ML21117A428

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April 23, 2021, Summary of Meeting with Nuclear Energy Institute Regulatory Issues Task Force
ML21117A428
Person / Time
Site: 99902028
Issue date: 05/11/2021
From: Ekaterina Lenning
Licensing Processes Branch
To: Craig Erlanger
Office of Nuclear Reactor Regulation
Lenning E
Shared Package
ML21117A006 List:
References
EPID L-2019-TOP-0044
Download: ML21117A428 (7)


Text

May 11, 2021 MEMORANDUM TO: Craig Erlanger, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:

Ekaterina Lenning, Project Manager /RA/

Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF APRIL 23, 2021, MEETING WITH NUCLEAR ENERGY INSTITUTE REGULATORY ISSUES TASK FORCE (EPID L-2019-TOP-0044)

On April 23, 2021, an observation public meeting was held virtually between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of the Nuclear Energy Institute (NEI)

Regulatory Issues Task Force (RITF). The purpose of the meeting was to discuss regulatory issues associated with licensing and oversight. Presentation slides are available in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML21110A697. A list of attendees is provided as an enclosure to this memorandum.

The NRC staff provided updates on EMBARK Venture Studio (EMBARK) activities, operating reactor licensing actions/review of metrics, efficiencies of the very low safety significance issue resolution (VLSSIR) process and risk-informed process for evaluations (RIPE), NUREG-1409 Backfitting Guidelines, Revision 1, retroactive review of administrative requirements (RROAR),

resolution of pre-generic issue on high energy arcing faults involving aluminum components, the endorsement status for American Society of Mechanical Engineers NML-1-2019, Rules for the Movement of Loads Using Overhead Handling Equipment in Nuclear Facilities, Title 10 of the Code of Federal Regulations (10 CFR) 50.55a two-year rule timeline, and the Standard Review Plan modernization project. The NEI representatives led a discussion on industry operability lessons learned. No regulatory decisions were made during this meeting.

EMBARK Venture Studio Activities The NRC staff provided updates on EMBARK activities, including Web-based Relief Requests (WRR), which is one of the first features of the NRCs Mission Analytics Portal (MAP-X),

MAP-X timeline and next steps, and the soon-to-be-launched reactor oversight process (ROP) analytics webpage that will present ROP information in a user-friendly format that can be explored or downloaded for analysis. The staff stated that the WRR website went live on April 5, 2021 and they held three WRR licensee portal open house public information sessions.

CONTACTS: Ekaterina Lenning, NRR Luis Betancourt, NRR (301) 415-3151 (301) 415-6146

Operating Reactors Licensing Actions/Review of Metrics The NRC staff provided updates on several licensing action workload initiatives including updates on the actions taken in response to the COVID-19 Public Health Emergency (PHE),

improvements achieved in communications with the industry during the PHE, enhanced workload management processes, and efficiencies gained in FY 2020. The NRC staff provided updates on the recent activities being undertaken at the NRC which include risk-informed submittals and workload management enhancements including development of new internal goals and metrics to gain additional efficiencies. The NRC staff mentioned the importance of licensees informing their respective project managers about future submittals of exemptions for planning purposes.

The NRC staff provided an update on workload management enhancements. The staff outlined the Nuclear Energy Innovation and Modernization Act (NEIMA) mentioning that Section 102(c) requires the NRC to develop Performance Metrics and Milestone Schedules for requested activities of the Commission, while Section 3(10) defines requested activities of the Commission, which encompasses most NRC licensing actions. The NRC staff stressed that NEIMA requires reporting to the Commission and Congress delays in issuance that exceed the established milestone schedule including an explanation for each delay and a plan for timely completion.

The NEI representatives provided feedback on licensing reviews and indicated that cost estimates and review times have improved. They highlighted good communication between staff and licensees and that reviews have become more efficient with less requests for additional information.

Efficiencies of the Very Low Safety Significance Issue Resolution (VLSSIR) Process and Risk-Informed Process for Evaluations (RIPE)

The NRC staff provided an update on the VLSSIR process which became effective on January 1, 2020. The staff informed the RITF that an effectiveness review of VLSSIR process execution in CY2020 was completed on March 2, 2021 (ADAMS Accession No. ML21070A334).

The staff shared that the VLSSIR process is meeting the goals and objectives outlined in the February 5, 2020 (ADAMS Accession No. ML19260G224), memorandum from the Low Safety Significance Issue Resolution working group to the Director, Office of Nuclear Reactor Regulation. The VLSSIR process has helped reduce the number of unresolved items (URIs) in inspection reports to only 12 items. A URI is an issue of concern associated with inspection activity which requires more information to determine if: (a) a performance deficiency exists, (b) the performance deficiency is More-than-Minor, or (c) the issue of concern potentially constitutes a violation. The effectiveness review also identified an area where procedural guidance may be enhanced to help facilitate the processing of issues where a Detailed Risk Evaluation is required. In CY 2020, seven issues were closed using the VLSSIR process.

The NRC staff provided an update on RIPE. The NRC is modifying its RIPE guidance to allow those sites that have an approved Technical Specification Task Force (TSTF) TSTF 425, Relocate Surveillance Frequencies to Licensee Control, license amendment to use RIPE where TSTF 425 applies to the requested exemption.

The staff indicated that the NRC plans to conduct a lessons-learned review of RIPE after an initial implementation period and make enhancements. The NEI representatives asked the staff to indicate if industry support on RIPE is needed. The staff stated that, before expanding

further, there is a need to address any lessons learned and to engage broader stakeholder groups to highlight the potential benefit of using RIPE.

NUREG-1409, Backfitting Guidelines, Revision 1, Update The NRC staff provided an update on the development of draft NUREG-1409, Backfitting Guidelines, Revision 1. The NRC staff stated that approximately 250 comments from the public, industry, and NRC staff were received with significant comments in the areas of reorganizing the content, increasing communication between NRC and licensees, clarifying stakeholder participation, revising forward fitting terminology and examples, and enabling Management Directive 8.4 appeals of proposed actions.

The staff summarized changes made to the Chapters 1-5. The NRC staff outlined next steps after NUREG-1409, Revision 1, is published. The next steps include updating office-level procedures (office instructions, ROP documents, enforcement manual, etc.), developing initial and refresher training, and updating qualification programs.

Retroactive Review of Administrative Requirements (RROAR)

The NRC staff provided an overview and current status of the RROAR. The staff also outlined next steps for RROAR including further engagement with stakeholders during the rulemaking process.

Update on Pre-generic Issue - PRE-GI-018, High Energy Arcing Faults Involving Aluminum Components The NRC staff provided an update on the NRC proposed generic issue (GI) 0018 (Pre-GI-0018)

High Energy Arcing Faults (HEAF) involving aluminum components, which currently is in the assessment stage, and an overview of the path to resolution of Pre-GI-0018. The NRC staff is developing an approach to resolve Pre-GI-0018 without additional NRC sponsored large-scale testing. The approach will be based on a joint NRC and Electric Power Research Institute (EPRI) working group project plan to determine the extent of aluminum in plants and plant-specific electrical configurations. Initial steps will include filling in gaps identified in the 2019 EPRI survey on configuration of aluminum in HEAF-susceptible equipment. The NRC/EPRI working group is developing specific zones of influence (ZOI) and probabilistic risk assessment methods to address the hazards posed by aluminum HEAFs. The NRC staff indicated that NRC will be evaluating applicability of pilot plants to complete the pre-GI assessment phase after the completion of ZOI. The staff also presented information on the NRC/EPRI working group project schedule. The NRC staff held two virtual information meetings with question-answer sessions on April 6, 2021, to provide an update to stakeholders and the public regarding the status and path forward for pre-GI-018 (meeting summaries ADAMS Accession Nos.

ML21109A009 and ML21109A015). The staff established a public web site to keep all stakeholders informed on the HEAF issue: https://www.nrc.gov/about-nrc/regulatory/research/fire-research/heaf-research.html.

The NRC staff stressed that there are no immediate actions for industry stakeholders.

Endorsement Status of the American Society of Mechanical Engineers NML-1-2019, Rules for the Movement of Loads Using Overhead Handling Equipment in Nuclear Facilities

The NRC staff presented an update on the endorsement status of American Society of Mechanical Engineers NML-1-2019, Rules for the Movement of Loads Using Overhead Handling Equipment in Nuclear Facilities, indicating that draft regulatory guide (RG) internal reviews will commence in mid-November with RG issuance for stakeholder comments planned for the second quarter of FY21. The final RG is planned to be issued in the fourth quarter of FY21. The NEI representatives inquired as to what support the industry can give to help create the standard. The NRC staff indicated that at this time no industry support is needed. The NEI representatives asked the NRC staff to let NEI know if the need for support is identified.

10 CFR 50.55(a) 2-year Rule Change Update and Timeline The NRC staff provided several updates on the 10 CFR 50.55(a) 2-year rulemaking activities.

These updates included:

The rulemaking plan on Relaxation of Inservice Testing and Inservice Inspection Program Update Frequencies Required in 10 CFR 50.55a was provided to the Commission and is awaiting Commission vote.

The proposed rule for the ASME 2019-2020 Code Editions Rulemaking was published on March 25, 2021. The 60-day public comment period is open through May 25, 2021.

The proposed rule for the next revision of the ASME Code Case RGs was published on February 2, 2021, with a 60-day public comment period that ended on April 5, 2021. The NRC received a total of 12 public comments. The final rule is estimated to be published in the first quarter of 2022.

The NRC removed operational leakage from the proposed rule and is pursuing a generic communication to provide clarification which is in the initial stages of the process.

Industry Operability Lessons Learned The NEI representatives led a discussion on industry operability lessons learned. The NRC staff emphasized that the focus should be not only on the negative aspects of the lessons learned, but also on the positive aspects of what was done right. A public meeting is being planned to share lessons learned from industrys implementation of operability determination guidance described in NEI 18-03 Operability Determination.

Standard Review Plan Modernization Project The NRC staff provided an overview of the Standard Review Plan Modernization (SRPMod) project including its purpose, objectives, schedule, and next steps. The staff emphasized that the SRPMod effort focuses on what is important to safety and guidance that is focused on requirements. The SRPMod effort goals are clear and concise guidance for completing reviews and improved quality of the NRC review products including requests for additional information and safety evaluations with the consistent application of risk-insights and engineering judgement. The NEI representatives stated that they will monitor progress of this effort and will offer their support as needed and asked the NRC staff to let NEI know if the need for support is identified.

Please direct any inquiries to Ekaterina Lenning at Ekaterina.Lenning@nrc.gov.

Docket No. 99902028

Enclosure:

List of Attendees

ML21117A006 (Package)

ML21111A172 (Meeting Notice)

ML21110A697 (Meeting Slides)

ML21117A428 (Meeting Summary)

OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/TA NAME ELenning DHarrison LBetancourt DATE 04/27/2021 04/28/2021 05/06/2021 OFFICE NRR/DORL/LLPB/BC NRR/DORL/DD NAME DMorey CErlanger DATE 05/07/2021 05/11/2021

Enclosure LIST OF ATTENDEES NUCLEAR ENERGY INSTITUTE REGULATORY ISSUES TASK FORCE PUBLIC MEETING APRIL 23, 2021 Name Organization Joey Clark Certrec Larry Nicholson Certrec Jana Bergman Curtiss-Wright Deann Raleigh Curtiss-Wright Art Zaremba Duke Phil Lashley Energy Harbor Ron Gaston Entergy Dave Gullott Exelon Nuclear Tim Riti Nuclear Energy Institute (NEI)

Andrew Mauer NEI James Slider NEI Justin Wearne NEI Maggie Staiger NEI Mike King U.S. Nuclear Regulatory Commission (NRC)

Luis Betancourt NRC Robert Krsek NRC Shakur Walker NRC Craig Erlanger NRC Phillip McKenna NRC Caroline Carusone NRC David Wrona NRC Ekaterina Lenning NRC Jeremy Groom NRC Jennifer Whitman NRC Doug Broaddus NRC Antonios Zoulis NRC Tim Reed NRC Audrey Klett NRC Andrew Carrera NRC Steve Jones NRC Mike Franovich NRC Mark Thaggard NRC Nick Melly NRC Bob Caldwell NRC Victor Cusumano NRC James Hickey NRC Jason Paige NRC Christian Araguas NRC Ilka Berrios NRC Andrea Mayer NRC Ed Miller NRC Charles Moulton NRC Name Organization Reinaldo Rodriguez NRC Shilp Vasavada NRC Paul Duke PSEG Nuclear Justin Wearne PSEG Nuclear Hossein Hamzehee Strategic Teaming and Resource Sharing Group Cheryl Gayheart Southern Nuclear Company (SNC)

Matt Euten SNC Wendy Brost South Texas Project Brian Mann Technical Specification Task Force James Polickoski Tennessee Valley Authority Marty Murphy Xcel Energy Sarah Scott Xcel Energy