ML18228A834
| ML18228A834 | |
| Person / Time | |
|---|---|
| Issue date: | 08/16/2018 |
| From: | Adrienne Brown, Mike Franovich, Michael Montecalvo, Sunil Weerakkody NRC/NRR/DRA |
| To: | |
| References | |
| Download: ML18228A834 (22) | |
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Joint BWROG/PWROG Technical Committee Meetings NRC Panel: August 16, 2018 Mike Franovich, Director Division of Risk Assessment Sunil Weerakkody, Sr. Technical Advisor, Division of Risk Assessment Mike Montecalvo, Acting Branch Chief, Division of Risk Assessment Adrienne Brown, Reliability and Risk Analyst
Risk-Informed Decision Making (RIDM): Action Plan Mike Franovich, Director Division of Risk Assessment 12 2
An Action Plan is Being Implemented to Improve Risk-Informed Decisionmaking Enhance the integration of risk information into the organizations decision making practices and processes to improve the technical basis for regulatory activities, increase efficiency, and improve effectiveness NRR RIDM Mission SECY Paper Strategies Strategy IV Advance Risk-Informed Initiatives Strategy III Enhance Mandatory Training Tasks PHASE 1 Evaluate tasks to generate findings and recommendations PHASE 2 Implement recommendations Strategy I Evaluate/Update Guidance Strategy II Develop Graded Approach Cross-Cutting Communication Strategy V Enhance Communication 3
The Action Plan Supports Increased Use of Integrated Reviews and Safety and Risk Insights 4
Strategies to Optimize Regulatory Activities
- Broaden efforts to promote RIDM practices
- Increase FLEX regulatory credit
- correlate future plant modifications with FLEX to reduce other hazards risk (e.g., internal fires & floods)
- showcase FLEX capabilities when NRC conducts onsite audits -
increase reviewers, inspectors, and managers awareness
- Focus communications and coordination
- Conduct joint NRC-Industry workshops on lessons learned from 50.69 and TSTF-505 reviews
- Improve coordination and accuracy of forecasted LAR submittals
- Sequence risk related LARs:
- Consider submitting TSTF-505 prior to 50.69 or lower tier LARs (TSTF-505 program has a very high pedigree for PRA acceptability), or
New Methods Sunil Weerakkody Sr. Technical Advisor Division of Risk Assessment 12 6
7 PRA Acceptability - 3 Elements
- All 3 elements have to work together to demonstrate PRA acceptability Regulatory Guide (RG) 1.200 provides NRC staff position Peer Review to demonstrate conformance with PRA Standard PRA Standard to demonstrate conformance with staff position PRA ACCEPTABILITY
8 New Methods Are a Current Focus Area for NRC and Industry
- Ongoing focus on industry peer-review and the F&O closure process
- ASME/ANS PRA Standard updates
- RG 1.200 update
- A risk-informed oversight process will complement licensing activities and possibly new methods
Crediting Mitigating Strategies in Regulatory Applications Mike Montecalvo Acting, Branch Chief Division of Risk Assessment 12 9
Crediting Diverse and Flexible Coping Strategies (FLEX) 1 0
- FLEX developed to meet the Commissions Orders after the Fukushima accident
- FLEX can also be utilized for:
- Outages
- Defense-in-Depth
- The NRC wants to encourage safety enhancements
- Addressing ongoing challenges
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Challenges to Crediting FLEX
- No Operational Experience (OpE) data
- Needed to develop, and support, equipment reliability used in risk assessments
- Prior OpE collection effort by EPRI abandoned
- Owners Groups have taken lead
- Have committed to sharing draft and final results
- Current HRA methods not adequate for all FLEX actions
- Ongoing work in NRR and RES to address this challenge
- RES held an expert elicitation in April 2018
- EPRI Workshop in February 2018
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FLEX OpE data expectations
- Commissions PRA policy statement states:
- PRA evaluations in support of regulatory decisions should be as realistic as practicable and appropriate supporting data should be publicly available for review.
- The data needs to be of comparable resolution to what the NRC publishes on its public website.
- Failures, Number of attempts (or hours), and number of components
- The data does not need to identify individual plants, consistent with our current approach.
- The data should be of sufficient resolution to verify that any poolability assumptions are statistically sound.
- Basis for pooling FLEX diesels from different vendors
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Path Forward on FLEX OpE data
- Owners Group Effort
- Draft report Fall 2018
- Publish report (1st quarter 2019)
- NRC is looking forward to reviewing the report
- Possible Public Meeting
- Discuss the NRCs review of the report
- Discuss how RES will integrate this information into the current process
- NRC staff is looking forward to engaging the owners groups on the FLEX OpE data.
Lessons Learned: Recent Risk-Informed LAR Reviews Adrienne Brown Reliability and Risk Analyst Division of Risk Assessment 12 1
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Influx of Risk-Informed Applications Requires Increased Coordination and Planning Between NRC and Industry 41 79 184 0
50 100 150 200 FY16 FY17 FY18 Number of Licensing Actions Risk-Informed Licensing Actions Received from FY16-FY18 Projected TMRE NTTF R2.1 50.69 Misc AOT TSTF-505, 4B GSI-191 TSTF-411 RI-ISI RI TS TSTF-425, 5B NFPA805 ILRT 66
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High Quality Submittals to Streamline Efficient Staff Reviews PRA Configuration and Control Implementation (Oversight)
PRA Acceptability PRA Quality Up-to-date full-scope PRA peer reviews Crediting Appendix X, consistent with staff letter of acceptance Incorporations of precedent from previous SEs Disposition of open F&O applicable to risk-application
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50.69: Risk Informed Categorization of Structures, Systems, and Components
- LAR review scope:
- NRC staff reviews the quality of the PRA models used in the categorization process
- NRC approves categorization process
- NRC does not review categorization results, procedures, or alternative treatment during LAR review. These are subject to inspection
- 16 applications for 50.69 received
- 6 in early stages of review; 3 withdrawn
- One SE has been issued, several reviews approaching completion
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Insights from Initial 50.69 Reviews
- Deviations from endorsed guidance
- Categorization of passive SSCs
- Public meetings preferred to discuss generic industry topics/deviations prior to LAR submittal
- Public meetings to resolve generic topics related to seismic or fire (sites without seismic analysis or fire PRA)
- Some LARs require more review hours due to scope of PRA (e.g., seismic, high winds)
- NRC review resources are challenged due to the large volume of applications
- License Condition for approval specifying modeled PRA hazards and non-PRA methods
Tornado Missile Risk Evaluator (TMRE)
- Plant audits and RAIs generated to pilots
- Pilot plant RAI responses also updating NEI 17-02
- Staff positioned to complete safety evaluations (SEs) following receipt of licensee responses
- Post-pilot amendments could model pilot SEs in advance of NEI 17-02 endorsement
- Staff prepared to receive approximately 12 amendments in FY19
- 13 of 13 EGM 15-002 extension requests dispositioned between January and June 1
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TSTF-505: Risk-Informed Technical Specification Completion Times
- Background
- TSTF-505 suspended (November 2016)
- Vogtles License Amendment for RICT issued (August 2017)
- Vogtle was the pilot for changes needed to unsuspend TSTF-505
- NRC staff modified TSTF-505 and the model application/SE
- No RICT for loss of function
- Enables licensing efforts to advance forward
- License Condition for use of new methods
- September/October target for revised TSTF model application and safety evaluation report
NRC PANEL: QUESTIONS 2
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Acronyms ANS: American Nuclear Society ASME: The American Society of Mechanical Engineers CDF: Core Damage Frequency CFR: Code of Federal Regulations DRA: Division of Risk Assessment EGM: Enforcement Guidance Memorandum FLEX: Diverse and Flexible Coping Strategies F&O: Fact/Finding and Observation FY: Fiscal Year HRA: Human Reliability Analysis LAR: License Amendment Request LERF: Large Early Release Frequency NEI: Nuclear Energy Institute NFPA: National Fire Protection Association NOED: Notice of Enforcement Discretion NTTF: Near Term Task Force PM: Project Manager PRA: Probabilistic Risk Assessment RG: Regulatory Guide RI: Risk-Informed RICT: Risk-Informed Completion Time RIDM: Risk-Informed Decision-Making RISC: Risk-Informed Steering Committee RITS: Risk-Informed Technical Specifications ROP: Reactor Oversight Process SDP: Significance Determination Process SE: Safety Evaluation SFCP: Surveillance Frequency Control Program SR: Surveillance Requirement SSC: Structure, System, or Component TMRE: Tornado Missile Risk Evaluator TS: Technical Specification TSTF: Technical Specification Task Force