ML18025C025
| ML18025C025 | |
| Person / Time | |
|---|---|
| Issue date: | 03/07/2018 |
| From: | Mike Franovich Office of Nuclear Reactor Regulation |
| To: | Krueger G Nuclear Energy Institute |
| M. Drouin 415-2091 | |
| Shared Package | |
| ML18025C022 | List: |
| References | |
| NEI 12-13 | |
| Download: ML18025C025 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 7, 2018 Mr. Greg Krueger, Director, Risk Regulation Nuclear Energy Institute 1201 F St. NW, Suite 1100 Washington, DC 20006
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION ACCEPTANCE OF NUCLEAR ENERGY INSTITUTE (NEI) GUIDANCE NEI 12-13, EXTERNAL HAZARDS PRA PEER REVIEW PROCESS GUIDELINES (AUGUST 2012)
Dear Mr. Krueger:
The Nuclear Energy Institute (NEI) published NEI 12-13, External Hazards PRA Peer Review Process Guidelines, (August 2012) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12240A027) and provided it to the U.S. Nuclear Regulatory Commission (NRC) in a letter dated August 21, 2012 (ML12240A025). NEI 12-13 states that the objectives of the External Hazards Peer Review process are to provide (1) a consistent and uniform method for establishing the technical adequacy of an External Hazards PRA that addresses risk from a particular set of hazards, for a spectrum of potential risk-informed plant licensing applications for which the External Hazards PRA assessment may be used; and (2) a means for identifying, over time, areas of consistency or inconsistency in the treatment of issues important to understanding plant external event risk and implementing risk-informed applications. The letter indicated that NEI 12-13 would be revised pending trial application of the guidance.
On November 16, 2012, the NRC issued a letter providing staff comments on the guidelines (ML12321A280). The NRC 2012 letter documents staff comments that should be addressed during the initial exercising of the process and when revising the guidance. Moreover, in its 2012 letter, the NRC staff indicated its intention to continue to work with NEI and industry during the initial use of the guidance to further the NRC confidence in the implementation of the guidance. To date, NEI has not revised NEI 12-13 in response to the NRCs letter dated November 16, 2012.
The NRC staff has revisited the comments provided in its letter dated November 16, 2012, and through this letter is providing new and revised comments on NEI 12-13 and attached in (ADAMS Accession No. ML18025C024). These comments supersede the comments in the 2012 letter. The NRC staff finds the process proposed in NEI 12-13, as modified by the attached comments, is suitable for licensees to use in risk-informed licensing applications. Following the guidance in NEI 12-13, as modified by the attached comments, will reinforce the NRC staffs confidence in the licensees process and potentially obviate the need for a more in-depth review.
A PRA method is new if it has not been reviewed by the NRC staff for the licensee.
G. Krueger There are two ways new methods are considered accepted by the NRC staff: (1) the new method has been explicitly accepted by the NRC (i.e., it has been reviewed and the acceptance has been documented in a safety evaluation, frequently-asked-questions, or other publicly available organizational endorsement), or (2) the new method has been implicitly accepted by the NRC (i.e., there has been no documented denial) in multiple risk-informed licensing applications. The NRC staff recognizes that the definition of a new PRA method is currently being assessed separately by the industry and NRC. This definition, once finalized, will supersede the definition provided above.
Licensees may choose to retain their facilitys current PRA peer review approach, or revise it to be consistent with NEI 12-13, as modified by the attached comments. Any licensees use of NEI 12-13, as modified by the attached comments, is voluntary. Further, the NRC does not plan to endorse NEI 12-13, as modified by the attached comments, or NEI 12-13 as submitted, in the next revision of RG 1.200 (estimated draft revision for public comment 2018 and publication 2019). Instead, the NRC staff currently plans to consider endorsement of NEI 17-07 in the next revision to RG 1.200. In updating RG 1.200, the staff may ultimately take positions different from those in either NEI 12-13 or NEI 17-07. The NRCs ultimate endorsement (or non-endorsement) of NEI 12-13 or NEI 17-07, or parts thereof, would not constitute backfitting to the extent that the ultimate position does not impose a regulatory staff position interpreting the Commissions regulations that is either new or different from previously applicable staff positions.
The NRC also may periodically conduct audits of a licensees implementation of NEI 12-13. The purpose of the audits is to further NRC confidence in the process for peer review of external hazards PRAs and to provide continued monitoring and oversight of PRA acceptability.
The NRC looks forward to continuing to work with the industry, and other stakeholders on fostering an environment conducive to achieving the full benefit of risk-informed regulation.
Please contact Mary Drouin at 301-415-2091, mary.drouin@nrc.gov, if you have any questions.
Sincerely,
/RA/ R. Felts for Mike Franovich, Director Division of Risk Assessment Nuclear Reactor Regulation
DISTRIBUTION:
A. Gilbertson S. Rosenberg J. Robinson S. Lyons S. Vasavada M. Stutzke ADAMS Accession No.: ML18025C022 OFFICE RES/DRA RES/DRA RES/DRA NRR/DORL NRO/DSRA OGC NRR/DRA NAME M. Drouin H. Rasouli M. Cheok G. Casto J. Monninger D. Roth M. Franovich (Via email) (via email) (R. Felts for)
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