ML052230040
| ML052230040 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/09/2005 |
| From: | Eugene Kelly Exelon Generation Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML052230040 (13) | |
Text
Piloting Regulatory Guide 1.200 Eugene Kelly Limerick Engineering Programs Manager RIC 2005 - Session Wed G4: Risk-Informed
Risk-Informed Session G4 Regulatory Information Conference March 9, 2005 2
Overview ASME Standard and Regulatory Guide were used to identify gaps Process is transportable Application success provides incentive Success drives model improvement
Risk-Informed Session G4 Regulatory Information Conference March 9, 2005 3
December 2003 Gap Analysis 84 actions to meet Category II Half are documentation-related 28 high priority actions Gaps addressed strategically
Risk-Informed Session G4 Regulatory Information Conference March 9, 2005 4
July 2004 NRC Audit Not peer review Focus on base Model Substantial changes to Category II Peer review recommended Significant agreement (LGS and NRC)
Risk-Informed Session G4 Regulatory Information Conference March 9, 2005 5
Significant Agreement 267 ASME supporting requirements 192 grades agreed with Exelon Approximately 80% are pass/fail 73 requirements not met 16 of 68 graded Category II
Risk-Informed Session G4 Regulatory Information Conference March 9, 2005 6
Areas for Improvement Documentation for pre-initiator HEPs Pedigree and consistency of HRA Enhanced references for data and bases for success criteria Increased use of plant-specific data Comprehensive system notebooks
Risk-Informed Session G4 Regulatory Information Conference March 9, 2005 7
Feedback on RG 1.200 Open-ended meaning of key assumptions and areas of uncertainty Significant differences term unclear Table B-4 does not address MU Absolute versus application-specific
Risk-Informed Session G4 Regulatory Information Conference March 9, 2005 8
Maintenance and Upgrade Precedent of update versus upgrade Exelon updates every 3 years Methodology for HRA and data Re-arrangement of event trees Expanded treatment of common cause
Risk-Informed Session G4 Regulatory Information Conference March 9, 2005 9
5b Application LAR submitted in June 2004 TSTF-425 and NEI 04-010 Guideline BWROG and NEI sponsorship Potential RAIs on justifying low priority gaps and diversity of HRA methods
Risk-Informed Session G4 Regulatory Information Conference March 9, 2005 10 Inter-relationships Maintenance Rule Surveillance Frequency Control Program Corrective Action Process
Risk-Informed Session G4 Regulatory Information Conference March 9, 2005 11 Administrative Controls Process mapping underway Analogous to Maintenance Rule Incorporate feedback from NSRB, Owners Group, PORC comments Continue conduct of pilot panels (IDP)
Risk-Informed Session G4 Regulatory Information Conference March 9, 2005 12 Cost and Impact RG 1.200 Gap Analyses PRA Model upgrade 5b Application Reliability data Peer review in 2005
Risk-Informed Session G4 Regulatory Information Conference March 9, 2005 13 Challenges Fire PRA and 2006 Standard Seismic and Appendix C Closing all the gaps Achieving full Category II capability Future changes and higher standards