|
|
| Line 15: |
Line 15: |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:Public Meeting with the Nuclear Energy Institute Regulatory Issues Task Force April 23, 2021 1 | | {{#Wiki_filter:}} |
| | |
| Time Topic Speaker Introductions/Opening remarks 9:00 am -9:10 am NRC/NEI 9:10 am - 9:30 am EMBARK Venture Studio activities NRC 9:30 am - 10:00 am Licensing actions/review of metrics NRC/NEI 10:00 am - 10:10 am Efficiencies of VLSSIR/RIPE processes NRC 10:10 am - 10:20 am NUREG-1409 update NRC 10:20 am - 10:35 am Break 10:35 am - 10:50 am Retroactive Review of Administrative Requirements NRC 10:50 am - 11:00 am Potential generic issues - PRE-GI-018 HEAF NRC Endorsement of ASME NML-1-2019, Rules for the movement of loads using overhead handling equipment in nuclear 11:00 am - 11:10 am NRC facilities 11:10 am - 11:20 am 10 CFR 50.55a 2-year update and timeline NRC 11:20 am - 11:30 am Industry operability lessons learned NEI/NRC 11:30 am - 11:40 am SRP modernization project NRC Members of the 11:40 am - 11:55 am Opportunity for public comments Public 11:55 am - 12:00 pm Wrap up/Action items/Closing remarks NRC/NEI 12:00 pm Adjourn 2
| |
| | |
| Introductions and Opening Remarks 3
| |
| | |
| Jeremy Groom Managing Director
| |
| | |
| Launched April 5th WEB-https://wrr.nrc-gateway.gov/
| |
| BASED Public Information Session May 6th from 10:30-11:30 AM RELIEF REQUESTS Addressing User Feedback Web-BasedReliefRequests.Resource
| |
| @nrc.gov
| |
| | |
| MAP-X TIMELINE
| |
| * April 2021 - Enhanced Web-Based Relief Requests (WRR) -
| |
| LAUNCHED!
| |
| * Present - Fall 2021 -
| |
| Event Notification Development and Deployment*
| |
| * Fall 2021 - Spring 2022 -
| |
| Module 2 Development and Deployment*
| |
| *Estimated schedule subject to change 6
| |
| | |
| MAP-X NEXT STEPS
| |
| * Continue gathering internal and external feedback
| |
| * Identify challenges
| |
| * Continue quarterly public meetings
| |
| * Identify users
| |
| * User Acceptance Testing
| |
| * Event Notification Submitters 7
| |
| | |
| ROP Analytics Webpage (Coming Soon!)
| |
| * ROP information in a user-friendly format to explore or download for analysis
| |
| * Public comments and suggestions
| |
| * Future development
| |
| * Cross Cutting Issues
| |
| * Traditional Enforcement Findings
| |
| * Findings by IP
| |
| * Action Matrix Details 53 8
| |
| | |
| Licensing actions/Review of metrics COVID-19 Actions Workload Management April 23, 2021 9
| |
| | |
| COVID-19 Related Significant Activities/Accomplishments
| |
| * Continued Prompt Actions in Response to COVID-19 Public Health Emergency (PHE)
| |
| * Collective Contributions Across the Agency Enabled Mission Success
| |
| * Engagement on Regulatory Requirements that Posed Challenges and Communications with Industry were Effective 10
| |
| | |
| Completed COVID-19 Actions COVID-19 (as of April 16, 2021)
| |
| Actions
| |
| * Part 26 Work Hours Relief
| |
| * Part 50 Fire Protection Requests
| |
| * Owner Activity Reports (relief requests) 35
| |
| * Part 55 Operators Licenses Amendments
| |
| * Part 73 Security Training 26 Exemptions
| |
| * Part 20 Respiratory Requirements 372 Other 6
| |
| * Part 50 EP Biennial Exercise Other Requests Processed
| |
| * License Amendments
| |
| * Part 50.55a relief/alternative
| |
| * Part 50 Quality Assurance Programs
| |
| * Topical Reports - Audit Frequencies 11
| |
| | |
| 12 13 COVID What is Next?
| |
| * Licensing Needs Appear More Normalized (Issues Can be Handled Case-by-Case)
| |
| - Minimal impact on spring outages (licensing perspective)
| |
| - Steam Generator Inspections deferred to fall appear on track
| |
| * Continue Evaluation of and Engagement on Regulatory Requirements that Pose Challenges
| |
| * Implementing efficiencies and flexibilities developed during COVID-19 14
| |
| | |
| Workload Management Enhancements
| |
| * Working to expand on-line access through MAP-X and WRR
| |
| * New and Revised Performance Measures
| |
| - Nuclear Energy Innovation and Modernization Act (NEIMA) and its impact
| |
| - Outcomes and Key Results (OKR)
| |
| * Enhanced Analytics Tools
| |
| - Increased access to historical information (e.g., level of effort and schedule)
| |
| - Identify challenges and pinch points
| |
| * Integrated Workload Management
| |
| - Consistent approach for all NRR licensing programs 15
| |
| | |
| Continued Performance Gains FY2021 compared to FY2020 Performance continues to improve in almost all areas in FY2021
| |
| * Increased number of completed actions:
| |
| - 48% more completions in 1st half of FY2021 vs same period in FY2020
| |
| - 63% of the total number completed in all of FY2020
| |
| * Decreased average completion time:
| |
| - <7 months for all actions
| |
| - 2 months for COVID-19 actions
| |
| - 8.5 months for routine actions
| |
| - Subject to consistent schedules and priorities from applicants
| |
| * Improved performance against all but one metric goal
| |
| - Exception is 2-Year other licensing tasks (OLT) timeliness (discussed later) 16
| |
| | |
| Nuclear Energy Innovation and Modernization Act Implementation
| |
| * Nuclear Energy Innovation and Modernization Act (NEIMA)
| |
| - Section 102(c) required NRC to develop Performance Metrics and Milestone Schedules for requested activities of the Commission
| |
| - Section 3(10) defines requested activities of the Commission, which encompasses most NRC licensing actions
| |
| - Requires reporting to the Commission and Congress for a delay in issuance that exceeds the established milestone schedule
| |
| * Describe and explain the delay
| |
| * Provide a plan for timely completion 17
| |
| | |
| Agency Level Measures
| |
| * NEIMA - 100% Completed w/in the established Generic Milestone Schedule (2-years for most licensing actions)
| |
| * Performance to date: 100%
| |
| * 2 Year Timeliness - 100% of Licensing Actions (LA) and Demonstrated Other Licensing Tasks (OLT) Completed w/in 2 years
| |
| * Performance to date: LA - 100%, OLT - 99% (missed Steam Generator Tube Inspection Report)
| |
| Performance High Level Office Level Measures Measures
| |
| * 1-Year Timeliness - 90% of LAs and OLTs Completed within 1 year
| |
| * Performance To date: 98% (Combined LA & OLT)
| |
| * 90% of licensing actions completed have actual hours within 125% of the estimated hours communicated to the applicant
| |
| * Performance to date: 99%
| |
| 18
| |
| | |
| Outcomes and Key Results Process 19
| |
| * OBJECTIVE: Improve accuracy of resource estimates and information provided to promote increased stakeholder confidence in the regulatory process and support appropriate resource allocation (Effective 1/1/2021)
| |
| * KEY RESULT: 75% of licensing actions completed have actual hours +/-
| |
| 25% of the estimated hours communicated to the licensee. Aggressive goal to progressively increase New OKR performance to 75% by the end of FY2021:
| |
| - Performance: 39% within +/- 25% in 1st Quarter Examples
| |
| * OBJECTIVE: Increase the use of traditional and analytical data tools to promote continued improvement in the quality of licensing application reviews (Effective 1/1/2021)
| |
| * KEY RESULT: Tracking the percent of acceptance reviews resulting in a supplement; Identifying and addressing one perceived challenge or improvement per quarter:
| |
| - Addressing challenge of delayed Steam Generator Tube Inspection Reports
| |
| - Percent of acceptance reviews resulting in a supplement = 4% (14 of 374) 20
| |
| | |
| Questions?
| |
| 21
| |
| | |
| Resources
| |
| * Generic Milestone Schedules of Requested Activities of the Commission https://www.nrc.gov/about-nrc/generic-schedules.html
| |
| * Nuclear Innovation and Modernization Act https://www.congress.gov/115/plaws/publ439/PLAW-115publ439.pdf
| |
| * NRC Operating Reactor Performance Dashboard https://www.nrc.gov/reactors/operating/nrc-performance-dashboard.html
| |
| * Agencywide Transformation Performance Measures (discusses development of OKRs) https://www.nrc.gov/docs/ML2014/ML20149K586.pdf 22
| |
| | |
| Back-up Slide Large Submittals (TSTF-582, TSTF-505, 10 CFR 50.69)
| |
| * Requests for TSTF-582, Reactor Pressure Vessel Water Inventory Control Enhancements
| |
| - Up to 22 submittals. Most expected to request a 6-month completion times
| |
| - 9 completed in FY 2021: All in less than 6 months from acceptance
| |
| - 4 under review
| |
| * Requests to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times
| |
| - 2 completed in FY 2021: Within estimated hours; one ahead of and one a month after the estimated schedule
| |
| - 3 new submittals under acceptance review
| |
| - 5 expected to complete in next three months
| |
| * Requests to Implement 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components
| |
| - 2 completed; All close to or below the estimated schedule and estimated hours
| |
| - 2 new submittals; Estimates similar to other recent submittals
| |
| - 3 expected to complete in next three months 23
| |
| | |
| Efficiencies of Very Low Safety Significance Issue Resolution (VLSSIR)/
| |
| Risk-informed Process for Evaluations (RIPE)
| |
| Processes 24
| |
| | |
| Very Low Safety Significance Issue Resolution (VLSSIR) Process
| |
| * Effectiveness Review of VLSSIR Process execution in CY2020 was completed on March 2, 2021 (ML21070A334)
| |
| - Determined that the VLSSIR process is meeting the goals and objectives outlined in the February 5, 2020, memorandum from the LSSIR working group to the Director, NRR.
| |
| - VLSSIR process has helped reduce the number of unresolved items that the NRC is tracking with only 12 items appearing in the RPS database as of 2/10/21.
| |
| - Identified an area where procedural guidance may be enhanced to help facilitate the processing of issues where a Detailed Risk Evaluation (DRE) is required.
| |
| - Seven issues were closed using the VLSSIR process in CY 2020:
| |
| 25 25
| |
| | |
| Very Low Safety Significance Issue Resolution (VLSSIR) Process 26 26
| |
| | |
| Risk-informed Process for Evaluations (RIPE)
| |
| * Adoption of RIPE was recommended and approve by memos dated January 5, 2021 (ML20261H428) and January 7, 2021 (ML21006A324), respectively.
| |
| - Enclosure 1 - Guidelines for Characterizing the Safety Impact of Issues (ML20261H462)
| |
| - Enclosure 2 - Temporary Staff Guidance TSG-DORL-2021-01 (ML20261H473)
| |
| * NRC is working with industry to allow use of TSTF-425 applications in lieu of TSTF-505.
| |
| * NRC plans to conduct a lessons-learned review of RIPE after an initial implementation period and make enhancements.
| |
| * Open to industry proposals to further expand RIPE to issues that arent readily assessed through PRA methods.
| |
| - Need to engage broader stakeholder groups (e.g., in the case of security and EP)
| |
| - Potential benefit to exercising RIPE and addressing any lessons-learned before expanding further 27 27
| |
| | |
| NUREG-1409, Rev. 1 Update 28
| |
| | |
| ===Background===
| |
| * SRM-SECY-18-0049 (May 29, 2019)
| |
| - Issue Management Directive (MD) 8.4
| |
| * SRM-SECY-18-0042 (July 26, 2019)
| |
| - Conform NUREG-1409 to MD 8.4
| |
| - Provide NUREG-1409, Rev. 1 to Commission for information 10 days before issuance
| |
| * Draft NUREG-1409, Rev. 1 issued for comment
| |
| - March 2020
| |
| - Category 3 public meeting in April 2020
| |
| - Comments submitted late July 2020 29
| |
| | |
| Public Comments on Draft NUREG-1409, Rev. 1
| |
| * Approximately 250 comments from the public, industry, and NRC staff
| |
| * Significant comments
| |
| - Reorganize content
| |
| - Increase communication between NRC and licensees
| |
| - Clarify stakeholder participation
| |
| - Revise forward fitting terminology and examples
| |
| - Enable MD 8.4 appeals of proposed actions 30
| |
| | |
| Changes to Draft NUREG-1409, Rev. 1
| |
| * Chapter 1 - Introduction
| |
| - Terminology
| |
| - Relocated guidance on issue finality, communications, and ISFSIs
| |
| - Community of Practice Charter discussion
| |
| * Chapter 2 - Backfitting and Issue Finality
| |
| - Application of screening questions
| |
| - Relocated guidance 31
| |
| | |
| Changes to Draft NUREG-1409, Rev. 1
| |
| * Chapter 3 - Forward Fitting
| |
| - Screening
| |
| - Justification:
| |
| * Direct nexus
| |
| * Essential
| |
| - Cost considerations
| |
| - Scenarios 32
| |
| | |
| Changes to Draft NUREG-1409, Rev. 1
| |
| * Chapter 4 - Appeals
| |
| - Submitting and processing appeals
| |
| - Appealing proposed and issued actions
| |
| * Chapter 5 - Various NRC Processes
| |
| - Reorganized based on grouping similar topics
| |
| * Licensing
| |
| * Generic
| |
| * Inspection
| |
| * Enforcement
| |
| - Added and revised topics
| |
| * Conforming changes to Appendices 33
| |
| | |
| SECY-21-0037 Contents
| |
| * SECY Information Paper (now a vote paper)
| |
| - Summarizes changes to draft NUREG-1409, Rev. 1
| |
| - No new policy issues presented
| |
| * Enclosure 1 - Final NUREG-1409, Rev. 1
| |
| * Enclosure 2 - NRC response to comments
| |
| * Enclosure 3 - RLSO of draft NUREG-1409
| |
| * Enclosure 4 - Federal Register notice 34
| |
| | |
| Next Steps
| |
| * Awaiting Commission SRM on SECY-21-0037
| |
| * After NUREG-1409, Rev. 1 is published:
| |
| - Update office-level procedures (office instructions, ROP documents, enforcement manual, etc.)
| |
| - Develop initial and refresher training
| |
| - Update qualification programs 35
| |
| | |
| BREAK 36
| |
| | |
| NEIs Regulatory Issues Task Force (RITF) Meeting April 23, 2021 Topics:
| |
| * RROAR Overview
| |
| * Next Steps 37
| |
| | |
| RETROSPECTIVE REVIEW OF ADMINISTRATIVE REQUIREMENTS (RROAR)
| |
| BY THE NUMBERS 5 99 14 Commission-approved Comments received from Affected 10 CFR Parts - 2, 20, 21, 26, 37, evaluation criteria and the public and NRC staff 50, 52, 55, 70, 71, 72, 74, 100, and 160 NRC staff programmatic experience (80 FR 6103) 5 NRC Offices Impacted 4 4 Public meetings to discuss ~40 17 Outcomes for comments - 1) new RROAR NRC staff rulemaking effort, 2) existing participated in the rulemaking effort, 3) administrative NRC Divisions review working from correction rule, and 4) non-rulemaking Involved standardized review plan 38
| |
| | |
| Information SECY paper, with the RROAR Comment Next Steps Evaluation Summary enclosure (Late April, 2021)
| |
| Rulemaking plan(s)
| |
| (Late 2021)
| |
| Further stakeholder engagements during the rulemaking process 39
| |
| | |
| High Energy Arcing Faults Involving Aluminum Components NEI Regulatory Issues Task Force Public Meeting Nicholas Melly, RES April 23, 2021 40
| |
| | |
| Proposed Path to Resolution of Pre GI-0018 on HEAF
| |
| * NRC staff developing approach to resolve the pre generic issue on HEAF involving aluminum without additional NRC sponsored testing
| |
| * Approach will build off NRC/EPRI Working Group project plan, including the EPRI survey, to determine the extent of aluminum in plants and plant-specific electrical configurations
| |
| * Initial steps will include filling in gaps identified in the survey
| |
| * The NRC/EPRI Working group is developing specific Zones of Influence (ZOI) and PRA methods to address the hazard posed by aluminum HEAFs
| |
| * Anticipate public meeting no later than the next quarter of FY21 41
| |
| | |
| Proposed Path to Resolution of Pre GI-0018 on HEAF
| |
| * NRC staff developing approach to resolve the pre generic issue on HEAF involving aluminum without additional NRC sponsored large scale testing
| |
| * Approach will build off NRC/EPRI Working Group project plan, including the EPRI survey and operating experience to determine the potential risk of aluminum HEAF based on plant-specific electrical configurations
| |
| * The NRC/EPRI Working group is developing specific Zone of Influences (ZOI) and PRA methods to address the hazards posed by HEAFs
| |
| * Two Public Meetings April 6, 2021
| |
| - Morning NRC/EPRI Working Group Progress
| |
| - Afternoon NRC discussion Pre Generic Issue
| |
| * NRC Working group members addressing concerns operating experience has not been adequately incorporated
| |
| - EPRI is publishing a white paper which will detail survey results, publicly available on the EPRI website, once released, by searching 3002020692
| |
| - New PRA methodology and ZOI insights both heavily incorporate OpEx and will be documented 42
| |
| | |
| Proposed Path to Resolution of Pre GI-0018 on HEAF
| |
| * NRC/EPRI HEAF working group will fill the EPRI survey gaps as follows:
| |
| * Compile Draft Hazard Tables to estimate the Zone of Influences using currently available information (e.g., expert judgement, completed testing data, operating experience, modeling insights)
| |
| * Develop representative PRA methods considering equipment categories, plant specific location and electrical configurations / lineups as documented in the EPRI survey
| |
| * NRC established a public web site to keep all stakeholders informed
| |
| * https://www.nrc.gov/about-nrc/regulatory/research/fire-research/heaf-research.html
| |
| * No immediate actions for Industry stakeholders
| |
| * Following the ZOI completion the NRC will be evaluating applicability of pilot plants to complete the Pre GI Assessment phase 43
| |
| | |
| NRC/EPRI Working Group Project Schedule 44 44
| |
| | |
| American Society of Mechanical Engineers NML-1-2019, Rules for the Movement of Loads Using Overhead Handling Equipment in Nuclear Facilities Endorsement Status NEI REGULATORY ISSUES TASK FORCE PUBLIC MEETING APRIL 23, 2021 45
| |
| * Regulatory Guide (RG) endorsement expected to enhance handling system use flexibility and reduce special lift device nondestructive examination and testing frequency consistent with risk insights
| |
| * Draft RG internal reviews commencing mid-November
| |
| * RG issuance for stakeholder comments 2nd Quarter FY21; final RG in 4th Quarter FY21 46
| |
| | |
| 10 CFR 50.55(a) 2-year update and timeline 47
| |
| | |
| Industry operability lessons learned NEI 48
| |
| | |
| SRP Modernization Project 49
| |
| | |
| SRP Modernization (SRPMod) Effort Status April 23, 2021 SRPMod Team Caroline Carusone, NRR/DORL Deputy Division Director Phil McKenna, Acting NRR/DORL Deputy Division Director Dennis Morey, NRR/DORL/LLPB Branch Chief Jason Paige, SRP Modernization Task Lead Mark Notich, Sr. Project Manager Kate Lenning - Project Manager 50
| |
| | |
| SRPMod Purpose
| |
| * Focus on Whats Important to Safety Guidance focused on requirements
| |
| * Clear, Concise Guidance for Completing Reviews Clarity on application details
| |
| * Improve Quality of NRC Review Products Requests for Additional Information Safety Evaluations
| |
| * Consistency on Using Risk-Insights and Engineering Judgement Capture Best Practices
| |
| * SRP Issue vs. Training Issue Not every section will need extensive revising 51
| |
| | |
| SRPMod Objectives Reinforce Focus Empower Reinforce Expectations Focus on Regulatory Empower the Staff to for Reasonable Requirements Consistently Use Risk-Assurance of Adequate
| |
| * Reformatting sections Insights and Engineering Protection
| |
| * Align specific acceptance Judgment
| |
| * Rebranding Introduction criteria and findings to the
| |
| * Reference PRA Policy to General Review applicable requirements Statement and SRM-Principles
| |
| * Remove extraneous SECY-17-0112
| |
| * General Review information
| |
| * Integrate risk guidance:
| |
| Principles will provide
| |
| * Incorporate ISGs, BTPs LIC-206 and Be guidance on completing information riskSMART reviews
| |
| * Reference AEA on the use of engineering judgement 52
| |
| | |
| Schedule: SRPMod Performance Goals
| |
| * SRPMod Performance Goals are Division-Driven!
| |
| Priority for Modernizing
| |
| - Division-specific goals based on available resources Chapters Chapter 2
| |
| * Divisions Select SRP Sections to Modernize to Meet Goals Chapter 3
| |
| - Based on division needs Chapter 5
| |
| * Performance Goals Track Number of Sections Chapter 6 Modernized within Next 2-years Chapter 7
| |
| * Schedule to Issue One SRP Section: 50 weeks Chapter 9
| |
| - Draft Modernized Section: 8 weeks
| |
| - Issue Draft Section (Public Comment): 18 weeks Chapter 14
| |
| - Address Public Comments: 4 weeks *Prioritization based on division needs and available
| |
| - Issue Final SRP Section: 20 weeks resources for next 2-years
| |
| **Divisions will select sections to modernize NRR Goal: 173 Modernized Sections in 2-years!
| |
| 53
| |
| | |
| Status: Next Steps
| |
| * SRPMod Team Hosted 3/31 Public Meeting Incorporated feedback into SRPMod process
| |
| * SRPMod Officially Kicked-Off in April 2021!
| |
| Divisions selecting SRP sections to modernize
| |
| * Draft SRP Sections Issued for Public Comment Public Comment requested via Federal Register Notice First batch expected Fall 2021 Draft SRP Sections will be piloted before issuance of final 54
| |
| | |
| Questions?
| |
| 55
| |
| | |
| Opportunity for Public Comment 56
| |
| | |
| NEI and NRC Management Closing Remarks 57
| |
| | |
| List of Abbreviations AEA - Atomic Energy Act of 1954 BTP - Branch Technical Position EPRI - Electric Power Research Institute ISG - Interim Staff Guidance LSSIR - Low Safety Significance Issue Resolution NEI - Nuclear Energy Institute NEIMA - Nuclear Energy Innovation and Modernization Act NRC - U. S. Nuclear Regulatory Commission NRR - Office of Nuclear Reactor Regulation PRA - Probabilistic Risk Assessment RLSO - Red line strike out ROP - Reactor Oversight Process RPS - Reactor Program System SRP - NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants}}
| |