ML17289A708
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| ML17289A708 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 10/17/2017 |
| From: | Anderson V, Demoss G, Krueger G, Linthicum R Nuclear Energy Institute |
| To: | NRC/RES/DRA/PRB |
| References | |
| RG-1.200 | |
| Download: ML17289A708 (8) | |
Text
INDUSTRY INPUT ON REGULATORY GUIDE 1.200 CHANGES Roy Linthicum Gary DeMoss Victoria Anderson Greg Krueger October 17, 2017
SEISMIC PRA CODE CASE COMMENTS
- 1. The Code Case does NOT rescind or replace the Standard that it is based on. It provides an alternative way of compliance, so meeting the original Addendum B Part 5 still complies with the Standard
- 2. You cant mix-and-match the Supporting Requirements (SRs) from Addendum B with the Code Case on Addendum B - you must use one or the other in total
- 3. The Code Case did not address all the consistency issues across the Parts of the Standard, because that also requires all the Parts to change. (I.e., the code case is consistent with Addendum B, and Part 5 will be brought into consistency with the new edition of the Standard along with the other Parts, which will address all remaining open issues) 2
TREATMENT OF NEW METHODS
- 1. NEI 16-04 guidance document effort suspended
- Requested revisions would not have resulted in efficiencies over existing processes
- 2. New methods will be addressed via existing processes with augmented guidance for peer review teams 3
INDUSTRY PLANS FOR PEER REVIEW GUIDANCE
- 2. Will include new language on treatment of new methods in peer review
- 3. Will work with NRC to support schedule needs for RG 1.200
- Willing to discuss earlier issuance if interim approval is available 4
MOST IMPORTANT RECOMMENDED CHANGES TO RG 1.200
- 1. Include a definition (rather than a footnote) for Key sources of uncertainty and Key assumptions
- Set expectations on what should be submitted
- 2. Desire endorsement of updated Peer review process & F&O closure process
- Industry to include process for reviewing new to the industry methods
- Industry to include how to document Peer Review assessment of Key Sources of uncertainty and key assumptions
- What schedule does NRC need to endorse?
- 3. Clearly identify what documentation is required to be submitted and what should be archival
- Currently get requests for Archival documentation to be submitted (e.g., peer review 5 finding results and resolution)
MOST IMPORTANT RECOMMENDED CHANGES TO RG 1.200 (CONT.)
- 4. Methods and new to the industry methods should be defined
- 5. A listing of NRC approved methods should be provided
- 6. Definitions of significant accident sequence and significant basic event/contributor should eliminate the numerical values or reference the new decision being developed for the PRA standard
- The next edition of the Standard is proposing to change the definitions to remove the numbers. RG 1.200 should endorse this change.
6
ADDITIONAL RECOMMENDED CHANGES TO RG 1.200
- 1. Retain the term PRA Technical Adequacy versus Acceptability
- 2. Endorsement of current Standard if next revision of the Standard is not ready on RG revision schedule
- 3. The LPSD standard should not be endorsed
- No current or anticipated applications require it
- 4. Revision and implementation schedule should consider impact on in-process applications
- Utilities need to understand NRC expectations, including gap assessments 7
ADDITIONAL RECOMMENDED CHANGES TO RG 1.200 (CONT.)
- 5. Treatment of bounding analysis for RI LARs should be discussed
- Example - use of seismic penalty for Risk Informed Completion Time
- 6. A proposed Non-mandatory Appendix on multi-unit risk is being added to the Standard. RG 1.200 should not endorse at this time
- No consensus on How it should be calculated
- 7. Screening should be allowed for low Seismic Hazard plants
- 8. Eliminate the discussions that ASME Capability Category III is appropriate for some applications
- The Standard is being revised to eliminate CC-III completely 8