ML18206A408
| ML18206A408 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 07/25/2018 |
| From: | Vaughn S Nuclear Energy Institute |
| To: | May Ma Office of Administration |
| Agrawal A, NRR/DIRS, 415-8310 | |
| References | |
| NRC-2018-0131 | |
| Download: ML18206A408 (3) | |
Text
STEPHEN J. VAUGHN Senior Project Manager, Risk and Technical Support 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8123 sjv@nei.org nei.org July 25, 2018 Ms. May Ma Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
NEI Comments on Draft Regulatory Guide (DG)-1336, Proposed Revision 4 to Regulatory Guide 1.160 [Docket ID - NRC-2018-0131]
Project Number: 689
Dear Ms. Ma:
The Nuclear Energy Institute (NEI)1, on behalf of our members, appreciates the opportunity to provide comments on DG-1336, Proposed Revision 4 to Regulatory Guide 1.1602. The proposed Revision 4 to RG 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants endorses Revision 4f of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, specifically the applicability of the Maintenance Rule (i.e., 10 CFR 50.65) to the use of licensees diverse and flexible coping strategies (FLEX) support guidelines (FSGs) in plant emergency operating procedures (EOPs).
Overall, the changes reflected in DG-1336 are appropriate and well-articulated. However, NEI did note an unexpected addition in Section 2.1 Use of Probabilistic Risk Assessments (page 17 of DG-1336.) The last sentence of Section 2.1 notes that RG 1.200 An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities is an acceptable approach to develop and maintain Probabilistic Risk Assessment (PRA) acceptability in support of risk-informed decision-making.
1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.
2 ML18129A080, Draft Regulatory Guide (DG)-1336, Proposed Revision 4 to Regulatory Guide 1.160
Ms. May Ma July 25, 2018 Page 2 Adding RG 1.200 to the PRA section of RG 1.160 is a new position and should be deleted, as RG 1.200 addresses licensing applications and is not applicable for RG 1.160 activities. NEI recommends maintaining the current language in Revision 3 of RG 1.160 (page 7 under Section entitled Use of Probabilistic Risk Assessments) that states When a PRA is used in a licensees implementation of the maintenance rule, the technical adequacy of the base PRA should be sufficient to provide the needed confidence in the results being used in the decision. If the staff does not agree with removing the reference to RG 1.200 from the proposed Revision 4 to RG 1.160, then NEI requests a public meeting at the staffs earliest convenience to support a technical discussion in resolving the comment.
Please find the full list of comments in the attachment to this letter for consideration as the staff incorporates stakeholder feedback and continues the DG-1336 concurrence process.
If you have any questions or require additional information, please contact me at (202) 739-8163; sjv@nei.org.
Sincerely, Stephen J. Vaughn Attachment c:
Mr. Michael King, NRR/DIRS, NRC Mr. Michael Franovich, NRR/DRA, NRC Mr. Michael Cheok, RES/DRA, NRC Ms. Ami Agrawal, NRR/DIRS/IRIB, NRC Mr. Thomas Hipschman, NRR/DIRS/IRIB, NRC Mr. Stephen Burton, RES/DE/RGGIB NRC Document Control Desk
ATTACHMENT l NEI Comments on DG-1336: Proposed Revision 4 to Regulatory Guide 1.160 Page Comment Recommendation 9
Editorial. There is a comma after EA 12-049 and there should be a period.
Remove the comma after EA 12-049 and replace it with a period.
9 In the sentence Because the FSG equipment is not essential to the EOPs, the phrase essential to the EOPs should be clarified.
Change essential to the EOPs to essential to the successful implementation of the EOP mitigating strategies 12 In Section 1, the phrase subject to the following exceptions and clarifications is different than Revision 3 to RG 1.160 which states subject to the following provisions and clarifications. It isnt clear why the term exceptions is being used instead of the previously used term provisions.
Given that the proposed Revision 4 to RG 1.160 is not taking any specific exceptions to Revision 4F of NUMARC 93-01, the term provisions should be maintained or condense the phrase provisions and clarifications to just clarifications.
17 In Section 2.1, the last sentence RG 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment results for Risk-Informed Activities, (Ref. 18) describes an approach the NRC staff finds acceptable to develop and maintain PRA acceptability in support of risk-informed decision-making is a new position compared to Revision 3 (and all previous Revisions) to RG 1.160.
Remove the last sentence in section 2.1 regarding RG 1.200 and maintain the Revision 3 to RG 1.160 language from the section Use of Probabilistic Risk Assessments that states When a PRA is used in a licensees implementation of the maintenance rule, the technical adequacy of the base PRA should be sufficient to provide the needed confidence in the results being used in the decision.
24 Reference 18 is RG 1.200. As described in the comment on page 17 and the associated recommendation, the addition of RG 1.200 as a PRA reference in RG 1.160 is not warranted.
Remove Reference 18 NRC, RG 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment results for Risk-Informed Activities, Washington DC. from page 24.