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