ML23331A966

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November 28, 2023, Public Meeting with the Nuclear Energy Institute (NEI) Regulatory Issues Task Force - Presentation Slides
ML23331A966
Person / Time
Issue date: 11/28/2023
From: Leslie Fields
Licensing Processes Branch
To: Gerond George
Licensing Processes Branch
References
Download: ML23331A966 (70)


Text

PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI)

R E G U L AT O R Y I S S U E S TA S K F O R C E November 28, 2023

Time Topic Speaker Bo Pham (NRC, Director, Division of Operating Reactor Licensing) 1:00 pm Introductions/Opening Remarks Brett Titus (NEI, Director of Licensing) 1:10 pm Power Uprates William Orders (Division of Operating Reactor Licensing)

Innovation/EMBARK Venture Studios Laura Smith (EMBARK) 1:25 pm

AGENDA 1:50 pm Differing Views Program Gladys Figueroa-Toledo (Office of Enforcement) 2:10 pm Enhanced Weapons Rule Bo Pham (NRC) 2:30 pm Break 2:45 pm Generic Communications Lisa Regner (Division of Reactor Oversight)

Process for Ongoing Assessment of Natural Hazard Information 3:00 pm

  • Seismic Ed Miller (Division of Operating Reactor Licensing)
  • Program Update (Other Natural Hazards) Kevin Quinlan (Division of Engineering and External Hazards) 3:10 pm Regulatory Guide 1.183 Rev 1 Update Kevin Hsueh (Division of Risk Assessment) 3:15 pm Risk Informed Process for Evaluations Michele Kichline (Division of Risk Assessment) 3:25 pm Open Discussion - Standing Topics Bo Pham (NRC), Brett Titus (NEI)
  • Forthcoming Process Changes
  • Staffing, Budgeting, and Resources
  • Reports on Timeliness Metrics, RAIs
  • Trends/ Patterns/ Best Practices
  • Knowledge Management 4:15 pm Opportunity for Public Comments 4:25 pm Closing Remarks NRC 4:30 pm Adjourn November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 2

Bo Pham Director, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission OPENING REMARKS Brett Titus Director, Licensing Nuclear Energy Institute November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 3

Readiness to License US NUCLEAR REGULATORY COMMISSION Power Uprates William Orders Senior Project Manager, NRR/DORL November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 4

TYPES OF POWER UPRATES November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 5 5

ACTIVELY MONITORING THE LANDSCAPE

  • >50% of sites are planning for one or more power uprates with a combined capacity equivalent to 2 large Light Water Reactors (LWRs).

Photo Credit: Nuclear Energy Institute (NEI) The Future of Nuclear Power 2023 Baseline Survey Note: Unspecified Power Uprates in the 1% to 3% range are identified as Other on this graphic.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 6

USING POWER UPRATE HISTORICAL DATA TO OPTIMIZE OUR FUTURE PROCESSES Level of Effort for Power Uprates 14000 12000 10000 8000 6000 4000 2000 0

Jan-1993 Jul-1998 Jan-2004 Jul-2009 Dec-2014 Jun-2020 Stretch Power Uprate Measurement Uncertainty Recapture Extended Power Uprare November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 7

NEXT STEPS

  • Revise LIC-112, power uprate process Use NRC lessons learned and industry feedback to streamline/update the staff guidance November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 8

MAP-X Update US NUCLEAR REGULATORY COMMISSION Laura Smith Product Owner, NRR/EMBARK Melissa Walker Director, NRR/EMBARK November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 9

EMBARK Change organization housed within the Office of Nuclear Reactor Regulation (NRR)

Facilitating innovation and data improvements across the agency Strong partnership with program data owners and users and the Office of the Chief Information Officer (OCIO)

MAP-X A user-authenticated web portal that improves the way that the agency can exchange data and information with licensees and approved stakeholders.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 10

MAP-X STATUS

  • Active MAP-X Modules Web-Based Relief Requests Event Notification (Form 361)

Licensee Event Reports (Form 366) (late November)

General Submission (Similar to the EIE General Form) (late November)

  • Proposed MAP-X Modules Fitness for Duty Operator Licensing November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 11

MAP-X BENEFITS External Users NRC

  • Individual access from anywhere - not tied to a
  • Receives information as structured data rather than specific computer/physical location narrative text or attachments (as applicable)
  • Due to user credentialling and authentication, portal
  • Can support streamlining and monitoring incoming access and submission viewing is secure - can share data processes sensitive or curated information
  • Routing and availability of information within the NRC
  • Email record/proof of submission is enhanced
  • Form field validation / auto-populated fields
  • View previous submissions November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 12

BUILDING A SMARTER WEB FORM

  • Drop down lists
  • Required fields
  • Validation of data field formatting (dates, phone numbers)
  • Conditional input fields
  • Auto population of fields based on user information
  • Ability to expand/minimize parts of forms November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 13

RECENT MAP-X PROGRESS

  • Licensee Event Report Availability
  • General Submission Modules Availability
  • Optimization of MAP-X Portal performance
  • Establishment of NRC-Licensee focus groups November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 1414

PROPOSED MAP-X UPGRADES

  • Continued MAP-X User Experience Improvements Status updates of submitted requests Interfaces with Requests for Additional Information (RAIs)
  • More reporting/interactive functionality within the application for NRC users
  • Continue to explore possible future MAP-X modules November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 15

ADVICE FOR MAP-X USERS

  • If you may have a near-term use for MAP-X, sign up for a user account today!
  • Informing your NRC project manager that you want to use MAP-X will help ensure the process goes smoothly; you can also contact MAP-X.resource@nrc.gov with any issues or questions
  • Once you are credentialled, login to the portal https://mapx.nrc-gateway.gov/ to become familiar with the application, your roles/permissions, and the forms

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 16

NRC Differing Views US NUCLEAR REGULATORY Program COMMISSION Gladys Figueroa-Toledo Senior Differing Views Program Manager, OE Nadim Khan Differing Views Program Manager, OE November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 17

NRC POLICY ON DIFFERING VIEWS All NRC employees and contractors are encouraged to raise concerns and differing views promptly without fear of reprisal. A respectful environment that promotes the free and open exchange of ideas is the ideal forum for raising and addressing concerns and differing views in an efficient and timely manner. Raising and addressing differing views improves decision-making processes and supports the agencys mission.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 18

ROLES AND RESPONSIBILITIES

  • Employees have a responsibility to raise concerns and propose solutions as early as possible in the decision-making process.
  • Management has the responsibility to listen and consider differing views, and critically assess the merits of each position to make the most informed and sound decision.

Management retains final decision-making authority and accountability.

  • Behaviors bring policies and processes to life.

Everyones attitudes and behaviors shape the NRC safety culture and our ability to fulfill our mission.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 19

WAYS TO RAISE DIFFERING VIEWS The NRCs dedication to safety is ingrained in our tiered approach for addressing safety concerns and differing views:

  • Informal Discussions,
  • the Open Door Policy (Management Directive (MD) 10.160),
  • the Differing Professional Opinion [DPO] Program (MD 10.159).

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 20

INFORMAL DISCUSSIONS The routine, recommended process for resolving a differing view is through informal discussions with the immediate supervisor.

If informal discussions do not resolve concerns, the following formal avenues are available for employees to express and have their differing views heard and considered by management:

  • The Open Door Policy
  • The DPO Program Informal discussions are necessary and a precondition for engaging in the NCP and DPO Program formal processes.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 21

OPEN DOOR POLICY The Open Door Policy promotes early discussion of differing views and provides a channel for communicating concerns or issues directly to all levels of responsible agency officials.

Allows an employee to discuss any work-related issue or concern with any agency supervisor or manager (including a Commissioner or the Chairman of the NRC) beyond informal discussions with their immediate supervisor.

The Open Door Policy is managed in the Office of the Chief Human Capital Officer (OCHCO) and is described in MD 10.160, "Open Door Policy."

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 22

THE NCP An NRC employee who has a role in creating or reviewing a document in the concurrence process is eligible to submit a non-concurrence as a means of formally communicating disagreement with the document.

  • The NCP is a voluntary process.
  • The NCP has eligibility requirements for both individuals and the subject document.

The individual with the different view must have a role in the review.

The subject document must be a draft and in the active concurrence process.

  • The NCP follows the concurrence review schedule of the subject document.
  • The NCP concerns are reviewed and dispositioned by management in the line organization with oversight over the subject document.

Described in MD 10.158, "NRC Non-Concurrence Process."

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 23

THE NCP NCPs Filed by Year 25 The primary purpose of the NCP is to provide a consistent approach to processing non-concurrences to 20 ensure that a differing view is heard, understood, and Number of NCPs considered to inform and support the decision-making 15 process.

10 5

Described in MD 10.158, NRC Non-Concurrence Process. 0 2007 08 09 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Year November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 24

THE DPO PROGRAM DPOs Filed by Year 10 A DPO is a means of communicating a position that differs from an established agency position involving 9 technical, legal, or policy issues provided it is related the 8 agency's mission and to the strategic goals and 7 objectives that support the mission as addressed in the Number of DPOs 6

NRC's Strategic Plan.

5 4

3 Described in MD 10.159, NRC Differing Professional Opinion Program.

2 1

0 06 07 08 09 10 11 12 13 14 15 16 17 18 19 20 21 22 Year November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 25

THE DPO PROGRAM

  • The DPO Program is a voluntary process.
  • The DPO Program applies to final documents where an agencys position has been established.
  • The DPO Program does not apply for issues that already have been considered, addressed, unless significant new information is available.
  • Timeliness goals and scope of review is established after a kick-off meeting that includes the submitter and decision-maker and is based on safety significance of the issue, complexity of the issue, and priority of other work activities.
  • The DPO program features a review by an independent panel of NRC subject matter expert(s).
  • The DPO concerns are dispositioned by an Office Director or Regional Administrator.
  • The DPO program features an appeal that allows an NRC employee to have their concerns considered and responded to by the Executive Director for Operations (EDO), or the Chairman or the Commission for those offices reporting to the Chairman or the Commission.

Described in MD 10.159, NRC Differing Professional Opinion Program.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 26

DIFFERING VIEWS PROGRAM IMPROVEMENTS

  • A Differing Views Program Improvement (DVPI) Project was completed in 2018 (ADAMS Accession No. ML19133A284, public version).
  • The DVPI Project provided agency senior leadership with recommendations to improve the effectiveness and efficiency of the NRCs NCP and DPO Program.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 27

DIFFERING VIEWS PROGRAM IMPROVEMENTS

  • The Rapid Resolution Stage: The rapid resolution stage proactively creates opportunities for earlier understanding of the involved parties interests and for the effective and efficient informal resolution of differing views before entering the resource intensive NCP and DPO Program.
  • A DPO kick-off meeting: The enhanced DPO kick-off meeting that includes the submitter, DPO decision-maker, DPO panel members, and any others who have already been identified as being needed. This kick-off meeting gives the submitter an opportunity to share their concerns directly to a DPO decision-maker and includes a discussion on roles and responsibilities, other expectations, appropriate process flexibilities, a plan to resolve and disposition the issue, milestones, target dates, available resources, among others.
  • DPO Decision Delegation to Deputies Office Directors/Regional Administrators: Allows ODs and RAs to delegate the disposition of DPO cases to their deputies.
  • Senior Level Advisors serving as chairperson in DPO panels: Only Senior Executive Service (SES) members were permitted to serve as DPO panel chairs to lead the independent review of the safety concerns raised in a DPO and provide recommendations to a DPO decision-maker. The recent change also allows Senior Level Advisors to chair a DPO panel.

Although not inclusive, additional program improvements are described in the DVPI Project report (ADAMS Accession No. ML19133A284, public version)

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 28

DIFFERING VIEWS PROGRAM IMPROVEMENTS

  • The DPO Tiger Team: The DPO Tiger Team establishes a list of subject matter experts that can be called upon to a conduct an evaluation of the issues, scope, and any other important circumstances that can help to quickly understand and assess the issues raised in a DPO submittal to the extent that it can assist in resolving concerns and recommend potential DPO Program process flexibilities, so that the agency can prioritize its activities and apply the appropriate resources.
  • Upfront Clarity: The DPO form now reflects the submitters opinion and justification of each of the following:

(1) importance of prompt action on the issue, (2) safety significance of the issue, and (3) complexity of the issue to inform the review plan. In addition, the submitter should also include a list of the area(s) of technical expertise they feel is necessary to properly assess the issue.

  • Immediate safety concerns in the DPO forms: Guidance to assist decision-makers assigned a DPO where the submitter believes the issue represents an immediate public health and safety concern was developed. Note that the guidance describes one way to perform and document an assessment of the safety and security significance of a concern, the decision-maker has the authority to decide on the scope and methodology for addressing assertions of immediate safety concerns.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 29

THE DIFFERING VIEWS PROGRAM

  • The NCP and DPO Program has evolved and will continue to evolve.
  • As a forward-thinking organization committed to continuous learning, we continue to seek opportunities to improve and integrate safety considerations into the prioritization for resolving safety concerns.
  • We are dedicated to striking a balanced differing views program that -

supports enhanced decision-making, ensures safety concerns are effectively and efficiently resolved, fosters a culture of respect and openness, and provides reasonable assurance of the protection for the public health, safety, and the environment.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 30

The NCP vs The DPO Program NCP DPO Program Used for the Resolution of Safety and Security Concerns X X Features a Rapid Resolution Stage facilitated by the Differing Views Program Managers X X Informal Discussions are a Precondition X X Does Not Apply to Documents that Address Personnel Actions, Issues that are Subject to Collective Bargaining, and Issues Involving Allegations X X Has Eligibility Requirements for Submitters X Subject Document Must Be in Draft Form and in Active Concurrence X Timeliness Goals Driven by the Timeliness Goal of the Subject Document X Concerns are Dispositioned by Management in the Same Line Organization as the Subject Document (normally at the division level) X For Issues on Final Documents where an Agencys Position Has Been Established X Does Not Apply for Issues that Already Have Been Considered, Addressed, Unless Significant New Information is Available X Features an Independent Review by NRC Experts X Concerns are dispositioned by an Office Director or Regional Administrator X Timeliness Goals and Scope of Review Established after a Kick-Off Meeting and Based on Safety Significance of the Issue, Complexity of the Issue, and Priority of Other Work Activities X Option to Use DPO Tiger Team X Submitter can Appeal to the Executive Director for Operations (EDO), or the Chairman or the Commission for Those Offices Reporting to the Chairman or the Commission X November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 31

SUMMARY

  • It is the NRCs policy to establish and maintain an environment where all NRC employees and contractors may raise concerns and differing views promptly without fear of reprisal.
  • Raising and addressing differing views improves decision-making processes and supports the agencys safety and security mission.
  • The NRC places safety as its utmost priority and has implemented a robust process to ensure diverse views are considered during the decision-making process.
  • The NRC uses a tiered system for addressing differing views. This includes informal discussions, the Open Door Policy, the NCP, and the DPO Program.
  • The existence of multiple channels helps create an open, collaborative work environment by reducing barriers to expressing differing views.
  • The NRCs commitment to safety entails creating and maintaining a culture where staff are encouraged to raise safety concerns, which are assessed and resolved based on their safety significance. These processes allow decision-makers and employees to incorporate safety considerations into the prioritization for the resolution of safety concerns.
  • As a forward-thinking organization committed to continuous learning, we continue to seek opportunities to improve and integrate safety considerations into the prioritization for resolving safety concerns.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 32

RESOURCES NCPPM.Resource@nrc.gov Gladys Figueroa-Toledo Gladys.Figueroa@nrc.gov DPOPM.Resource@nrc.gov Nadim Khan MDKadim.Khan@nrc.gov For questions about the Open Door Policy, please contact:

OrganizationalCulture.Resource@nrc.gov November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 33

US NUCLEAR REGULATORY Enhanced Weapons Rule COMMISSION Bo Pham Division Director, NRR/DORL November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 34

BREAK 2:30 - 2:45 November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 35

US NUCLEAR REGULATORY Generic Communications COMMISSION Lisa Regner NRR/DRO November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 36

EMERGENCY TELECOMMUNICATIONS SYSTEM DISCONNECT INFORMATION NOTICE

  • NRC licensed facilities are at risk of losing emergency telecommunications with the NRC that rely on legacy, copper-based wire technology (alternate communication means are available)
  • The NRC is required to establish and maintain a mechanism for instantaneous and uninterrupted verbal communication with licensees; licensees required to have this ability for EP
  • Information Notice provides information on options provided by NRC to ensure continued emergency communications

NRC RESOURCE PLANNING REGULATORY ISSUE SUMMARIES (RIS)

  • Digital Instrumentation & Control (proposed)

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 38

OTHER REGULATORY ISSUE SUMMARIES

  • Draft - Required Assessments of DOE Labs (88 FR 69555; comment closure December 5)

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 39

INFORMATION NOTICES (INS)

  • Power Operated Valve Inspections Lessons Learned (ML23129A014)
  • Non-Power Production and Utilization Facilities Lesson Learned (ML23059A539)
  • Discontinuation of recognition of American Board of Radiology training certification (pending)

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 40

Process for Ongoing Assessment US NUCLEAR REGULATORY of Natural Hazard Information COMMISSION Ed Miller NRR/DORL Kevin Quinlan NRR/DEX November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 41

POANHI PROCESS FOR SEISMIC EVALUATIONS Six POANHI seismic hazard and risk evaluations have been completed:

  • Implemented hazard and risk screening process for each plant
  • Plants have screened out
  • POANHI seismic hazard reports for each plant site have been made publicly available in ADAMS. Reports provide:

Description of seismic hazard reevaluation Multiple tables of site geologic profile, Ground-Motion Response Spectrum (GMRS), and hazard curves POANHI seismic evaluations ongoing for remaining Near-Term Task Force (NTTF) Recommendation 2.1 Group 1 plants November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 42

POANHI DECISION-MAKING FLOWCHART November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 43

SEISMIC RISK EVALUATION USING POANHI HAZARD - GENERAL APPROACH

  • Use latest available information to obtain a key input (termed plant-level fragility) for risk evaluation.

SPRA results, if licensee submitted a SPRA report in response to post-Fukushima actions Risk-informed LARs or GI-191 information, if licensee did not submit a SPRA report in response to post-Fukushima actions Consistent with approach discussed in previous public meetings.

  • Use convolution approach as discussed in previous public meetings.
  • Use average of 1, 5, 10, and 100 Hz results consistent with approach in flowchart and discussions in previous public meetings.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 44

ADDITIONAL RISK EVALUATION

  • Utilize available plant-specific seismic risk insights; Examples:

Dominant risk contributors Frequencies of interest based on differences between NTTF 2.1 and POANHI GMRS Safety enhancements performed by licensee via permanent plant modifications

  • If issues resolved, issue final letter and hazard report
  • If issues remain:

Engage Senior Management Review Panel (SMRP)

Enter formal regulatory process, if approved by SMRP November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 45

APPROACH

  • DORL PM will issue letter to licensee documenting results of NRC staff evaluation
  • Any outcome other than no further regulatory action will have licensee engagement before letter is issued NRC is internally considering methods of licensee engagement
  • As with normal ListServ process, letter will not be made publicly available in ADAMS for about 5 days following issuance
  • Licensees can engage through their assigned PM if they have any technical questions about the report November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 46

POANHI SEISMIC EMAIL ACCOUNT

  • Members of the public and external stakeholders can submit any comments or feedback to the staff by emailing POANHI.Seismic@nrc.gov
  • Future comments should continue to be sent to email address above November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 47

SCHEDULE Complete Upcoming (Estimated dates)

  • Summer (Q4 2023)
  • Peach Bottom (Q4 2023)
  • DC Cook (Q4 2023)
  • Dresden (Q1 2024)
  • Oconee (Q1 2024)
  • Callaway (Q2 2024)
  • Beaver Valley (Q2 2024)

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 48

POANHI RECENT UPDATES

  • NRC Staff published the POANHI public website, which can be found at:

https://www.nrc.gov/reactors/operating/ops-experience/poanhi.html

  • The intent of this site is to provide updates on staff activities related to hydrology, meteorology, geology, and seismology, as well as answering many frequently asked questions about POANHI. This website also includes an email address where members of the public and external stakeholders can submit any comments or feedback related to seismic hazards to the staff.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 49

POANHI NATURAL HAZARDS INFORMATION DIGEST (NHID)

  • The NRC conducted a modification on the existing contract with Idaho National Laboratory, which hosts and maintains the Natural Hazards Information Digest (NHID)

Planned updates over the next year include the addition of volcanic hazards and an expansion of scope beyond natural hazards associated with POANHI via the inclusion of human-induced external hazards for sites where these hazards are applicable NRC staff conducted outreach sessions to areas of the agency that would find the information in the NHID to be useful Staff continues to seek feedback from internal stakeholders to improve the functionality and the usefulness of the NHID November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 50

POANHI OUTREACH

  • NRC staff cooperated with resident inspectors and project managers at six plants located along the Mississippi River on potential low-water considers and its impacts on the performance of the nuclear power plants.
  • Based on coordination with the pertinent project managers and resident inspectors, the NRC determined that the low-water conditions on the Mississippi River effort did not require placement into a regulatory process for further action.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 51

RG 1.183 Revision 1 US NUCLEAR REGULATORY COMMISSION Update Kevin Hsueh Branch Chief, NRR/DRA/ARCB November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 52

RG 1.183 REVISION 1 UPDATE

  • Staff developed Revision 1 based upon experience since issuing Revision 0, research data, new analyses, and significant stakeholder involvement.
  • Guidance advancements in Revision 1 included expanding Revision 0s applicability to encompass fuel burnup extensions to 68 GWd/MTU rod average and enrichments up to 8 weight-percent U-235 for certain near-term ATF designs.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 53

RG 1.183 REVISION 1 UPDATE

  • On September 20, 2023, ACRS issued a letter (ML23256A179) to the NRC Chair recommending that Revision 1 should be issued.
  • ACRS also recommended that Revision 2 should be developed and the schedule for this development should be aligned with the Increased Enrichment rulemaking.
  • On October 16, 2023, the FRN (88 FR 71277) announcing issuance of Revision 1 was published.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 54

RG 1.183 REVISION 1 UPDATE

  • In response to the ACRS recommendation, staff has started to work on Revision 2 with a proposed schedule to complete the draft Revision 2 in December 2024 to be aligned with the current Increased Enrichment proposed rule schedule to the Commission.
  • Similar to the Revision 1 development, staff plans to hold multiple public meetings to seek stakeholders input and feedback on the proposed changes to Revision 1.
  • Staff plans to commence these public engagements with the stakeholders in January 2024 to meet the Revision 2 schedule.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 55

Risk Informed Process US NUCLEAR REGULATORY COMMISSION for Evaluations Michele Kichline NRR/DRA November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 56

AGENDA

  • Communicate NRCs assessment of the Nuclear Energy Institutes (NEIs) recommendations to enhance use of the Risk-Informed Process for Evaluations (RIPE).
  • Communicate the path forward for incorporating NEIs recommendations into the NRCs RIPE guidance documents:

Temporary Staff Guidance (TSG) TSG-DORL-2021-01, Risk-Informed Process for Evaluations, (Currently Revision 3 - ML23122A014) and Guidelines for Characterizing the Safety Impact of Issues (SIC) (Currently Revision 2 - ML22088A135).

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 57

NEI FEEDBACK

  • NEI submitted feedback on RIPE by letter dated April 19, 2023 (ML23163A048).
  • The letter included two recommendations.
  • NEI recommendation #1 was to revise of the risk acceptance criteria to allow the use of RIPE when:

The issue contributes less than 5 x 10-7/year to core damage frequency (CDF).

The issue contributes less than 5 x 10-8/year to large early release frequency (LERF).

  • NEI recommendation #2 was to not treat the risk acceptance criteria as pass/fail criteria, consistent with the guidance in Regulatory Guide (RG) 1.174, Section 2.5.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 58

NRC STAFF ASSESSMENT OF NEI RECOMMENDATIONS

  • The NRC held a public meeting on October 5th to communicate our preliminary assessment of NEIs recommendations.
  • The NRC responded by letter dated October 25, 2023 (ML23285A270) to NEIs recommendations with the staff's preliminary assessment.
  • The NRC found NEIs recommendations to revise the risk acceptance criteria for RIPE reasonable because:

applications submitted under RIPE will be reviewed by NRC staff in accordance with the principles of risk-informed decision making (RIDM) in RG 1.174, and the new acceptance criteria are indicative of a very small change in risk in accordance with RG 1.174.

  • However, the NRC noted that increasing the risk acceptance criteria for RIPE should be accompanied by increased flexibility in the review timeline/resources.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 59

NRC STAFF ASSESSMENT OF NEI RECOMMENDATIONS (CONTINUED)

  • The NRC noted that NEIs recommendation to revise the risk acceptance criteria so that they are not pass/fail risk criteria could add complexity and delays in the review process that do not align with the goals of RIPE.
  • However, the NRC will consider applications for review under RIPE with minor deviations from the RIPE acceptance criteria on a case-by-case basis.

For these case-by-case basis reviews where the RIPE risk acceptance criteria are slightly exceeded, the licensee should provide an explanation as to why the minor deviation is acceptable, such as an explanation of how the analysis provided is overly conservative.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 60

PATH FORWARD TO INCORPORATE NEI RECOMMENDATIONS

  • The NRC received NEI 21-01 Revision 2, Industry Guidance to Support Implementation of NRCs Risk-Informed Process for Evaluations, in October 2023 (ML23306A074), which incorporates NEIs recommendations.
  • The NRC identified no major issues with NEIs guidance.
  • The NRC will revise the RIPE SIC and TSG to incorporate NEIs recommendations, consistent with the staff's assessment.
  • Ultimately, after the staff completes several additional RIPE reviews, the final agency position on RIPE will be provided using the Regulatory Guide process.

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 61

NEXT STEPS Action Date

  • Issue letter to NEI with results of our preliminary review of NEI 21- November /

01 Revision 2 December 2023

  • Revise SIC to Revision 3 Spring 2024 Requires office level concurrence and review by the Office of Management and Budget (OMB)
  • Revise TSG-DORL-2021-01 to Revision 4 Spring 2024 Requires office level concurrence (Issue with SIC)

November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 62

Open Discussion US NUCLEAR REGULATORY Bo Pham COMMISSION Division Director, NRR/DORL Brett Titus Director of Licensing, NEI November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 63

OPEN DISCUSSION/STANDING TOPICS

  • Forthcoming Process Changes
  • Staffing, Budgeting, and Resources
  • Reports on Timeliness Metrics, RAIs
  • Trends/ Patterns/ Best Practices
  • Knowledge Management
  • RIC 2024 November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 64

Jorge Hernandez-Munoz, RIC Co-Champion INFORMATION Division of Advanced Reactors and Non-power Production and FOR 2024 Utilization Facilities Office of Nuclear Reactor Regulation REGULATORY INFORMATION Jonathan Evans, RIC Co-Champion Division of Risk Analysis CONFERENCE Office of Nuclear Regulatory Research 2023 U.S.NRC - PUBLIC MEETING WITH NEI RITF 65

In keeping with the theme, Adapting to a Changing Landscape, the 2024 hybrid RIC will deliver a program that meets our goal of providing all attendees with important and relevant information with consideration to the changing landscape to the NRCs safety and security mission.

Featuring 24 Technical Sessions, 18 Digital Exhibit, and 4 Operations Center Tours The 2023 hybrid RIC had nearly 3,000 registrations from 43 countries, remaining consistent with registrations from the prior two virtual RICs, even after transitioning to hybrid for the year.

Plenary session recordings will be available for viewing at https://video.nrc.gov/.

2023 U.S.NRC - PUBLIC MEETING WITH NEI RITF 66

LOOKING FORWARD TO THE 2024 RIC:

The 36th RIC is scheduled for We welcome input from the public, NEI, and other stakeholders to March 12-14, 2024 inform next year s topics. Please include this input in the RIC survey and engage with organizational counterparts on specific topics, as appropriate.

Conference agenda and technical Please use the Contact Us form on program currently being finalized. the RIC public website if you have Registration will open in January. any questions or want to share feedback with the NRC.

2023 U.S.NRC - PUBLIC MEETING WITH NEI RITF 67

QUESTIONS AND/OR COMMENTS OPPORTUNITY FOR PUBLIC QUESTIONS AND/OR COMMENTS November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 69

CLOSING REMARKS November 28, 2023 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 70