ML18212A218

Comment (2) of Stephen Vaughn on Monitoring the Effectiveness of Maintenance at Nuclear Power Plants; Draft Regulatory Guide (DG) - 1336

ML18212A218
Person / Time
Site:	Nuclear Energy Institute
Issue date:	07/25/2018
From:	Vaughn S Nuclear Energy Institute
To:	Rules, Announcements, and Directives Branch
References
83FR30469 00002, DG-1336, NRC-2018-0131
Download: ML18212A218 (4)

Text

As of: 7/26/18 9:50 AM Received: July 25, 2018 Status: Pending_Post PUBLIC SUBMISSION Tracking No. lk2-94hl-2cbx Comments Due: July 30, 2018 Submission Type: Web Docket: NRC-2018-0131 Monitoring the Effectiv:eness of Maintenance at Nuclear Power Plants; Draft Regulatory Guide (DG) -1336 Comment On: NRC-2018-0131-0001 SUNS! Review Complete Template= ADM-013 Monitoring Effectiveness of Maintenance at Nuclear Power Plants E-RIDS=AD M-03 ADD= Ami Agrawal & Stephen Document: NRC-2018-0131-DRAFT-0002 Burton Comment on.FR Doc# 2018-13876 COMMENT (2)

Submitter Information PUBLICATION DATE: 6/28/2018 CITATION 83 FR 30469 Name: Stephen Vaughn Organization:: Nuclear Energy Institute General Comment See attached file '"\

Attachments 07-25-2018_NRC_NEI Membership Comments on Draft Regulatory Guide (DG)-1336 + Attachment

~I STEPHEN J. VAUGHN Senior Project Manager, Risk and Technical Support

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1201 F Street, NW, Suite 1100 NUCLEAR ENERGY INSTITUTE 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 Numbel'.': 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 1.160"2

• 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 ~ule (i.e., 10 CFR 50.65) to the use of licensee's 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 Activiti~s" is an acceptable approach to develop and maintain Probabilistic Risk Assessment (PRA) acceptability in support of risk-informed decision-making.

1 lhe 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 indude entities licensed to operate commercial nudear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cyde 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 licensee's 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 staff's 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 concu~rence process.

If you have any questions pr require additional information, please contact me at (202) 739-8163; sjv@nei.org.

Sincerely,

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§ Stephen J. Vaughn Attachment c: Mr. Michael King, NRR/DIRS, NRC Mr. Michael Franovich, NRR/DRA, NRC Mr. Michael Cheak, 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 I NEI Comments on DG-1336: "Proposed Revision 4 to Regulatory Guide 1.160" Page Comment Recommendation 9 Editorial. There is a comma after "EA Remove the comma after "EA 12-049" and 12-049" and there should be a period. replace it with* a period.

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9 In the sentence "Because the FSG Change "essential to the EOPs" to "essential to equipment is not essential to the EOPs," the successful implementation of the EOP the phrase "essential to the EOPs" mitigating strategies" should be clarified.

12 In Section 1, the phrase " ... subject to Given that the proposed Revision 4 to RG 1.160 is the following exceptions and not taking any specific exceptions to Revision 4F clarifications" is different than Revision of NUMARC 93-01, the term "provisions" should 3 to RG 1.160 which states " ... subject to be maintained or condense the phrase "provisions the following provisions and and clarifications" to just "clarifications."

clarifications." It isn't clear why the term "exceptions" is being used instead of the previously used* term "provisions."

17 In Section 2.1, the last sentence "RG Remove the last sentence in section 2.1 regarding 1.200, "An Approach for Determining RG 1.200 and maintain the Revision 3 to RG the Technical Adequacy of Probabilistic 1.160 language from the section "Use of Risk Assessment results for Risk- Probabilistic Risk Assessments" that states "When Informed Activities," (Ref. 18) describes a PRA is used in a licensee's implementation of an approach the NRC staff finds the maintenance rule, the technical adequacy of acceptable to develop and maintain PRA the base PRA should be sufficient to provide the acceptability in support of risk-informed needed confidence in the results being used in decision-making" is a new position the decision."

compared to Revision 3 (and all previous Revisions) to RG 1.160.

24 Reference 18 is RG 1.200. As described Remove Reference 18 "NRC, RG 1.200, "An in the comment on page 17 and the Approach for Determining the Technical Adequacy associated recommendation, the of Probabilistic Risk Assessment results for Risk-addition of RG 1.200 as a PRA reference Informed Activities," Washington DC." from page in RG 1.160 is not warranted. 24.