ML22136A255

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Summary of April 21, 2022, Public Meeting with Pressurized Water Reactor Owners Group, and Industry to Discuss Owner Group'S Generic Risk Informed Process for Evaluations
ML22136A255
Person / Time
Issue date: 05/27/2022
From: Siva Lingam
NRC/NRR/DORL/LPL4
To: Antonios Zoulis
NRC/NRR/DRA/APOB
Lingam S, NRR/DORL/LPL4
Shared Package
ML22136A252 List:
References
EPID L-2022-PMP-0004
Download: ML22136A255 (6)


Text

May 27, 2022 MEMORANDUM TO: Antonios M. Zoulis, Chief PRA Oversight Branch Division of Risk Assessment Office of Nuclear Reactor Regulation FROM: Siva P. Lingam, Project Manager /RA/

Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF APRIL 21, 2022, PUBLIC MEETING WITH PRESSURIZED WATER REACTOR OWNERS GROUP, AND INDUSTRY TO DISCUSS THE APPLICABILITY OF GENERIC ISSUES UNDER RISK-INFORMED PROCESS FOR EVALUATIONS (EPID L-2022-PMP-0004)

On April 21, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff held an Observation public meeting with the Pressurized Water Reactor Owners Group (PWROG) and Industry representatives to discuss the generic applicability of the risk-informed process for evaluations (RIPE-G) being developed by the PWROG. The meeting notice and agenda, dated April 7, 2022, are available in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML22097A248. A list of attendees is provided in the enclosure.

The slides presented for this public meeting by the PWROG are available in ADAMS under Accession No. ML22110A024. PWROG presented the following topics:

Revision of the current NRC plant-specific RIPE process for resolution of generic issues.

Application of RIPE-G for topical reports (TRs).

Introduction of the Generic Assessment Evaluation Team (GAET) in place of the plant-specific Integrated Decision-Making Panel (IDP).

PWROG mentioned that the GAET team will consist of experts from plant operations, probabilistic risk assessment (PRA), engineering, licensing, safety analysis, and any other experts as needed. The GAET will evaluate and confirm the generic applicability of issues for RIPE-G.

The NRC staff expressed the following concerns/comments:

The NRC streamlined process for RIPE (ADAMS Accession No. ML22088A135), which is very different from the RIPE-G concept, leverages the existing risk framework such as prior NRC-approval of Technical Specifications Task Force (TSTF) Traveler TSTF-505, Provide Risk Informed Extended Completion Times - RITSTF [Risk-Informed TSTF]

A. Zoulis Initiative 4b1 or TSTF-425 Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative 5b, and an established IDP by having an approved and implemented Title 10 of the Code of Federal Regulations (10 CFR) Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power plants, as described in the Office of Nuclear Reactor Regulation Temporary Staff Guidance (TSG)-DORL-2021-01, Revision 1, Risk-Informed Process for Evaluations (ML21180A013), which gives confidence for NRC staff in the licensees existing PRA quality. RIPE-G seems to be leveraging mainly the GAET, which is a newly introduced concept. The NRC staff was not clear about the PWROGs intent on whether it was seeking NRCs approval/endorsement of a new framework and/or how this would be represented in a TR.

Requirements for an IDP are currently described in 10 CFR 50.69 and Nuclear Energy Institute (NEI) guidance, NEI Guidelines for the Implementation of the Risk-Informed Process for Evaluations Integrated Decision-Making Panel (ML20245E147). Will there be a published document outlining similar information for the GAET?

The RIPE-G process should be clearly defined to determine what types of documents (TRs, regulatory guides, White Papers, etc.) for NRC review apply to RIPE-G and which ones do not.

Expected use of qualitative risk versus items that are clearly within PRA (i.e.,

quantitative numbers for core damage frequency and large early release frequency).

What types of TRs might be going through RIPE-G and how would they be used by a licensee in a licensing action request?

PWROG should recognize that if the PWROG is expecting that the NRC staff would be conducting an expedited review of a proposed generic TR, the technical information described in the generic TR should not include new design or design evaluation methodologies that were not previously reviewed by the staff. Implementation of new design or design evaluation methodologies would require a normal topical report staff review process and schedule.

For the pilot TR being discussed in the GAET Asymmetric Natural Circulation Cooldown Dose Consequences for Main Steam Line Break Outside Containment, the assumptions of bounding reactor coolant system activity and primary to secondary leakage for the main steam line break accident should be provided in the TR, and be specified in the limitations and conditions.

1 NRC has approved some licensee programs for risk-informed initiatives consistent with NEI 06-09, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS)

Guidelines and NEI 04-10, Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies, which can be used in lieu of TSTF-505 or TSTF-425, respectively, for RIPE. Any references in this TSG to TSTF-505 and TSTF-425 also include NEI 06-09 and NEI 04-10, respectively.

A. Zoulis No comments were provided by members of the public. No regulatory decisions or commitments were made at the meeting.

Please direct any inquiries to me at (301) 415-1564 or by email at Siva.Lingam@nrc.gov.

Enclosure:

List of Attendees

LIST OF ATTENDEES APRIL 21, 2022, PUBLIC MEETING WITH PRESSURIZED WATER REACTOR OWNERS GROUP AND INDUSTRY TO DISCUSS OWNERS GROUPS GENERIC RISK-INFORMED PROCESS FOR EVALUATIONS Steve Bloom NRC1 Kristy Bucholtz NRC Angie Buford NRC Kevin Coyne NRC Jennifer Dixon-Herrity NRC Leslie Fields NRC John Hughey NRC Meena Khanna NRC Michelle Kichline NRC Chris Kreuzberger NRC Chang Li NRC Siva Lingam NRC Gurcharan Matharu NRC Philip McKenna NRC Caty Nolan NRC William Orders NRC Ben Parks NRC Charles Peabody NRC Bo Pham NRC David Rahn NRC Richard Stattel NRC Gregory Suber NRC Keith Tetter NRC Antonios Zoulis NRC Jim Andrachek PWROG2 Jana Bergman PWROG James Boatright PWROG (WEC3/Luminant)

Rob Burg PWROG Steve Catron PWROG Connor Medlen PWROG Matthew Cox PWROG (APS4) 1 U.S. Nuclear Regulatory Commission (NRC) 2 Pressurized Water Reactor Owners Group (PWROG) 3 Westinghouse Electric Company LLC (WEC) 4 Arizona Public Service Company (APS Enclosure

David Alford PWROG David Koenigsfeld PWROG Michael DiLorenzo PWROG (APS)

Bradley Dolan PWROG (TVA5)

Nathan Hall PWROG (STP6)

Melinda Higby PWROG (WEC)

Chad Holderbaum PWROG Andrew Howe PWROG (WEC)

Reed Labarge PWROG (WEC)

Andrea Maioli PWROG (WEC)

Jennifer Meneely PWROG Damian Mirizio PWROG Brian Mount PWROG Sara Scott PWROG Svetlana Lawrence PWROG Brett Titus NEI7 Phil Couture Entergy8 Ron Gaston Entergy Avil Julka NextEra Note: Couple of people from the Industry also attended (not able to capture the names by phone numbers in the Microsoft Teams).

5 Tennessee Valley Authority (TVA) 6 South Texas Project, (STP) 7 Nuclear Energy Institute, (NEI) 8 Entergy Operations, Inc. (Entergy)

Package: ML22136A252 Meeting Notice: ML22097A248 Meeting Slides: ML22110A024 Meeting Summary: ML22136A255 *by email OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DEX/EICB*

NAME SLingam PBlechman MWaters DATE 4/27/2022 5/17/2022 5/19/2022 OFFICE NRR/DNRL/NCSG/BC* NRR/DRA/APOB/BC* NRR/DSS/SCPB/BC*

NAME SBloom AZoulis BWittick (HWagage for)

DATE 5/19/2022 5/16/2022 5/16/2022 OFFICE NRR/DSS/SNSB/BC* NRR/DSS/SFNB/BC* NRR/DORL/LLPB/BC*

NAME SKrepel RLukes RChang DATE 5/19/2022 5/19/2022 5/17/2022 OFFICE NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*

NAME JDixon-Herrity (WOrders for) SLingam DATE 5/27/2022 5/27/2022