ML18131A296
| ML18131A296 | |
| Person / Time | |
|---|---|
| Issue date: | 05/11/2018 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Spore C | |
| Shared Package | |
| ML18131A298 | List: |
| References | |
| Download: ML18131A296 (3) | |
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Risk Informed Steering Committee NRC Activity Status Activity Current Status Issue: Staff modified TSTF-505, the model application and the Model SE based on Vogtle pilot (no RICT for loss of function) for TSTF - 505 approved methods only.
Next Steps: NRC is sending a revised traveler to the TSTF in early May for their review. We expect to receive comments from TSTF (July) and address comments (August). In October, 2018 NRC will issue revision to traveler, model SE and model application to lift suspension.
Issue: NRC has informed industry that resources are available for 10 reviews/year for completion within 12 months of acceptance.
NRC currently has 13 LARs in-house LARs and anticipates 3 additional submittals in the near term. Inclusion of Class 1 piping is an 50.69 expansion of scope from the Vogtle pilot application and will result in increased level of effort for reviews and longer schedules, and although the NRC staff is aware that industry now plans to limit the scope to Class 2 and Class 3 consistent with the Vogtle pilot amendment, the NRC staff still needs to resolve the issue formally through docketed correspondence for the licensees who included Class 1 piping in their applications. The use of seismic alternatives for 50.69 is still an issue and a meeting between the NRC and Industry is tentatively scheduled for May 22nd or 23rd to discuss progress made since the last meeting.
Next Steps:
NRC: Process for review has been established. 13 LARs have been submitted. 12 of the LARs have been accepted for review.
Several audits have been conducted, and additional audits are being scheduled. An additional focused scope peer review is needed for one LAR which will cause a delay in some of the RAI responses from the licensee. In a few instances, staff has determined during the audits that the Appendix X Independent Assessment F&O Closure process has not been followed in its entirety. Technical issues are being discussed and paths to resolution identified.
Issue: The NRC discussed three different options for accepting newly developed PRA methods following approval of licensing New applications at a public meeting on Jan. 24th, and requested stakeholder feedback. The industry expressed interest in pursuing Methods Option 3, a Conceptual Industry Proposal for Newly Developed Methods. Option 3 would require licensee to submit a report to the NRC covering the scope of the PRA Upgrade. Staff provided comments and questions on NEIs initial proposal for Option 3. On April 30, 2018 NEI provided a revised proposal. Staff is reviewing the revised proposal in a broad context and has an internal meeting with other divisions in NRR next week. Staff will then discuss dates for a telecom or public meeting.
Next Steps:
NRC: If it is decided to choose any Option other than continuing the Methods Vetting Panel process, then the NRC may re-convene the Risk-Informed Steering Committee Working Group 1 to more fully develop the proposed process.
NRC: In the meantime, the NRC staff plans to retain a license condition that all new methods must be accepted by the NRC for 4b applications presently under review similar to the pilot Vogtle 4b license condition and the condition specified in the staffs SE for NEI 06-09 (4b).
Risk Informed Steering Committee NRC Activity Status Issue: Industry has indicated that an improvement in fire PRA realism is necessary to support risk informed regulatory applications.
The staff is supporting this effort, despite its ability to make risk informed decisions with the current level of realism as proven by the NFPA 805 program.
Next Steps:
Fire PRA NRC: Public fire PRA meeting held in mid-March, to follow up on mid-December and mid-February fire PRA public meeting actions.
Realism Resolution was recently reached on 3 FAQs (FAQ 16-0011 - Bulk Cable Tray Ignition, FAQ 17-0013 - HEAF Non-Suppression Probability, and FAQ 14-0007 - Transient Fire Frequency Likelihood). HEAF Phase II Information Sharing Workshop was held on April 18/19, 2018.
NRC and Industry: Continue to work towards resolution of existing draft fire PRA FAQs and continue discussion on potential new FAQs discussed during the previous meeting.
NRC: Provide comments on 3 FAQs (FAQ 18-0005 - Fire Duration Limits, FAQ 18-0014 - Zero Time to Detection for Manual Non-Suppression Probability Calculations, and FAQ 18-0017 - Conditional Trip Probability for Modeling Operator Discretion). NRR has engaged RES to develop User Need or Research Assistance Requests for projects that improve Fire PRA realism to include potential joint MOU projects with EPRI.
Issue: Develop and demonstrate implementation of a risk informed tornado missile protection evaluation model for licensees with non-compliant legacy design SSCs. NEI 17-02 Revision 1 drafted for use by pilot plants TMRE Next Steps:
NRC: Progress continues for reviews of LARs for the TMRE pilot plants. The Vogtle audit is underway, with discussion of all audit plan questions completed on April 4-6, and a follow up clarification audit scheduled for May 8-9. Since many questions are common for all pilots, the other two licensees are actively involved (through attendance and internal interface) in the Vogtle audit.
In addition, TVA observed the Vogtle audit in preparation for a post-pilot TMRE LAR. Schedule for pilot LAR review completion has lagged slightly due to licensee resource availability and spring outages, but staff and licensees expect process efficiencies through coordinated efforts with the pilot plants to keep current end process milestones on schedule. EGM 15-002 extension letters have been issued to eleven (11) of the (12) licensees that have submitted requests.
Industry: NEI 17-02 Revision 2 expected to be submitted for NRC staff endorsement review in summer 2018, following or near completion of staff review of pilot LARs.
Issue: Licensees have requested credit for FLEX strategies in a number of areas beyond their original purpose (BDBEE) (e.g. SDP, LARs, NOEDs). NRC staff and licensees are conducting a plethora of activities to enable licensees to appropriately credit FLEX. There are Flex in several challenges that NRC staff and industry consider as challenges that require NRC & Industry RISC engagement.
RIDM Next Steps:
NRC (NRR\DRA&RES\DRA): Expert Elicitation regarding HRA for FLEX equipment (May 2018). Make the draft report that NRR\RES is developing on HRA for using FLEX publicly available (December 2018).
Industry: Provides schedule for sharing FLEX operational experience with NRC staff.
Industry: Provides schedule for delivering any industry guidance relating to HRA method development.
Risk Informed Steering Committee NRC Activity Status Issue: The staff had previously planned to close this item, however, the staff has observed instances where industry guidance was not being followed by licensees. NRC plans to continue to conduct audits and observations of the F & O closure process to establish and F&O maintain confidence that there is industrywide understanding of the process. Once this confidence is established, NRC will continue Closure audits and observations at a reduced periodicity.
(Finding Next Steps:
Closure) Industry: Industry should provide an updated list of future IA F&O closure reviews to the NRC.
NRC: During 50.69 audits, NRC staff has observed that in some cases the IA F&O Closure process was not followed (no documented basis for why each F&O not an upgrade or no documented basis for how the resolution now meets the impacted SRs).
Another issue the NRC staff observed is a few licensees have not performed a full-scope peer review since the late 1990s and there is no approved mapping to the current PRA standards. A public meeting is scheduled for May 10, 2018. At this meeting staff observations will be discussed as well as a process to make observations publicly available.