ML20135G754
| ML20135G754 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 05/14/2020 |
| From: | Anderson V, Mauer A Nuclear Energy Institute |
| To: | Division of Operating Reactor Licensing |
| Klett A | |
| References | |
| Download: ML20135G754 (8) | |
Text
©2019 Nuclear Energy Institute Andrew Mauer Technical Advisor Victoria Anderson Technical Advisor Public Workshop on the Risk-Informed Process for Exemptions May 14, 2020
©2020 Nuclear Energy Institute 2 Industry appreciates the continued effort to focus NRC and licensee resources on the most safety significant issues.
We are beginning to see the application of the VLSSIR process improvements implemented in January.
We are encouraged by the NRCs efforts to address very low safety significant compliance issues in a manner consistent with the Principles of Good Regulation.
A streamlined approach that leverages our advanced understanding of plant risk is appropriate.
Introduction
©2020 Nuclear Energy Institute 3 Development of a streamlined exemption using a risk-informed approach is appropriate The white paper includes a scope of potential issues for which RIPE could be used, including actions needed to address inspection findings Insights Regarding RIPE Process
©2020 Nuclear Energy Institute 4 IMC 0612 includes a process to disposition issues of very low safety significance The inspector processes the issue through IMC 0609 and if the issue does not proceed to a detailed risk evaluation, or a phase 2 evaluation when relevant, or Appendix M, then the issue would have very low safety significance RIPE should provide a path for a qualitative disposition of compliance issues that meet this criteria - some issues may not be modeled in the PRA RIPE process should not repeat the NRCs assessment and understanding of the risk-informed outcomes developed through the ROP Relationship to VLSSIR Process
©2020 Nuclear Energy Institute 5 We fully support leveraging work done in previous risk-informed initiatives, where appropriate:
The proposal identifies 50.69 and TSTF-505 based on the Integrated Decision-Making panel (IDP) under 50.69 and PRA technical acceptability under TSTF-505 An alternative approach should also be considered which relies on TSTF-425, which includes both an IDP and a PRA with technical acceptability evaluation TSTF-425 should be considered as an acceptable way to develop a streamlined risk-informed exemption, in instances where the NRC staff has approved a license amendment This should not prohibit or limit the use of other risk insights when assessing a condition Leveraging Risk-Informed Initiatives
©2020 Nuclear Energy Institute 6 TSTF-505 Explicit use of PRA to compute allowed outage times Highest PRA expectations TSTF-425 Use of risk information as one consideration in extending surveillance frequencies Rigorous PRA expectations LSSIR Does not depend on explicit use of precise PRA-based calculations in decision making More similar to TSTF-425 than TSTF-505 in terms of PRA use PRA Technical Adequacy for Risk-Informed Initiatives
©2020 Nuclear Energy Institute 7 0
10 20 30 40 50 60 70 80 90 100 2020 2021 2022 2023 2024
% of Units Year TSTF-425 Approved TSTF-505 + 50.69 Approved Anticipated Adoption Rates for Risk-Informed Applications Use of TSTF-425 approval as entry qualification maximizes use of risk-informed insights
©2020 Nuclear Energy Institute 8 We appreciate the NRCs risk-informed approach to address issue of low safety significance which helps focus NRC and licensee resources on the most safety significant issues.
Conclusion