ML21314A546

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NEI Comments on RG 1.247 November 2021
ML21314A546
Person / Time
Site: Nuclear Energy Institute
Issue date: 11/03/2021
From:
Nuclear Energy Institute
To:
NRC/OCM
Williams D
References
RG 1.247
Download: ML21314A546 (7)


Text

Industry Comments on RG 1.247 NRC Public Meeting November 3, 2021

©2021 Nuclear Energy Institute

Introduction Appreciate rapid staff action to endorse ASME/ANS PRA standard and NEI 20-09 peer review guidance Endorsement of NEI 20-09 without exception is very valuable to end users of these documents

  • Result of strong cooperation between NRC staff and industry.

Stakeholder concerns with some staff clarifications on the ASME/ANS ANLWR PRA standard

  • Detailed in todays presentation

©2021 Nuclear Energy Institute 2

Specific Comments on Staff Clarifications

- Human Reliability Addition of feasibility studies (e.g., HR-G1)

  • Not appropriate
  • Redundant to existing requirements
  • Too much of a how to for a standard Expectation of consideration of acts of commission (e.g., HLR-HR-E)
  • Not consistent with current state of practice

©2021 Nuclear Energy Institute 3

Specific Comments on Staff Clarifications

- References Addition of references to Regulatory Guides and NUREGs (e.g. HR-D4)

  • Not appropriate for SRs Reference to EPA or industry guidance instead of regional guidance for weather data (e.g. RCME-A3)
  • Applicable guidance will vary depending on where standard is used
  • Best available should be used

©2021 Nuclear Energy Institute 4

Specific Comments on Staff Clarifications

- Added Expectations Addition that all stages of licensing process should address low power and shutdown types of evolutions (e.g. POS A-1)

  • Belongs in regulatory guidance, not the SRs themselves Added proof expectation for SHA applicability (e.g. SFR-C1)
  • No additional discussion should be necessary Clarifications on Non-Mandatory Appendices and notes
  • Only requirements should be endorsed and clarified Discussion on absolute vs. relative risk significance (RI-N-1)
  • This portion is Non-mandatory and should not be part of the endorsement

©2021 Nuclear Energy Institute 5

Specific Comments on Staff Clarifications

- Miscellaneous Non-endorsement of reporting thresholds (e.g. RI-N-3)

  • Important aspect of PRA in any licensing process
  • These SRs should endorsed Expectation of documentation of evaluation of all previous risk informed decisions when updating (CC-E1)
  • Out of scope for a standard
  • Belongs in application regulatory guidance

©2021 Nuclear Energy Institute 6

Next Steps NEI to provide detailed, written comments to NRC NEI, NRC, and ASME/ANS to cooperate to best support ANLWR stakeholders

©2021 Nuclear Energy Institute 7