ML21174A317
| ML21174A317 | |
| Person / Time | |
|---|---|
| Issue date: | 06/02/2021 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| Wang, W, ACRS | |
| References | |
| NRC-1534 | |
| Download: ML21174A317 (134) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Docket Number:
(n/a)
Location:
teleconference Date:
Wednesday, June 2, 2021 Work Order No.:
NRC-1534 Pages 1-94 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 686TH MEETING 4
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
(ACRS) 6
+ + + + +
7 WEDNESDAY 8
JUNE 2, 2021 9
+ + + + +
10 The Advisory Committee met via 11 Teleconference, at 11:00 a.m. EDT, Matthew W. Sunseri, 12 Chairman, presiding.
13 COMMITTEE MEMBERS:
14 MATTHEW W. SUNSERI, Chairman 15 JOY L. REMPE, Vice Chairman 16 WALTER L. KIRCHNER, Member-at-Large 17 VICKI M. BIER, Member 18 DENNIS BLEY, Member 19 CHARLES H. BROWN, JR., Member 20 GREGORY H. HALNON, Member 21 VESNA B. DIMITRIJEVIC, Member 22 JOSE MARCH-LEUBA, Member 23 DAVID PETTI, Member 24 PETER RICCARDELLA, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 ACRS CONSULTANT:
1 STEPHEN SCHULTZ 2
3 DESIGNATED FEDERAL OFFICIAL:
4 WEIDONG WANG 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 CONTENTS 1
Call to Order and Opening Remarks 2
by the ACRS Chairman 4
3 Risk-Informed Process for Evaluations (RIPE) 4 of Low Safety-Significance Issue Resolution 5
(LSSIR).....................
8 6
Remarks from the Subcommittee Chairman 9
7 Presentations and Discussion with 8
Representative from NRC Staff....... 10 9
Jennifer Whitman, NRR........ 10 10 Timothy Reed, NRR.......... 10 11 Antonios Zoulis, NRR
...... 13, 44 12 Jonathan Evans, NRR......... 20 13 Michelle Kichline, NRR
....... 29 14 Presentation and Discussion with 15 Representatives from Industry....... 63 16 Victoria Anderson, NEI
....... 63 17 Roy Linthicum, PWR Owners Group... 72 18 Committee Deliberation
.......... 83 19 Opportunity for Public Comments...... 93 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 P R O C E E D I N G S 1
11:00 a.m.
2 CHAIRMAN SUNSERI: (Presiding) Good 3
morning, everyone. It's 11:00 a.m. Eastern Time. The 4
meeting will now come to order.
5 This is the first day of the 696th meeting 6
of the Advisory Committee on Reactor Safeguards. I'm 7
Matthew Sunseri, Chair of the ACRS.
8 I'll call the roll now to verify a quorum 9
and that open communications exist.
10 Member Ballinger is not available this 11 morning. He will join us later this week.
12 I'll start with Vicki Bier.
13 MEMBER BIER: Present.
14 CHAIRMAN SUNSERI: Thank you.
15 Dennis Bley?
16 CHAIRMAN BLEY: I'm here.
17 CHAIRMAN SUNSERI: Charles Brown?
18 MEMBER BROWN: I'm here.
19 CHAIRMAN SUNSERI: Vesna Dimitrijevic?
20 MEMBER DIMITRIJEVIC: I'm here.
21 CHAIRMAN SUNSERI: Greg Halnon?
22 MEMBER HALNON: Yes, I'm here.
23 CHAIRMAN SUNSERI: Walt Kirchner?
24 MEMBER KIRCHNER: Here.
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5 CHAIRMAN SUNSERI: Jose March-Leuba?
1 MEMBER MARCH-LEUBA: Here.
2 CHAIRMAN SUNSERI: Dave Petti?
3 MEMBER PETTI: Here.
4 CHAIRMAN SUNSERI: Joy Rempe?
5 VICE CHAIR REMPE: Here.
6 CHAIRMAN SUNSERI: Pete Riccardella?
7 MEMBER RICCARDELLA: Here.
8 CHAIRMAN SUNSERI: And myself.
9 So, we have everyone present. We have a 10 quorum, and everyone was loud and clear.
11 The ACRS was established by the Atomic 12 Energy Act and is governed by the Federal Advisory 13 Committee Act, and the ACRS section of the U.S. NRC 14 public website provides information about the history 15 of the ACRS and provides documents such as our 16
- Charter, Bylaws, Federal Register notices for 17 meetings, letter reports, and transcripts of all full 18 and subcommittee meetings, including the slides 19 presented at the meetings. The Committee provides its 20 advice on safety matters to the Commission through its 21 publicly available letter reports.
22 The Federal Register notice announcing 23 this meeting was published on May 7th, 2021, and 24 provided an agenda and instructions for interested 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 parties to provide written documents or to request 1
opportunities to address the Committee.
2 The Designated Federal Officer for this 3
meeting is Mr. Weidong Wang.
4 During this meeting, the Committee will 5
consider the following topics:
6 Our first topic for today is an 7
informational briefing on Risk-Informed Process for 8
Evaluations of Low Safety-Significance Issue 9
Resolution; LSSIR for short.
10 Later this morning, we'll get into 11 preparation of reports, which the only report that we 12 are working on currently is our Bylaws review. So, 13 we'll spend some time on that.
14 And then, later in this week, we will 15 prepare for our briefing to the Commission, which is 16 scheduled for October this year.
17 Portions of the informational briefing on 18 Risk-Informed Process Evaluations may be closed to the 19 public to protect proprietary information.
20 A phone bridge line has been opened to 21 allow members of the public to listen in on the 22 presentations and Committee discussions.
23 We have received no written comments or 24 requests to make oral statements from any members of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 the public regarding today's sessions.
1 There will be an opportunity for public 2
comment. We have set aside time in the agenda for 3
comments from the members of the public listening into 4
our meeting. Additionally, written comments may be 5
forwarded to Mr. Weidong Wang, the Designated Federal 6
Officer.
7 A transcript of portions of the open 8
meeting is being kept, and it is requested that 9
speakers identify themselves and speak with sufficient 10 clarity and volume, so that they may readily be heard.
11 In addition and finally, participants 12 should mute themselves when not speaking. And this is 13 particularly important for the public line because of 14 the way the muting system works, at least from our 15 technology perspective, and the interface with MS 16 Teams. We request that all members of the public 17 listening mute your local device, and it's important 18 that you mute your local device, so that any 19 background noise doesn't create feedback. If we have 20 to mute the entire public line, it, essentially, 21 renders it inoperable for two-way communication. So, 22 please, if you are a member of the public listening 23 in, it's essential that you mute your local device.
24 In addition, other participants should mute themselves 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 when they are not speaking.
1 As far as additional remarks, I don't 2
really have anything of note to report of general 3
interest. I will say that, from a conduct of the 4
meeting
- today, the
- Agency, NRC Headquarters, 5
experienced a significant loss of power last night.
6 It has been restored. However, computer services, 7
information technology services, have had a problem 8
with reliability this morning. It seems to be working 9
it out as the day goes on, but please be patient with 10 members, and members with staff.
11 If you happen to drop off, just re-sign 12 on, and make sure that you have an alternate backup in 13 case your primary and your preferred method is not 14 available. So, the two primary or predominant methods 15 are through the VPN or through the Office 360 window.
16 So, that's all I have at this point.
17 Members, I'll turn to you. Any questions 18 about the agenda or things that we are working on this 19 week, or any topic you want to bring up, before we get 20 into the first presentation?
21 (No response.)
22 All right. So, at this point in time, 23 I'll turn to Member Dimitrijevic, who is our lead for 24 this topic. She can introduce the topic and staff.
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9 So, I'll turn to Vesna for your opening remarks.
1 MEMBER DIMITRIJEVIC: Okay. Good morning.
2 So, this morning we will hear about the 3
Risk-Informed Process for the Evaluations of Low 4
Safety-Significance Issue Resolution. So, this 5
process applies to proposed changes to facilities; for 6
example, license amendments or exemption requests.
7 It's designed to expedite the review of low safety-8 significant
- issues, and in this
- way, reduce 9
unnecessary regulatory burden, and it enables a more 10 efficient way of using Agency resources. So, it's an 11 important step in the risk-informed decisionmaking 12 process.
13 And in this moment they have a limited 14 applicability. They apply for operating plants 15 licensed under 10 CFR Part 50, and then, they apply to 16 licenses that have already used tech spec applications 17 like technical specification TSTF-505 or I think 425, 18 too. The 505 applies to extension of completion times 19 Or they have implemented the 10 CFR 50.69. And I 20 think they're applicable for those cases because, in 21 this case, since the PRA technical adequacy has been 22 approved and applicants can use Integrated Decision 23 Panels in making decisions of importance of the 24 issues.
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10 So, at this moment, I am going to turn to 1
the NRC. And I'm not sure who will start, but I know 2
that we will be working with Antonios Zoulis and 3
Timothy Reed, who are developers of this application.
4 So, who will start today?
5 MS. WHITMAN: Good morning.
6 This is Jennifer Whitman. I'm the Acting 7
Deputy Director for NRR's Division of Risk Assessment.
8 And so, I wanted to thank you all for 9
giving us this opportunity this morning to present to 10 you on the Risk-Informed Process for Evaluations, or 11 RIPE. This is an excellent example of staff-driven 12 innovation efforts. It started with an idea from 13 Antonios, and then, a great team of people putting 14 together all of the guidance and documentation and 15 work to support this.
16 And it's really capitalizing on the 17 decades of work that both NRC and industry have put 18 into PRAs and risk-informed decisionmaking frameworks.
19 And so, I know Tim and Antonios have a great 20 presentation for you today, and we are looking forward 21 to hearing your thoughts and questions on this topic.
22 And so, with that, I will go ahead and 23 turn things over to Tim Reed to get us started.
24 MR. REED: Okay. Thanks.
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11 If we could move to -- yes, there you go.
1 So, I just wanted to give a little larger 2
context of where this Risk-Informed Process for 3
Evaluations came from. It came from a larger effort 4
that I was the lead for, working for Ho Nieh in this 5
regard. And it's called the Low Safety-Significance 6
Issue Resolution effort. We had a regional sponsor, 7
Jack Giessner, now the Regional Administrator of 8
Region III, who was involved. So, we had a Region and 9
NRR participation of a broad working group.
10 And what we were really trying to do 11 across the board was trying to mitigate the situations 12 where the NRC's staff is focusing its energy and 13 resources in areas of low safety-significance or no 14 safety-significance. And, of course, as a direct 15 result, that tends to tie up licensee resources. And 16 when everybody's resources are looking in the wrong 17 place, they're not looking in the right place, right?
18 We're distracting them from things that do matter for 19 public health and safety, and those things having 20 safety significance.
21 So, this box chart is kind of the 22 centerpiece to something that started with Ho.
23 Basically, his drawing of a box on a napkin in his 24 office has turned into this. It's been in several 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 different forms, but it's nice tool, if you will, to 1
divide the world of licensing issues and inspection 2
findings into four quadrants. And it gives a good 3
understanding of what NRC regulatory processes apply, 4
depending on where you fall in this chart.
5 Of most interest today is everything below 6
the horizontal line, where we judge things to have 7
very low safety, low or very low safety significance.
8 And, of course, everything is going to be focusing on 9
that lower right quadrant -- Antonios will talk about 10 that -- where we really don't have much choice. It's 11 in the licensing basis -- no arguments between us and 12 the licensee in that regard -- and there must be 13 something done. We have to change the licensing basis 14 to make the requirement equal it or change the means 15 by which they meet the requirement.
16 So, it requires prior review and 17 approval, and, of course, RIPE will address that.
18 I'll let Antonios talk about that.
19 The other quadrant, which many of you may 20 be familiar with, if you've followed along for the 21 last couple of years, is what's now called the very 22 low safety significance issue, as the most important 23 of the effort. That was Recommendation 1 out of the 24 analysis memo, called the LISSIR. And that's where 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 it's something that's not clear and where we can make 1
a judgment. If a licensee makes a determination it's 2
not in the licensing basis, we can't make that call, 3
or based on a reasonable amount of effort, we can't 4
determine it's in, we can, if we work to pretend it 5
was in, determine it's very low.
6 And since it's very low, why don't we just 7
stop? Why don't we make a public document and move 8
on? And we want that public document to be there for 9
others to see in the future if do find something that 10 does more to revisit it. But that's already to stop 11 spinning our wheels, if you will, on issues like that.
12 So, that was put into place in January 2020. It is 13 working very well.
14 So, with that, I wanted to provide a 15 larger context of where RIPE comes. It really comes 16 from Recommendation 5 in the LISSIR memo.
17 And with that, I'll turn it over to 18 Antonios, unless there's any questions from the 19 Committee.
20 MR. ZOULIS: Thanks, Tim and Jen.
21 So, as Jen mentioned, my name is Antonios 22 Zoulis. I'm the Branch Chief of the PRA Oversight 23 Branch in the Division of Risk Assessment, in the 24 Office of Nuclear Reactor Regulation. And I'm going 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 to be talking to you, giving you a high-level 1
overview. Then, we have Jonathan Evans or Keith 2
Tetter providing some more details of why we chose 3
50.69 and TSTF-505, and the basis for that. And then, 4
Michelle Kichline will go into kind of more details of 5
the process itself. And then, they'll turn it back to 6
me.
7 And please ask -- I know I don't need to 8
say this -- but ask questions as you see fit 9
throughout the presentation. We want this to be an 10 information exchange, and share your thoughts perhaps 11 on the process and any ideas you may have.
12 So, the foundation of RIPE was established 13 and approved by the Office Director back in January of 14 this year. We issued the recommendation. As Tim 15 mentioned, it's Recommendation 5 of the LISSIR effort.
16 The Office Director approved it.
17 And in those two documents, you'll find, 18 one, the guidelines that we developed for the safety 19 impact of issues, which, essentially, is the RIPE 20 process that the licensee can use, or is one approach 21 to determine that an issue is of low safety 22 significance.
23 And the second part of that, enclosure 2, 24 is just what we do when we receive an application to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 RIPE. How do we conduct the streamline review, if the 1
licensee met all the requirements within the RIPE 2
guidance?
3 So, all those are available publicly for 4
folks to read and digest.
5 One of the things that really we kind of, 6
when we started off with this initiative, was we 7
wanted it to use existing regulations. We didn't want 8
to go to rulemaking. We didn't want to go to the 9
Commission. We wanted to, essentially, use current 10 regulations that we
- have, but leverage those 11 regulations and work that was done in other risk 12 initiatives to be able to support a more streamlined 13 review of issues.
14 So, many of you are familiar with Reg 15 Guide 1.174, Risk-Informed Integrated Decisionmaking 16 Principles. As you'll see later, the low safety-17 significant issues we define as below 1E to the minus 18
- 7. So, having a way to determine that an issue is of 19 low safety significance, and leveraging those other 20 risk-informed initiatives, it helps for us to inform 21 and support a more streamlined review of those 22 scenarios, consistent with our principles under Reg 23 Guide 1.174 of Integrated Decisionmaking. So, it's 24 much a risk-informed process.
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16 Before we get into too many details, it 1
was important for us to kind of define the box where 2
RIPE fell. And you'll see later on that the top box 3
was a little bit changed, as we had more interactions 4
with the industry and public and others. So, we 5
really didn't want to impact the inspection or 6
enforcement.
7 So, RIPE does not impact or involve how a 8
finding or a violation gets dispositioned. It more 9
supports how the licensee and how we will correct or 10 review the corrective action or the ways that they 11 would address the violation or the finding. So, 12 again, it doesn't impact the inspection, the upfront 13 aspects of the violation or finding, but it does 14 support how the licensee can correct those issues.
15 The other thing that was important, it 16 does not change how -- the licensee still needs to 17 make the case for the exemption or the licensee 18 amendment. It doesn't change the validity of that 19 request, but it does inform the level of effort that 20 NRC staff will spend on reviewing the approval or 21 denying the license request for the exemption.
22 So, because it's based on current 23 regulations, we're not trying to change how someone 24 makes the determination that they need to come in for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 exemption or license amendment. All we're doing is, 1
given it's a low safety-significant issue, and 2
understanding it's a low safety-significant issue, 3
we're going to expend the commensurate resources to 4
review it.
5 And where the third item, regulations, was 6
very important for our friends in OGC was that you 7
can't use RIPE to displace rulemaking. You can't say, 8
because 50.46a or a regulation is of low safety 9
significance, we're not going to comply with that 10 regulation. It's more designed for specific unique 11 plant noncompliance issues or issues where a specific 12 narrow portion of the regulation may apply for that 13 licensee; that they may decide, well, it's not worth 14 us correcting, or we can live with the issue. We've 15 made some changes to the plant, some procedure change 16 perhaps. It's good enough for us to leave it as is 17 because the risk is so low. So, that was important 18 for our folks in OGC.
19 Okay. So, again, we're going to get into 20 more detail about RIPE, but, fundamentally, as Jen 21 mentioned, what we're doing is we're leveraging 22 previous risk-informed initiatives. We're saying you 23 have demonstrated an integrated decisionmaking panel, 24 either from a 50.69 application or an equivalent, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 either from 425, and you've demonstrated a PRA of 1
technical acceptability, of high-level technical 2
acceptability either from a TSTF-505 application or, 3
recently now, with 425, and with some conditions.
4 You've demonstrated now you have a robust integrated 5
decisionmaking process. You can use that in 6
conjunction with our safety impact characterization 7
process to evaluate the issue, make the determination 8
of its low safety significance, and use that as the 9
supporting information when you come in for us to 10 request either the review of the exemption or the 11 license amendment request.
12 And Jonathan or Keith are going to go into 13 more detail about why we picked 50.69 in the next 14 couple of slides and TSTF-505 initially.
15 Again, this is kind of like a high-level 16 overview. The licensee needs to define the issue. It 17 has to be evaluated using the Integrated 18 Decisionmaking Panel, and it must be assessed with the 19 PRA of sufficient technical acceptability. The 20 guidance allows for provisions for risk management 21 actions that can be taken, and you also need to assess 22 cumulative risks similarly to what you would do under 23 Reg Guide 1.174. So, again, it's very consistent with 24 our process.
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19 Once the licensee does that, they would 1
then submit it and request a streamlined review, and 2
we would either review or deny that approval, as we 3
would do today, but in a more streamlined effort, 4
again, consistent with, commensurate with the risk 5
injuries of the issue.
6 MEMBER HALNON: Hey, Antonios, this is 7
Greg Halnon.
8 MR. ZOULIS: Hi, Greg.
9 MEMBER HALNON: A quick question. Are you 10 going to go through and contrast the streamlined 11 process versus an older process later on or is this --
12 MR. ZOULIS: Yes. Yes, we are. Yes, we 13 are. Thank you.
14 MEMBER HALNON: Okay. I'll hold off then.
15 Thanks.
16 MR. ZOULIS: Thank you.
17 Again, this kind of highlights what are 18 the NRC's action and what are the licensee's actions.
19 So, essentially, the licensee will use the safety 20 impact of issues guidelines to determine if the issue 21 is of low safety significance. Once they've done 22 that, they would submit it to the NRC for a 23 streamlined review, and the NRC would then conduct the 24 review using our temporary staff guidance we developed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 on how we would assess that. And again, Greg, we'll 1
go into more details later, what exactly that entails.
2 Jonathan, are you on? I know Jonathan had 3
some conflicts.
4 MR. EVANS: Yes, I'm on.
5 MR. ZOULIS: Thanks, Jonathan. Go ahead.
6 MR. EVANS: All right. Hi, everybody.
7 My name is Jonathan Evans. I am a 8
Reliability and Risk Analyst in the Division of Risk 9
Assessment, in the Office of Nuclear Reactor 10 Regulation, and today I'll cover Initiative 4b and, 11 also, 10 CFR 50.69.
12 So, Initiative 4b, or a
Technical 13 Specification Task Force 505, allows a licensee to 14 extend existing completion times by evaluating their 15 plant's configuration-specific risk. In this example 16 on the slide, an existing three-day completion time to 17 restore inoperable subsystems could be extended up to 18 30 days by maintaining total plant risk below specific 19 risk thresholds and implementing actions to manage 20 risks associated with extended out-of-service times.
21 Next slide, please.
22 All right. So now, I'm going to talk 23 about what the NRC staff reviews for this Technical 24 Specification Task Force for 505. The review at the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 NRC involves a multidisciplinary team and includes 1
reviewers from various technical branches, including 2
PI analysts as well as engineering
- branches, 3
electrical, instrumentation and control, containment, 4
as well as Technical Specification Branch.
5 The boxes listed above cover the scope of 6
a PRA analyst's review. PRA technical acceptability, 7
which is where the focus of this will be, is evaluated 8
with broad applicability, since this amendment impacts 9
so many different conditions.
10 Facts and observations, which are 11 findings, as well as key assumptions or sources of 12 uncertainty, will receive in-depth review for overall 13 model impact and disposition relative to the 14 particular finding. Therefore, using the approval of 15 TSTF-505 or Initiative 4b for license amendments was 16 an acceptable basis for simplifying the Risk-Informed 17 Process for Evaluation reviews.
18 Next slide, please.
19 Okay. So, on to 10 CFR 50.69. This 20 categorizes the safety-related and non-safety-related 21 SSCs into subcategories based on high or low safety 22 significance. The portion of this product that 23 interacts with RIPE is the Integrated Decisionmaking 24 Panel, which I will discuss on the next slide.
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22 MEMBER DIMITRIJEVIC: Jonathan?
1 MR. EVANS: Uh-huh?
2 MEMBER DIMITRIJEVIC: Hi. This is Vesna 3
Dimitrijevic.
4 You know, I was wondering, when you 5
presented these two applications, are you presenting 6
them as what the licensee has done previous to 7
applying to any of the new changes under RIPE, or 8
you're describing this as a
potential RIPE 9
application?
10 MR. EVANS: So, what's happening here is 11 that, in order to validate, or I guess to use RIPE, a 12 licensee would need to have a TSTF-505 and 50.69 13 license amendment in place and have it approved.
14 MEMBER DIMITRIJEVIC: Right.
15 MR. EVANS: So, that's sort of the mindset 16 here, is that, for RIPE, if a licensee wants to use 17 RIPE the way that it's currently set up, they would 18 need TSTF-505 and 50.69, and that would allow them to 19 make use of this product.
20 MEMBER DIMITRIJEVIC: But can they make --
21 so, they already have applied and approved 50.69 and 22 the 505, for example, for --
23 MR. EVANS: Yes.
24 MEMBER DIMITRIJEVIC: -- the specific 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 SSCs? Or just in general?
1 MR. EVANS: So, they would have to have 2
the program approved, of course, in general. However, 3
in order to use RIPE for a particular SSC, they would 4
need to perform the IDP for that particular SSC, but 5
the scope would be limited. I believe that's going to 6
be described in detail in a later slide.
7 Correct me, if I'm wrong, Antonios.
8 MR. ZOULIS: Michelle may get into it, but 9
I think, Vesna, what you're asking is -- what we're 10 trying to share is, when we initially came up with 11 RIPE, we felt that these two programs demonstrated the 12 integrated decisionmaking process through the IDP and 13 through the PRA acceptability --
14 MEMBER DIMITRIJEVIC: Yes.
15 MR. ZOULIS: -- consistent with Reg Guide 16 1.174.
17 MEMBER DIMITRIJEVIC: Right. I completely 18 understand that. And as I said in my introduction, 19 you are using those for remedies --
20 MR. ZOULIS: Right.
21 MEMBER DIMITRIJEVIC: -- to prove that the 22 license already has a valid PRA and, you know, the 23 integrated decisionmaking process. But what I was 24 wondering, the licensee has already applied, for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 example -- so, 50.69, it's general, right? So, it's 1
applied to all licensees, where it's applied.
2 However, 505 can be applied to extend the completion 3
time for different components, right?
4 MR. ZOULIS: Uh-hum, yes.
5 MEMBER DIMITRIJEVIC: So, that could apply 6
or it can be accepted for something, and now they can 7
apply for every component using this process? That's 8
what I was wondering.
9 MR. EVANS: Oh, I see.
10 MEMBER DIMITRIJEVIC: If the licensees 11 come back and apply for the different extension times 12 for different components using this process?
13 MR. ZOULIS: Yes, Jonathan?
14 MR. EVANS: So, the way that I would 15 probably respond to that would be in this manner:
16 it's that TSTF-505 is a broad-scope application 17 process. So, it has wide-reaching impacts to a number 18 of different SSCs. So, really, the point here, at 19 least from my standpoint, my perspective, would be 20 that, when a licensee has a TSTF-505 that's been 21 reviewed and approved, we know that their PRA internal 22 events, their PRA for fires, and for some other 23 external hazards, depending on the scope of the 24 review, would have been captured as a part of that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 review.
1 So, while maybe -- I don't know -- just 2
thinking outside of the box here, if they're looking 3
at an SSC that is potentially outside of the scope of 4
TSTF-505, it wouldn't necessarily matter so much 5
because, again, we've looked at their PRA and the 6
internal events, and we've done the analysis as a part 7
of that. So, their internal PRA would technically be 8
acceptable for use in RIPE because of the pedigree of 9
the review.
10 MEMBER DIMITRIJEVIC: Right, but you'd 11 better give us some examples of how the RIPE is used.
12 Right?
13 MR. ZOULIS: We haven't had an example, 14 but we're going to walk through the guidance. And I 15 think the Owners Group is going to present some 16 potential applications that may benefit from RIPE in 17 their presentation.
18 MEMBER DIMITRIJEVIC: Okay. This is what 19 I wanted -- I saw the Owners Group has something which 20 is a slightly different, the generic issues. But I 21 tried to visualize how these would be applicable, in 22 which cases. So, this is why I sort of asked if it 23 would be applied for the new applications in those 24 areas. But, okay.
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26 MR. ZOULIS: And Michelle, when she goes 1
on, may be able to share some examples.
2 MEMBER DIMITRIJEVIC: All right. Thank 3
you.
4 MEMBER KIRCHNER: Antonios, this is Walt.
5 May I ask a question?
6 MR. ZOULIS: Sure.
7 MEMBER KIRCHNER: Yes. On the first 8
bullet, the second -- let's see -- no, "the conversely 9
requires additional controls for non-safety-related 10 SSCs." Does the licensee propose this or do you, 11 based on some inspection or other process, determine 12 subsequently that the licensee has to add additional 13 controls for non-safety-related SSCs? I'm just 14 searching for an example of how that --
15 MR. ZOULIS: Sure.
16 MEMBER KIRCHNER: -- particular case would 17 be implemented.
18 MR. EVANS: So, I don't have any 19 particular examples for you off the top of my head.
20 What I can say is that, the way that the risk-informed 21 safety categorization process is set up is that, 22 again, you have your safety-related and your non-23 safety-related. If a licensee is doing the analysis, 24 either the PRA or some defense-in-depth analysis 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 demonstrates that, hey, there is a component here 1
that's non-safety-related; however, it falls into this 2
higher-level criteria, then there would be additional 3
controls that would need to be put in place. That is 4
something that's actually put into the regulations for 5
a licensee to follow. And, of course, it's in the 6
guidance.
7 MR. ZOULIS: Yes, yes. And most probably 8
would fall into the Maintenance Rule. So, you would 9
have those controls under the Maintenance Rule 10 Program, if it was a non-safety-related, but risk-11 significant component. So, that would still apply for 12 that component.
13 MR. REED: Yes, again, to go into the 14 Wayback Machine to 50.69, basically, what we were 15 thinking about then was, hey, if you're going to 16 credit something, it goes into risk, too. If your PRA 17 shows that it's important, what's the credit you're 18 taking in that PRA and what should be the treatment?
19 So, if we tried to apply treatment to that 20 that would align with the credit you're taking for it, 21 and that would be an enhancement to safety, as opposed 22 to most folks were focusing only on the scope of risk, 23 going to risk three, removal of special treatment 24 requirements. So, that was part of our philosophy and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 it's built right into the regulation.
1 MEMBER KIRCHNER: Thank you.
2 MR. EVANS: All right. Thank you.
3 All right. So, let's go ahead and move on 4
to the next slide.
5 Okay. So now, we're going to talk about, 6
I guess, the Integrated Decisonmaking Panel process.
7 So, the safety significance of SSCs is determined 8
using a robust Integrated Decisionmaking Panel 9
process, which incorporates both risk and traditional 10 engineering insights.
11 This slide shows the different elements of 12 the categorization process. In addition to the use of 13 the PRA on the left, there are other deterministic 14 considerations that are listed on the right. All of 15 the considerations are provided to the Integrated 16 Decisionmaking Panel who makes the final determination 17 about the safety significance of an SSC, considering 18 all that information in a structured, documented 19 manner.
20 Therefore, the Integrated Decisionmaking 21 Panel must be comprised of highly experienced plant 22 personnel that are knowledgeable of the plant and have 23 collective expertise in PRA, safety analysis, plant 24 operation, design, and systems engineering.
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29 The strength of the review by the IDP, 1
coupled with the technical acceptability of the PRA, 2
is the basis for simplifying license applications 3
using RIPE.
4 Are there any other questions?
5 (No response.)
6 MR. ZOULIS: So now, we'll give it to 7
Michelle Kichline to go into a little bit more detail 8
about the actual safety impact process.
9 MS. KICHLINE: All right. Thanks, 10 Antonios and Jonathan.
11 And like they said, my name's Michelle 12 Kichline, and I'm going to talk about the safety 13 impact characterization process.
14 And so, this process -- I know you can't 15 read this slide, so I'm going to break it down in the 16 slides that follow -- but this process is conducted by 17 the licensee. It's not the NRC that does this 18 process.
19 And the purpose of this process is to 20 integrate the results of the PRA and the IDP's review 21 to come to a conclusion on whether or not this has 22 minimal risk significance.
23 So, next slide.
24 So, first, the easy step, licensee has to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 identify an issue that requires NRC review and is 1
expected to have a minimal risk impact. I do want to 2
note here that I'm using the word "minimal". You've 3
heard us use "very low" before. I'm choosing minimal 4
because we chose a risk threshold with core damage 5
frequency that's an order of magnitude below what we 6
normally call low or very low. And so, that's what 7
"minimal" means, and I'm going to show that on another 8
slide as well. But just in case you're curious.
9 So, once this license has identified an 10 issue that an NRC review, and they think it's going to 11 be low-risk or minimal risk, they're going to continue 12 the process. And some of the things we think that 13 they can use this for would be actions to address 14 inspection findings. Again, like Antonios said, 15 things that are within the licensing basis, but need 16 to be resolved. These things could also be non-17 compliances that they've identified themselves or 18 through some other process. These are maybe responses 19 to orders where they need to modify the plant.
20 We don't allow the process to be used for 21 immediate actions necessary for continued safe 22 operation of the plant, such as to restore compliance 23 with a tech spec. It's not for immediate repairs for 24 power operation, and it's not for anything where you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 can't assess the safety impact of the issue using a 1
PRA.
2 So, that's why at this time we don't have 3
anything like fuel changes, nothing for emergency 4
planning or security, because those things would 5
require a completely different framework that wouldn't 6
be based on risk-informed principles using a
7 probabilistic risk assessment.
8 Next slide.
9 So, once the safety impact has been --
10 sorry -- process has started with defining the issue, 11 this part is going to be done by a subject matter 12 expert; like Jonathan said, somebody who's really 13 knowledgeable about the plant.
14 They're going to answer the preliminary 15 screening questions, which are also on this slide.
16 And those questions are intended to look at the more 17 qualitative aspects that maybe aren't covered by the 18 PRA. And so, those preliminary questions ask about if 19 there's any impact on defense-in-depth, safety 20
- margins, fission product
- barriers, accident 21 consequences, the availability of components, things 22 like that.
23 And the reason it says "any impact" is 24 just because that it's important that the Integrated 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 Decisionmaking Panel, if there is any impact, they 1
want the IDP to review that impact to determine if 2
it's going to pose an issue.
3 So, after SME has defined --
4 MEMBER KIRCHNER: Michelle, this is Walt 5
Kirchner. Could I ask a question?
6 MS. KICHLINE: Sure.
7 MEMBER KIRCHNER: "Impact," how do you 8
define "impact" here? Is there some threshold that 9
you use or is it -- it can't be just any impact.
10 MS. KICHLINE: At this point, it's any 11 impact.
12 MEMBER KIRCHNER: Any impact in any of 13 these categories?
14 MS. KICHLINE: Correct. Later, once it's 15 been reviewed by the IDP, the IDP will determine if 16 it's minimal, using the criteria that we set up for 17 what "minimal" means.
18 MEMBER KIRCHNER: Okay. So, the test 19 comes when you apply your minimal impact or risk?
20 MS. KICHLINE: Yes.
21 MEMBER KIRCHNER: Okay.
22 MS. KICHLINE: Yes.
23 MEMBER KIRCHNER: Thank you.
24 MS. KICHLINE: No problem.
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33 So, when the issue's been defined by the 1
subject matter expert, it is then explored using 2
either a generic or plant-specific process. If it's 3
going to be generic, it's similar to the IDP, but it's 4
called a Generic Assessment Expert Team, or GAET. And 5
they would do a generic evaluation.
6 But, even if a generic evaluation is done, 7
the generic evaluation is -- say this applies to a 8
fleet of plants and they want to tell the fleet, "This 9
is what you need to consider." Each plant right now 10 has to do their own plant-specific evaluation using 11 their plant-specific IDP, even if the issue is 12 generically applicable. We're not allowing them at 13 this point to submit things together, like several 14 licensees that are different.
15 So, then, once the plant IDP -- like I 16 said, they're going to review these preliminary 17 questions, and then, they're going to look at the 18 final screening questions, and they're going to 19 determine if this impact that was identified is 20 minimal or if there is really no adverse impact. So, 21 no adverse means nothing negative. And if there's 22 minimal impact, I think I have that on the next slide.
23 MEMBER HALNON: Hey, Michelle, this is 24 Greg Halnon.
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34 MS. KICHLINE: Go ahead.
1 MEMBER HALNON: Can you help expand a 2
little bit on the generic assessment, too? I noticed 3
in the guidance it was a licensee team or an NRC team.
4 It didn't really lead me to know which was supposed to 5
be --
6 MS. KICHLINE: Yes. So, that did confuse 7
a lot of people. And so, in the revision, we are 8
going to take out that it would be an NRC team. We 9
originally envisioned that perhaps the NRC would have 10 a generic issue and the NRC would want to put out 11 generic guidance on how it would be applicable for a 12 plant to address something that's low safety 13 significance. And I think that causes more question 14 than it's helpful.
15 MEMBER HALNON: Okay.
16 MS. KICHLINE: Because we already have a 17 generic issues process. And so, we do plan to remove 18 that and just make it so that the generic assessment 19 would be done by industry alone.
20 MEMBER HALNON: Okay. So, when you say, 21 "industry alone," is there going to be some 22 requirements on pulling in other people from different 23 fleets? I guess if you've got a single-unit utility 24 that's got one plant, one technology, do they have the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 expertise to look at it from a generic perspective?
1 MS. KICHLINE: Yes, there would be no 2
reason for them to do that because we are making 3
-- like I said, everyone has to submit a plant-4 specific evaluation. And so, it would only be 5
beneficial to start with a generic evaluation if it 6
was something that applied to several plants.
7 MR. REED: Yes, I was just going to chime 8
in, Michelle, and to kind of go over what Greg's 9
asking. You know, in certain circumstances -- and 10 Antonios and I saw this back with the Risk 11 Prioritization Initiative, where you have a group of 12 experts in the industry. Say, EQ, for example, is a 13 group of experts. Sometimes it make sense to get 14 those experts together, where the plant really doesn't 15 have it, and have those folks and an Integrated 16 Decisionmaking Panel and a generic panel go through 17 and get those insights. And then, they can hand it 18 off to the plant, and then, let the IDP do the plant-19 specific approach. So, that's where I think it could 20 have a lot of benefit.
21 MEMBER HALNON: Tim, does the industry 22 have the infrastructure to do that or the process to 23 pull that together? Or is it an hoc type of thing?
24 MR. REED: Good question. I don't know 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 the answer to that question.
1 I don't know, Antonios, do you?
2 MR. ZOULIS: So, I mean, I think industry 3
issued what we call a RIPE-equivalent IDP guidance, 4
which defines the structure of an IDP and who should 5
be part of that team. That could the basis for either 6
an Owners Group setting up a team or industry. I 7
think, as Tim said, as part of the Risk Prioritization 8
Initiative, industry -- NEI, essentially -- put up a 9
team of experts to look at their issues.
10 As long as you meet the criteria and you 11 follow the process, all you're doing in the generic 12 assessment, essentially, is highlighting kind of, hey, 13 this may be applicable for you. This is important; 14 this is not important. And essentially, it's designed 15 to inform the plant-specific IDP to help them get 16 pointed to the right direction; look at do you meet 17 this criteria or you don't. Maybe for you it's more 18 important or not as important, or those are the areas.
19 So, it kind of, essentially, helps 20 streamline the IDP evaluation, leveraging the work 21 that was done by the generic assessment experts. And 22 that's the way it was envisioned when we developed 23 this process.
24 MEMBER HALNON: Okay. And I guess a more 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 specific question -- and whether we answer it here or 1
we let you all go back and think about it -- is, how 2
do you, as the NRC staff, have confidence in a generic 3
assessment, if you're not really sure what process the 4
industry is using to do that and who was involved with 5
that?
6 MR. ZOULIS: Well, see, that's exactly the 7
beauty, Greg, of the process. You would still need to 8
submit your own plant-specific requests. So, we would 9
make that determination on a case-by-case basis under 10 each individual plant, unless there was maybe a fleet 11 issue. You would still have to somehow make that come 12 to us in some fashion for us to review and approve the 13 request.
14 MEMBER HALNON: Okay. When a request 15 comes in, you would be looking at it from a generic 16 perspective as well, even though the industry has 17 already done that, or at least the submitter has done 18 it. To some extent, you will be looking at it from a 19 bagel test, whether or not it's a generic issue or 20 not. Is that fair?
21 MR. ZOULIS: Sure. Like, for example --
22 I don't want to steal the Owners Group's thunder 23
-- but we're thinking about is there a way that we can 24 approve something on a generic basis, and then, be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 used, if it's a low safety-significant issue. And 1
then, let each licensee then come in or do it under a 2
50.69 approach, or come in for a very streamlined 3
review. So, there's different ways, but all the ways 4
that we're thinking still require some sort of NRC 5
review of the issue.
6 MEMBER HALNON: Okay. It seems a little 7
fuzzy to me right now, Antonios, but we'll get through 8
it and see where we're at at the end.
9 MR. ZOULIS: It's fuzzy for all of us. We 10 had a vision for this process. Obviously, when you 11 issue something like this, people have other ideas.
12 And to be honest, they're very good ideas. We've got 13 to just think about what's the appropriate approach to 14 use, so we maintain safety and we also are efficient 15 and consistent with our principles of good regulation, 16 right, for issues that we all know -- but the bottom 17 line is, if we really know they're low safety-18 significant issues, it doesn't make sense for us or 19 industry spending unnecessary resources on them.
20 MEMBER HALNON: Well, I know all that. I 21 think just more specific on the generic assessment 22 process or team process, I think how that pans out, 23 maybe it just needs to mature a little bit more.
24 MR. ZOULIS: Sure, sure.
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39 MEMBER RICCARDELLA:
This is Pete 1
Riccardella.
2 It seems to me there's a lot of industry 3
groups that could participate in this sort of -- like 4
the Owners Groups, BWR, VIP, the MRP. There's lots of 5
groups, I think, that could give expert advice to an 6
individual plant.
7 MEMBER HALNON: Yes, I agree, because I 8
think the experts are out there. It's a matter of how 9
you consistently pull them into a committee or some 10 kind of team that will give you consistent results 11 going forward.
12 MEMBER RICCARDELLA: Yes.
13 MS. KICHLINE: Any other questions before 14 I move on?
15 (No response.)
16 Okay. So, I think the only thing left on 17 this slide I was going to say is that, if you started 18 with a generic assessment, you don't get away from 19 doing anything that you would have done before. You 20 still have to do the plant assessment. And the plant 21 assessment has to determine the final safety impact 22 characterization by assessing the final screening 23 questions, which are modified versions of these 24 preliminary screening questions, and the final risk 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 results using your PRA.
1 And the safety impact that they're going 2
to characterize can be a little different, depending 3
on if it's a compliance issue or not, but, basically, 4
the delta CDF, the change in core damage frequency 5
between with and without this change.
6 Next slide, please. Thank you.
7 Okay. So, the plant IDP is supposed to 8
review the issue until they have confidence that the 9
results wouldn't change if additional information was 10 obtained. And that doesn't mean that the PRA results 11 wouldn't change. It just means that, if they got more 12 information, they wouldn't say that it's more than 13 minimal.
14 They also have to consider risk management 15 actions, which they consider those for any issues 16 where there is a minimal safety impact. If there was 17 no adverse impacts, then they wouldn't need to 18 consider RMAs because there's nothing to offset. But 19 those are to look at, is there anything they could do, 20 maybe procedurally, some type of action they could 21 take that would reduce that small amount of risk that 22 they did increase/raise for the plant?
23 The next thing that they're going to do is 24 they're going to look at cumulative risk, and they're 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 going to look at that based on their plant-specific 1
baseline core damage frequency and, also, large early 2
release frequency, once the change has been 3
incorporated to make sure that it stays below the 4
guidelines in 1.174.
5 And then, in order for them to say that 6
the issue has a minimal impact, it has to meet all of 7
the criteria that are listed here, which is that the 8
issue itself contributes less than 1E to the minus 7 9
to CDF. So, the change is less than 1E to the minus 10 7 on CDF. The change is less than 1E to the minus 8 11 per year on LERF. It screens to know the minimal 12 impact using the final safety impact questions, and 13 then, cumulative risk is acceptable. So, if all of 14 those things are acceptable, then they can go ahead 15 and submit -- they would quality for a RIPE streamline 16 review because they would have said that that's the 17 way we're asking that they kind of prove that the 18 issue is low, is low-risk.
19 MEMBER RICCARDELLA: Excuse me, Michelle.
20 This is Pete Riccardella again.
21 As I recall, Reg Guide 1.174 has sort of 22 a tradeoff between actual CDF or total CDF or total 23 LERF, and then, the delta. So, that if an issue has 24 a small total CDF, or if the plant has a total small 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 CDF, then a larger delta CDF would be acceptable.
1 MS. KICHLINE: That's correct for --
2 MEMBER RICCARDELLA: Do you reflect that 3
tradeoff at all in this?
4 MS. KICHLINE: No, we do not. That's 5
correct that that's the way that 1.174 works for a 6
risk-informed application. The only part we really 7
refer to 1.174, for cumulative risk, which is actually 8
-- it's a much higher number. And so, it's not going 9
to be an issue for something that is less than 1E to 10 the minus 7 on CDF.
11 MEMBER RICCARDELLA: Yes. Yes, but these 12 deltas, then, are, as I recall, are at 1.174 sort of 13 acceptable deltas for a relatively --
14 MS. KICHLINE: Yes, they're smaller.
15 MEMBER RICCARDELLA: -- high cumulative 16 risk, right?
17 MS. KICHLINE: Yes, they're smaller than 18 what you'd be allowed to do under 1.174.
19 MEMBER RICCARDELLA: Okay. All right.
20 MS. KICHLINE: Because of the fact that we 21 are going to do a streamlined review where we don't do 22 as much of a technical review of the issue because it 23 is such low risk.
24 MEMBER RICCARDELLA: Okay.
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43 MS. KICHLINE: Anything else?
1 (No response.)
2 All right. Next slide.
3 So, I wasn't going to go over an actual 4
example because, unfortunately, we don't have an 5
actual example, but I do have an example submittal, 6
what it would look like. And so, this is what we put 7
out as the areas that we think we would want the 8
application to entail, which would be a detailed 9
description of the request.
10 And then, we also want them to submit the 11 results from steps 1 through 4 of the assessment, 12 which was the steps that I've talked about, which is 13 their Integrated Decisionmaking Panel results, the 14 final risk results for the screening questions, their 15 PRA results, risk management actions, and cumulative 16 risk, and then, a conclusion on why it's minimal 17 impact. They still have to submit the significant 18 hazards considerations and environmental 19 considerations that are required with submittals as 20 well.
21 And then, that's all I was going to talk 22 about. I believe, for the next slide, we're going 23 back to Antonios, is that correct?
24 MR. ZOULIS: Yes, Michelle. Thanks.
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44 Do, this is, Greg, where we kind of define 1
what the streamlined review would look like. And it 2
was important, when we talked to our friends in DORL, 3
that we didn't put a sense of urgency on these 4
requests, given that they're low safety significance.
5 It was more important for us to focus on the resources 6
that we would expend to review these issues.
7 So, as you could see, it is still a 8
truncated timeline between a RIPE exemption and a RIPE 9
license amendment request. And it follows the similar 10 steps that you would take, the key steps that occur in 11 license requests would take, but the difference here 12 is, for the acceptance review, the technical staff 13 will be able to review the issue and provide no 14 technical objection to us using RIPE to disposition 15 it.
16 Once they provide that no technical 17 objection, the review would essentially go to the 18 Division of Risk Assessment to ensure, as Michelle 19 said, that the issue is well-captured by your PRA and 20 your risk assessment; that the issue was well-defined 21 and reviewed by the IDP. And as long as they meet all 22 those checks and there is significant issues with the 23 way the issue was evaluated, here we're really more 24 looking for, if there were surrogates used, were they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 appropriate? Was the issue well-captured by the risk 1
assessment and the IDP?
2 Once those are done, essentially, then we 3
would submit the SE input to DORL. OGC would review 4
it, and then, it would be issued, approved within that 5
timeframe.
6 So, a very limited review, essentially, by 7
the staff, focusing more on did they use the RIPE 8
process appropriately and is the issue well-9 characterized by the criteria that we developed.
10 MEMBER HALNON: So, Antonios, this is 11 Greg.
12 The submittal itself is more focused, it 13 seems like, on the RIPE process. I don't know if 14 there was an issue in the evaluation of the risk, as 15 opposed to going into explaining why it's possibly, in 16 the licensing basis, possibly not, and all that other 17 stuff that went on before --
18 MR. ZOULIS: Yes, we're not going to --
19 but they still need to, like I mentioned, there still 20 has to be justification on why we're changing the 21 license. You know, we're changing it because -- you 22 know, whatever the amendment request or the exemption 23 request, it has to still be based on the regulation.
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46 that. And we're just taking it a step further and 1
saying, well, if you do that and you show it's low 2
safety significance, our review of it is going to be 3
very streamlined.
4 MEMBER HALNON: Okay.
5 MR. REED: Now --
6 MEMBER HALNON: Oh, go ahead, Tim. I'm 7
sorry.
8 MR. REED: Yes, I was just going to say, 9
all of the issues in this for RIPE are either going to 10 be -- all could be in the licensing basis. Even if 11 they were already an issue in enforcement and their 12 compliance, they're out of compliance and they need to 13 correct it, and if RIPE is the way they're going to 14 correct it, or they're in compliance and the licensee 15 is seeing an issue with it, and they're choosing like, 16 hey, I know this is not a safety; I'd like to get this 17 resolved, for whatever reason. So, they're still in 18 compliance, but, in that case, they're going to 19 proceed with RIPE to see if they can resolve the issue 20 that way, you know, if it's a lot of cost or 21 maintenance, whatever it might be.
22 MEMBER HALNON: Right. Absent that cost 23 or maintenance, or whatever the issue is, from a 24 licensing perspective or the regulatory process, is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 the industry satisfied with the savings that is going 1
to be implemented? Have you guys had a conversation 2
about it?
3 MR. ZOULIS: Well, I guess the proof's 4
going to be in the pudding, as they say. We need to 5
see an example, an exercise, and I think that's going 6
to go a long way in demonstrating that we have 7
discipline. As you know, a lot of these initiatives, 8
the important aspect is that we stick to the intent of 9
the initiative; that we're disciplined in the review; 10 that if the issue is really low safety significance 11 and they follow the process, our review should be 12 commensurate with that low safety significance.
13 So, it takes -- and we mentioned this in 14 many meetings, and public meetings as well -- it takes 15 discipline on both the NRC and the industry side to 16 follow these, what we've delineated here, and it meets 17 all these criteria. We need to be able to stay true 18 to the process and review it, maintain safety, of 19 course, but, again, spending resources commensurate 20 with the safety significance of the issue --
21 MEMBER HALNON: Okay.
22 MR. ZOULIS: -- not getting bogged down on 23 too much specifics or the technical attributes of it.
24 MEMBER HALNON: Right. And the original 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 letter that Ho Nieh had -- I guess, on what? --
1 February 20, or whatever, mentions self-assessment.
2 And it's self-assessment after a
year of 3
implementation of this, so that you can take a look at 4
that and tweak it, when necessary.
5 MR. ZOULIS: Yes. Exactly. But I don't 6
know the timeframe. I can't recall. I think it was 7
more after a number of these had been exercised, I 8
thought, because we weren't sure how many of these we 9
were going to get, to be honest. I know there's been 10 a lot of discussion -- maybe industry will go into it 11 more -- circling around some issues, but we haven't --
12 nothing has been ripe yet for RIPE.
13 MEMBER HALNON: In hindsight, would the 14 tornado missile issue have gone through this maybe for 15 something --
16 MR. ZOULIS: Personally, I believe so. I 17 think so. My view is probably, as long as it's well-18 captured by the risk and the PRA can support that.
19 MEMBER HALNON: That might be a good pilot 20 to look at.
21 MR. REED: Yes, we've actually had a 22 number of tornado missiles go through the velitzer 23 process. And so, it was a situation there where we 24 couldn't determine whether it was in. So, I would 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 imagine that, if they are in, and for any reason they 1
need to do something, then, yes, I think it could 2
possibly come in the RIPE also.
3 MEMBER HALNON: Okay. Thanks. That was 4
a very expensive issue for the industry and the NRC, 5
for the amount of resources put into it.
6 MR. ZOULIS: The example I always kind of 7
go to is equipment qualification. I know there was a 8
number finds that came out of Region II in that area.
9 So, to me, if there's a piece of equipment that was at 10 the end of life and the criteria was loop, maybe main 11 steam line break, and the room heatup, and for some 12 reason, that piece of equipment we can't tell whether 13 it will meet the EQ requirements, but the risk 14 associated with that issue could be either minus 10 or 15 very low, could they, then, come in and RIPE that 16 issue, essentially, and say, you know, we have a main 17 steam line break, we have a loss of offsite power, and 18 the probability of losing that piece of equipment is 19 quantified and it's very low --
20 MEMBER HALNON: Yes, I agree.
21 MR. ZOULIS: -- yes, that's the example 22 that I always go to.
23 MEMBER HALNON: Okay. Just a last 24 question real quick. Is this process open? Is it 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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50 ready for a submittal?
1 MR. ZOULIS: We're open for business, yes.
2 Yes.
3 MEMBER HALNON: Okay. Good.
4 MR. ZOULIS: And, I mean -- go ahead.
5 MEMBER DIMITRIJEVIC: Yes, I was going to 6
also add to Greg's questions on this. Because if we 7
here define the process will be much faster, we're 8
guaranteed faster now, but, actually, we don't even 9
see in the details what will be the difference in the 10 reviews, you know, and what will guarantee these fast 11 turnouts. So, if something is proved to have a low 12 safety significance, does that mean that RAIs will not 13 be issues?
14 MR. ZOULIS: Correct. That's correct.
15 MEMBER DIMITRIJEVIC: It does?
16 MR. ZOULIS: Yes.
17 MEMBER DIMITRIJEVIC: So, it will not be 18 additional technical --
19 MR. ZOULIS: Correct. Yes, Vesna. Yes.
20 MEMBER DIMITRIJEVIC: Okay.
21 MR. ZOULIS: Sorry, I didn't mean to 22 interrupt you.
23 But, again, I want to be very cautious.
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51 to be fast. They wanted us to spend the sufficient 1
resources, given it was a low safety-significant 2
issue. So, you can understand the dilemma that, 3
right? If it's low safety-significant, why are you 4
making me rush? Initially, when I proposed RIPE, I 5
said we should do it in 30 days, but, then, DORL came 6
across and said, "Well, why are you making us spin our 7
wheels so quickly for something that's very low 8
safety-significant?" It's more important that we 9
spend the resources, lower resources commensurate with 10 the issue, than spin up the organization to get it out 11 of the door that quickly.
12 But, you're right, there are no RAIs.
13 Under the RIPE process, there will be no RAIs. There 14 may be opportunities for some clarification calls, 15 opportunities to supplement, if needed, and no 16 technical review required, and only a DRA reviewer.
17 So, in my opinion, a very streamlined review.
18 MEMBER DIMITRIJEVIC: Well, would there be 19 something like template submittals or something like 20 that, so we'll also reduce the paperwork?
21 MR. ZOULIS: NEI may talk on their 22 presentation about that. I think they're planning to 23 develop some templates. So, I won't steal Victoria's 24 thunder on that, but she may get into that in her 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 presentation.
1 MEMBER DIMITRIJEVIC: Right.
2 MEMBER KIRCHNER: Antonios, this is Walt 3
Kirchner. May I ask a question?
4 It seems to me -- maybe it's an 5
observation, and then, it's a question -- that the 6
second box on the upper, the schematic that's in front 7
of us, that seems to be the point where the staff 8
really makes a major decision or not. And then, I can 9
see the rest of it going rather quickly.
10 But if you don't pass that orange second 11 box, the acceptance review for the exemption, then, by 12 default, does that turn the licensee back to an LAR 13 submittal?
14 MR. ZOULIS: Yes, that's a great question.
15 Yes, so, essentially, what we thought was, if it 16 doesn't meet the RIPE for some reason, it's still a 17 risk-informed review. We can do either a link to a 6 18 review, and have an integrated review team look at it, 19 or maybe just a traditional risk-informed review. So, 20 we wouldn't kick it out necessarily, but we want to 21 make sure, for RIPE, though, like Vesna said, no RAIs 22 and very clear-cut issue, well-defined. Because if we 23 get into these, like you said, these areas where maybe 24 it's gray or the issue is not well-defined, we don't 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 want the RIPE process to kind of, then, turn out to be 1
just other regular license amendment review process, 2
right? It's intended to be a streamlined review 3
process, a very efficient, thorough review done in a 4
very short time period. But we are willing to kick it 5
back and say we have other ways to review it. It 6
might not be a RIPE review, but it might be something 7
of that nature.
8 Does that answer the question?
9 MEMBER KIRCHNER: Yes. And I guess it 10 will be the proof will be in the actual submittals, 11 the examples, but it seems to me that second box is 12 the key one.
13 MR. ZOULIS: You're right. You're 14 correct. You're very correct, yes.
15 MEMBER KIRCHNER: Yes, and for this to be 16 effective.
17 MR. ZOULIS: That's where the discipline 18 will take place, the discipline to ensure that, if 19 we're okay with the issue and it's well-defined, and 20 follows the RIPE process we've delineated, we need to 21 be true to that process. We can't just, all of 22 sudden, be subjective and start changing that, due to 23 personal preference or because this issue is my issue, 24 or this is an important issue to me, or those kind of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 issues that may arise sometimes when we deal with very 1
complex issues amongst staff.
2 MEMBER BROWN: Walt, are you done?
3 MEMBER KIRCHNER: Yes. Thank you.
4 MEMBER BROWN: Okay. This is Charlie 5
Brown. Can I ask a question, please?
6 MR. ZOULIS: Sure. Sure. Of course, sir.
7 MEMBER BROWN: I'm trying to connect the 8
dots. I presume, looking at, again, the second boxes, 9
where we accept the review issued, and I'm trying to 10 connect this back to your slide 10 relative to a 11 system inoperable; restore system to inoperable 12 status, three days normally, or -- all in red -- this 13 risk-informed process.
14 If you pass the second box, that's three 15 weeks in each of them. Oh-oh.
16 MR. ZOULIS: Agree you talking about his 17 slide?
18 MEMBER BROWN: Yes. So, we're back to 19 this. How does this connect to this backstop routine?
20 Does that mean now -- let me finish my question here 21 to make sure I understand my question. The second box 22 is three weeks. But, to get final dispensation, it's 23
-- I don't know -- it's 30 weeks or 20 weeks, or 24 whatever it is. It's the last boxes. Does that mean 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 the plant can continue to operate with an inoperable 1
system for two or three months, or four months?
2 MR. ZOULIS: So, the question is --
3 they're not related. Sorry. The answer is, the 4
reason we provided this was just to give a background 5
on TSTF-505 and the Risk-Informed Completion Program 6
for maybe folks that weren't familiar with those two 7
initiatives.
8 But RIPE only uses the PRA, the technical 9
quality of the PRA that went to support this 10 initiative. It's leveraging that for its process.
11 They're unrelated. Sorry for that confusion.
12 MEMBER BROWN: So, they will never have 13 more than 30 days to restore a system?
14 MR. ZOULIS: That's correct, the 30-day 15 backstop is part of the RIC program, the TSTF-505 16 program. Now they can come in for a special 17 amendment, as one licensee did -- and maybe Jonathan 18 may want to jump in -- but that's separate. That's 19 not part of the RIC program. Maybe a one-time 20 extension, but not part of the RIC program.
21 MEMBER BROWN: Okay. So, if it's not an 22 operability of the plant issue, it's the license 23 exemption or LAR is a larger-scale issue, but of a low 24 safety significance?
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56 MR. ZOULIS: Correct. Yes. If it is an 1
operability issue, then the plant needs to --
2 actually, you can't RIPE -- I think Michelle mentioned 3
that -- if it's an immediate issue.
4 MEMBER BROWN: Okay.
5 MS. KICHLINE: Yes. We specifically did 6
not allow them to use the RIPE process for tech spec 7
changes because we already have a risk-informed tech 8
spec change process, and we don't expect tech spec 9
issues to be minimal safety impact.
10 MR. REED: But just to get it back, Tim, 11 what Antonios' idea was, it was to take the very best 12 IDP, because it's a qualitative assessment at issue; 13 the very best PRA, which is 505 because it's 14 quantitative, and based on those both being 15 implemented and approved, you don't have to do that 16 again. And you've got to be very confident, once you 17 have those in place, that they're going to be able to 18 properly characterize them. That's why we're showing 19 505, because 505 is a better PRA than what's required 20 by 50.69, for example. So, this will be a very robust 21 risk-informed process that they use. It's what we 22 called it the "gold standard".
23 MEMBER BROWN: Thanks.
24 MEMBER DIMITRIJEVIC: Michelle said 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 something important from my point of view, which I 1
didn't really get until this moment. Actually, this 2
is not intended for risk-informed applications because 3
risk-informed applications already have their own 4
platforms. That's what Michelle just said, is that 5
true?
6 MS. KICHLINE: Well, RIPE is kind of its 7
own type of risk-informed application, but we have 8
other risk-informed processes, and --
9 MEMBER DIMITRIJEVIC: Yes, right, the tech 10 specs --
11 MS. KICHLINE: Yes.
12 MEMBER DIMITRIJEVIC: -- the in-service 13 testing and --
14 MS. KICHLINE: This is something different 15 from those processes. It just uses the same --
16 MEMBER DIMITRIJEVIC: I see. So, these 17 processes, they go by their own using the 1.174. You 18 have modified it, actually, by 1.174 with these 19 smaller values.
20 MS. KICHLINE: Yes.
21 MEMBER DIMITRIJEVIC: So, okay. So, that 22 was one of my first questions, actually, when you 23 started, because I was wondering, can they be 24 submitting the 505 now on the RIPE? But, actually, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 you just said no. So, I understand, you know. And 1
there was a Charlie question, too. So, basically, 2
risk-informed applications which already have their 3
Reg Guide are standing by themself, you know, and this 4
is just for the different type of -- okay. All right.
5 MR. ZOULIS: Now, having said that, we are 6
looking perhaps at expanding RIPE to look at maybe 7
tech spec. But, as Michelle mentioned, we felt that, 8
if it was in tech spec, it's probably not low safety-9 significant. But we're open to ideas. We're always 10 open to expand the process. And I'll talk about a 11 little bit, I think, later on where we're heading with 12 that.
13 MEMBER DIMITRIJEVIC:
And that's 14 interesting. All right. Okay.
15 MR. ZOULIS: So, should we go on to the 16 next -- sorry.
17 MEMBER BROWN: Can I ask one other 18 question?
19 I'm trying to remember which document it 20 was. There were two documents, one called Draft 21 Guidance for Characterizing Safety Impact Issues, and 22 then, NRR Temporary Staff Guidance. And they talked 23 about how this process wouldn't be used for something 24 like -- I guess the two that I remember, one was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 replacing an existing pump with a lower-capacity pump.
1 Or the other one was replacing a main transformer, I 2
presume with something that was not quite the same as 3
the original.
4 It said that this process was not used for 5
variations in the plant capabilities. I presume those 6
are tech-spec-type issues.
I'm making that 7
assumption, but I don't really know what I'm talking 8
about from an operational standpoint.
9 How does those get treated? Are they LAR-10 type things, irregardless?
11 MR. ZOULIS: Michelle, do you want to take 12 that?
13 MS. KICHLINE: What you're talking about, 14 yes, they would just submit a normal license amendment 15 request, not through RIPE. And potentially, they 16 could risk-inform them, but some of the things we 17 specifically said you couldn't use RIPE for were like 18 immediate concerns, because it's not meant to be fast 19 or it's meant to have less resources. And again, we 20 have standard, we have good processes for emergency 21 license amendment changes.
22 MR. REED: Yes, not to confuse the 23 Committee, but that would actually start with a plant 24 change control process and you look at the widget 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 you're changing out, and one of the first you could do 1
under 50.69 is to count that you're in license 2
amendment. And if you're in license amendment space, 3
you may want to risk-inform it, and there may or may 4
not be a tech spec involved. So, yes, it could be 5
almost anything in that case.
6 MEMBER BROWN: Okay. You answered my 7
question. The last I had on your viewgraph here is 8
that the total completion time, then, is 13 weeks for 9
an exemption, 10 weeks after you did the acceptance 10 review, and the total time on the other one is 20 11 weeks. So, that's a relatively quick turnaround, I 12 guess.
13 MR. ZOULIS: Yes.
14 MEMBER BROWN: You're going to add all 15 these weeks up, I take it?
16 MR. ZOULIS: Yes.
17 MEMBER BROWN: The total time is expressed 18 in the last box, is that correct?
19 MR. ZOULIS: Correct. That's right.
20 MEMBER BROWN: Okay.
21 MR. ZOULIS: It's still a truncated 22 timeline, but it's not 30 days, which I would call 23 expedited, 30 days.
24 MEMBER BROWN: Okay. I know we've got two 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 presentations from industry. I presume they'll 1
comment on whether they view this as a positive thing 2
or not?
3 MR. ZOULIS: Sure. Hopefully, we'll hear 4
from them soon.
5 MEMBER BROWN: Okay.
6 MR. ZOULIS: So, let me go through a 7
couple of slides I have left.
8 So, I just wanted really, what was the 9
purpose of RIPE? RIPE was essentially intended to 10 focus NRC and licensing resources on low safety-11 significant issues. It benefits both us, the 12 licensees, and the public, if we do that. And it also 13 addresses these low safety-significant issues in an 14 efficient particular manner which is consistent with 15 our principles of good regulation.
16 It also leverages our existing regulations 17 and uses risk insights. And one of the things that I 18 felt was, if we can show another benefit of using the 19 PRA, and a high-quality PRA would incentive licensees 20 to develop or implement some of these risk-informed 21 initiatives, or at least enhance their PRAs and 22 enhance their integrated decisionmaking processes.
23 So, what's next? Right now, we're very 24 close to issuing guidance for expansion of RIPE to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 include TSTF-425. Industry has developed some 1
guidance that's out there that's available to NEI 2
members. We're in the process of developing our 3
guidance to match that, guidance to be able to use 4
TSTF-425 with some caveats and conditions.
5 We've also kind of said, if you can 6
demonstrate a RIPE-equivalent IDP -- for example, if 7
you have a 425 IDP and you ensure that your IDP has 8
the management, the composition, and the staff being 9
the appropriate staffing, you could use that guidance, 10 and it would be a RIPE-equivalent IDP and you can use 11 that in lieu of having a 50.69 IDP.
12 The other, as we mentioned before, EP and 13 security are other areas that we think may benefit 14 from at least a structure probably. I think one of 15 the reasons Vesna was interested in RIPE was that it's 16 a structured process that you can use to determine 17 something is low safety significant. I think there 18 are elements in that process that you can adopt for EP 19 and security and just inform it with other information 20 to help you get to maybe the similar conclusion.
21 So, I think that's really the power of the 22 RIPE process, to show a systematic, structured way, 23 using a multidisciplinary team, to evaluate an issue, 24 and to determine its safety significance.
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63 And we're continuing to do outreach to 1
interested parties like yourself. We always like to 2
do that. If you have any questions, contact Tim Reed.
3 (Laughter.)
4 But, other than that -- I don't know if 5
Tim likes that joke. I keep doing it after every 6
presentation.
7 MR. REED: Yes, scratch my name off that.
8 (Laughter.)
9 MR. ZOULIS: So, if there aren't any other 10 questions, should we go to the industry's 11 presentation, NEI or the PWR Owners Group? I don't 12 know who would want to go first, but is the Committee 13 okay with that?
14 MEMBER DIMITRIJEVIC: Absolutely. Yes, 15 since there are no more questions, we can speak to the 16 industry representatives.
17 Who is planning to go first on this?
18 MR. ZOULIS: I guess I'm going to pick 19 Victoria. Let me pick Victoria and let her go first.
20 Victoria, are you available?
21 MS. ANDERSON: Yes, I can get it going.
22 All right.
23 So, I'm Victoria Anderson with NEI. I'm 24 a topical advisor for Risk and Engineering, and I'm 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 going to be talking about industry perspectives and 1
progress on the risk-informed process for evaluation.
2 So, next slide, please.
3 I'll talk a little bit about our general 4
perspective on RIPE, and I'll go into a little more 5
detail on what our efforts on RIPE implementation have 6
entailed, including work with potential first movers; 7
work to expand the scope of applicability of RIPE to 8
more plants; our development of supporting documents, 9
and, also, go over our next steps.
10 So, next slide, please.
11 We really appreciate the innovative 12 concept from the NRC. This gives licensees the 13 potential to leverage our existing analysis and PRA 14 infrastructure to streamline decisionmaking. I think, 15 as you heard from the staff, it relies on previous NRC 16 staff evaluation and already completed PRA analysis.
17 It does offer licensees an option for more rapid 18 resolution of emerging issues if their existing 19 analyses support a RIPE approach.
20 There was a question that just came up a 21 few minutes ago of whether or not we believe that this 22 improvement delivered by RIPE is positive or not. I 23 think we see most of the benefit as being in reduction 24 of NRC staff resources used, but also do appreciate 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 the schedule benefit and believe that that could be 1
beneficial as well.
2 We really see this overall as a prime 3
example of progress on modern risk-informed 4
regulation; and also, see the use of the Integrated 5
Decisionmaking Panel as a positive development, as it 6
supports a streamlined review and helps eliminate 7
duplication of efforts.
8 I think, as Vesna mentioned earlier, 9
traditional risk-informed exemptions and license 10 amendments can still continue since RIPE is not 11 suitable for all issues. So, RIPE is not a specific 12 risk-informed license amendment request in the way 13 that we consider it, but it is another tool in the 14 toolbox for NRC and licensees.
15 Next slide, please.
16 So, as has been noted a couple of times 17 during this meeting, we don't yet have any uses of 18 RIPE. It has been available to licensees with 19 approved TSTF-505 programs since late 2020. That 20 means, starting in late 2020, it was available to 21 somewhere between 12 and 14 sites.
22 We've been discussing potential RIPE uses 23 with licensees who do have approved TSTF-505 programs.
24 We've identified a couple of potential uses. So far, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 all of the other cases were resolved by other means, 1
but we are still having regular discussions with 2
eligible licensees to discuss these possibilities 3
regularly.
4 I think, as was referenced at the end of 5
the last presentation, we're looking at the potential 6
to use TSTF-425 to support RIPE evaluations. So that 7
PRA evaluations that have PRA technical adequacy that 8
was done to support a TSTF-425 application could be 9
used for a RIPE submittal. And that would make this 10 available to more licensees for use. I'll go into 11 what that is in the next slide, please.
12 So, as you can see here, we sort of 13 plotted the adoption rate of TSTF-425 versus TSTF-505 14 plus 50.69. And as you can see, if you break down my 15 number of units, at the end of last year, less than 20 16 percent of units would be able to use the RIPE 17 process. If you expand it to licensees that have an 18 approved TSTF-425 program as a basis for the PRA 19 technical adequacy for entry into RIPE, you're 20 currently right not almost at 100 percent. There is 21 only one operating licensee that does not have an 22 approved TSTF-425 program, and they have just recently 23 turned in their application. So, you're essentially 24 at 100 percent of licensees that would be able to use 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 this program when TSTF-425 could be used as the PRA 1
technical adequacy basis.
2 If you look at sort of where you reach a 3
plateau of the percentage of units that could use this 4
process, if you remained relied on TSTF-505, you're 5
looking at about 50 percent, based on current 6
projections for intended applications.
7 MEMBER DIMITRIJEVIC: Victoria, just for 8
curiosity, because you have grouped 505 and 50.69 9
together, is there 50.69 applications which didn't use 10 505?
11 MS. ANDERSON: Yes, there are licensees 12 that have just 50.69 and do not have TSTF-505.
13 MEMBER DIMITRIJEVIC: Okay. All right.
14 Thanks.
15 MS. ANDERSON: All right. So, I want to 16 talk a little bit about why the industry believes that 17 it's sufficient to use TSTF-425 as the technical basis 18 for PRA technical adequacy. So, as we look through 19 the various applications and we go through this table, 20 I think we had mentioned before in this meeting that 21 TSTF-505 is really the highest level of PRA rigor 22 expected for any kind of risk-informed application we 23 have right now. For internal events PRA, you need to 24 meet Capability Category 2 of the PRA standard; the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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68 same for an internal fire PRA. For external hazards 1
PRA, it's site-specific, but it's the highest level of 2
PRA technical adequacy is expected for that 3
application. If you look at 425, you also need 4
Capability Category 2 for internal events, but for 5
internal fire and external hazards, you could use 6
qualitative or bounding.
7 Looking at RIPE, it seemed to us that 8
Capability Category 1, basically screening, would be 9
sufficient technical acceptability for an internal 10 events PRA, and that qualitative, or possibly not 11 applicable for external fire and external hazards, 12 would serve as a standard for the RIPE program. So, 13 our perspective was that TSTF-425 would be a 14 sufficient PRA technical adequacy basis for pursuing 15 a RIPE application.
16 I'll just stop and see if there are any 17 questions there, because there's definitely a lot of 18 information and data on that slide.
19 (No response.)
20 Okay. So, if there aren't any questions, 21 I'll move to the next slide, which is the industry 22 document development and support.
23 As was noted previously, we issued some 24 guidance in April, NEI 21-01, that gives information 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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69 on implementation of RIPE. It documents the 1
Integrated Decisionmaking Panel process and 2
expectation. So, that's sort of where that 50.69-3 equivalent IDP that was mentioned earlier comes into 4
play. And it also describes the necessary PRA 5
technical adequacy documentation for submittals, 6
either by referencing an approved TSTF-505 application 7
or an approved TSTF-425 application with additional 8
information provided about the PRA technical adequacy 9
and the scope of PRA evaluation that is relevant to 10 the issue RIPE is being used for.
11 I think there was a question before if we 12 were looking at using templates, and we do have a 13 template available. It is an appendix to NEI 06-02, 14 License Amendment Request Submittals. And we're 15 continuing to interface with the NRC staff to ensure 16 adequate support for RIPE.
17 MEMBER HALNON: Victoria, this is Greg 18 Halnon.
19 MS. ANDERSON: Yes?
20 MEMBER HALNON: Does this document detail 21 out the Generic Assessment Team?
22 MS. ANDERSON: NEI 21-01?
23 MEMBER HALNON: Yes.
24 MS. ANDERSON: Yes.
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70 MEMBER HALNON: Could we just go into a 1
little detail on how that's assembled and how it 2
works? Is it part of the Integrated Decisionmaking 3
Panel or is it prior to, or how does that work?
4 MS. ANDERSON: Yes, it's prior to. So, 5
that's sort of looking at something from a broader 6
perspective, and then, that would feed into the IDP, 7
if relevant.
8 MEMBER HALNON: How is it assembled?
9 MS. ANDERSON: I would have to go back and 10 look. I don't think we went into great detail about 11 how it was assembled. We didn't really foresee that 12 being a substantial part of how RIPE would be 13 implemented. We see it as being more plant-specific 14 in its use.
15 MEMBER HALNON: Okay. The reason I ask, 16 and this is why I am questioning and I asked you about 17 the tornado missile issue. That turned into be a very 18 generic issue amongst many plants, costing millions of 19 dollars and lots of time on both the staff and the 20 licensee perspective, in addition to the regulatory 21 turmoil that we had because of it. And that 22 translated to other utilities because of kind of an 23 evolving generic issue as opposed to one that was 24 actually determined to be low significance, and people 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 had to look at it. It eventually got there, but it 1
really took a lot of effort to get that characterized.
2 I was curious, if the tornado missile 3
issue was one of those that could have gone through 4
this process, how that would have made it into the 5
generic space. And to me, other than the individual 6
NRC inspections and an inspector calling it out, this 7
Generic Assessment Team seems like the mechanism to 8
get it there in the generic space. So that if it's 9
not well-defined, either on the NRC or the licensee 10 side, then I'm just wondering how that would work out.
11 So, it might be something to go back and look at.
12 Just work with the NRC to make sure that it's 13 understood and well-defined.
14 MS. ANDERSON: Yes, we can definitely do 15 that. I think we left it sort of intentionally vague 16 and said that it should include experts and 17 individuals knowledgeable of relevant phenomenon and 18 that kind of thing. It's sort of hard to predict what 19 you would need to have versus for the plant-specific 20 IDP, where you can say you need to have specific 21 personnel from the site.
22 MEMBER HALNON: Right. In the absence of 23 any process that is consistent, you're going to leave 24 it to what we have called "inspection creep," and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 sometimes getting it; sometimes not; maybe a year 1
later; maybe not at all. And that's what I'm 2
concerned about.
3 MS. ANDERSON: Yes, I think that's a fair 4
concern. So, we'll make sure that we take a look at 5
that.
6 All right. Any other questions?
7 (No response.)
8 All right. So, the final slide is next 9
steps that we're looking at. We're looking to NRC to 10 update their Temporary Staff Guidance to reflect what 11 we've given them in NEI 21-01. We'll continue 12 integrating feedback that we get from NRC and other 13 sources into guidance and templates, and we'll 14 continue to interface with licensees to identify a 15 lead use of RIPE.
16 That's all I have for today. If there are 17 any other questions, I'll take them. If not, I'll 18 turn it back to the staff.
19 MR. ZOULIS: Thanks, Victoria.
20 I guess now Roy Linthicum will present.
21 MR. LINTHICUM: Thanks, Antonios. Have 22 you got my slides?
23 MR. ZOULIS: Yes, I do.
24 MR. LINTHICUM: All right. Thank you.
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73 Good morning.
1 This is Roy Linthicum. I'm Chairman of 2
the Risk Management Committee for the PWR Owners 3
Group, and I'm going to go down a little bit different 4
path. In the Owners Group, we're working to see if we 5
can actually expand the RIPE concept to deal with more 6
generic issues.
7 Next slide, please.
8 Of course, as Victoria mentioned, from an 9
Owners Group perspective, similar to NEI and the rest 10 of the industry, we do think that the current process 11 that's been developed for RIPE is a significant step 12 forward on risk-informed decisionmaking. It really 13 does help focus both the industry and NRC resources 14 appropriately on issues that are safety-significant.
15 We do think, though, that it can be expanded for 16 further support/reduction of resources on low-17 significant issues, and we can do that by dealing with 18 some issues on a more generic basis.
19 Next slide, please.
20 So, what we would like to do, working with 21 the staff, is to develop a process where we can 22 leverage the RIPE concepts for expedited review of 23 generic issues of low-risk significance; maximize the 24 applicability of these generic evaluations. And to do 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 that, we believe we can use bounding risk calculations 1
to demonstrate the low safety significance, so we can 2
get the expedited NRC review and focus that burden.
3 And we would want to do that rather than have to use 4
plant-specific PRAs specific for the submittal.
5 We do have a specific issue we're dealing 6
with, and I'll go into that in a little more detail 7
because I think examples always help. That's a main 8
steam line break which requires an asymmetric cooling 9
of Westinghouse PWRs. And we are looking to see if 10 there are other suitable examples that we can deal 11 with on a generic basis.
12 And like I said, we do believe PRA 13 adequacy for some issues, obviously not all, can be 14 addressed via bounding assumptions and use of a 15 Generic Assessment Team, that can then be confirmed 16 for plant-specific applicability and possibly replace 17 the use of a plant-specific IDP.
18 MEMBER HALNON: Hey, Roy, this is Greg 19 Halnon.
20 You're using the term "expedited review" 21 and the NRC used "streamlined review". Are you guys 22 on the same page there?
23 MR. LINTHICUM: I would say yes, the 24 difference being if we end up -- we're ending up 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 getting a little bit ahead -- but if we end up going 1
down a risk-informed review of Topical Reports, 2
expediting those reviews would actually be part of a 3
streamlined process, because we start right now on 4
topical reviews on a two-year review period, and that 5
could be a very long time. So, we would like to both 6
reduce
- that, but also reduce that timeframe 7
significantly as well.
8 MEMBER HALNON: All right. Thanks.
9 MR. LINTHICUM: Yes.
10 Next slide, please.
11 So, the example that we're using -- and 12 this is a real issue that we're dealing with now 13 within the Owners Group. It relates to asymmetric 14 natural cooldown. In this particular case, if you 15 have a main steam line break and a faulted steam 16 generator which is unisolated, so you're cooling down 17 with a steam generator isolated from the feed side, 18 you can challenge your offsite dose limits for 19 Westinghouse plants.
20 In order to deal with this, under the 21 current design basis, we do need to make significant 22 EOP changes to focus on rapidly cooling down the plant 23 to eliminate the calculated dose. I will mention that 24 more rapid cooldown does pose additional operator 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 challenges. You're starting from what would be a 1
fairly stable plant and working on cooling it down.
2 So, you need to be concerned about, are you drawing a 3
bubble in the head; are you possibly putting nitrogen 4
into the system, and a lot of other errors that could 5
happen during that rapid cooldown that could challenge 6
the path and actually increase the frequency of going 7
to core damage. And you're doing this to address what 8
we believe is generically a non-or very low risk-9 significant scenario.
10 Next slide, please.
11 So, as to the specific conditions we're 12 dealing with, you have a faulted steam generator 13 that's a main steam line break, and the MSIV fails to 14 close. Concurrent with that, you have the loss of 15 offsite power event. Also, you're operating at your 16 maximum tech-spec-allowed fuel leakage, and you're 17 operating at your maximum allowed primary to secondary 18 leakage rates. So, you need to have all of these 19 conditions occur simultaneously in order to challenge 20 your offsite dose calculations.
21 So, the assumptions that we would have 22 going into a generic evaluation are, even though it 23 doesn't go to core damage, we would assume, if you 24 have all those conditions simultaneously, you're still 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 going to core damage. And that, we think, is a very 1
conservative assumption. The plant is still in a safe 2
and stable state with your normal cooldown going on, 3
but the rapid asymmetric cooldown does limit the total 4
offsite dose. But, once again, it can provide 5
additional operational challenges.
6 Next slide, please.
7 So, when we started putting this together, 8
and we were thinking we can evaluate this using a 9
Generic Team as a replacement for the IDP, from a 10 generic evaluation perspective, the types of things we 11 want to look at are: what is the generic initiating 12 event frequency that we would use to demonstrate that 13 low-risk significance? We want to make sure that 14 anyone that's using this does not allow fuel damage 15 associated with a main steam line break. We need to 16 recognize what the bounding single failure is. We do 17 know not every plant's bounding single failure is the 18 same across the Westinghouse fleet. We need to look 19 at your fuel leakage history, primary to secondary 20 leakage history; identify the conservatisms that 21 already exist in the offsite dose calculations, and 22 then, also identify what would a plant need to confirm 23 for plant-specific applicability.
24 Next slide, please.
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78 So, what we're looking to see if we can 1
do, once again, it's, can we use a generic bounding 2
analysis, most likely in the form of a Topical Report, 3
to determine safety significance? We'd like to be 4
able to use the Generic Team to replace the plant-5 specific IDP requirements. And as we expand the 6
concept, if we can demonstrate that it's of very low 7
risk significance, once we're in the streamline for 8
expedited NRC review of the Topical Report, it would 9
go a long way.
10 We are still working through and having 11 discussions with the staff. We do think when you have 12 a risk-informed review of the Topical Report, then 13 plants can implement those changes via the 50.59 14 process, not necessarily make a submittal. But the 15 staff would have an SE associated with the Topical 16 Report.
17 As an alternative path for some issues, it 18 may be possible to have a plant submit the Topical 19 Report as part of a plant-specific submittal. We're 20 still working out the details of what makes the most 21 sense from a generic perspective, and that's the type 22 of things we want to continue to work with the staff 23 on at this point.
24 MEMBER DIMITRIJEVIC: So, you have not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 assembled yet the GAET, the Generic --
1 MR. LINTHICUM: No, we haven't yet. We 2
haven't that yet. I mean, part of our plan -- and 3
we're just getting this kicked off -- is to determine 4
what would be required from a generic team.
5 Like I say, for this particular issue --
6 MEMBER DIMITRIJEVIC: It's that that team 7
would be on the Owners Group level, right?
8 MR. LINTHICUM: Correct. Yes, it would be 9
on the Owners Group level.
10 MEMBER DIMITRIJEVIC: Okay.
11 MR. LINTHICUM: Like I say, for this 12 particular issue, we know we would need to have people 13 with an operations background, a risk background, a 14 safety analysis background, an offsite dose 15 background. So, I mean, for the specific issue, we 16 want to make sure we would bring in the right 17 expertise to be able to deal with the issues.
18 Now the challenge is, how do you convert 19 that into a generic guidance that can cover all 20 issues? But that can be accomplished, since we've 21 done that for other initiatives as well.
22 MEMBER DIMITRIJEVIC: Understood. And you 23 have done some preliminary, obviously, calculations to 24 see that that will fall in the low safety 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 significance, right?
1 MR. LINTHICUM: Yes, yes, yes. Yes, we're 2
well below the -- like I say, if we assume this 3
condition goes to core damage, we're well below the 1E 4
to the minus 7 CDF criteria that the NRC has for the 5
current process. And once again, that's not even 6
actually going to core damage. You're in a safe and 7
stable condition.
8 We do recognize, like I said, we're 9
dealing with offsite dose, not core damage in this 10 case. But you're not going to have a very significant 11
-- you know, you're not going to exceed, most likely 12 not going to exceed the offsite dose limits by a lot 13 for this very low frequency event.
14 MEMBER DIMITRIJEVIC: All right.
15 MR. LINTHICUM: So, that's all I have, 16 unless you have any questions. I would say we have 17 started some preliminary discussions with the staff 18 and gotten some good feedback from Antonios and the 19 people working with Antonios, and we are looking 20 forward to those continued interactions as well.
21 MEMBER HALNON: Hey, Roy, this is Greg 22 Halnon.
23 Is the BWR -- oh, that's right, the two 24 Owners Groups are together, right? So, you're 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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81 covering both Bs and Ps?
1 MR. LINTHICUM: Well, I mean, we are 2
inviting the PWRs to participate, and depending on 3
what the other issue is, we'll have the BWRs Owners 4
Group as well. This particular issue that happened to 5
be going on was actually initially identified in some 6
inspection reports as something that's challenging the 7
offsite dose limits for a couple of plants already.
8 It's a really a PWR-specific issue, which is why we're 9
dealing with this.
10 MEMBER HALNON: Okay, but you're talking 11 to the Bs?
12 MR. LINTHICUM: Yes, yes.
13 MEMBER HALNON: Okay.
14 MR. LINTHICUM: Yes.
15 MEMBER DIMITRIJEVIC: Roy, can you 16 identify any -- do you have some initial issue you 17 guys considered that would be applicable for that --
18 like Greg mentioned earlier, tornado missiles -- or 19 anything else which is going on in the industry?
20 MR.
LINTHICUM:
- Well, as Victoria 21 mentioned, I'm aware of a couple of other plant-22 specific issues that were resolved through other 23 means, though RIPE was definitely being considered.
24 It is a little challenging, given the fairly low 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 criteria, to identify something that fits into that 1
narrow range of applicability. But we are continuing 2
to look to see if there are other generic issues that 3
we can look at as well, but we have not at this point 4
identified any specific issue.
5 I will say, I think I go back to what Tim 6
Reed says on the tornado missile evaluations, or not 7
-- yes, tornado missile evaluations. I think it 8
depends on if it was or was not clearly in the 9
licensing basis. So, for some plants, I think RIPE 10 could have saved us a lot of time and resources, had 11 that been available at the time. And I would even 12 argue, potentially, GSI-191 may have been an issue.
13 We spent a lot of time and money on a generic basis 14 and ended up pretty much concluding it was of low 15 safety significance, but did a lot of deterministic 16 work to support that and millions of dollars spent on 17 that issue that really didn't provide any significant 18 benefit.
19 MEMBER DIMITRIJEVIC: Thanks. That's 20 interesting.
21 Okay. Then, we have concluded the 22 presentation with this, right? So now, we're just 23 going to open for discussion.
24 I am especially curious from the last 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 discussion, this has a limited application, and 1
Victoria talked how to expand this to plants beyond 2
the 505, and if we extend it to 425, then all 3
operating plants would be involved, almost all.
4 So now, my question is, do we think about 5
extending some basic principles beyond the operating 6
plants or beyond the plants which are for design 7
certification, for the plants which are licensed under 8
10 CFR 52, or even for the future 53 applications?
9 Because the reduction in the regulatory burden and the 10 streamlining process for this issue is, obviously, 11 interesting for everybody, right? That's the basic 12 risk-informed process.
13 So, I was just curious, what are you 14 thinking about future application and extending this?
15 Are you working on anything else in this moment?
16 MR. ZOULIS: So, yes. So, right now, 17 Vesna, we're looking at expanding it to include Part 18 52 sites, especially given the fact that some, they're 19 required to have a PRA of sufficient quality, which is 20 essentially what RIPE is driving to, is to demonstrate 21 you have a PRA of sufficient quality. And so, 22 therefore, you should be able to leverage that PRA to 23 disposition issues that low safety-significant.
24 The other aspect is having an Integrated 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 Decisionmaking Panel. With the RIPE guidance 1
developed, the RIPE-equivalent IDP developed by 2
industry, that could also be used to leverage a team 3
that could follow the guidance and demonstrate that 4
you have the integrated decisionmaking process.
5 So, right now, it is still the early 6
stage. We need to talk it over with the working group 7
that would meet tomorrow to kind of talk over what the 8
working group's thoughts are and get a little bit more 9
input. But we're heading to kind of expand it for 10 Part 52 plants after they get their licenses, I 11 believe. I'm not sure as part of the licensing 12 process; I don't know about that, but maybe to use it 13 after they're licensed and operational.
14 MR. REED: Also, to chime in a little bit, 15 I agree with everything that Antonios said, but keep 16 in mind -- and then, by the way, I agree with you 17 completely, Roy, on the soft issue. But you've got to 18 keep in mind that RIPE has to be something that's 19 truly plant-specific. Folks, I did rulemaking for 25 20 years, and you can't get around rulemaking by using 21 this process. In other words, if we start to do 22 something generically -- let's say, for example, long-23 term cooling for a blockage, and we say, hey, it 24 doesn't matter, and we just want to say give everybody 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 RIPE, what you're doing is rulemaking. And you're 1
doing rulemaking outside the Administrative Procedure 2
Act. You don't want to go there. You're put in the 3
Commission in a bad place there. So, we've got to be 4
careful how that we do it.
5 And I say that with regard to, like the 6
AP1000, that was very, very low risk, as this 7
Committee is well aware. And so, we've got to be 8
careful about that and make sure it's truly plant-9 specific; it's one specific issue at a time, and not 10 something generic, where we're really kind of going in 11 the back door around rulemaking, for example.
12 MR. ZOULIS: Yes, and as far as Part 53, 13 again, the same issues would apply. I'm not sure how 14 you would be able to use RIPE in that area, but --
15 MEMBER DIMITRIJEVIC: It could be called 16 something else. I was just thinking the basic 17 principles, if you want to extend the review on the 18 risk significance, you know, that's -- especially when 19 we are having much safer plants applying. So, this 20 was my thinking, you know. Everybody's expecting that 21
-- yes, but I understand your limitation at this 22 moment, and they're different, and the ambitions are 23 different. But, in the long run, they can expand to 24 something much bigger, hopefully.
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86 So, my other question is, you have 1
actually modified Reg Guide 1.174. And Pete had a 2
question on that, and he was right. I mean, 3
currently, 1.174 allows you whatever delta CDF of 10 4
to the minus 6. Independently of your CDF, you can 5
use that for risk-informed applications, right? So, 6
you have introduced these measures which define low 7
safety significance. So, is there a plan to introduce 8
this in the Reg Guide 1.174 as an addition, or no?
9 And you don't plan to discuss that in the next level?
10 MR. ZOULIS: No.
11 MEMBER DIMITRIJEVIC: Okay. All right.
12 Thank you.
13 So, Members, any questions we have for our 14 panel maybe?
15 MEMBER KIRCHNER: I think we have a hand 16 up in the audience there.
17 MEMBER DIMITRIJEVIC: Okay.
18 MEMBER KIRCHNER: Mike Franovich.
19 MR. FRANOVICH: Yes. This is Mike 20 Franovich. I'm the Director of the Division of Risk 21 Assessment in NRR.
22 And if I could just take a moment to talk 23 about application or consideration in the new reactor 24 space, it's an intriguing question. And when I look 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 at Part 53, in particular, you'll see some common 1
elements of what in these core programs that we're 2
talking about. I call them the advanced risk 3
management programs, 425, 505, and 50.69. Central to 4
them is the IDP concept, which we've gone through 5
pretty thoroughly. But when you look over at the 6
Licensing Modernization Project, again, the IDP 7
concept shows up there as well, and the whole notion 8
of how you go through binning, whether a component or 9
SSC is safety-related or non-safety-related, it's a 10 derivative of 50.69.
11 There's a lot of cross-themes in these 12 areas that we should probably keep in mind when we 13 look into the Part 53 work. Is there something here 14 that we're doing today in the operating fleet that 15 could benefit there? For example, the Facility Safety 16 Program, which the staff has come back and spoken with 17 the ACRS, I was not involved directly with this. But 18 if there are elements of that program that bring in 19 these kinds of concepts for risk management into the 20 program, why should we limit ourselves? Why not think 21 about how that could benefit any future regulatory 22 oversight or exchange or licensing actions for a plant 23 that's operational under Part 53?
24 So, just wanted to share that perspective 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 with the Committee.
1 MR. REED: Yes, Mike, I was going to say 2
something similar. And I was going to say, if you're 3
really smart about the way you do it from the get-go 4
in terms of the requirements and the supporting 5
infrastructure, it's obviously very challenging to do 6
this, but you can avoid the circumstances where you 7
get, basically, the regulations and the supporting 8
infrastructure driving into the situation where you 9
have, clearly, a compliance with issues that are, 10 obviously, either minimal or even low safety-11 significant. So, hopefully, when we structure Part 12 53, we can at least mitigate that to some extent and 13 avoid this from the get-go.
14 MEMBER DIMITRIJEVIC: And to minimize the 15 need for exemptions, exactly what -- we are trying to 16 have a modern framework which would fit the new 17 designs.
18 MEMBER KIRCHNER: Yes, Vesna, this is 19 Walt.
20 Mike got to it before I could find my 21 unmute. But the Facility Safety Program as outlined 22 so far in 10 CFR 53 seems to have a lot in common with 23 this process that they've shared with us today.
24 MEMBER DIMITRIJEVIC: Right. Yes, and we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 could look at that from that perspective. Okay.
1 DR. SCHULTZ: Vesna, this is Steve 2
Schultz.
3 MEMBER DIMITRIJEVIC: Oh, okay. Hi, 4
Steve.
5 DR. SCHULTZ: I would just like to make a 6
comment or perhaps turn it into a question. But I'm 7
going back, Antonios, to your comment that management 8
in the Division at first said this could be problem 9
with the tight schedule and putting emphasis on that 10 tight schedule could, in fact, redirect our resources.
11 I think to get an appropriate balance in resources, 12 the communication and the coordination with industry 13 here is very important.
14 You can imagine, if 20 plants come in with 15 a RIPE submittal, that's going to take a lot of safety 16 resources out of the risk program. And it's much 17 better if industry can come in with what has been 18 described here by Roy as an approach that is fairly 19 simply determined, and then, plants and the staff 20 review can be simplified accordingly. I think that's 21 just very important in the application of the overall 22 process, as it moves forward, for it to be successful.
23 MR. ZOULIS: Yes. No, I agree, Steve. I 24 was going to mention I think doing some sort of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 streamlined review of the Topical Report, or some 1
other way of ripening this generic process, and then, 2
allowing licensees to use it, is something that we 3
should probably think about more. And I think, like 4
you said, it's beneficial.
5 And I didn't even think of that point.
6 You're absolutely right, you're actually diverting 7
resources now, when you get 30 of these or so many of 8
these in, and that's a great point you can think 9
about. So, no, thanks for that.
10 MR. REED: I'd also add, Antonios, we are 11 flexible. I mean, there can be circumstances, as you 12 know, where we can get RIPE to do something we 13 actually do need in a short period of time, and we 14 could do that. And maybe it's a critical path or 15 something. So, I mean, we are flexible. Obviously, 16 I think we're not saying one size fits all here. But, 17 as Roy mentioned, it's typically two years, and you're 18 going to come down -- it's going to be a shorter 19 review, no matter what, I think. But, in some cases, 20 we might want to go faster. But, like you said, if we 21 have a lot of these, and we're now reprioritizing the 22 staff's attention on those, well, we're generally 23 distracting the staff. So, we've got to be careful, 24 too.
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91 MEMBER HALNON: This is Greg Halnon. Just 1
a couple of questions, maybe for you, Tim.
2 If you could just address, just real 3
briefly, the training that you're giving to the DORL 4
staff and possibly even the inspectors; and also, the 5
coordination of the 50.59 effort? That was mentioned 6
early on, too.
7 MR. REED: Actually, our RIPE training, 8
Antonio, do you want to talk --
9 MR. ZOULIS: Well, we've done a lot of 10 outreach as part of this process, as you can imagine, 11 introducing it. We had a number of townhalls early on 12 with inspectors and licensing folks. Then, we had 13 follow-on townhalls with the Regions, and we're going 14 to plan for another one. I think Phil is probably in.
15 McKenna is going to present again to Region I.
16 We also did branch-specific interactions 17 in DORL with the different branches to kind of, again, 18 share the process, help them understand what we're 19 trying to do. And we also had interaction with the 20 technical branches to help them, again, understand 21 what we're trying to do here with RIPE.
22 As part of the 50.59 evaluation, I think 23 that's something we're thinking about talking maybe in 24 the future about, perhaps somehow, because I think 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 we've realized there could be ways you can use risk 1
insights for 50.59, but if you really want it to be 2
more risk-informed, you'll probably have to do 3
rulemaking in some fashion.
4 But, again, we're open. I think we're 5
going to talk about that. We have a planned meeting 6
with the Owners Group and others: what's the future 7
of risk-informed initiatives? And I think we might 8
touch on that aspect of it.
9 MR. REED: Yes. Okay. Yes, I was just 10 going to say, in terms of 50.59, Greg, you know, Phil 11 was part of the analysis; McKenna was part of the 12 analysis, and obviously, I was part of it. But we 13 were also both part of that 50.59 effort, in terms of 14 the putting the I&C together. So, we do have that 15 cross-fertilization.
16 And by the way, we did a lot of outreach, 17 and to Phil's credit, Phil did a lot of the work, and 18 I helped him a little bit, but really through the 19 Regions to get them familiar with it, and hopefully, 20 implementing that process. So, a lot of outreach 21 there.
22 But, to date, we haven't gotten one of 23 these RIPEs, but, also, when we get them, when the 24 rubber really hits the road, it will be interesting 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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93 to see and we can use those lessons and roll them 1
downstream to any training we would like, too.
2 MEMBER HALNON: Great. Thanks, Tim.
3 Thanks, Antonios.
4 MEMBER DIMITRIJEVIC: Okay. Any more 5
questions from the Committee?
6 (No response.)
7 Okay. Hearing none, should we see if 8
there are questions from the public?
9 CHAIRMAN SUNSERI: Yes, go ahead, Vesna.
10 So, Thomas, could you open the public line 11 for comments?
12 MR. DASHIELL: The public bridge line is 13 open for comments.
14 CHAIRMAN SUNSERI: Thank you.
15 MEMBER DIMITRIJEVIC: If anybody from the 16 public wishes to make a comment, please do.
17 (No response.)
18 All right. The 30-second rule, hearing 19 none, I would like to thank our presenters for the 20 wonderful presentation and interesting discussion, and 21 finishing everything on time. Perfect.
22 And so, we can adjourn now for lunch.
23 Thank you so much.
24 MR. ZOULIS: Thank you, Vesna, for the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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94 opportunity. We appreciate it. Thank you to the 1
Committee members as well and everyone. Thanks.
2 Thank you.
3 MEMBER KIRCHNER: Yes, thank you on behalf 4
of the Committee. It was a good presentation. I 5
think we learned a lot, and we look forward to seeing 6
more, as this continues to develop.
7 So, Members, we are at our lunch hour here 8
a little early. Anything before we break for lunch 9
from anybody?
10 (No response.)
11 So, what we'll do is we'll take a lunch 12 break here. At two o'clock, we will come back into 13 session. It will be open session, and we will 14 continue with review of our Bylaws. And an updated 15 copy was sent out to your emails yesterday and you 16 should have received that.
17 So, anyway, we are recessed until two 18 o'clock Eastern. Thank you.
19 (Whereupon, at 12:56 p.m., the foregoing 20 matter went off the record.)
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ACRS Full Committee Meeting Agenda Risk-Informed Process for Evaluations (RIPE)
June 2, 2021, 11:15AM to 01:00PM Time Topic Speaker 11:15am Welcome and Introduction NRC - 5 mins NRC Presentation on RIPE NRC - 40 mins Industry Presentation and/or comments Industry - 45 mins NRC and Industry Discussion NRC & Industry - 15 mins 1:00pm Adjourn Meeting
Tim Reed, NRR/DORL
3 A Map of the Universe of Findings High safety Low safety Clearly within the licensing basis Address issue with appropriate tools such as:
- Enforcement
- Order
- Inspect licensee corrective actions Clearly within the licensing basis Address finding/violation with appropriate tools (i.e., either the licensee comes into compliance or proposes changes to the licensing basis):
- Inspect licensee corrective actions (e.g., 50.59, PI&R)
- Change the licensing basis (LAR, relief, exemptions, etc.)
- Assess adequacy of the requirement (i.e., rulemaking)
Not clearlywithin the licensing basis Evaluate issue to determine regulatory actions with tools suchas:
- 50.54(f) or generic communication
- Backfitting
- Generic issue process
- Use LIC-504 and TIA as applicable Not clearly within the licensing basis but clearly low safety significance EXIT:
- Document decision
- Make public record Address issues in this quadrant
4 Risk-informed Process for Evaluations (RIPE)
- RIPE establishes a more efficient process to review licensing actions that address low safety significance (LSS) issues within the licensing basis.
- Adoption of RIPE was recommended in a memo to the NRR Office Director dated January 5, 2021 (ML20261H428).
- Enclosure 1 - Guidelines for Characterizing the Safety Impact of Issues (ML20261H462)
- Enclosure 2 - Temporary Staff Guidance TSG-DORL-2021-01 (ML20261H473)
- The NRR Office Director approved RIPE by memo dated January 7, 2021 (ML21006A324).
5 RIPE (Cont.)
- RIPE can be used to address low risk significant licensing actions using existing regulations under 10 Code of Federal Regulations (CFR) 50.12 or 50.90
- RIPE leverages current regulations and risk-informed initiatives to allow licensees to request plant-specific exemptions or license amendments for LSS issues using a streamlined NRC review process.
- Consistent with our RG 1.174 risk-informed integrated decision-making principles
6 What is RIPE?
Regulations Does not generically apply to regulatory issues and is not intended to displace rulemaking.
Does address unique plant non-compliance issues that would be specific to a narrow portion of the regulation for that licensee.
Evaluation Does not change how licensees make the determination concerning validity of licensing request.
Does inform the level-of-effort NRC staff will expend to conduct review and approval/denial of license requests.
Inspection/Enforcement Does not involve inspection and enforcement of findings and violations.
Does support how those violations and findings are corrected.
7 Leverage work done in previous risk-informed initiatives IDP PRA RIPE (using existing regulations)
Integrated Decision-making Panel (IDP) Reviews Key Engineering Principles Demonstrated Probabilistic Risk Assessment Acceptability
8 Implementation of RIPE Request via streamlined licensing process Review and Approval Define licensing issue Evaluate using IDP and assess plant-specific risk Identify risk management actions as necessary Assess cumulative risk
Licensee identifies a licensing issue that has a minimal safety impact Licensee documents the exemption or amendment request using Guidelines for Analyzing the Safety Impact of Issues (ML20261H462)
Licensee requests licensing action per streamlined review process 9
NRC reviews licensing action using streamlined review guidance in TSG-DORL-2021-01 (ML20261H473)
Approval Process Safety Impact Characterization Submittal to NRC Implementation of RIPE NRC Actions Licensee Actions
10 Initiative 4b - Risk Informed Completion Time Program R - Risk I - Informed C - Completion T - Times Existing TS Completion Time Frontstop Risk-Informed Completion Time (RICT) Limit Backstop Component Inoperable RICT Risk Management Actions Risk-Informed Completion Time (RICT)
Areas of Review for Initiative 4b (TSTF-505) LARs 11 Loss of Function
- Maintain the capability to perform all safety functions assumed in accident analysis PRA Modeling
- Confirm that the risk resulting from LCO inoperability can be numerically estimated PRA Technical Acceptability All Non-PRA Modeled Hazards are adequately justified (screened out or conservative bounding estimate)
Total CDF and LERF meet RG 1.174 acceptance guidelines Derivation of Risk Management Actions Configuration Risk Management Tool
- Benchmarking against the base PRA model
- Use of the tool
12 10 CFR 50.69 - Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors What does it allow the licensee to do?
- Allows reduction of many special treatment requirements for safety-related SSCs that are categorized as low safety significance. Conversely, requires additional controls for non-safety-related SSCs categorized as safety significant be evaluated to ensure they can perform their safety significant function(s)
- 10 CFR 50.69 does not replace the existing "safety-related" and "non-safety related" categories. Rather, 10 CFR 50.69 divides these categories into two subcategories based on high or low safety significance How does a licensee implement the program, once the SE is issued?
- Upon NRC review and approval of these processes, a licensee could then apply the categorization process to as many (or as few) systems as desired, provided that the entire system is considered
Integrated Decision-making Panel (IDP)
- Final decisions using PRA insights and non-PRA aspects
- Highly experienced plant personnel with combined expertise in: PRA, Safety Analysis, Operations, Design Engineering, System Engineering
- Guidance describes a well-defined and highly structured process
- Documentation requirements Robust Categorization Process 13 Periodic Review and Update PRA / Risk Analyses Internal Events Other External Events Seismic Pressure Boundary Failures Sensitivity Studies Fire Qualitative Questions Non-PRA Defense in Depth
14 Safety Impact Characterization Overview
15 Safety Impact Characterization Identify an issue that potentially has a minimal risk impact EP SECURITY Current phase will focus on Reactor Safety NRC-identified or licensee-identified
16 Safety Impact Characterization Define the issue Explore the issue in detail using a Generic Assessment Expert Team (GAET) and/or plant-specific integrated decision-making panel (Plant IDP)
Finalize responses to the screening questions Preliminary Screening Questions Does the issue:
- 1. Result in any impact on the frequency of occurrence of an accident initiator or result in a new accident initiator?
- 2. Result in any impact on the availability, reliability, or capability of SSCs or personnel relied upon to mitigate a transient, accident, or natural hazard?
- 3. Result in any impact on the consequences of an accident sequence?
- 4. Result in any impact on the capability of a fission product barrier?
- 5. Result in any impact on defense-in-depth capability or impact in safety margin?
17 Safety Impact Characterization Consider risk management actions Assess the cumulative risk Is the risk impact minimal?
Characterize the issue as having a minimal safety impact Characterize the issue as having a more than minimal safety impact All of the following must apply to characterize an issue as having a minimal safety impact:
- CDF less than 1 x 10-7 / year.
- LERF less than 1 x 10-8 / year.
- The issue screens to no impact or minimal impact using the screening questions.
- Cumulative risk is acceptable.
18 Example Submittal REGULATORY REQUEST DETAILED DESCRIPTION OF THE REGULATORY ISSUE REFERENCES SUPPORTING INFORMATION FOR CONCLUSIONS REGARDING SAFETY IMPACT:
- If a generic assessment was performed, provide the generic preliminary screening question results, including explanations
- Steps 1 and 2: Site-specific screening question results, including explanations STEP 3 - PRA RESULTS AND ASSOCIATED DISCUSSIONS, INCLUDING SENSITIVITY ANALYSES STEP 4 - ASSESS NEED FOR RISK MANAGEMENT ACTIONS CUMULATIVE RISK RESULTS SAFETY IMPACT CHARACTERIZATION CONCLUSION SIGNIFICANT HAZARDS CONSIDERATIONS ENVIRONMENTAL CONSIDERATIONS
19 Streamlined NRC Review Process T < 13 Weeks DORL Issues Exemption to Licensee T < 11 Weeks OGC NLO to DORL T < 9 Weeks DORL SE to OGC T < 7 Weeks SE Input to DORL T < 3 Weeks Acceptance Review Issued T=0 Licensee Submits RIPE Exemption T < 20 Weeks DORL Issues LAR to Licensee T < 17 weeks OGC NLO to DORL T < 15 Weeks DORL SE to OGC T < 10 Weeks SE Input to DORL T < 6 Weeks DORL PM Submits Bi-Weekly FRN T < 3 Weeks Acceptance Review Issued T=0 Licensee Submits RIPE LAR Emphasis is on using resources commensurate with safety significance, not duration
20 Why RIPE?
- Focus NRC and licensee resources on the most safety significant issues
- Address low safety significance compliance issues in an efficient and predictable manner consistent with our Principles of Good Regulation
- Leverage existing regulations and risk insights
- Incentivize the further development and use of probabilistic risk assessment models and applications
21 Whats Next?
- Continue to explore expansion of RIPE to include:
- Exemption and amendment requests from licensees that do not have an approved TSTF-505 (Risk-Informed Completion Times) amendment, but have an approved TSTF-425 (Surveillance Frequency Control) amendment or can provide other forms of risk information.
- Exemption and amendment requests in other areas (EP, Security, etc)
- Continue outreach to interested parties
22 Questions?
Send additional feedback or questions to:
Antonios.Zoulis@nrc.gov Timothy.Reed@nrc.gov
Global Expertise
- One Voice Expanding RIPE Concept to Deal with Generic Issues ACRS Meeting June 2, 2021 Westinghouse Non-Proprietary
- Current Risk Informed Process for Evaluations (RIPE) is a significant step forward in risk informed decision making
- Focus industry and NRC resources on safety significant issues
- Expansion of current process supports further reduction of resources on low risk significant issues Introduction
- Leverage RIPE concept of expedited review for low-risk significance
- Maximized applicability to generic evaluations
- Using bounding risk calculations for demonstrably low safety significant issues to support expedited NRC review and focus effort.
- MSLB asymmetric cooling issue (dose timeline)
- Looking for additional suitable examples
- PRA technical adequacy for some issues can be addressed via bounding assumptions and assessed via GAET (Generic Assessment Expert Team) and confirmed for plant specific applicability Expanding RIPE Concept to Deal with Generic Issues
- Asymmetric Natural Cooldown
- For low risk conditions, current cooldown practices may challenge offsite dose limits using current methodology/assumptions
- Specific conditions
- Main Steamline Break (MSLB), faulted Steam Generator (SG), cooldown with 1 SG isolated
- Offsite doses can be challenged if concurrent conditions occur (Design Basis)
- EOP changes needed to address the condition focus on rapidly cooling down the plant to limit the calculated doses (success path)
- More rapid cooldown imposes additional operator challenges
- Increase error potential (more complicated cooldown strategies, including RCS opening) increase frequency of failure path.
- Non risk significant scenario Example of Low Safety Significance Issue
- Boundary Conditions
- Faulted/un-isolated SG
- Concurrent Loss of Offsite Power
- Maximum allowable fuel leakage
- Maximum allowable primary to secondary leakage
- Assumptions
- Faulted SG/un-isolated SG with concurrent loss of offsite power = core damage
- Conservative
- Plant can be safe/stable with normal cooldown
- Rapid asymmetrical cooldown limits total offsite dose Specific Conditions for Generic Risk Calculation
- Generic Initiating Events (i.e., entry condition) frequency
- Fuel damage not allowed by the event
- Bounding Single Failure
- Fuel Leakage history
- Primary to secondary leakage history
- Conservatism in offsite dose analysis
- Plant-specific applicability Generic assessment and Evaluation Team (IDP/GAET) Considerations
- Some issues of generic very low safety significance
- Use generic bounding analysis (e.g., topical report) to determine safety significance
- Streamlined NRC review of topical report
- Submittal process (topical)
- Risk-informed review of a topical report
- Implement via 50.59 Or
- Alternatively enabling simplified plant-specific submittal Potential RIPE Enhancement
Questions?
©2021 Nuclear Energy Institute Industry Progress on Risk Informed Process for Evaluations Victoria Anderson, NEI June 2, 2021
©2021 Nuclear Energy Institute 2 General industry perspective on the Risk Informed Process for Evaluations (RIPE)
Industry efforts on RIPE implementation First movers Expansion of scope Industry document development Next steps Overview
©2021 Nuclear Energy Institute 3 Industry appreciates innovative concept from NRC Potential to leverage existing analysis and PRA infrastructure to streamline decision making Offers licensees an option for more rapid resolution of emerging issues if existing analysis supports RIPE approach Prime example of progress on modern, risk-informed regulation Use of output from Integrated Decision Making Panel and reliance on previously NRC-reviewed analysis supports streamlined review and eliminates duplication of efforts Traditional risk-informed exemptions and license amendments will still continue as RIPE is not suitable for all issues Perspective on RIPE
©2021 Nuclear Energy Institute 4 RIPE available to licensees with approved TSTF-505 programs since late 2020 NEI regularly discussing possible RIPE uses with licensees who have approved TSTF-505 programs Several potential uses identified to date All cases involved resolution via other means Continuing to discuss possibilities regularly Expansion to additional licensees will result in more opportunities for use RIPE using TSTF-425 approval as basis for PRA technical acceptability accomplishes this Available since late April 2021 Industry efforts - First Movers
©2021 Nuclear Energy Institute 5 Adoption of TSTF-425 and TSTF-505 Over Time 0
10 20 30 40 50 60 70 80 90 100 2020 2021 2022 2023 2024
% of Units Year TSTF-425 Approved TSTF-505 + 50.69 Approved
©2021 Nuclear Energy Institute 6 Comparison of PRA Technical Acceptability by Program Internal Events PRA Internal Fire PRA External Hazards PRA RIPE Capability Category I (Screening)
Qualitative of N/A Qualitative of 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
©2021 Nuclear Energy Institute 7 Issued NEI 21-01, Industry Guidance to Support Implementation of NRCs Risk Informed Process for Evaluations, in April 2021 Documents Integrated Decision Making Panel process and expectations Describes necessary PRA technical adequacy documentation for submittals Template for RIPE submittals included as appendix to NEI 06-02, License Amendment Request Submittals Continuing to interface with NRC staff to ensure adequate support for RIPE Industry Document Development and Support
©2021 Nuclear Energy Institute 8 NRC update to Temporary Staff Guidance Continue to integrate feedback into guidance and templates Lead licensee uses of RIPE Next Steps