reinert NRC
- 17. Justin Braisted NRC
- 18. Derek Scully NRC
- 19. Mel Holmberg NRC 1
Unknown organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.
Enclosure
- 20. Mahesh Chawla NRC
- 21. Gordon Curran NRC
- 22. Ed Miller NRC
- 23. Carolyn Fairbanks NRC
- 24. John Tsao NRC
- 25. David Aird NRC
- 26. Raul Hernandez NRC
- 27. Matthew Euten NRC
- 28. Daneira Melendex-Colon NRC
- 29. Jorge Corujo-Sandin NRC
- 30. Geoffrey Ottenberg NRC
- 31. Kristy Bucholtz NRC
- 32. Bill Rogers NRC
- 33. Isaac Anchondo-Lopez NRC
- 34. Dan Widrevitz NRC
- 35. Michael Markley NRC
- 36. Alex Garmoe NRC
- 37. David Gullott Exelon Energy
- 38. Douglas Pollock Unknown
- 39. Christian Williams Exelon Energy
- 40. Phil Couture Entergy
- 41. Darani Reddick Exelon
- 42. Peter LeBlond LeBlond & Associates, LLC
- 43. James Polickoski Unknown
- 44. Brett Titus NEI
- 45. David Bajumpaa Dominion Energy
- 46. Walter Boatwright Comanche Peak Nuclear
- 47. Steve Pope Unknown
- 48. Kyle Kriesel Unknown
- 49. Fred Madden Certrec Corporation
- 50. Neil Archambo Duke Energy
- 51. Robert Budnitz Unknown
- 52. Brian Mount Dominion Energy
- 53. Brian Thomas Unknown
- 54. DeLisa Pournaras Unknown
- 55. Susan Hoxie-Key Member of the Public
- 56. R. Briggs Energy Harbor
- 57. Jana Bergman Unknown
- 58. Wayne Lunceford EPRI
- 59. Darin Jensen Xcel Energy
- 60. Sara Scott Unknown
- 61. Tony Brown NEI
- 62. Joseph Rivers Unknown
- 64. Roy Linthicum Exelon Nuclear
- 65. Bradley Dolan TVA
- 66. Joe Cole Entergy
- 67. Warren Odess-Gillett Unknown
- 68. Andrew Mauer NEI
- 69. Hossein Hamzehee Unknown
- 70. Jordon Hagaman Unknown
- 71. John Richards Unknown
- 72. Tony Zimmerman Duke Energy
- 73. Jim Slider NEI
- 74. Rob Burg Unknown
- 75. Robin Armistead Unknown
- 76. Steve Vaughn X-Energy
- 77. Mohamed Talaat Unknown
- 78. Lee Grzeck Unknown
- 79. Alan Campbell NEI
- 80. Lon Dawson SNL