ML24017A299

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Public Meeting with the Nuclear Energy Institue (NEI) Regulatory Issue Task Force Presentation Slides, May 29, 2024
ML24017A299
Person / Time
Issue date: 05/29/2024
From: De Los Reyes J, Mark King, Bo Pham, Undine Shoop
Office of Nuclear Reactor Regulation
To:
References
May 29, 2024
Download: ML24017A299 (1)
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P U B L I C M E E T I N G W I T H T H E N U C L E A R E N E R G Y I N S T I T U T E ( N E I )

R E G U L AT O R Y I S S U E S TA S K F O R C E May 29, 2024

AGENDA May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 2

Time Topic Speaker 9:00 am Introductions and Opening Remarks Mike King (NRR, Deputy Office Director for Reactor Programs)

Brett Titus (NEI, Director of Licensing) 9:05 am NRC Power Uprate Preparation Bo Pham (Division of Operating Reactor Licensing) 9:25 am Data Analytics and Trends for Operating Reactor Licensing Sam Bina (DORL) 9:45 am Risk Informed Process for Evaluations Antonio Zoulis (Division of Risk Assessment) 10:05 am Accident Sequence Precursor Program Chris Hunter (Division of Risk Analysis) 10:25 am Break 10:35 am Treating Technical Specifications as Data Stuart Rymer (Tennessee Valley Authority) 10:55 am Open Discussion - Standing Topics

  • Forthcoming Process Changes
  • Staffing, Budgeting, and Resources
  • Trends/Patterns/Best Practices
  • Knowledge Management 11:45 am Opportunity for Public Comments 11:55 am Closing Remarks Mike King (NRR)

Brett Titus (NEI) 12:00 pm Adjourn

OPENING REMARKS PUBLIC MEETING WITH U.S. NRC AND NEI RITF 3

Mike King Deputy Director, Reactor Programs Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Brett Titus Director, Licensing Nuclear Energy Institute May 29, 2024

US NUCLEAR REGULATORY COMMISSION NRC Power Uprate Preparation Bo Pham Director, Division of Operating Reactor Licensing May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 4

Dedicated Power Uprate Project Team Led by NRR Division of Operating Reactor Licensing leadership Includes project managers who lead the completion of our deliverables Meets every two weeks and briefs the NRR Executive Team every month Utilizing dashboards and online tools to track actions and milestones 5

May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Power Uprate Deliverables Core Team Charter Regulatory Issues Summary Communication Plan Licensing Process Improvements Planned Activities/Timeline 6

May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Licensing Process Improvements to Focus and Streamline Reviews Used data to determine the technical areas with the largest equities in previous EPU reviews 01 Experienced staff from those technical areas are reviewing NRC guidance and processes 02 Looking for ways to leverage other reviews, risk in-sights, project management tools, etc.

03 7

May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Planned Activities/Timeline Targeting public engagement during June, August, and following Regulatory Issues Summary responses JUNE

  • Finalize the power uprate project plan, core team charter, and communication plan
  • Conduct a public meeting to discuss NRC staff efforts August
  • Conduct an interactive workshop with stakeholders to further explore potential power uprate improvement areas September
  • Issue staff recommendations to improve power uprate review process 8

May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

US NUCLEAR REGULATORY COMMISSION Data Analytics and Trends for Operating Reactor Licensing Sam Bina Project Manager, NRR/DORL/LPMB Undine Shoop Branch Chief, NRR/DORL/LPMB May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 9

Overview

  • Congressional Budget Justification (CBJ) and Quarterly Performance Review (QPR) Metrics
  • Schedule Utilization
  • Trends in Requests for Additional Information (RAIs) 10 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Data Disclaimer Data throughout this presentation is based on the following:

  • Operating Reactors licensing actions
  • Licensing actions related to COVID-19 have been removed
  • Any cancelled or withdrawn actions removed;
  • All data on schedule utilization is based on the schedule shared with licensees following the acceptance review 11 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Congressional Budget Justification (CBJ) for Schedule Utilization

  • Average Percentage of time allotted used in the established schedule must be 115% and 75% for all requested activities completed during the reporting period.

12 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Schedule Utilization 13 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF Year

Quarterly Performance Review (QPR) for Schedule Utilization

  • 80% of Requested Actions should be complete between 75% and 115% of the estimated schedule.
  • Established FY 2024 14 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Estimated Project Length

  • Previous metric required 12-month timeframe
  • 12 months seen as a default timeframe 2021 2022 2023 2024 Number of Months 15 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

RAIs Since 2018 Total Actions Included: 1905 Total RAI Questions: 4149 Average RAI per Action: 2.18 Actions with RAIs Issued vs Actions without Number of RAIs per Action for those Actions that included RAIs 16 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Licensing Action Types with Above Average Number of RAIs Action Type Number of Actions Average number of Questions Percent With Questions TSTF 505 29 12 76%

Methodology Change 15 11 87%

Emergency Action Level Scheme Change 21 8

81%

10 CFR 50.69 39 8.5 80%

17 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Licensing Action Types with Below Average Number of RAIs Action Type Number of Actions Average number of Questions Percent With Questions TSTF (other than 505) 313 0.85 25%

Testing Relief Alternative 183 1

33%

TS Change 243 1.71 43%

18 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Accuracy of Estimate vs RAI count 19 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Metrics and RAIs Schedule usage Number of Actions Total Number of RAI Questions Average Percent with multiple RAI Rounds Below 75%

564 368

.65 1.4%

75-115%

1068 2732 2.56 7.3%

Above 115%

76 714 9.39 25%

Schedule Utilization Totals 20 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Conclusions

  • New QPR metric shows an expected increase in estimated schedule fidelity, although complete results will not be evident until FY 2025 when the licensing actions with more accurate estimated schedules are completed.
  • Certain types of review represent a disproportionally large number of RAIs.
  • The number of RAIs associated with a review correlate with the likelihood of a review exceeding 115% of the estimated schedule.

21 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

US NUCLEAR REGULATORY COMMISSION Risk Informed Process for Evaluations Antonio Zoulis Branch Chief, NRR/DRA/APOB May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 22

PRINCIPLES OF RISK-INFORMED DECISION MAKING (RIDM)

Licensees can request license amendments or exemptions to any current regulations using 10 CFR 50.90 and 50.12.

The burden is on the licensee to make an adequate justification.

Must submit risk-informed application consistent with RG 1.174 integrated RIDM principles 23 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

RIDM for RIPE Acceptable PRA Model IDP Issue contributes

<5E-7/yr to CDF Issue contributes

<5E-8/yr to LERF Minimal increase in the frequency of a risk-significant accident initiator Minimal decrease in availability, reliability, or capability of an SSC Minimal increase in consequences (dose)

Minimal decrease in the capability of a fission product barrier Minimal decrease in DID or SM Acceptable Cumulative Risk Performance Monitoring Strategies Meets current regulations unless it is an exemption 24 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Minimal decrease in DID or SM (additional considerations)

RIPE LAR CONTENT Ensure all adverse impacts are identified.

Clearly describe the extent and implications of each adverse impact.

Avoid vague or generic justifications for minimal adverse impact. Ensure the rational is detailed enough to stand alone without unstated inferences or assumptions.

Ensure the justification for minimal adverse impact describes the supporting plant documentation with adequate detail.

Ensure any reliance on manual actions includes specific descriptions of procedure steps, adequate recognition of need for action, adequate time to implement, configuration control, and training.

25 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

BEST PRACTICES (FOR LICENSEE CONSIDERATION)

  • Consider requesting a pre-submittal meeting before submitting a request using RIPE. Staff recommends licensees address the following during the pre-submittal meeting:
  • A description of the issue and whether compliance with any regulations will be impacted
  • How the screening questions will be answered
  • How risk was calculated, including a description of any surrogates used, and the risk results
  • Ensure application is consistent with 50.90 (or if exemption, 50.12)
  • Ensure application is consistent with RG 1.174
  • Consider providing NRC staff access to the integrated decisionmaking panel (IDP) report on a secure portal when the RIPE request is submitted to support efficient staff review.

26 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

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 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).
  • 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.

27 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

NRC STAFF ASSESSMENT OF NEI FEEDBACK

  • The NRC responded by letter dated October 25, 2023 (ML23285A270) to NEIs recommendations with the staff's preliminary assessment.
  • The NRC revised the RIPE SIC and TSG to incorporate NEIs recommendations, consistent with the staff's assessment.

NEXT STEPS Action Date

  • Develop recommendations for RIPE refinement 3 months from last completed pilot RIPE licensing action (5 to 7 Licensing Actions)
  • Evaluate RIPE recommendations and incorporate TSG and SIC updates 3 months from recommendations development
  • Incorporate TSG into local guidance 12 months from final TSG updates
  • Develop Regulatory Guide to sunset SIC 18-24 months from final SIC updates 29 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

US NUCLEAR REGULATORY COMMISSION Accident Sequence Precursor Program Chris Hunter Senior Reliability and Risk Engineer, RES/DRA/PRB May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 30

=

Background===

In 1978, Risk Assessment Review Group performed an independent evaluation of WASH-1400 and recommended in NUREG/CR-0400 that the NRC increase use of operational data to assess the risk from commercial NPPs.

It is important, in our view, that potentially significant sequences and precursors, as they appear, be subjected to the kind of analysis contained in WASH-1400, in such a way that the analyses are subjected to peer review.

After the TMI accident, the NRC instituted a special inquiry to review and report on the event and concluded the following in NUREG/CR-1250:

the systematic evaluation of operating experience must be undertaken on an industrywide basis, both by the utility industry, which has the greatest direct stake in safe operations, and by the NRC.

In response to these insights and recommendations, the NRC established the ASP Program as part of the AEOD.

- In 1998, ASP Program was transferred to RES.

31 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

2006 Program Changes

  • Regulatory Issue Summary (RIS) 2006-24 communicated ASP Program changes.

- Minimize duplication of effort and the different program results that led to confusion.

- An independent ASP analysis would still be performed if:

  • a licensee performance deficiency was not identified, or
  • there were concurrent unavailabilities (i.e., windowed events) not considered in the SDP risk evaluation.
  • ASP review process was also revised.

- Licensee analysis reviews would be limited to events/conditions with a CCDP/CDP 10-4.

32 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Revised Transmittal Process

  • All preliminary precursors analyses will be sent to the licensee.

- Provides an early notification that a precursor has been identified at their respective plant.

  • No licensee response is required.

- Feedback on modeling assumptions and results will be considered prior to finalizing the results.

  • ASP analysis reports are publicly available in ADAMS.
  • Any feedback must be provided in writing within 30 days.

- In addition, an informal meeting can be held to discuss clarification on the analysis assumptions and results.

33 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

Information Resources

- Interactive source of precursor information that provides various filters and slicing tools.

- All final precursor reports are hyperlinked within the tool.

  • Public Webpage

- Provides brief program summary and links to past annual reports.

34 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

BREAK 10:25 - 10:35 35 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF

©2024 Nuclear Energy Institute May 29, 2024 Treating Technical Specifications as Data

©2024 Nuclear Energy Institute 37 Introduction Applicability Format Changes to the Tech Specs Implementation Next Actions Agenda

©2024 Nuclear Energy Institute 38 Introduction The current practice by the NRC and licensees is to treat Technical Specifications (TS) as controlled documents. Any change to the TS - technical, administrative, editorial, or appearance - requires a license amendment under 10 CFR 50.90. This results in license amendment requests (LAR), requests for additional information, supplements, and corrections that have no technical significance and are purely related to document appearance.

The proposed change is for industry to coordinate with the NRC to change this treatment and to instead treat the TS as data. The requirement wording and intent-affecting format (numbering, punctuation, etc.) will remain controlled under 10 CFR 50.90, but other aspects of the presentation (fonts, page breaks, spacing, etc.) would become licensee controlled. Licensees and the NRC would be free to present the TS in any desired format -

paper, web-based, database, etc. - provided the requirements are unaltered.

©2024 Nuclear Energy Institute 39 Substantive Information

Wording/punctuation of Definitions, Improved Technical Specifications (ITS) Sections 1.2, 1.3, and 1.4, Safety Limits, Design Features, and Administrative Controls

Wording/punctuation of Limiting Condition of Operations (LCO), Actions, and Surveillances (including associated notes and logical connectors)

Wording/punctuation of Applicabilities

ITS plants - Required Actions logical connectors, numbering, and indention

Figures, figure numbers, and associated notes

Table data, table numbers, and associated notes

Footnotes Presentation-Only Information

Fonts, spacing, line breaks, location of information on a page

Single and double lines in tables

TS chapter, section, and specification titles/headers

Table and figure titles

Spacing/arrangement of table rows/columns

Size/orientation of figures

Footers (plant name, page/amendment numbers)

Revision bars

Table of contents

One-time, time-limited, or event-limited requirements which are no longer applicable.

Applicability

©2024 Nuclear Energy Institute 40 Revision bars and amendment numbers are tied to the affected text.

A licensee would be able to choose how to implement the new revision (i.e., revision bars for all past amendments, only last amendment to specification, or add no revision bars until a new amendment is approved)

Format Changes to the Tech Specs

©2024 Nuclear Energy Institute 41 Removing temporary information that no longer represents an operating restriction (e.g., one-time changes that are no longer applicable) does not amend the license, and a LAR is not required to remove it.

The NRC amendment that approved the temporary allowance could state that it may be removed from the TS when it is no longer applicable.

10 CFR 50.90 only requires a LAR when a licensee desires to amend a license or permit. A licensee should be able to make presentation-only changes to the TS that do not amend the license.

Format Changes to the Tech Specs (cont.)

©2024 Nuclear Energy Institute 42 Different methods a licensee could adopt to implement the new treatment in a plants TS:

Recreate or update all the TS word processing files to create a new version of the TS. Provided there are no substantive changes made, the creation of a new working copy of the TS does not require submittal of an amendment or NRC approval Implement the new treatment in future LARs and only change the presentation for specifications as they are affected by amendments.

NRC could inform licensees of the availability of the new treatment.

Participation by licensees is voluntary, and licensees could choose to continue with current practices.

Implementation

©2024 Nuclear Energy Institute 43 Potential changes to industry and NRC guidance documents:

NEI 06-02 TSTF-GG-05-01 NRR Office Instruction LIC-101 Implementation

©2024 Nuclear Energy Institute 44 Summer-Fall 2024 Workshop meetings between NRC and industry to identify common ground and challenges with the proposed new treatment of TS In depth review of guidance - NRC and NEI - affected by new treatment 2025 Presentation meeting for finalized proposed change to TS treatment Next Actions

Questions or Comments?

US NUCLEAR REGULATORY COMMISSION Open Discussion May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 46

47 May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF OPEN DISCUSSION/STANDING TOPICS

  • Forthcoming Process Changes
  • Staffing, Budgeting, and Resources
  • Reports on Timeliness Metrics, RAIs
  • Trends/Patterns/Best Practices
  • Knowledge Management

QUESTIONS AND/OR COMMENTS

OPPORTUNITY FOR PUBLIC QUESTIONS AND/OR COMMENTS May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 49

CLOSING REMARKS May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 50

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