ML21312A554

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Presentation Slides for the November 10, 2021, Nuclear Energy Institute Regulatory Issues Task Force Public Meeting
ML21312A554
Person / Time
Site: 99902028
Issue date: 11/10/2021
From:
Nuclear Energy Institute
To:
Licensing Processes Branch
Lenning E, NRR/DORL/LLPB, 415-3151
References
Download: ML21312A554 (47)
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Text

Public Meeting with the Nuclear Energy Institute Regulatory Issues Task Force November 10, 2021

AGENDA Time Topic Speaker 9:00 am -9:10 am Introductions/Opening Remarks NRC, NEI 9:10 am - 9:50 am Licensing actions/review of metrics:

COVID-19 exemptions/licensing action support Update on licensing metrics and actions Update on the NRCs workload management tools and prediction capabilities NRC 9:50 am - 10:00 am Update on SRP Modernization Effort NRC 10:00 am - 10:15 am Feedback on the use of FLEX in licensing submittals NRC, NEI 10:15 am - 10:45 am Update on RIPE and discussion on exclusions NRC, NEI 10:45 am - 11:00 am Lessons learned from implementation of the VLSSIR process NRC, NEI 11:00 am - 11:15 am Break 11:15 am - 11:30 am Best practices for communicating with the NRC during potential NOED/Emergency Amendment situations NRC, NEI 11:30 am - 11:45 am Early feedback for 2022 RIC and other regulatory interactions NRC, NEI 11:45 am - 11:55 am Opportunity for public comments Members of the Public 11:55 am - 12:00 pm Closing remarks NRC, NEI 12:00 pm Adjourn 2

Introductions

and Opening Remarks Mike King Deputy Office Director for Reactor Programs Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Brett Titus Technical Advisor Nuclear Energy Institute 3

Licensing Actions/Review of Metrics:

COVID-19 Exemptions/Licensing Action Support Update on Licensing Metrics and Actions 4

Update on the NRCs Workload Management Tools and Prediction Capabilities

Caroline Carusone, Deputy Director Ed Miller, Project Manager Doug Broaddus, Sr. Project Manager Annie Mayer, Technical Assistant Division of Operating Reactor Licensing, NRR Modernizing Our Licensing Program 5

Data intake architecture and access Data visualization to track performance and understand resource impacts Trends analysis to predict and plan for the future Expanding Use of Data and Business Tools 6

v Early Returns on Data Modernization Efforts Intake: Web-Based Relief Request Portal Performance: Integrated Workload Management Tools Prediction: Licensing Action Precedent Analysis WRR 7

v Significant COVID-19 Related Activities and Accomplishments Collective Contributions Across the Agency Enabled Mission Success Opportunities for public and industry engagement were effective Continued Prompt Actions in Response to COVID-19 Public Health Emergency (PHE) 8

v COVID-19: Next Steps Licensing Needs More Normalized (Case-by-Case Submittals)

Licensees should maintain continued vigilance for upcoming licensing needs Continue Engagement on Potential Regulatory Requirements that may Pose Challenges 9

v Integrated Approach to Support the Licensing Workload Performance Measures and OKRs Expanded Analytics Tools Integrated Workload Management 10

v Continued Performance Gains in FY 2021 WRR 0

200 400 600 800 1000 1200 0

200 400 600 800 1000 1200 1

2 3

4 Average Duration (Days)

No. of Completions Series2 Series3 Series1 Series5 Series4 11

v WRR

  • NEIMA Generic Milestone Schedule (GMS) Goal: 100%

Completed w/in the GMS (2-years for most actions)

  • 100% for FY 2021
  • 2 Year Timeliness Goal: 100% of Licensing Actions (LA) and Other Licensing Tasks (OLT) Completed w/in 2 years
  • 100% for LAs, 97% for OLTs in FY2021
  • All Steam Generator Tube Inspection Reports Are Up-To-Date Agency Level Measures
  • 1-Year Timeliness - 90% of LAs & OLTs Completed in 1 year
  • 97% for FY 2021 (Combined LA & OLT)
  • 90% of licensing actions completed have actual hours within 125% of the estimated hours communicated to the applicant
  • 97% for FY 2021
  • >99% for FY 2021 Office Level Measures 12

v New Agency Level Performance Measures Applicable in Fiscal Year 2022 WRR 13

Tools for Tracking Performance and Refining Estimates 14

Operating Reactor Licensing Resource Estimator Tool Coming Soon to the NRC Public Website 15

Operating Reactors Licensing -

Resource Estimate Tool What is the Resource Estimate Tool?

Our resource estimates below are based on the whole dataset of completed licensing actions from 2018 - 2021. From analysis of this dataset, we have resource estimates based on current data, and we can see trends and outliers that inform engagement efforts with the NRC staff and the industry to have a common understanding of best practices and expectations.

Resource Estimates by Generic Licensing Action Category Resource Estimates for Types of License Amendment Requests Resource Estimates for Types of Relief Requests Resource Estimates for COVID-19 Related Licensing Actions Resource Estimates by Generic Licensing Action Category Our resource estimates.

Near Term Current State Future Capability 16

  • All estimates are +/- 25% from median, Data 2018-2021. COVID-19 related licensing actions are included in a separate category and excluded from averages.
    • Not all estimates to scale in this mock-up.

Generic Licensing Action Estimates (interactive - click through and return)

  • Amendments
  • Exemptions
  • Program Change Reviews (e.g., QA)
  • Relief Requests
  • License Transfers 50 HOURS 500 HOURS 1500 HOURS
  • COVID-19 Related Licensing Actions 10-35 17

License Amendments

  • Adoption of 50.69 - Risk-Informed Categorization Of SSCs
  • TSTF-425 - Surveillance Freq Control Program
  • Reviews under the Consolidated Line-Item Improvement Program (CLIIP) 1400-2000 360-560 500-800 80-130 120-200 50-100
  • One-Time TS Changes (may not be whole population - keyword search)
  • Exigent Amendments (may not be whole population - keyword search) 100-200 200-335 2000 HOURS 18

Relief Requests

  • Inservice Inspection
  • Inservice Testing
  • Relief Requests
  • ISI Impracticality 50 HOURS 150 HOURS 300 HOURS
  • Code Case N-513 Temp Acceptance of Flaws in Moderate Energy Piping 50-150 35-75 60-105 45-120 100-200 50-100 19

COVID-19 Related Actions

  • Temporary exemptions during the COVID-19 pandemic are part of a framework that includes standardized templates, roll-up Federal Register Notices, licensee compensatory actions, etc.
  • License Amendments
  • Exemptions
  • Relief Requests
  • QA Plan Change
  • Overall Average 20 HOURS 100 HOURS 200 HOURS70-250 10-25 30-70 50-80 10-35 20

MEDIUM VARIES WITH QUALITY HIGH MEDIUM LOW VARIES WITH QUALITY HIGH HIGH DURATION HOURS Application complexity Application Quality First-of-its-Kind Submittal KEY INFLUENCING FACTORS*

Plant-specific deviations Referencing Unapproved TRs PRA Quality MEDIUM LOW MEDIUM-HIGH MEDIUM-HIGH

  • Not all possible impacts to review schedule or resources are included. Other factors include prioritization, fleet vs single submittal, licensee need date, responsiveness to RAIs, etc. Examples of positive influencing factors not shown here but will be included: CLIIP reviews, high quality PRA, referencing approved topical reports (TRs) 21

Questions 22

Jason Paige Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Update on Standard Review Plan Modernization Effort 23

Refresher: SRPMod Purpose Focus on Whats Important to Safety Guidance focused on requirements Clear, Concise Guidance for Completing Reviews Clarity on application details Improve Quality of NRC Review Products RAIs Safety Evaluations Consistency on Using Risk-Insights and Engineering Judgement Capture Best Practices SRP Issue vs. Training Issue Not every section will need extensive revising 24

Refresher: SRPMod Objectives Emphasize Emphasize Expectations for Reasonable Assurance of Adequate Protection Rebranding Introduction to General Review Principles General Review Principles will provide guidance on completing reviews Focus Focus on Regulatory Requirements Reformatting sections Align specific acceptance criteria and findings to the applicable requirements Remove extraneous information Incorporate ISGs, BTPs information Empower Empower the Staff to Consistently Use Risk-Insights and Engineering Judgment Reference PRA Policy Statement and SRM-SECY-17-0112 Integrate risk guidance: LIC-206 and Be riskSMART Reference AEA on the use of engineering judgement 25

Under Review

  • Currently 72 SRP Sections Being Modernized Chapters Represented: 2, 3, 4, 5, 6, 8, 9, 10, 15, & 16
  • PNNL Supporting Staff with Modernizing SRP Chapter 16 Identified based on PNNLs familiarity with the chapter PNNL will capture lessons-learned on the SRPMod process
  • Submitting Draft Modernized SRP Sections in Batches for OMB Review OMBs major rule determination under Congressional Review Act (CRA)

A batch will include ~10-20 SRP sections per CRA summary First batch to be submitted approximately in December 2021 26

Whats Next?

Next Steps:

  • Submit 1st Batch of SRP Sections for OMBs Major Rule Determination 1st batch submitted: ~December 2021 Sections 2.4.2, 3.3.1, 3.4.1, 3.5.1.4, 5.4.6, 6.2.2, 6.2.4, 6.2.6, 6.4, 9.1.2, 9.2.1, 9.2.2, 9.4.1, 10.2, 10.4.1, & 16.0
  • Pilot Modernized SRP Sections Issue sections for use and public comment after OMBs review 27

Mihaela Biro Division of Risk Assessment Office of Nuclear Reactor Regulation Feedback on the Use of FLEX in Licensing Submittals 28

Can FLEX Credit in PRA Impact Regulatory Decision?

RG 1.174 & RG 1.200: staff reviews PRA key assumptions Failure data and some operator actions are potential areas of uncertainty for FLEX credit in PRA Operating Data Human Reliability Assessment Plant Specific Implementation Application Type 29

Treatment of FLEX Credit in Risk-informed License Amendment Requests (LARS)

  • NRC memo dated May 30, 2017, (ML17031A269), documented staff concerns on FLEX credit in PRA
  • Most risk-informed LARs take credit for FLEX
  • Variety of meetings with industry
  • Revised NEI guidance Overarching statement on FLEX credit Permanently installed equipment Portable equipment Data sources and updates Human actions Revised NEI Guidance 30

Observations/Next Steps Adherence to NEI guidance on LAR information on FLEX credit continues to be mixed Staff will continue to gather and review information on FLEX using audits and requests for additional information:

  • 7 applications for 50.69 are under review Staff is developing a revision to the NRC memo dated May 30, 2017. Revision will incorporate new developments:
  • PWROG report on equipment reliability

Antonios Zoulis Division of Risk Assessment Office of Nuclear Reactor Regulation Update on Risk-informed Process for Evaluations (RIPE) and Discussion on Exclusions 32

33

RIPE Exclusions EP SECURITY Current phase will focus on Reactor Safety NRC-identified or licensee-identified Technical Specifications Emergent Repairs 34

35 Whats Next?

  • First RIPE submittal expected from Palo Verde in FY22

- Partial Exemption from 10CFR50.62(c)(1) (ATWS rule) to remove diverse auxiliary feedwater actuation system (DAFAS)

- Pre-submittal meeting held on September 1, 2021

- Integrated Decision-Making Panel in late September 2021

  • Evaluate lessons-learned from initial submittals
  • Expand RIPE to allow Technical Specifications changes
  • Continue working with PWROG on RIPE-G generic process

- Conducted public meeting October 14, 2021

  • Any other applications?

36 Questions?

Send additional feedback or questions to:

Antonios.Zoulis@nrc.gov

Alex Garmoe Division of Reactor Oversight Office of Nuclear Reactor Regulation Lessons Learned from Implementation of the Very Low Safety Significance Issue Resolution (VLSSIR) Process 37

VLSSIR Status Process implemented in January 2020 via revisions to IMC 0612 Appendix B and IMC 0611 Filled a narrow gap in risk-informed treatment of inspection issues (those items for which the licensing basis application is not clear and not easily determined)

Effectiveness review completed in March 2021 found that VLSSIR meets intended objectives Seven issues closed to VLSSIR in 2020 and three to the date in 2021 Program office continuing to oversee efficient, effective, and appropriate use of VLSSIR process 38

VLSSIR Items Closed in 2021 McGuire Capability of Diesel Building Ventilation System to Withstand the Effects of a Tornado Hatch Capability of Diesel Building Ventilation System to Withstand the Effects of a Tornado Palo Verde Change to Emergency Plan in 1994 Relative to Emergency Response Organization (ERO) Augmentation Timelines 39

Lessons-learned from VLSSIR Implementation Helped focus resources on issues that are clearly within the licensing basis Helped reduce the backlog of open and long-standing unresolved items Positive addition to the inspection issue screening process Important for VLSSIR point of contact to continue monitoring process for efficient, effective, and appropriate use 40

Break 41

Best Practices for Communicating with the NRC During Potential NOED/Emergency Amendment Situations 42

Milton Valentin Division of Risk Assessment Office of Nuclear Reactor Regulation Early Feedback for 2022 Regulatory Information Conference and other Regulatory Interactions 43

  • The 2022 RIC will have both in-person and virtual components
  • The in-person component will follow all applicable safety guidelines
  • Tuesday, March the 8th and Wednesday, March the 9th from 8:30 am to 4:30 pm (ET), and Thursday, March the 10th from 8:30 am to 12:00 pm (ET)
  • 5-7 plenary sessions, 30 technical sessions, 16 digital exhibits
  • Conference agenda and technical program currently being finalized 44

Opportunity for Public Comments 45

Closing Remarks Mike King Deputy Office Director for Reactor Programs Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Brett Titus Technical Advisor Nuclear Energy Institute 46

AEA Atomic Energy Act of 1954 ATWS Anticipated Transient Without Scram BTP Branch Technical Position CFR Code of Federal Regulations EP Emergency Preparedness EPRI Electric Power Research Institute FLEX Diverse and Flexible Coping Strategies HRA Human Reliability Analysis ISG Interim Staff Guidance LAR License Amendment Request NEI Nuclear Energy Institute NEIMA Nuclear Energy Innovation and Modernization Act NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation NOED Notice of Enforcement Discretion OKRs Outcomes and Key Results OMB Office of Management and Budget PRA Probabilistic Risk Assessment PWROG Pressurized-Water Reactor Owners Group RAIs Requests for Additional Information RIC Regulatory Information Conference SRP NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants TSTF Technical Specifications Task Force 47 Acronyms

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