Text

NEI 50.59 Public Meeting Presentation 6 4 2020
	ML20155K910
Person / Time
Site:	Nuclear Energy Institute
Issue date:	06/03/2020
From:	; Nuclear Energy Institute
To:	; Office of Nuclear Reactor Regulation
	Govan T
References
	Download: ML20155K910 (16)
	v • d • e

Use of Risk Insights to support 10 CFR 50.59 Evaluations NRC PUBLIC MEETING June 4, 2020

©2020 Nuclear Energy Institute 2 Engage with NRC to discuss opportunities on using risk insights in the application of 10 CFR 50.59 Identify areas within industry and NRC guidance documents to enhance the application of 10 CFR 50.59 Propose engagement strategy and schedule PURPOSE

©2020 Nuclear Energy Institute 3 NEI 96-07 rev. 1, Guidelines for 10 CFR 50.59 Implementation endorsed by RG 1.187 was issued in November, 2000 based on a 10 CFR 50.59 rule change made in 1999 Intent was to conserve both licensee and NRC resources while continuing to ensure that significant changes are thoroughly evaluated and approved by the NRC as appropriate BACKGROUND

©2020 Nuclear Energy Institute 4 NEI 96-07 rev. 1 may include self-imposed limitations on the ability to fully utilize the provisions allowed by 10 CFR 50.59 to make changes Not efficient for either the licensee or the NRC staff Serves as an unnecessary distraction Doesnt support the principles of good regulation PROBLEM STATEMENT

NEI focus team was established to review 50.59 guidance and experience for improvement opportunities

Developed cross walk between NEI 96-07 rev.1 and 10 CFR 50.59

Reviewed 50.59 violations from 2000-Present

Reviewed 50.59 related guidance including insights from Tornado Missile Resolution and Low Safety Significance Issue Resolution (LSSIR) Memos

The result was the identification of 3 focus areas SCOPE

Clarifying the use of more than minimal as it pertains to 10 CFR 50.59

E.g., Criterion 2: Does the Activity Result in More Than a Minimal Increase in the Likelihood of Occurrence of a Malfunction of an SSC Important to Safety?

Consider approaches similar to sufficiently low described in NEI 96-07, Appendix D 2.

Clarifying the application of GDC language contained within NEI 96-07, rev. 1 3.

Clarifying application of methods of evaluations (MOE)

FOCUS AREAS

Industry team composed of regulatory expertise/50.59 working knowledge and leadership NRC team composed of headquarters and regional branch chiefs and staff members with senior executive sponsor Frequent interaction between industry and NRC to address distinct areas during public meetings STRATEGY

©2020 Nuclear Energy Institute 8 June Public meeting - overview of focus areas July Public meeting - insights from focus area #1 August Public meeting - insights from focus area #2 September Public meeting - insights from focus area #3 October Public meeting - discuss proposed guidance changes November Review/prepare guidance changes December Prepare for implementation PROPOSED SCHEDULE

Petition for risk informing 10 CFR 50.59 ( e.g., SECY 18-0060, encl. 5 (withdrawn in 2019))

Streamlined review and approval for low safety significant changes that requires NRC approval (LSSIR memo, rec. 5 - LSSIR focus team)

FOLLOW UP/LONGER TERM ACTIONS

©2020 Nuclear Energy Institute 10 We see an opportunity to provide clarity to industry guidance related to the application of 50.59 We have identified 3 focus areas that we believe will support that goal We are prepared to engage with the NRC on these focus areas

SUMMARY

©2020 Nuclear Energy Institute 12 A licensee may make changes in the facility as described in the final safety analysis report (FSAR) (as updated) make changes in the procedures as described in the FSAR (as updated), and conduct tests or experiments not described in the FSAR (as updated) without obtaining a license amendment pursuant to Sec. 50.90 only if:

(i) A change to the technical specifications incorporated in the license is not required, and; (ii) The change, test, or experiment does not meet any of the criteria in paragraph (c)(2) of this section.

10 CFR 50.59(c)(1)

©2020 Nuclear Energy Institute 13 A licensee shall obtain a license amendment pursuant to Sec. 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would:

(i) Result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the FSAR (as updated);

(ii) Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the FSAR (as updated);

(iii) Result in more than a minimal increase in the consequences of an accident previously evaluated in the FSAR (as updated);

(iv) Result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the FSAR (as updated);

(v) Create a possibility for an accident of a different type than any previously evaluated in the FSAR (as updated);

(vi) Create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the FSAR (as updated);

(vii) Result in a design basis limit for a fission product barrier as described in the FSAR (as updated) being exceeded or altered; or (viii) Result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses.

10 CFR 50.59(c)(2)

©2020 Nuclear Energy Institute 14 NEI 96-07 rev. 1, Guidelines for 10 CFR 50.59 Implementation is endorsed by RG 1.187 rev. 1, Guidance for the Implementation of 10 CFR 50.59, Changes, Tests, and Experiments Other Industry 50.59 related guidance

NEI 96-07 Appendix B, Guidelines for 10 CFR 72.48 Implementation endorsed by RG 3.72 (will be superseded by NEI 12-04 currently under NRC review)

NEI 96-07 Appendix C, Guidelines for implementation of changes for new nuclear power plants licensed under 10 CFR 52

NEI 96-07 Appendix D, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications (currently being reviewed for NRC endorsement via RG 1.187 revision 2)

NEI 96-07 Appendix E, Users Guide for NEI 96-07, Revision 1 contains examples of commonly encounter 50.59 industry topics. Not submitted for NRC endorsement REFERENCES

RG 1.187 rev. 1, Guidance for the Implementation of 10 CFR 50.59, Changes, Tests, and Experiments (rev. 2 under review for endorsing NEI 96-07 Appendix D)

RG 3.72, Guidance for Implementation of 10 CFR 72.48, Changes Tests, and Experiments

NRC letter to NEI (ML14113A529) Acceptance for endorsement of NEI 96-07 Appendix C (Part 52 plants)

RIS 01-003, Changes, Tests, and Experiments

IP 71111.17, Evaluations of Changes, Tests, Experiments REFERENCES

IP 71111.18, Plant Modifications

RIS 2015-03, 10 CFR 50.59 Issues Identified in NRCs San Onofre Steam Generator Tube Degradation Lessons Learned Report

RIS 2002-22 Supplement 1, Clarification on Endorsement of NEI Guidance in Designing Digital Upgrades in I&C Systems

Timely Resolution of Issues Related to Tornado-Missile Protection-Supplemental Information Memorandum (ML20015A299)

Low Safety Significance Issue Resolution Working Group Recommendations Memorandum-Recommendation 5 (ML19260G224)

REFERENCES

ML20155K910

Text

SUMMARY

Navigation menu

Search