ML051640463

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Letter to S. Floyd Mitigating Systems Performance Index
ML051640463
Person / Time
Issue date: 06/17/2005
From: Dyer J
Office of Nuclear Reactor Regulation
To: Floyd S
Nuclear Energy Institute
Thompson JW, NRR/DIPM/IIPB, 415-1011
References
Download: ML051640463 (3)


Text

June 17, 2005 Mr. Stephen D. Floyd Vice President, Regulatory Affairs Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW Suite 400 Washington, D.C. 20006-3708

Dear Mr. Floyd,

The staff and industry continue to work toward the milestones mutually established to meet a January 2006 Mitigating Systems Performance Index (MSPI) implementation date. As we understand it, the June 20-21, 2005 public MSPI workshop in New Orleans is intended to educate licensees on system-component level aspects of MSPI, and address unique questions regarding the implementation guidance. The industry has stated its intent to address what alternate minimum probabilistic risk assessment (PRA) quality requirement or commitment the industry recommends for MSPI implementation, following the workshop. Based on discussions with industry representatives, the NRC staff anticipates that a major element of this recommendation will be the successful study, assessment, and resolution of independent PRA comparison studies performed by the industry of important plant attributes in order to identify any outliers that may have PRA quality issues that need resolution prior to implementation.

This critical path activity and milestone will also likely be part of the process that staff will use to inspect and assess the adequacy of MSPI prior to implementation. If the industrys PRA quality recommendation is agreed to, each licensee will be expected to update their MSPI basis documents, as required by the draft Appendix G to NEI 99-02, another critical path activity and milestone, and provide them for staff review by September 1, 2005. These documents should contain all the relevant MSPI information, including the alternate minimum PRA quality requirements. We also anticipate that the industry, through INPO, will finalize and validate software needed by MSPI prior to implementation, with the historical baseline data in place by February 2006.

The following are critical path activities that if not performed according to schedule, could delay the January 2006 MSPI implementation date.

1.

The industry will host the second of three MSPI public workshops on June 20-21, 2005, in New Orleans. The goal of this workshop is to address specific issues and questions licensees may be experiencing in applying the MSPI guidance and to review cross-comparison studies performed by the owners groups. It is expected that each licensee will give copies of their plant-specific MSPI PRA data by the end of the workshop to the staff so that the staff can continue with the development of an independent plant attribute comparison study.

2.

NEI needs to provide the staff a response to the NRC letter dated April 22, 2005, regarding what alternate PRA quality requirements the industry recommends in order to implement MSPI. NEI previously stated their intent to submit this letter soon after the June 20-21, 2005, MSPI workshop, when there will be a better understanding of the challenges licensees are facing in meeting these requirements. The alternate requirements need to be submitted, reviewed by the joint NRC/industry MSPI PRA task group, and endorsed by the NRC/industry Reactor Oversight Process Working Group prior to September 1, 2005.

3.

The staff is currently performing a PRA comparison study that will group plants according to their risk-important plant attributes. The goal of this study is to find out how plants should be grouped together in order to determine the best method of identifying plant outliers. The results of this study will be reviewed against the results of the industrys own comparison study to assess the adequacy of the industry effort, and to independently evaluate and confirm candidate outliers identified by the two studies.

This effort is expected to be completed September 1, 2005. However, critical to the successful completion of this effort is understanding what criteria the various vendor groups used for determining plant groupings, and the comparative results sorted by plant name. If this information is not provided, it could hinder the ability of the staff to independently assess the PRA quality necessary for MSPI implementation and assess industrys alternative PRA approach.

4.

The output of the staffs work described in the paragraph above will be submitted to the staffs PRA quality review teams that will perform the first part of the MSPI implementation review. These teams are expected to start their reviews in mid-September and end no later than early November, 2005, based on the current schedule and assuming the comparison studies are completed on time. Any significant findings or discrepancies identified by these teams must be satisfactorily addressed prior to MSPI implementation.

My staff plans to discuss these critical path items with industry at the next MSPI public meeting.

Please contact John W. Thompson of my staff at 301-415-1011 if you have any questions.

Sincerely, J. E. Dyer, Director /RA/

Office of Nuclear Reactor Regulation

ML051640463 OFFICE NRR/DIPM/IIPB NRR/DIPM/IIPB/SC NRR/DIPM/IIPB/BC NRR/DSSA/PSPB NRR/DIPM/D NRR/D NAME JThompson JAndersen SRichards MTschiltz BBoger JDyer DATE 6/15/05 6/15/05 6/15/05 6/16/05 6/17/05 6/17/05