ML24017A299
| 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) | |
Text
PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI)
REGUL ATORY ISSUES TASK FORCE May 29, 2024 Time Topic Sp e ake r
9:00 am Introductions and Opening Remarks Mike King (NRR, Deputy Office Director for Reactor Programs)Brett Titus (NEI, Director of Licensing)
AGENDA 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
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 2 Mike King Deputy Director, Reactor Pro grams Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission OPENING REMARKS Brett Titus Director, Licensing Nuclear Energy Institute
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 3 NRC Power Upr ate US NUCLEAR REGULATORY COMMISSION Pr epar ation
Bo Pham Dir ector, Division of Oper ating Reactor Licensing
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 4 Led by NRR Division Includes project of Operating Reactor managers who lead Licensing leadership the completion of our Dedicated Power deliv erables Uprate Project Team
Meets ev ery two Utilizing dashboards weeks and briefs the and online tools to NRR Executiv e Team track actions and ev ery month milestones
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF5 Core Team Charter
Regulatory Issues Summary Power Uprate Deliverables Communication Plan
Planned Activities/Timeline
Licensing Process Improvements
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF6 Licensing Process 01 02 03 Improvements to Used data to Experienced staff Looking for ways to Focus and Streamline determine the from those leverage other technical areas with technical areas are reviews, risk in-sights, Reviews the largest equities reviewing NRC project in previous EPU guidance and management tools, reviews processes etc.
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF7 JUNE
- Finalize the power uprate project plan, core team charter, and Planned communication plan Activities/Timeline
- Conduct a public meeting to discuss NRC staff efforts
August Targeting public
- Conduct an interactive workshop with engagement during June, stakeholders to further explore August, and following potential power uprate improvement Regulatory Issues Summary areas responses September
- Issue staff recommendations to improve power uprate review process
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF8 Data Anal ytics and Tr ends for Oper ating Reactor Licensing US NUCLEAR REGULATORY COMMISSION Sam Bina Pr oject Mana ger, NRR/DORL/LPMB Undine Shoop Br anch Chief, NRR/DORL/LPMB
May 29, 2024 PUBLIC MEETING WITH U. S. NRC AND NEI RITF9 Over view
- Congressional Budget Justification (CBJ) and Quarterly Performance Review (QPR) Metrics
- Schedule Utilization
- Trends in Requests for Additional Information (RAIs)
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF10 Data Disclaimer
Data throughout this presentation is based on the following:
- Operating Reactors licensing actions
- Licensing actions as defined within scope of the definition in the Nuclear Energy Innovation and Modernization Act (NEIMA) (License Amendments, Exemptions, NFPA 805, iSTSconversions, License Transfers, Relief Requests, Power Uprates, and Plant Specific Topical Reports)
- 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
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF11 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.
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF12 Schedule Utilization
Ye a r
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF13 Quar terly Per formance Review (QPR) for Schedule Utilization
- 80% of Requested Actions should be complete between 75% and 115% of the estimated schedule.
- Established FY 2024
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF14 Estimated Project Length
- Previous metric required 12-mo n th timef r ame
- 12 months seen as a default timeframe
Number of Months
2021 2022
2023 2024
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 15 RAIs Since 2018
Actions with RAIs Issued Number of RAIs per Action for vs Actions without those Actions that included RAIs
Total Actions Included: 1905 Total RAI Questions: 4149 Average RAI per Action: 2.18
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF16 Licensing Action Types with Above Average Number of RAIs
Action Type Number Average Percent of number of With Actions Questions Questions TSTF 505 29 12 76%
Methodology Change 15 11 87%
Emergency Action 21 8 81%
Level Scheme Change 10 CFR 50.69 39 8.5 80%
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 17 Licensing Action Types with Below Average Number of RAIs
Action Type Number Average Percent of number of With Actions Questions Questions TSTF (other than 505) 313 0.85 25%
Testing Relief 183 1 33%
Alternative TS Change 243 1.71 43%
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 18 Accuracy of Estimate vs RAI count
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF19 Metrics and RAIs
Schedule Utilization Totals
Schedule Number of Total Number Average Percent with usage Actions of RAI multiple RAI Rounds Questions Below 75% 564 368.65 1.4%
75-115% 1068 2732 2.56 7.3%
Above 115% 76 714 9.39 25%
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 20 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.
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF21 Risk Infor med Pr ocess for US NUCLEAR REGULATORY COMMISSION Evaluations
Antonio Zoulis Br anch Chief, NRR/DRA/APOB
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF22 PRINCIPLES OF RISK -INFORMED DECISION MAKING (RIDM)
Licensees can request Must submit risk-license amendments The burden is on i n fo r m e d application or exemptions to any the licensee to consistent with RG current regulations make an adequate 1.174 integrated using 10 CFR 50.90 justification. RIDM principles and 50.12.
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF23 Minimal Minimal Minimal decrease in increase in decrease in the Minimal Minimal increase in availability, consequences capability of a decrease in the frequency of a reliability, or (dose) fission product DID or SM risk-significant capability of barrier accident initiator an SSC
Acceptable Cumulative Issue contributes Risk
<5E-8/yr to LERF RIDM Performance Issue contributes Monitoring
<5E-7/yr to CDF S t rateg ies for RIPE
Meets current IDP regulations Acceptable unless it is an PRA Model exemption
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF24 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 Minimal decrease in DID or SM assumptions.
(additional considerations)
- 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.
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF25 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 eff i c i e nt staff revi ew.
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF26 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).
- 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.
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF27 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.
- Temporary Staff Guidance TSG -DORL-2021- 01 (TSG), Revision 4, issued May 1, 2024 (ML23354A150)
- Safety Impact Characterization Guidance for Implementing the Risk -Informed Process for Evaluations (SIC), Revision 3, issued May 1, 2024 (ML23354A152)
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF28 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 3 months from recommendations SIC updates development
- Develop Regulatory Guide to sunset SIC 18-24 months from final SIC updates
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 29 Accident Sequence US NUCLEAR REGULATORY COMMISSION Pr ecur sor Pr og r am
Chris Hunter Senior Reliability and Risk Engineer, RES/DRA/PRB
May 29, 2024 PUBLIC MEETING WITH U. S. NRC AND NEI RITF30
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.
May 29, 2024 PUBLIC MEETING WITH U. S. NRC AND NEI RITF31 2006 Program Changes
- ASP Program would leverage Significance Determination Process (SDP) results when possible.
- Minimize duplication of effort and the different program results that led to confusion.
- An independent ASP analysis would still be performed if:
- a reactor trip occurred,
- 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.
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF32 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.
- 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.
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF33 Information Resources
- ASP Dashboard
- 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.
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF34 BRE AK 10: 2 5 - 10: 3 5
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 35 Treating Technical Specifications as Data
May 29, 2024
©2024 Nuclear Energy Institute Agenda
Introduction
Applicability
Format Changes to the Tech Specs
Implementation
Next Actions
©2024 Nuclear Energy Institute 37 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 38 Applicability
Substantive Information Presentation-Only Information
Wording/punctuation of Definitions, Improved Fonts, spacing, line breaks, location of information on a Technical Specifications (ITS) Sections 1.2, 1.3, and page 1.4, Safety Limits, Design Features, and Single and double lines in tables Administrative Controls TS chapter, section, and specification titles/headers Wording/punctuation of Limiting Condition of Table and figure titles Operations (LCO), Actions, and Surveillances (including associated notes and logical connectors) Spacing/arrangement of table rows/columns Wording/punctuation of Applicabilities Size/orientation of figures ITS plants - Required Actions logical connectors, Footers (plant name, page/amendment numbers) numbering, and indention Revision bars Figures, figure numbers, and associated notes Table of contents Table data, table numbers, and associated notes One-time, time-limited, or event-limited requirements Footnotes which are no longer applicable.
©2024 Nuclear Energy Institute 39 Format Changes to the Tech Specs
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)
©2024 Nuclear Energy Institute 40 Format Changes to the Tech Specs (cont.)
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.
©2024 Nuclear Energy Institute 41 Implementation
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.
©2024 Nuclear Energy Institute 42 Implementation
Potential changes to industry and NRC guidance documents:
- TSTF-GG- 05- 01
- NRR Office Instruction LIC -101
©2024 Nuclear Energy Institute 43 Next Actions
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
©2024 Nuclear Energy Institute 44 Questions or Comments?
US NUCLEAR REGULATORY COMMISSION Open Discussion
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 46 OPEN DISCUSSION/STANDING TOPICS
- Forthcoming Process Changes
- Staffing, Budgeting, and Resources
- Reports on Timeliness Metrics, RAIs
- Trends/Patterns/Best Practices
- Knowledge Management
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF47 QUESTIONS AND/OR COMMENTS OPPORTUNITY FOR PUBLIC QUESTIONS AND/OR COMMENTS
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF49 CLOSING REMARKS
May 29, 2024 PUBLIC MEETING WITH U.S. NRC AND NEI RITF 50