ML20252A211
| ML20252A211 | |
| Person / Time | |
|---|---|
| Issue date: | 09/08/2020 |
| From: | Monika Coflin Office of Nuclear Reactor Regulation |
| To: | Antonios Zoulis NRC/NRR/DRA/APOB |
| Monika Coflin (301)415-5932 | |
| References | |
| Download: ML20252A211 (5) | |
Text
1 September 8, 2020 MEMORANDUM TO:
Antonios Zoulis, Branch Chief PRA Oversight Branch Division of Risk Assessment Office of Nuclear Reactor Regulation FROM:
Monika Coflin, Venture Agent /RA/
EMBARK Venture Studio Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF CATEGORY 2 PUBLIC MEETING ON THE RISK-INFORMED PROCESS FOR EVALUATIONS (RIPE), HELD ON AUGUST 13, 2020 On August 13, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a Category 2 public meeting to have a second public engagement on the NRC staffs efforts to address Recommendation 5 (i.e., assess options for addressing low safety significant issues within the licensing basis) that was endorsed in the Low Safety Significant Issue Resolution (LSSIR)
Recommendation memorandum dated February 5, 2020 (Agency wide Documents Access and Management System (ADAMS) Accession No. ML19260G224). This meeting discussed an initiative by the NRCs EMBARK Venture Studio, in conjunction with experts within the Office of Nuclear Reactor Regulation (NRR), to develop the Risk Informed Process for Evaluations (RIPE), a risk-informed process to address exemptions and license amendment requests for very low safety significant issues within the licensing basis. This meeting provided an opportunity for NRC staff, industry, and the public to discuss EMBARK Venture Studio's initiative and to explore its viability and usefulness, including whether it or portions of it can be used to address low safety significant issues through exemptions or other NRC approval processes.
The public meeting agenda included presentation slides and summaries by the NRC staff and the Nuclear Energy Institute (ADAMS Accession Nos. ML20220A291 and ML20225A095).
CONTACT:
Shaun M. Anderson, NRR/EVS 301-415-2039
Summary of Discussions During the public meeting, the NRC staff discussed recent changes for the proposed process and the boundaries for using the process. Specifically, the NRC staff discussed proposed changes based on feedback since the last public meeting:
The name of the process was changed to Risk-informed Process for Evaluations (RIPE). This change reflects the applicability to reviewing licensing requests that are not limited to any specific exemption.
The NRC will consider an option to use an equivalent integrated decision-making panel (IDP) process that meets the standards of the IDP in Title 10 of the Code of Federal Regulations (CFR) 50.69 Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors. Licensees using either a 50.69 IDP or equivalent would be able to use the RIPE streamlined review pending NRC review of the proposed guidance.
Again, the NRC reinforced that the process does not eliminate NRC review, nor does it imply an immediate approval, rather its a streamlined approach to the level of review. Any immediate actions necessary for continued safe operations, repairs for continued power productions, and issues for which the safety impact cannot be directly assessed using probabilistic risk assessment (PRA) are not within the scope of the process. The NRC also presented an example of how the process could be applied for a specific issue (ML20220A292). Industry discussed and requested clarification regarding the process in general as outlined in their presentation (ADAMS Accession No. ML20225A095).
Specifically, industry proposed the following changes to RIPE:
RIPE should be considered to assist with resolutions of issues in the inspection program.
Industry reinforced their position that the PRA model used to support TSTF-425 is appropriate for the level of review needed for very low safety significant issues.
RIPE should be expanded to include license amendments and not just exemption requests.
The NRC staff guidance should be revised to provide clarity as follows:
o Consider use of absolute change in risk as basis.
o Remove more than minimal and risk significant criteria given lack of context or clear definition.
o Use the criteria of degradation instead of any impact because it is more appropriate.
o Reconsider treatment of defense in depth and safety margins in cases where the PRA appropriately reflects the issue being evaluated.
o The cumulative risk approach referencing the PSA Applications Guide is not appropriate. RG 1.174 criteria are more appropriate.
There was a question as to whether there would be changes to the amendment request or request for additional information (RAI) processes. The NRC staff responded that RIPE was envisioned without the need for RAIs and that the temporary staff guidance may need to be enhanced to provide flexibility in the schedule or to allow for clarification meetings with the licensee or other input from technical branches. A question was asked whether RIPE would
need to be approved by the Commission before implementation. The NRC staff replied that Commission approval was not necessary since existing processes and regulations would be used, and only the level of review would be different.
During the presentation, the industry again noted that TSTF-425 was adopted by many licensees and the PRA expectations were sufficiently rigorous to address the purpose of RIPE. In addition, Industry noted that TSTF-425 also includes an IDP. The NRC staff noted that they would further evaluate the use of TSTF-425 to determine if it meets the pedigree necessary for the process and indicated their openness to evaluate other methods or approaches to support disposition of these very low safety significant issues.
Overall the Industry was supportive of this initiative and appreciated the creative approach to focusing agency and licensee resources on matters of most safety significance. Further, the Industry stated that RIPE provides a path for licensees to focus limited resources on improving plant safety and reliability, rather than correcting potentially old design issues.
NEI stated that they plan to provide comments on the NRCs guidance document, Guidelines for Characterizing the Safety Impact of Issues (ML20118C231) and provide an NEI guidance document for performing an IDP for licensees that want to use RIPE but do not have an approved 50.69 license amendment within two weeks.
Members of the public were in attendance; one comment was received that decisions will need to be communicated in a way that the public can understand. The NRC did not receive public meeting feedback forms. The NRC will take the feedback presented during the meeting and will continue dialogue on the process.
The enclosure provides the attendance list for this meeting.
Enclosure:
List of Attendees cc: Listserv
- Via email OFFICE NRR/EVS/PM NRR/DORL/PM NRR/DRA/APOB/BC NAME MCoflin*
Treed*
AZoulis*
DATE 9/8/20 9/8/20 9/8/20 Enclosure LIST OF MEETING ATTENDEES RISK-INFORMED PROCESS FOR EXEMPTIONS (RIPE) PUBLIC MEETING August 13, 2020 Name Organization Name Organization Shaun Anderson NRC Ron Gaston Entergy Antonios Zoulis NRC Steve Catron FPL Tim Reed NRC Anil Julka FPL Audrey Klett NRC Michael Henshaw Duke Michelle Kichline NRC Cheryl Gayheart SouthernCo Greg Bowman NRC Ryan Joyce SouthernCo Jen Whitman NRC Russell Thompson TVA Jonathan Evans NRC Doug Pollock TVA Phil McKenna NRC Don Vanover Jensen Hughes Ata Istar NRC Victoria Warren Jensen Hughes Monika Coflin NRC Shane Jurek Talen Energy Dan Frumkin NRC Robin Ritzman Curtiss Wright Luis Betancourt NRC Anthony Leshinskie State of Vermont Jeff Mitman NRC Justin Hiller Ameren Eric Bowman NRC Andrew Breshears ANL Rick Scully NRC Marty Murphy Xcel Shakur Walker NRC Steven Dolley Global Platts Ed Miller NRC Michael DiLorenzo APS Ching Ng NRC Thomas Forland Nebraska Public Power District Angela Buford NRC Jonathan Ford David Wrona NRC Jenny Tobin Joe Gillespie NRC David Slankard Jeff Mitman NRC Cailyn Ludwig Charles Moulton NRC Harold Stiles Sunil Weerakkody NRC Jarrett Mack John Hughey NRC Tim Riti Michael Marshall NRC Scott Brinkman Victoria Anderson NEI Jeff Stone Maggie Staiger NEI Andy Ratchford Justin Wearne NEI Fernando Ferrante Roy Linthicum Exelon Jana Bergman David Gullott Exelon Allen Moldenhauer Suzanne Loyd Exelon Wyatt Godes Virginia Esquillo Dominion J Robinson Brian Mount Dominion Sunwoo Park Drew Richards STP Russell Jones STP