ML21054A282

Summary of February 4, 2021, Meeting on the Conceptual Topical Report Implementation and Oversight (Trio) Process

ML21054A282
Person / Time
Site:	Technical Specifications Task Force
Issue date:	03/01/2021
From:	Michelle Honcharik NRC/NRR/DSS/STSB
To:	Scott Krepel NRC/NRR/DSS/SNSB
Honcharik, M., NRR/DSS, 301-415-1774
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ML21055A812	List: ML21054A282
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Download: ML21054A282 (6)

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S. Krepel S. Kre re re re re re re re re re ree re re ree re re ree ree ree re re re r pe pe pe pe pe pee pe pee pee pee pee pe pe pee pel MEMORANDUM TO:

Scott T. Krepel, Branch Chief Nuclear Performance Branch Division of Safety Systems Office of Nuclear Reactor Regulation FROM:

Michelle C. Honcharik, Senior Project Manager Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation

SUMMARY

OF FEBRUARY 4, 2021, MEETING ON THE CONCEPTUAL TOPICAL REPORT IMPLEMENTATION AND OVERSIGHT PROCESS On February 4, 2021, the U.S. Nuclear Regulatory Commission (NRC) staff held a Category 2 meeting to introduce the conceptual Topical Report (TR) Implementation and Oversight (TRIO) process. The purpose of the meeting was for the NRC staff to gain feedback and answer questions regarding the proposed TRIO process. The meeting notice is available in the Agencywide Document Access and Management System (ADAMS) at Accession No. ML21032A043. The NRC staffs presentation is available in ADAMS at Accession No. ML21029A308. A list of attendees is enclosed.

Josh Borromeo (NRC) presented an explanation of the TRIO process concept and provided illustrative examples.

The following issues were clarified by NRC staff in response to questions during (or e-mails subsequent) to the meeting.

The NRC staff envisions that there will be a set periodicity of inspections. However, the

periodicity may be adjusted if the NRC staff finds problems with specific TRs.

The TRIO process could not be applied if a licensee had any significant deviations from

the approved TR. Minor deviations could be accommodated within the TRIO process, such as specific changes to analyze other vendors fuel designs in transition cores.

The NRC staff plans to apply the TRIO process to TRs typically listed in the Core

Operating Limits Report and listed in Chapter 15 of the Final Safety Analysis Report.

But the use of the TRIO process may be expanded to other areas, when/if the TRIO process is in use for a while.

Licensees will not be included in the vendor inspections. However, if a licensee

performs their safety analyses in-house for multiple sites and wants to use the TRIO process in a similar manner, then the NRC staff would inspect the licensees overall reload analysis process.

The inspection process is something that the NRC staff still needs to establish. The

TRIO process wouldnt give NRC staff carte-blanc to chase every piece of paper the March 1, 2021 Signed by Honcharik, Mic on 03/01/21

S. Krepel vendor has on file. The intent of the inspection would be for the NRC staff to gain confidence that the vendor is doing the work properly. The NRC staff would determine the appropriate inspection criteria and focus on risk significant issues.

The effort saved in preparing license amendment requests (LARs) and performing LAR

reviews would be expected to more than offset the increase in inspection space.

The NRC staff does not expect that implementation of the TRIO process would lead to

an increase in 10 CFR Part 21 notifications, as the expectation is that items identified during the TRIO inspection would not rise to the level of 10 CFR Part 21 reporting requirements.

Right now, the TRIO process is just a concept. The NRC is looking for stakeholder

input. If there is interest, then the NRC staff will consider further developing the TRIO process. The NRC is factoring in input from industry into the decision on whether to pursue this further. The TRIO process is not necessary for the NRC to continue to review TRs and LARs. NRC staff is looking for ways to gain efficiencies in the TR reviews. A decision will likely be made in the next few months.

NRC staff does not expect that there would be many questions for licensees during the

TRIO inspections. Most questions would involve the fuel vendor. But these details are still being worked out.

The intent of inspection in TRIO is to confirm TR methods are being implemented

properly. The NRC staff would not be re-reviewing the TR during the inspection.

Currently when the NRC staff reviews a TR, we review demonstration or reference

analyses for a given TR. In the TRIO process, the NRC staff would inspect the analyses performed after the LAR review has been completed. Design changes, cycle-specific items, etc. are considered in the lifecycle. The NRC staff envisions the TRIO process would be an option, not a requirement. We think it is just a more efficient way to review certain LARs. As to the lifecycle, each vendor typically has their own way for doing reloads. During LAR reviews, the NRC staff only gets a snapshot of how that applies to a certain licensee. If we use the TRIO process, and we do an inspection and look at something where we have concerns, we would get a better feel for the overall context and see how the regulatory requirements are met.

On slide 15, Benefits, bullet 2 states reduction in license amendment request

development effort. This means that for individual LARs, the analysis with the NRC-approved TR does not have to be done until after the LAR is approved. The NRC staff envisions the LAR reviews under the TRIO process as being narrowly targeted on a few things: (1) whether the methodology is applicable to the plant in question; (2) whether the limitations and conditions in the TR have been met; and (3) any plant-specific deviations from the methods as described in the TR (such as how fuel designs from competing vendors are handled). This is driven by the fact that the regulatory finding would be that the TR methodology is applicable and using that method with the appropriate acceptance criteria will ensure that the regulatory requirement is met, not that the licensee has provided a demonstration showing that the regulatory requirement is met. Licensees would still be responsible for ensuring that the regulatory requirement is met.

The NRC staff expects that, most of the time, questions would be answered via a

template-based approach (like how the Technical Specifications Task Force travelers are handled) and would not require explicit NRC review of analyses. Instead, the NRC staff would review a limited sample of analysis documentation as part of inspections.

Comments received from meeting attendees:

S. Krepel The comments on the later slides about broader oversight of the lifecycle of an

implemented TR and Consistent means to address latent/emergent issues seem like a way to give the NRC staff the ability to sunset an approved TR and force licensees to adopt a new method without invoking the backfit considerations.

There are also financial aspects. Vendors arent going to want to pay for inspections;

they will want to pass it on to the customers. However, if the NRC staff is inspecting a core reload thats already been completed and closed out, licensees arent going to want to pay for it.

A larger meeting for other stakeholders was recommended.

Industry appreciates the NRC staff looking to improve the process.

For fuel vendors, addressing requests for additional information (RAIs) during the LAR

review process is far less disruptive, from an efficiency standpoint, than supporting later inspections. While a fuel vendor is in the process of addressing RAIs, everyone is already there to help. It may be more work to bring everyone back later in time during an inspection. From a vendor standpoint, the TRIO process would require a reallocation of resources.

Next Steps:

The NRC staff plans to gather data in order to better quantify the potential benefits of the

TRIO process.

The NRC staff will gauge the level of interest in performing a pilot program for the TRIO

process.

Project No. 753

Enclosure:

As stated cc: See next page CONTACT: Michelle C. Honcharik, NRR/DSS 301-415-1774

Package ML21055A812: Meeting summary; Meeting notice:

ML21032A043; Meeting handout: ML21029A308 NRR-106 OFFICE NRR/DSS/SNSB*

NRR/DSS/SNSB/BC*

NRR/DSS/STSB*

NAME JBorromeo SKrepel MHoncharik DATE 2/26/2021 2/26/2021 3/1/2021

Enclosure LIST OF ATTENDEES NRC Staff Honcharik, Michelle Donoghue, Joseph Borromeo, Joshua Fields, Leslie Markley, Michael Parks, Benjamin Lukes, Robert Harbuck, Craig Beaton, Robert Lu, Shanlai Shoop, Undine McKenna, Philip Whitman, Josh Krepel, Scott Ashley, Clinton Galletti, Greg Kaizer, Joshua Grasso, John Wood, Kent Lenning, Ekaterina West, Khadijah Nolan, Ryan Sahd, Phillip Panicker, Mathew Cusumano, Victor Mahoney, Michael Karipineni, Nageswara Tilton, Caroline Heller, Kevin Gamin, Kayla Morey, Dennis Danna, James Chien, Nan Siwy, Alexandra Kavanagh, Kerri Peabody, Charley Wagage, Hanry Lehning, John Thurston, Carl Hernandez, Raul Wittick, Brian Hamm, Matthew Suh, Kate Rau, Adam Chawla, Mahesh Ross-Lee, MJ Wise, Brandon Barrett, Antonio Bales, Michelle Industry/Public Richards, Drew Halac, Kent E (GE Power Portfolio)

Andrachek, James Gullott, David M.:(Exelon Nuclear)

Brian L Mount (Services - 6)

Kusumawatimurray, Putri:(Exelon Nuclear)

Mann, Brian Joyce, Ryan M.

Holm, Jerald Hannah, John C (GE Power Portfolio)

Sparkman, Wesley A.

Billy Steelman Wagner, Jennifer Harper, Zachary S Dolley, Steven Holderbaum, Chad M.

Schichlein, Lisa (GE Power Portfolio)

Miksa, Jim Miksa (LSC Chair - Entergy)

Cantonwine, Paul E (GE Power Portfolio)

Phillippe, Aaron M.

Enclosure Technical Specifications Task Force Project No. 753 cc:

Technical Specifications Task Force c/o EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 Attention: Brian D. Mann E mail: brian.mann@excelservices.com James P. Miksa Entergy Nuclear Operations, Inc.

Palisades Nuclear Power Plant 27780 Blue Star Memorial Highway Covert, MI 49043 E mail: jmiksa@entergy.com Jordan L. Vaughan Duke Energy EC07C / P.O. Box 1006 Charlotte, NC 28202 E mail: jordan.vaughan@duke energy.com Ryan M. Joyce Southern Nuclear Operating Company 3535 Colonnade Parkway / Bin N-274-EC Birmingham, AL 35243 E mail: rmjoyce@southernco.com David M. Gullott Exelon Generation 4300 Winfield Road Warrenville IL 60555 E mail: David.Gullott@exeloncorp.com Wesley Sparkman Southern Nuclear Operating Company 3535 Colonnade Parkway / Bin N-226-EC Birmingham, AL 35242 E mail: wasparkm@southernco.com