ML20225A095
| 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) | |
Text
©2019 Nuclear Energy Institute Victoria Anderson Technical Advisor Tim Riti Senior Project Manager Public Meeting Risk-Informed Process for Exemptions August 13, 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 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 Introduction
©2020 Nuclear Energy Institute 3 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 Insights Regarding RIPE Process
©2020 Nuclear Energy Institute 4 Resolution of Box 4 Issues Consideration for NRCs RIPE Phase 2 NRCs RIPE Phase 1
©2019 Nuclear Energy Institute 5 Potential Areas for Use of RIPE Part 20, Part 26, Part 74 Exemptions Conformance to ANSI, IEEE and Regulatory Guides, or Clarification of DB or CLB Amendments
©2020 Nuclear Energy Institute 6 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 Entry Criteria: Leveraging Risk-Informed Initiatives
©2020 Nuclear Energy Institute 7 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 RIPE IDP Composition
Internal Events PRA Internal Fire PRA External Hazards PRA RIPE Capability Category I (Screening)
Qualitative or N/A Qualitative or N/A TSTF-425 Capability Category II Qualitative/
Bounding Qualitative/
Bounding TSTF-505 Capability Category II Capability Category II Site specific (Qualitative/
Bounding or Capability Category II Increasing PRA Rigor Comparison of PRA Acceptability by Program
©2020 Nuclear Energy Institute 9 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 RIPE Risk Evaluation - Screening Considerations
©2020 Nuclear Energy Institute 10 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 Streamlined Licensing Actions
©2020 Nuclear Energy Institute 11 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