ML17264A065

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Task Order No. NRC-HQ-20-17-T-0016 Under Interagency Agreement No. NRC-HQ-25-14-D-0001
ML17264A065
Person / Time
Issue date: 09/20/2017
From: Carolyn Cooper
Acquisition Management Division
To: Madera G
Pacific Northwest National Laboratory
References
NRC-HQ-25-14-D-0001
Download: ML17264A065 (15)
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Text

PAGE OF INTERAGENCY AGREEMENT

,j NRC-HQ-20-17-T-0016 1 3

2. ORDER NO 3. REQ.UISITION NO. 4 SOLICITATION NO NRR~-17-0175 1
5. EFFECTIVE DATE 6: AWARD DATE 7. PERIOD OF PERFORMANCE 08/22/2017 /22/2017 08/23/2017 TO 04/30/2018
8. SERVICING AGENCY ij 9.DEUVER TO PACIFIC NORTHWEST NAT LAB BERNARD GRENIER ALC: :1 US NUCLEAR REGULATORY COMMISSION DUNS: 000000000 +4:

" ONE WHITE. FLINT NORTH BUILDING US DEPARTMENT OF ENERGY ;; 11555 ROCKVILLE PIKE

  • i PACIFIC NORTHWEST SITE O~FICE MAIL STOP 0-10Cl5 PO BOX 350 MS K9-42 ROCKVILLE MD 20852 RICHLAND WA 99352 POC Genice Madera TELEPHONE NO. 509-372-4010
10. REQUESTING AGENCY 'ii! 11. INVOICE OFFICE ACQUISITION MANAGEMENT DJ'iVlSION

.1 US NUCLEAR REGULATORY COMMISSION ALC: 31000001

1 ONE WHITE FLINT NORTH DUNS: 040535809 +4: "

il US NUCLEAR REGULATORY cot-fr.ass ION 11555 ROCKVILLE PIKE TWO WHITE FLINT NORTH i MAILSTOP 03-E17A 11545 ROCKVILLE PIKE

  • I MAIL STOP T-8E06M I ROCKVILLE MD 20852-2738 ROCKVILLE MD 20852-2738 Poe Carolyn A. Cooper I

TELEPHONE NO. 3 Q1- 4 15- 6 7 3 4 :i

12. ISSUING OFFICE 13. LEGISLATIVE AUTHORITY Energy Reorganization Act of 1974 US NRC - HQ i ACQUISITION MANAGEMENT D~VISION MAIL STOP TWFN-8E06M WASHINGTON DC 20555-0001 14 PROJECT ID 15_ PROJECT TITLE REVIEW THE SEISMIC PRA SUBMITT.Z\L FOR BEAVER VALLE 16 ACCOUNTING DATA :1 2017-X0200-FEEBASED-20-2QD007-1062-11-4-212-253D-ll-4-212-1062
17. 1J 18. 19. 20. 21 22 ITEM NO. :i SUPPLIES/SERVICES QUANTITY UNIT UNIT PRICE AMOUNT NRC-HQ-20-17-T-00!6 The NRC and Paciflc Northwest National Laborato y (PNNL) hereby ent~r into this Agreement Task Order Number NRc-,rQ-20-17-T-0016; for the projec entitled, " Revieif1 of Beaver Valley Units 1 and 2 Seismic Probabili~tic Risk Assessment Submittal 4 .

in Response to thf March 12, 201~ 50.54(f) Lett r (NTTE' Recommendat;j.on 2 .1 SeismicJ:*."

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.j NRC COR: Bernard:\ Grenier (301)4l5-2726 ALT COR: Sara Lyi;:ms i (301)415-2861

'I Continued :1 2J. PAYMENT PROVISIONS 25a SIGNATURE OF GOVERNMENT REPRESENTATIVE 1jSERVIC1NG) l11 251> NAME AND TITLE 1:

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1 1EMPl.Alt . Anun01 SEP 2 0 2011

IAANO NRC-HQ-20-17-T-0016 IORDER NO PAGE 2

OF I3 PNNL PI: Gar ill !~oles (509)372-6246 PNNL PM: Tara O~~eil (541)738-0362

"'i ii The period of pe~formance

., of this project shall commence on Augusit 23, 2017 and shall end on

~pril 30, 2018. ~btwithstanding the agreement effective dates d~d period of performance start ii dates stated els~~here in the agreement, the effective date o~ the agreement and start date of the period of pe~formance are the last date of signature by the iparties.

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I Consideration an~ Obligations:

i1 (a) Authorized cd st Ceiling $157 202. 00.

I (b) The amount p~lesently obligated with respect to this DOE Agre~~ent is $50,500.00 When and if the amount(s) pa~~ and payable to the DOE Laboratory hereunber shall equal the obligated amount, the DOE ~laboratorv s~all. not be obligated

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to continue perf~[rmance of the work unless and until the NRC Coritracting Officer shall increase the amount oblig~lted with respect to this DOE

~greement. Any 1ork undertaken by the DOE Laboratory in exd,ess of the obligated amount

'r specified above ~s done so at the DOE Laboratory's sol~ risk.

The following do~Lmen t is hereby made a part of this Agreement: !\

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!Attachment No. l:i! Statement of Work 1l trhis agreement i~i entered im:o pursuant to the authority of the fnergy Reorganization Act of 1974, as amended ij(42 U.S.C 5801 et seq.). This

!work will be perf~rmed in accordance with the

~RC/DOE MemorandJ~ ,, of Understanding dated November 24, 199cil. To the best of our knowledge, the work request~6 will not place the DOE and its contractor in diJ 1ect competition with the domestic. private

' u1sector.

1I Ii IThis 1-<'ork is Fee !Recoverable 1;

Work.

CAC Number Descr~ption: Beaver Valley Nuclear Plant Units 1 & 1 CAC Numbers are a*s follows: MG0096 (Unit 1)

IMG0097 (Unit 2) !I Continued ~

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IA.ANO NRC-HQ-20-17-T-0016 IORDER NO PAGE 3

OF I3 li ii DUNS: 040535809 i TAS: 31X0200.32~

~LC: 31000001 ~

Master IAA: NRCH~2514D0001 II 11 i

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DEPARTMENT OF ENERGY- PNSO ACCEPTANCE

1. TO 2. AGREEMENT NUMBER AMOUNT (as Listed on Agreement)

NRC Office of Nuclear Reactor Regulation 1 NRCHQ2017T0016 $50,500.00

4. The Agree111ent identified above is accepted and the items requested will be provided as follows: (Check as Applicable) a.
b. *0 ALL ITEMS WILL BE PROVIDED THROUGH REIMBURSEMENT (Category I)

ALL ITEMS WILL BE PROCURED BY THE DIRECT CITATION OF FUNDS (Category II)

c. 0 ITEMS WILL BE PROVIDED BY BOTH CATEGORY I AND CATEGORY II AS INDICATED BELOW
d. 0 THE ACCEPTANCE, FOR CATEGORY I ITEMS, IS QUALIFIED BECAUSE OF ANTICIPATED CONTINGENCIES AS TO FINAL PRICE.

CHANGES IN THIS ACCEPTANCE FIGURE WILL BE FURNISHED PERIODICALLY UPON DETERMINATION OF DEFINITIZED PRICES, BUT PRIOR TO SUBMISSION OF BILLINGS.

5. 0 AGREEMENT ITEM NUMBER(S) IDENTIFIED IN BLOCK 13, "REMARKS," IS NOT ACCEPTED (JS REJECTED) FOR THE REASONS INDICATED.
6. TO BE PROVIDED THROUGH REIMBURSEMENT 7. TO BE PROCURED BY DIRECT CITATION OF FUNDS CATEGORY I CATEGORY II ITEM NO. QUANTITY ESTIMATED PRICE ITEM NO. QUANTITY ESTIMATED PRICE
a. b. c. a. b. c.

$50,500.00

d. TOTAL ESTIMATED PRICE $50,500.00 e. TOTAL ESTIMATED PRICE
8. ANTICIPATED DATE OF OBLIGATION FOR CATEGORY II ITEMS 9. GRAND TOTAL ESTIMATED PRICE OF ALL ITEMS
10. FUNDS DATA (Check if Applicable)
a. 0 ADDITIONAL FUNDS IN THE AMOUNT OF$ ARE REQUIRED (See justification in Block 13)
b. 0 FUNDS iN THE AMOUNT OF$ ARE NOT REQUIRED AND MAY BE WITHDRAWN
11. REMARKS Action authorized to support DOE Project No. 71370A Consistent with the Department of Energy's (DOE) full cost recovery policy, DOE collects, as part of its standard indirect cost rate, a Laboratory Directed Research and Development (LORD) cost. Based on the amount of funds being accepted for this project, $770,500 represents the estimated amount that will be used for LORD efforts. The LORD amount might be different than what was proposed due to the timing of the proposal and the function action due to a proposed accounting change that is awaiting DOE approval. DOE believes that LORD efforts provide opportunities in research that are instrumental in promoting cutting-edge science capabilities. In addition, DOE believes these capabilities benefit all the customers at the laboratory. By providing funds to DOE to perform work, you acknowledge that such activities are consistent with appropriations acts that provide funds to you.
12. ACCEPTING ACTIVITY 13. TYPED NAME AND TITLE OF AUTHORIZED OFFICIAL U.S. Department of Energy Pacific Northwest Site Office Melanie P. Fletcher, Contractin! Officer
14. SIGNATURE 15. DATE P.O. Box 350 (Mail Stop K9-42)

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Richland, WA 99352 9/15/2017

NRC-HQ-25-14-D-0001 NRC-HQ-20-_17-T-0016 Attachment No. 1 STATEMENT OF WORK NRC Agreement Number NRC Agreement Modification NRC Task Order Number (If NRC Task Order Number Applicable) Modification Number (If Applicable)

NRC-HQ-25-14-0-0001 NRC-HQ-20-17-T-0016 N/A Project Title Review of Beaver Valley Unit 1 and 2 Seismic Probabilistic Risk Assessment (SPRA) Submittal, in Response to the March 12, 2012 50.54(f) Letter (NTTF Recommendation 2.1: Seismic)

Job Code Number B&R Number DOE Laboratory Cost Center 1062 11-4-212 Pacific Northwest National Laboratory NRC Requisitioning Office Nuclear Reactor Regulation (NRR), Division of Risk Assessment (DRA)

NRC Form 187, Contract Security and Classification Requirements

[8] Involves Proprietary Information D Applicable D Involves Sensitive Unclassified

[8] Not Applicable D Non Fee-Recoverable ~Fee-Recoverable (If checked, complete all applicable sections below)

Docket Number (If Fee-Recoverable/Applicable) Inspection Report Number (If Fee Recoverable/Applicable) 05000334,05000412 N/A I

Technical ~ssignment Control Number (If Fee- Technical Assignment Control Number Description (If Fee-Recoverable/Applicable) Recoverable/Applicable)

TBD Beaver Valley Nuclear Plant, Units 1 and 2

1.0 BACKGROUND

On March 11, 2011, a 9.0-magnitude earthquake struck Japan and was followed by a 45-foot tsunami, resulting in extensive damage to the nuclear power reactors at the Fukushima Dai-ichi facility. The NRG has taken significant action to enhance the safety of reactors in the United States based on the lessons learned from this accident.

Operating reactor sites are using present-day information to reevaluate the earthquake effects-or hazards-that could impact their site. These newly reevaluated hazards, if worse than what the plant had originally calculated, will be analyzed to determine if plant structures, systems, and/or components need to be updated to protect against the new hazard. The NRG will review each step in the analysis process and take further regulatory action if necessary. Depending on the comparison between the re-evaluated seismic hazard and the current design basis, the result is either no further risk evaluation or the performance of a seismic risk assessment. Risk assessment approaches acceptable to the staff include a seismic probabilistic risk assessment (SPRA), or a seismic margin assessment (SMA).

1.0 BACKGROUND

(CONTINUED)

One acceptable approach for determining the technical adequacy of the SPRA is described in RG 1.200, Revision 2, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Agencywide Document Access and Management System (ADAMS) Accession No. ML090410014, ASME/ANS RA-SA-2008 (Reference 1) and ASME/ANS RA-SA-2009 (Reference 2). Consistent with the NRC's probabilistic risk assessment (PRA) policy statement, the technical adequacy of the methods used to develop the requested information must be sufficient to provide confidence in the results, such that the seismic risk information can be used in regulatory decision-making.

About 20 nuclear power plant sites are scheduled to submit a SPRA responses to the 50.54(f) letter (se_ismic), ADAMS Accession No. ML12053A340. Beaver Valley is one of the nuclear power plants that has submitted a response to 50.54(f) letter. These responses will be reviewed according to the guidance in the EPRl-NEI SPID 1 document (Reference 3) which was endorsed by the staff for this purpose. Peer reviews are to follow the guidance in NEI 12-13, "External Hazards PRA Peer Review Process Guidance," dated August 2012 (Reference 4) which was reviewed by the staff, as documented in an NRC letter to the Nuclear Energy Institute dated November 16, 2012 (Reference 5). The SPRA responses will be reviewed against specific Review Guidance and a process which has been developed to define the appropriate scope, and allow for more uniform reviews which focus on the most important technical topics. The Review Guidance uses a check-list type of format; see Attachment 1.

The results of this evaluation will enable the NRC staff to determine whether any additional regulatory action is needed by examining not only the important accident sequences but also assessing the seismic risk for the basic events representing systems, structures and components (SSCs) resulting in the Seismic PRA (SPRA) model.

2.0 OBJECTIVE The objective of this task order is to obtain technical expertise from Pacific Northwest National Laboratory (PNNL) to assist the NRC staff in determining the technical adequacy of the SPRA methods and sufficiency of the fragility analysis used in the Beaver Valley SPRA response such that NRC can have confidence in the results and use of them in regulatory decision making.

3.0 SCOPE OF WORK PNNL must provide all resources necessary to accomplish the tasks and deliverables described in this statement of work (SOW).

Using the guidance contained in EPRl-SPID, 2012 and review guidance contained in , PNNL is to review and evaluate the technical adequacy of the Beaver Valley Nuclear Power Plant, Units 1 and 2 response to the 50.54(f) letter, identify and develop, if necessary, a summary of information deficiencies, draft clarification questions and additional information requests and prepare a technical letter report (TLR) of the results of the review and evaluation; and, as part of the TLR, recommend whether any and what type of regulatory action may be needed.

1 Screening, Prioritization and Implementation Details (SPID) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic 2

3.0 SCOPE OF WORK (CONTINUED)

The parts of the SPRA submittal to be reviewed by PNNL are limited to the following: 1) plant response associated with the plant seismic accident sequence model and the quantification of results; 2) plant seismic logic model and fragility determination; 3) Submittal appendix A -

Seismic PRA Technical Adequacy Assessment and Peer Review.

4.0 SPECIFIC TASKS PNNL must perform the following tasks:

Completion Schedule

1. Based on the criteria found in NTTF 2.1 (seismic) Four weeks from and EPRl-SPID, 2012, the EPRl-SPID and other authorization of work.

regulatory guidance, such as RG 1.200, RG 1.174, SRP 19.1, SPR 19.2, etc., determine whether the response contains sufficient information to enable the staff to perform a detail review of the response.

Specifically, determine if the response provides sufficient information to understand the inputs and methods used, the evaluations performed and the decisions made as a result of the insights gained from the Beaver Valley SPRA. The types of information with the SPRA reporting shall satisfy the requirements in the 50.54(f) letter. Specifically, review:

  • The list of the significant contributors to seismic core damage frequency (SCDF) for each seismic acceleration bin, including importance measures (e.g. Risk Achievement Worth, Fussel-Vesely and Birnbaum).
i. Methodologies used to quantify the seismic fragilities of SSCs, together with key assumptions.

ii. SSC fragility values with reference to the method of Seismic qualification, the dominant failure mode(s),

and the source of information iii. Seismic fragility parameters iv. Important findings from plant walkdowns and any corrective actions taken.

v. Process used in the seismic plant response analysis and quantification, including the specific adaptations made in the internal events PRA model and their motivation.

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4.0 SPECIFIC TASKS (CONTINUED)

Completion Schedule vi. Assumptions about the containment performance.

  • Description of the process used to ensure that the SPRA is technically adequate, including the dates and findings of any peer reviews.
  • Identified plant-specific vulnerabilities and actions that are planned or taken.

Identify information deficiencies and develop clarification questions and additional information requests along with the basis for such requests. Prepare a TLR.

2. Based on the staff review guidance checklist found at Eight weeks after Attachment 1, review and evaluate the Beaver Valley, completion of Task 1.

Units 1 and 2 response to the 50.54(f) letter in the areas of fragilities and system plant response (SPR) and determine if the response is suitable for decision-making.

With respect to the review guidance checklist (Reference 6), the information should be provided based on the following areas:

Fragilities -Topical Sections 4, 5, 6, 8, 9, 10, 12, appropriate parts of 7, 11, 14, 15, 16 SPRA - Topical Sections 12 and 13 and appropriate parts of 14, 15 and 16.

Identify areas where any clarification and/or any additional information is needed. Prepare a TLR using the checklist as guidance for writing the report.

3. Review and evaluate licensee responses and determine Two weeks after receipt if the response(s) adequately address the open issues. of the response(s).

If the response(s) is not acceptable, discuss the response(s) with the NRC staff who may determine that a conference call is needed to discuss the response(s) with the licensee in which case the Principal Investigator (Pl) will be notified and a mutually acceptable date to participate in the conference call will be set. If the response is deemed inadequate, prepare proposed follow-up requests along with the bases. Incorporate the results in the TLR prepared under Task 2 and submit the updated TLR.

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-i 4.0 SPECIFIC TASKS (CONTINUED)

Completion Schedule

4. Review and assess any potential substantial safety Two weeks from Improvements as may be directed by the staff. receipt of the request from the COR.

a) Based on guidance contained in the guidance document identify potential substantial safety improvements or the recommendation for no further action.

b) Review licensee-provided list of safety improvements (if any) to inform plant group recommendation.

  • c) Based on guidance contained in the guidance document, insights from previous reviews, and licensee-identified/

planned modifications, review and assess any potential substantial safety improvements to the extent necessary to support a draft recommendation for the TRB that the plant be moved forward as a Group 1, 2, or 3 plant.

Prepare a technical letter report.

5. Audit2
a. Prepare for the audit by reviewing the appropriate One week prior to the references whi'ch will be provided. Prepare a technical scheduled audit.

report consisting of input to the audit plan.

b. Travel to the licensee site and participate in the audit in accordance with LIC-111, "Regulatory Audits" to review the areas reviewed under Tasks 1 and 2; identify the need for any additional information or clarifications.

Prepare TLRs as follows:

(1) Prepare on-site clarification questions and additional One day prior to the exit information requested, if necessary. meeting.

(2) Prepare a trip report. One week after the on-site audit.

6. Upon notification by the Contracting Officer Representative (COR) and/or receipt of final comments from the COR, update the TLR.
a. Draft. Two weeks after notified by the COR.

2 An audit will be performed if directed by the NRC Technical Review Board s

4.0 SPECIFIC TASKS (CONTINUED)

Completion Schedule

b. Incorporate NRG comments and prepare the final Two weeks after receipt report. of NRG comments.

5.0 DELIVERABLES AND/OR MILESTONES SCHEDULE See Section 4.0 6.0 TECHNICAL AND OTHER SPECIAL QUALIFICATIONS REQUIRED One senior PRA specialist on a part-time, intermittent basis, who are knowledgeable in U.S.

nuclear power plant systems and operations and who possesses in-depth knowledge and experience in nuclear power plant probabilistic risk assessment.

One Structural Engineer on a part-time, intermittent basis who have fundamental understanding and proven experience in structural mechanics as applicable to assessment of nuclear power plant structures and components.

Note: more than one PRA specialist and one structural engineer may be assigned but within the same level of effort.

7.0 MEETINGS AND TRAVEL One two-person, three-day trip to the licensee site located in Shippingport, PA.

8.0 REPORTING REQUIREMENTS PNNL is responsible for structuring the deliverables to follow agency standards. The current agency standard is Microsoft Office Suite 2013. The current agency Portable Document Format (PDF) standard is Adobe Acrobat XI Professional. Deliverables must be submitted free of spelling and grammatical errors and conform to requirements stated in this section.

Technical,Reporting Requirements NOTE: The transmittal letter and cover page shall contain the job code number (JCN), the task order number and title.

1. At the completion of Task 1, submit a TLR report that contains a summary of the work performed and the recommendation as to the completeness and acceptability of the submittal and any request(s) for additional information based on the deficiencies found.
2. At the completion of Task 2, submit a TLR that consists of the completed review guidance checklist along with a determination of technical adequacy of SPRA submittal and suitability for regulatory decision-making. Include a list of technical deficiencies along with their bases.

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3. At the completion of review of each request to evaluate the responses under Task 3, submit the updated TLR along with any outstanding/new requests which clearly articulates the bases for the need for further information or discussion.
4. At the completion of Task 4, submit a TLR that contains the recommendation on whether any potential backfit may be warranted along with the bases for such a proposal.
5. At the completion of Task 5.a., submit a TLR that contains input to the audit plan.
6. At the completion of Subtask 5.b.(2), submit a trip report that contains summary of the activities performed during. the audit and a summary of significant highlights, observations, insights, and findings. Include the title and description of any documents, slides, or other materials reviewed on the trip. As appropriate, describe possible resolution of the findings/observations, noting disposition responsibility (if appropriate) of the items presented and reviewed.
7. At the completion of Task 6, submit the final TLR, draft and final as appropriate, that contains the completed review guidance checklist along with a summary of the results of the evaluation findings.

9.0 PERIOD OF PERFORMANCE The period of performance of this task order is August 23, 2017 through April 30, 2018.

10.0 CONTRACTING OFFICER'S REPRESENTATIVE The COR monitors all technical aspects of the agreement/task order and assists in its administration. The COR is authorized to perform the following functions: assure that the PNNL performs the technical requirements of the agreement/task order; perform inspections necessary in connection with agreement/task order performance; maintain written and oral communications with PNNL concerning technical aspects of the agreement/task order; issue written interpretations of technical requirements, including Government drawings, designs, specifications; monitor PNNL's performance and notify PNNL of any deficiencies; coordinate availability of NRG-furnished material and/or GFP; and provide site entry of PNNL personnel.

COR: Bernard L.Grenier,Bernard.Grenier@nrc.gov, 301/415-2726 Alternate COR: Sara Lyons, Sara.Lyons@nrc.gov, 301/415-2861 Technical Reviewer (Plant Response): Courtney St. Peters Technical Reviewer (Fragility): Ian Tseng Project Manager: Sara Lyons 11.0 MATERIALS REQUIRED N/A 12.0 NRC-FURNISHED PROPERTY/MATERIALS A copy of the Review Project Plan, to include the Review Guidance Checklist which define the scope of the review was provided to the Pl under separate cover.

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The ADAMS Accession No. for the Beaver Valley, Units 1 and 2 SPRA Submittal is ML17213A014.

NOTE: Some of these documents contain proprietary information and must be safeguarded against unauthorized disclosure. After completion of work, the documents should either be destroyed or returned to NRG. If they are destroyed, please confirm this in an E-mail to the COR and include the date and manner in which the documents were destroyed.

PNNL shall identify any additional NRG documentation that is needed and the COR will determine whether these will be provided by the NRG or obtained directly by PNNL from' ADAMS, NRG public document room or the NRG website at www.nrc.gov.

13.0 RESEARCH QUALITY N/A 14.0 STANDARDS FOR CONTRACTORS WHO PREPARE NUREG-SERIES MANUSCRIPTS N/A 15.0 OTHER CONSIDERATIONS Assumptions and Understandings It is assumed that the contractor staff personnel who are going to conduct the work have participated in the Review Orientation Session held in February 2017, and that it is understood that the preferable approach to conduct the review is to begin with Review Guidance Checklist Item number 14.

  • It is understood that the level of effort for each Task includes sufficient effort to participate in telephone conference calls with the NRG staff for the purpose of addressing comments by the staff and responses from the licensee.

The assumption for the level of effort for Task 5, 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />, is based upon eight hours for input into the audit plan, eight for preparation and travel to the site, eight hours for the audit and eight hours for return travel and preparation of the trip report.

References

1. ASME/ANS RA-S-2008, "Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications", American Society of Mechanical Engineers and American Nuclear Society, 2008
2. ASME/ANS 2009: "Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications", American Society of Mechanical Engineers and American Nuclear Society, 2009 8
3. EPRl-SPID, 2012: "Screening, Prioritization and Implementation Details (SPID) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic", Electric Power Research Institute, EPRI report 1025287, November 2012
4. NEI, 2012: NEI 12-13 "External Hazards PRA Peer Review Process Guidelines" Nuclear Energy Institute, August 2012(ML12240A027).
5. NRG, 2012: "U.S. Nuclear Regulatory Commission Comments on NEI 12-13, 'External Hazards PRA Peer Review Process Guidelines' Dated August 2012", NRG letter to Nuclear Energy Institute, November 16, 2012(ML12321A280) 6 .. NRG Staff Review Guidance for Seismic PRA Submittals and Technical Review Checklist, Bob Budnitz, revised version, dated 3 August, 2016 9

Attachment 1 REVIEW PROCESS The SPRA review process has been scoped such that the level of effort is reduced from that of a license amendment request review. The review should focus on those aspects that aid the SMRP in determining whether a potential backfit should be considered under existing processes described in the Phase 2 decision-making guidance. Reviewer questions and concerns that come up during the review process should be balanced against whether the question or concern will be relevant to determining whether the SPRA is adequate for decision-making, as well as the impact on Phase 2 related decision-making.

The review process is described below:

1) NRC receives the licensee's submittal, which contains a description of the SPRA results, including: *
a. SCDF and SLERF values J
b. List of the significant contributors to SCDF for each seismic acceleration bin, including importance measures (e.g., Risk Achievement Worth, Fussell-Vesely, and Birnbaum)
c. A summary of the methodologies used to estimate the SCDF and SLERF, including the following:
i. Methodologies used to quantify the seismic fragilities of SSCs, together with key assumptions ii. SSC fragility values with reference to the method of seismic qualification, the dominant failure mode(s), and the source of information iii. Seismic fragility parameters iv. Important findings from plant walkdowns and any corrective actions taken
v. Process used in the seismic plant response analysis and quantification, including the specific adaptations made in the internal events PRA model to produce the SPRA model and their motivation iv. Assumptions about containment performance
d. Description of the process used to ensure that the SPRA is technically adequate, including the dates of and findings from any peer review(s) vi. Plant-specific vulnerabilities identified and actions that are_

planned or taken

2) The assigned review team confirms that the SPRA was developed using acceptable methods and is of acceptable quality. For this purpose, the reviewers will use the SPRA review checklist. The assigned review team is not expected to perform confirmatory calculations. The review team will rely on peer review findings to determine whether an acceptable level of technical adequacy has been achieved. The team may need to develop RAls or perform an audit in order to complete this step. RAls will be vetted by the SPRA Technical Review Board prior to sending them to the licensee.

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3) Given acceptable results from step 2, the assigned review team will utilize a guidance document that is currently in development and provide the technical team lead with input to be assembled in a briefing package which will be used to communicate the team's findings with the SPRA Technical Review Board. The contents and level of detail included in the briefing packages will vary based on the difficulty of the review and the risk insights gained from the submittal, with the focus being on providing the SPRA Technical Review Board with a draft recommendation for classifying the plant as a Group 1, 2, or 3 site.
4) The assigned review team will continue to interact with the TRB to further develop the draft recommendation until the TRB determines that they are prepared to move a recommendation forward to the SMRP. Any additional RAls will be vetted by the SPRA Technical Review Board prior to sending them to the licensee. (Note: RAls are possible at several stages of the review. These RAls are not considered subsequent rounds of RAls if they are needed to complete the various steps of the review. However, if multiple rounds of RAls are needed to complete the same step, the RAls will need to be elevated through the TRB prior to sending them to the licensee.)

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