ML21050A203
| ML21050A203 | |
| Person / Time | |
|---|---|
| Issue date: | 02/25/2021 |
| From: | Siva Lingam, Antonios Zoulis NRC/NRR/DORL/LPL4 |
| To: | |
| Lingham S, NRR/DORL | |
| Shared Package | |
| ML21050A202 | List: |
| References | |
| Download: ML21050A203 (10) | |
Text
Proposed Expansion to the Risk Informed Process for Evaluations Public Meeting February 25, 2021
Introduction
- As approved, licensees must have an approved TSTF505 (RiskInformed Completion Times) license amendment to use RIPE.
- The RIPE working group reviewed the process proposed by the Nuclear Energy Institute (NEI) for expanding RIPE to include Disclaimer licensees with an approved TSTF425 (Surveillance Frequency Control Program) license amendment, as presented at the January 26, 2021 public meeting (ML21015A003).
- The views presented in this presentation are the views of the RIPE working group and do not represent an official NRC position.
High Level Feedback Case 1 Classic RIPE NRC would like to see additional It seems appropriate that licensees guidance on how the review would with an approved TSTF425 be done to justify the issue only amendment can use RIPE asis, if:
impacts internal events.
- the licensees internal events PRA
- This justification would need to does not have any open F&Os be part of the application.
AND
- We expect that very few issues
- the exemption/amendment does will be able to justify that the not have any impact on external exemption/amendment does not events. impact any external event risk.
Case 2 - Open F&Os It seems appropriate that licensees with an approved TSTF425 amendment and a FEW open F&Os could use RIPE.
- Reviewing open F&Os will take more NRC review than is currently part of the RIPE TSG, including the potential need for requests for additional information (RAIs).
- The number, complexity, and applicability of open F&Os could significantly increase the NRC review time.
- If the open F&Os have been reviewed in a recent application, NRC review could be streamlined.
Case 3 - Applicable External Events It seems appropriate that licensees with external event PRA models that have been previously reviewed for other purposes, such as for NFPA805 or PostFukushima 50.54(f) seismic/flooding evaluations, may qualify for RIPE.
- The external event PRA that will be used must be peer reviewed and all applicable F&Os must be closed in order to use RIPE.
- Any open F&Os that need to be reviewed by the NRC will require additional review time.
- If external events are applicable and the external events PRA has not been previously reviewed by the NRC, the licensee does not qualify for RIPE.
Other Concerns
- When was the PRA last updated?
- The application needs to discuss when the PRA was last reviewed by the NRC and any updates and peer reviews that occurred since the last review.
- The TSG and Guidelines for Characterizing the Safety Impact of Issues guidance will require revision to use TSTF425.
- The approved TSG does not include the option to ask RAIs or use TSTF425 for RIPE submittals.
- The Guidelines for Characterizing the Safety Impact of Issues guidance allows case by case use of TSTF 425 in lieu of TSTF505.
Path Forward
- Further guidance enhancements can be completed as more experience is gained with the use of RIPE.
- Expansion to other areas will require significant additional guidance development and engagement with cognizant technical staff.
Questions?
Send additional feedback or questions to:
Antonios.Zoulis@nrc.gov