ML21110A697

Presentation Slides for the April 23 2021 Nuclear Energy Institute Regulatory Issues Task Force Public Meeting

ML21110A697
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Issue date:	04/20/2021
From:	Ekaterina Lenning Licensing Processes Branch
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Lenning E
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Download: ML21110A697 (58)

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Public Meeting with the Nuclear Energy Institute Regulatory Issues Task Force April 23, 2021 1

Time Topic Speaker 9:00 am -9:10 am Introductions/Opening remarks NRC/NEI 9:10 am - 9:30 am EMBARK Venture Studio activities NRC 9:30 am - 10:00 am Licensing actions/review of metrics NRC/NEI 10:00 am - 10:10 am Efficiencies of VLSSIR/RIPE processes NRC 10:10 am - 10:20 am NUREG-1409 update NRC 10:20 am - 10:35 am Break 10:35 am - 10:50 am Retroactive Review of Administrative Requirements NRC 10:50 am - 11:00 am Potential generic issues - PRE-GI-018 HEAF NRC 11:00 am - 11:10 am Endorsement of ASME NML-1-2019, Rules for the movement of loads using overhead handling equipment in nuclear facilities NRC 11:10 am - 11:20 am 10 CFR 50.55a 2-year update and timeline NRC 11:20 am - 11:30 am Industry operability lessons learned NEI/NRC 11:30 am - 11:40 am SRP modernization project NRC 11:40 am - 11:55 am Opportunity for public comments Members of the Public 11:55 am - 12:00 pm Wrap up/Action items/Closing remarks NRC/NEI 12:00 pm Adjourn 2

Introductions and Opening Remarks 3

Jeremy Groom Managing Director

WEB-BASED RELIEF REQUESTS Launched April 5th https://wrr.nrc-gateway.gov/

Public Information Session May 6th from 10:30-11:30 AM Addressing User Feedback Web-BasedReliefRequests.Resource

@nrc.gov

MAP-X TIMELINE

• April 2021 - Enhanced Web-Based Relief Requests (WRR) -

LAUNCHED!

• Present - Fall 2021 -

Event Notification Development and Deployment*

• Fall 2021 - Spring 2022 -

Module 2 Development and Deployment*

• Estimated schedule subject to change 6

MAP-X NEXT STEPS

• Continue gathering internal and external feedback

• Identify challenges

• Continue quarterly public meetings

• Identify users

• User Acceptance Testing

• Event Notification Submitters 7

ROP Analytics Webpage (Coming Soon!)

• ROP information in a user-friendly format to explore or download for analysis

• Public comments and suggestions

• Future development

• Cross Cutting Issues

• Traditional Enforcement Findings

• Findings by IP

• Action Matrix Details 53 8

Licensing actions/Review of metrics COVID-19 Actions Workload Management April 23, 2021 9

COVID-19 Related Significant Activities/Accomplishments

• Continued Prompt Actions in Response to COVID-19 Public Health Emergency (PHE)

• Collective Contributions Across the Agency Enabled Mission Success

• Engagement on Regulatory Requirements that Posed Challenges and Communications with Industry were Effective 10

COVID-19 Actions Part 26 Work Hours Part 50 Fire Protection Owner Activity Reports (relief requests)

Part 55 Operators Licenses Part 73 Security Training Part 20 Respiratory Requirements Part 50 EP Biennial Exercise Other Requests Processed License Amendments Part 50.55a relief/alternative Part 50 Quality Assurance Programs Topical Reports - Audit Frequencies Exemptions 372 Relief Requests 35 Amendments 26 Other 6 Completed COVID-19 Actions (as of April 16, 2021) 11

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COVID What is Next?

Licensing Needs Appear More Normalized (Issues Can be Handled Case-by-Case)

- Minimal impact on spring outages (licensing perspective)

- Steam Generator Inspections deferred to fall appear on track Continue Evaluation of and Engagement on Regulatory Requirements that Pose Challenges Implementing efficiencies and flexibilities developed during COVID-19 14

Workload Management Enhancements Working to expand on-line access through MAP-X and WRR New and Revised Performance Measures

- Nuclear Energy Innovation and Modernization Act (NEIMA) and its impact

- Outcomes and Key Results (OKR)

Enhanced Analytics Tools

- Increased access to historical information (e.g., level of effort and schedule)

- Identify challenges and pinch points Integrated Workload Management

- Consistent approach for all NRR licensing programs 15

Continued Performance Gains FY2021 compared to FY2020 Performance continues to improve in almost all areas in FY2021 Increased number of completed actions:

- 48% more completions in 1st half of FY2021 vs same period in FY2020

- 63% of the total number completed in all of FY2020 Decreased average completion time:

- <7 months for all actions

- 2 months for COVID-19 actions

- 8.5 months for routine actions

- Subject to consistent schedules and priorities from applicants Improved performance against all but one metric goal

- Exception is 2-Year other licensing tasks (OLT) timeliness (discussed later) 16

Nuclear Energy Innovation and Modernization Act Implementation Nuclear Energy Innovation and Modernization Act (NEIMA)

- Section 102(c) required NRC to develop Performance Metrics and Milestone Schedules for requested activities of the Commission

- Section 3(10) defines requested activities of the Commission, which encompasses most NRC licensing actions

- Requires reporting to the Commission and Congress for a delay in issuance that exceeds the established milestone schedule

• Describe and explain the delay

• Provide a plan for timely completion 17

Demonstrated Performance High Level Measures

• NEIMA - 100% Completed w/in the established Generic Milestone Schedule (2-years for most licensing actions)

• Performance to date: 100%

• 2 Year Timeliness - 100% of Licensing Actions (LA) and Other Licensing Tasks (OLT) Completed w/in 2 years

• Performance to date: LA - 100%, OLT - 99% (missed Steam Generator Tube Inspection Report)

Agency Level Measures

• 1-Year Timeliness - 90% of LAs and OLTs Completed within 1 year

• Performance To date: 98% (Combined LA & OLT)

• 90% of licensing actions completed have actual hours within 125% of the estimated hours communicated to the applicant

• Performance to date: 99%

Office Level Measures 18

Outcomes and Key Results Process 19

New OKR Examples OBJECTIVE:

Improve accuracy of resource estimates and information provided to promote increased stakeholder confidence in the regulatory process and support appropriate resource allocation (Effective 1/1/2021)

KEY RESULT:

75% of licensing actions completed have actual hours +/-

25% of the estimated hours communicated to the licensee. Aggressive goal to progressively increase performance to 75% by the end of FY2021:

- Performance: 39% within +/- 25% in 1st Quarter OBJECTIVE:

Increase the use of traditional and analytical data tools to promote continued improvement in the quality of licensing application reviews (Effective 1/1/2021)

KEY RESULT:

Tracking the percent of acceptance reviews resulting in a supplement; Identifying and addressing one perceived challenge or improvement per quarter:

- Addressing challenge of delayed Steam Generator Tube Inspection Reports

- Percent of acceptance reviews resulting in a supplement = 4% (14 of 374) 20

Questions?

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Resources Generic Milestone Schedules of Requested Activities of the Commission https://www.nrc.gov/about-nrc/generic-schedules.html Nuclear Innovation and Modernization Act https://www.congress.gov/115/plaws/publ439/PLAW-115publ439.pdf NRC Operating Reactor Performance Dashboard https://www.nrc.gov/reactors/operating/nrc-performance-dashboard.html Agencywide Transformation Performance Measures (discusses development of OKRs) https://www.nrc.gov/docs/ML2014/ML20149K586.pdf 22

Back-up Slide Large Submittals (TSTF-582, TSTF-505, 10 CFR 50.69)

Requests for TSTF-582, Reactor Pressure Vessel Water Inventory Control Enhancements Up to 22 submittals. Most expected to request a 6-month completion times 9 completed in FY 2021: All in less than 6 months from acceptance 4 under review Requests to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times 2 completed in FY 2021: Within estimated hours; one ahead of and one a month after the estimated schedule 3 new submittals under acceptance review 5 expected to complete in next three months Requests to Implement 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components 2 completed; All close to or below the estimated schedule and estimated hours 2 new submittals; Estimates similar to other recent submittals 3 expected to complete in next three months 23

Efficiencies of Very Low Safety Significance Issue Resolution (VLSSIR)/

Risk-informed Process for Evaluations (RIPE)

Processes 24

25 Very Low Safety Significance Issue Resolution (VLSSIR) Process

• Effectiveness Review of VLSSIR Process execution in CY2020 was completed on March 2, 2021 (ML21070A334)

- Determined that the VLSSIR process is meeting the goals and objectives outlined in the February 5, 2020, memorandum from the LSSIR working group to the Director, NRR.

- VLSSIR process has helped reduce the number of unresolved items that the NRC is tracking with only 12 items appearing in the RPS database as of 2/10/21.

- Identified an area where procedural guidance may be enhanced to help facilitate the processing of issues where a Detailed Risk Evaluation (DRE) is required.

- Seven issues were closed using the VLSSIR process in CY 2020:

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26 Very Low Safety Significance Issue Resolution (VLSSIR) Process 26

27 Risk-informed Process for Evaluations (RIPE)

Adoption of RIPE was recommended and approve by memos dated January 5, 2021 (ML20261H428) and January 7, 2021 (ML21006A324), respectively.

- Enclosure 1 - Guidelines for Characterizing the Safety Impact of Issues (ML20261H462)

- Enclosure 2 - Temporary Staff Guidance TSG-DORL-2021-01 (ML20261H473)

NRC is working with industry to allow use of TSTF-425 applications in lieu of TSTF-505.

NRC plans to conduct a lessons-learned review of RIPE after an initial implementation period and make enhancements.

Open to industry proposals to further expand RIPE to issues that arent readily assessed through PRA methods.

- Need to engage broader stakeholder groups (e.g., in the case of security and EP)

- Potential benefit to exercising RIPE and addressing any lessons-learned before expanding further 27

NUREG-1409, Rev. 1 Update 28

=

Background===

• SRM-SECY-18-0049 (May 29, 2019)

- Issue Management Directive (MD) 8.4

• SRM-SECY-18-0042 (July 26, 2019)

- Conform NUREG-1409 to MD 8.4

- Provide NUREG-1409, Rev. 1 to Commission for information 10 days before issuance

• Draft NUREG-1409, Rev. 1 issued for comment

- March 2020

- Category 3 public meeting in April 2020

- Comments submitted late July 2020 29

Public Comments on Draft NUREG-1409, Rev. 1

• Approximately 250 comments from the public, industry, and NRC staff

• Significant comments

- Reorganize content

- Increase communication between NRC and licensees

- Clarify stakeholder participation

- Revise forward fitting terminology and examples

- Enable MD 8.4 appeals of proposed actions 30

Changes to Draft NUREG-1409, Rev. 1

• Chapter 1 - Introduction

- Terminology

- Relocated guidance on issue finality, communications, and ISFSIs

- Community of Practice Charter discussion

• Chapter 2 - Backfitting and Issue Finality

- Application of screening questions

- Relocated guidance 31

Changes to Draft NUREG-1409, Rev. 1

• Chapter 3 - Forward Fitting

- Screening

- Justification:

• Direct nexus

• Essential

- Cost considerations

- Scenarios 32

Changes to Draft NUREG-1409, Rev. 1

• Chapter 4 - Appeals

- Submitting and processing appeals

- Appealing proposed and issued actions

• Chapter 5 - Various NRC Processes

- Reorganized based on grouping similar topics

• Licensing

• Generic

• Inspection

• Enforcement

- Added and revised topics

• Conforming changes to Appendices 33

SECY-21-0037 Contents

• SECY Information Paper (now a vote paper)

- Summarizes changes to draft NUREG-1409, Rev. 1

- No new policy issues presented

• Enclosure 1 - Final NUREG-1409, Rev. 1

• Enclosure 2 - NRC response to comments

• Enclosure 3 - RLSO of draft NUREG-1409

• Enclosure 4 - Federal Register notice 34

Next Steps

• Awaiting Commission SRM on SECY-21-0037

• After NUREG-1409, Rev. 1 is published:

- Update office-level procedures (office instructions, ROP documents, enforcement manual, etc.)

- Develop initial and refresher training

- Update qualification programs 35

BREAK 36

NEIs Regulatory Issues Task Force (RITF) Meeting April 23, 2021 Topics:

• RROAR Overview

• Next Steps 37

RETROSPECTIVE REVIEW OF ADMINISTRATIVE REQUIREMENTS (RROAR)

BY THE NUMBERS 5

Commission-approved evaluation criteria and NRC staff programmatic experience (80 FR 6103) 4 Public meetings to discuss RROAR 99 Comments received from the public and NRC staff 5

NRC Offices Impacted 17 NRC Divisions Involved

~40 NRC staff participated in the review working from standardized review plan 4

Outcomes for comments - 1) new rulemaking effort, 2) existing rulemaking effort, 3) administrative correction rule, and 4) non-rulemaking 14 Affected 10 CFR Parts - 2, 20, 21, 26, 37, 50, 52, 55, 70, 71, 72, 74, 100, and 160 38

Information SECY paper, with the RROAR Comment Evaluation Summary enclosure (Late April, 2021)

Further stakeholder engagements during the rulemaking process Rulemaking plan(s)

(Late 2021)

Next Steps 39

High Energy Arcing Faults Involving Aluminum Components NEI Regulatory Issues Task Force Public Meeting Nicholas Melly, RES April 23, 2021 40

Proposed Path to Resolution of Pre GI-0018 on HEAF NRC staff developing approach to resolve the pre generic issue on HEAF involving aluminum without additional NRC sponsored testing Approach will build off NRC/EPRI Working Group project plan, including the EPRI survey, to determine the extent of aluminum in plants and plant-specific electrical configurations Initial steps will include filling in gaps identified in the survey The NRC/EPRI Working group is developing specific Zones of Influence (ZOI) and PRA methods to address the hazard posed by aluminum HEAFs Anticipate public meeting no later than the next quarter of FY21 41

Proposed Path to Resolution of Pre GI-0018 on HEAF NRC staff developing approach to resolve the pre generic issue on HEAF involving aluminum without additional NRC sponsored large scale testing Approach will build off NRC/EPRI Working Group project plan, including the EPRI survey and operating experience to determine the potential risk of aluminum HEAF based on plant-specific electrical configurations The NRC/EPRI Working group is developing specific Zone of Influences (ZOI) and PRA methods to address the hazards posed by HEAFs Two Public Meetings April 6, 2021

- Morning NRC/EPRI Working Group Progress

- Afternoon NRC discussion Pre Generic Issue NRC Working group members addressing concerns operating experience has not been adequately incorporated

- EPRI is publishing a white paper which will detail survey results, publicly available on the EPRI website, once released, by searching 3002020692

- New PRA methodology and ZOI insights both heavily incorporate OpEx and will be documented 42

Proposed Path to Resolution of Pre GI-0018 on HEAF NRC/EPRI HEAF working group will fill the EPRI survey gaps as follows:

Compile Draft Hazard Tables to estimate the Zone of Influences using currently available information (e.g., expert judgement, completed testing data, operating experience, modeling insights)

Develop representative PRA methods considering equipment categories, plant specific location and electrical configurations / lineups as documented in the EPRI survey NRC established a public web site to keep all stakeholders informed https://www.nrc.gov/about-nrc/regulatory/research/fire-research/heaf-research.html No immediate actions for Industry stakeholders Following the ZOI completion the NRC will be evaluating applicability of pilot plants to complete the Pre GI Assessment phase 43

NRC/EPRI Working Group Project Schedule 44 44

American Society of Mechanical Engineers NML-1-2019, Rules for the Movement of Loads Using Overhead Handling Equipment in Nuclear Facilities Endorsement Status NEI REGULATORY ISSUES TASK FORCE PUBLIC MEETING APRIL 23, 2021 45

Regulatory Guide (RG) endorsement expected to enhance handling system use flexibility and reduce special lift device nondestructive examination and testing frequency consistent with risk insights Draft RG internal reviews commencing mid-November RG issuance for stakeholder comments 2nd Quarter FY21; final RG in 4th Quarter FY21 46

10 CFR 50.55(a) 2-year update and timeline 47

48 NEI Industry operability lessons learned

SRP Modernization Project 49

SRP Modernization (SRPMod) Effort Status April 23, 2021 SRPMod Team Caroline Carusone, NRR/DORL Deputy Division Director Phil McKenna, Acting NRR/DORL Deputy Division Director Dennis Morey, NRR/DORL/LLPB Branch Chief Jason Paige, SRP Modernization Task Lead Mark Notich, Sr. Project Manager Kate Lenning - Project Manager 50

SRPMod Purpose Focus on Whats Important to Safety Guidance focused on requirements Clear, Concise Guidance for Completing Reviews Clarity on application details Improve Quality of NRC Review Products Requests for Additional Information Safety Evaluations Consistency on Using Risk-Insights and Engineering Judgement Capture Best Practices SRP Issue vs. Training Issue Not every section will need extensive revising 51

SRPMod Objectives Reinforce Reinforce Expectations for Reasonable Assurance of Adequate Protection Rebranding Introduction to General Review Principles General Review Principles will provide guidance on completing reviews Focus Focus on Regulatory Requirements Reformatting sections Align specific acceptance criteria and findings to the applicable requirements Remove extraneous information Incorporate ISGs, BTPs information Empower Empower the Staff to Consistently Use Risk-Insights and Engineering Judgment Reference PRA Policy Statement and SRM-SECY-17-0112 Integrate risk guidance:

LIC-206 and Be riskSMART Reference AEA on the use of engineering judgement 52

Schedule: SRPMod Performance Goals SRPMod Performance Goals are Division-Driven!

Division-specific goals based on available resources Divisions Select SRP Sections to Modernize to Meet Goals Based on division needs Performance Goals Track Number of Sections Modernized within Next 2-years Schedule to Issue One SRP Section: 50 weeks Draft Modernized Section: 8 weeks Issue Draft Section (Public Comment): 18 weeks Address Public Comments: 4 weeks Issue Final SRP Section: 20 weeks Priority for Modernizing Chapters Chapter 2 Chapter 3 Chapter 5 Chapter 6 Chapter 7 Chapter 9 Chapter 14

• Prioritization based on division needs and available resources for next 2-years

• • Divisions will select sections to modernize NRR Goal: 173 Modernized Sections in 2-years!

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Status: Next Steps

• SRPMod Team Hosted 3/31 Public Meeting Incorporated feedback into SRPMod process

• SRPMod Officially Kicked-Off in April 2021!

Divisions selecting SRP sections to modernize

• Draft SRP Sections Issued for Public Comment Public Comment requested via Federal Register Notice First batch expected Fall 2021 Draft SRP Sections will be piloted before issuance of final 54

Questions?

55

Opportunity for Public Comment 56

NEI and NRC Management Closing Remarks 57

List of Abbreviations AEA -

Atomic Energy Act of 1954 BTP -

Branch Technical Position EPRI -

Electric Power Research Institute ISG -

Interim Staff Guidance LSSIR - Low Safety Significance Issue Resolution NEI -

Nuclear Energy Institute NEIMA - Nuclear Energy Innovation and Modernization Act NRC -

U. S. Nuclear Regulatory Commission NRR -

Office of Nuclear Reactor Regulation PRA -

Probabilistic Risk Assessment RLSO - Red line strike out ROP -

Reactor Oversight Process RPS -

Reactor Program System SRP -

NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants