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NEI Presentation for the RIPE Public Meeting on August 13,2020
	ML20225A095
Person / Time
Site:	Nuclear Energy Institute
Issue date:	08/13/2020
From:	Anderson V, Riti T; Nuclear Energy Institute
To:	; Office of Nuclear Reactor Regulation
	Shaun Anderson (301)415-2039
References
	Download: ML20225A095 (11)
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Public Meeting Risk-Informed Process for Exemptions Victoria Anderson Technical Advisor Tim Riti Senior Project Manager August 13, 2020

Introduction Industry appreciates the continued effort to focus NRC and licensee resources on the most safety significant issues We are seeing 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

Insights Regarding RIPE Process Development of streamlined licensing actions using a risk-informed approach is appropriate Further consideration of issues discussed at May 14, 2020 public meeting

Examples of issues that could be used with RIPE

Entry criteria

Risk evaluation

Streamlined licensing actions

NRCs streamlined review process

Resolution of Box 4 Issues NRCs RIPE Phase 1 Consideration for NRCs RIPE

Potential Areas for Use of RIPE Exemptions Part 20, Part 26, Part 74 Conformance to ANSI, IEEE and Regulatory Amendments Guides, or Clarification of DB or CLB

Entry Criteria: Leveraging Risk-Informed Initiatives 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

Consideration should be given to allowing use of a TSTF-425 IDP, and a TSTF-425 PRA which has a technical acceptability evaluation

The NRC should also consider a graded approach informed by the rigor of the PRA and the issue being evaluated This should not prohibit or limit the use of other risk insights when assessing a condition

RIPE IDP Composition Using the TSTF-425 IDP as a model, an appropriate RIPE IDP would consist of:

Engineering Manager

Maintenance Manager

Operations Manager (ideally SRO qualified)

Risk Management (PRA) Engineer

Work Control/Work Management Representative

Systems Engineering Representative

Safety Analysis Representative

Licensing Representative

Comparison of PRA Acceptability by Program Increasing Internal Events Internal Fire PRA External Hazards PRA PRA PRA Rigor Capability RIPE Category I Qualitative or N/A Qualitative or N/A (Screening)

Capability Qualitative/ Qualitative/

TSTF-425 Category II Bounding Bounding Site specific (Qualitative/

Capability Capability TSTF-505 Bounding or Category II Category II Capability Category II

RIPE Risk Evaluation - Screening Considerations Consider use of absolute change in risk as basis Remove more than minimal and risk significant criteria given lack of context or clear definition A criteria of degradation instead of any impact is more appropriate Reconsider treatment of defense in depth and safety margins in cases where the PRA appropriately reflects the issue being evaluated The cumulative risk approach referencing the PSA Applications Guide is not appropriate - RG 1.174 criteria are more appropriate

Streamlined Licensing Actions There are benefits in the use of the RIPE process for both streamlined exemption requests and streamlined license amendment requests Allowing both types of licensing actions would allow broader use of the RIPE process that could be used to address potential areas and issues described earlier

Conclusion 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

ML20225A095

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