ML18247A148
| ML18247A148 | |
| Person / Time | |
|---|---|
| Issue date: | 08/30/2018 |
| From: | Mary Drouin, Sunil Weerakkody NRC/NRR/DRA, NRC/RES/DRA |
| To: | |
| Miller Ed, 415-2481 | |
| References | |
| Download: ML18247A148 (17) | |
Text
Use of Newly Developed Methods in PRA Models September 6, 2018 Mary Drouin, Sr. Programs Manager, RES\DRA Sunil Weerakkody, Sr. Technical Advisor, NRR\DRA 08/30/2018 Public Meeting on Newly Developed Methods 1
Outline Of NRR Presentation
- Regulatory strategies on Tech Spec 4b reviews.
- Staff views on NEI Letter (ADAMS Accession No. ML18183A059).
- Staff views and status update on the alternative license condition proposed for Tech Spec 4b (ADAMS Accession No. ML18124A307).
Public Meeting on Newly Developed 08/30/2018 2 Methods
Regulatory Strategies on Tech Spec 4B LAR Reviews Public Meeting on Newly Developed 08/30/2018 3 Methods
Regulatory Strategies on Tech Spec 4b Reviews
- NRC continues to review LARs that have been submitted.
- NRC will accept and review new LARs on Tech Spec 4b.
- NRC will accept and review new LARs on Tech Spec 4b LARs that use TSTF-505, when the suspension is lifted (October\November 2018).
- In summary, NRC plans to collaborate with stakeholders to disposition issues related to Newly Developed methods without affecting LAR review\schedules.
Public Meeting on Newly Developed 08/30/2018 4 Methods
Regulatory Strategies on Tech Spec 4b (Cntd.)
- NRC will continue to work with stakeholders to enable implementation of an alternative License Condition by:
- Active participation in updates to ASME\ANS PRA Standard.
- Updating RG 1.200 and endorsing revised Standard with appropriate clarification and exceptions.
- Reviewing and endorsing NEI-17-07 with appropriate clarification and exceptions.
- Enhancing the existing ROP to focus on safety performance of implanting risk-initiatives.
- Additional consideration for appropriate level of regulatory oversight if the NRC approves an approach for licensee self-approved Newly Developed methods (i.e., no LAR).
Public Meeting on Newly Developed 08/30/2018 5 Methods
Regulatory Strategies on TS 4b (Cntd.)
After an alternative license condition is endorsed, licensees who have received safety evaluation for Tech Spec 4b will have the option to maintain their License Condition or request staff approval to adopt the alternative.
Public Meeting on Newly Developed 08/30/2018 6 Methods
NRC Staff Views on NEI Letter to Mike Franovich on Vetting Panel Process (NEI-16-04)
(ADAMS Accession No. ML18183A059).
Public Meeting on Newly Developed 08/30/2018 7 Methods
Staff views on NEI Letter
- Letter withdrew an earlier request to review NEI 16-04.
- Letter expressed NEI views with respect to peer-review process.
- Letter expressed NEI views on regulatory purview on PRA Methods.
- Staff shared letter with internal stakeholders (Division of Operator Reactor Licensing, Division of Inspection of Regional Support, Office of the General Counsel).
- Staff conclusions relating to key points noted in the letter will be documented in a formal agency document and made publicly available.
Public Meeting on Newly Developed 08/30/2018 8 Methods
Staff Feedback on NEIs Alternative Proposal (ADAMS Accession No. ML18124A307 Public Meeting on Newly Developed 08/30/2018 9 Methods
Key Elements of NEI Proposal
- Submitting an LAR on change in Approaches.
- Criteria to determine whether a model change constitutes an Upgrade.
- Performing a peer-review of upgrade (including Newly Developed methods).
- Content of the report submitted to NRC.
- A 30-day review period for NRC.
- Reporting changes to NRR Project Manager.
- Reporting changes to NRC Resident Inspector.
Public Meeting on Newly Developed 08/30/2018 10 Methods
Submitting an LAR on change in Approaches
- Progress:
- The process was tested when Vogtle submitted an LAR to change approach from seismic SSEL to seismic PRA.
- Challenges:
- None known at this time.
- Next Steps:
- None postulated at this time.
Public Meeting on Newly Developed 08/30/2018 11 Methods
Criteria to determine whether a model change constitutes an Upgrade.
- Progress:
- NRR & RES staff holding periodic discussions\workshops on these topics.
- NRR & RES staff observing industry discussions.
- NRR & RES briefings to NRR\RES management.
- Challenge:
- Reaching alignment on key issues such as Newly Developed methods, PRA Upgrade among internal and external stakeholders.
- Plan\Next Steps:
- Observe industry meetings, hold workshops\public meetings.
- Planned updates to RG 1.200 and the ASME\ANS PRA Standard can be used to document enhance clarity\predictability.
Public Meeting on Newly Developed 08/30/2018 12 Methods
Performing a peer-review of PRA upgrade (including Newly Developed
- Progress:
methods).
- RES has proposed high-level criteria that could be used by peer reviewers to evaluate Newly Developed methods to ANS\ASME PRA Standards Committee.
- NRR is evaluating adequacy of the proposed high-level criteria using pilots.
- RES & NRR will participate in the development of supporting criteria.
- Challenge:
- Alignment on review criteria for Newly Developed methods.
- Clarity on roles peer-reviewers, licensees, and the regulatory role\purview.
- Plan\Next Steps:
- Continue to actively participate in the development of Newly Developed methods evaluation criteria.
- Use planned updates to RG 1.200 and the ASME\ANS PRA Standard to enhance clarity\predictability.
Public Meeting on Newly Developed 08/30/2018 13 Methods
Use of upgraded PRA model to calculate RICTs 30 days after submitting reports.
- Progress:
- NRC staff and management discussed the proposal and briefed senior management about this particular element of proposal.
- Consulted with the Office of General Counsel.
- Compared the proposal with staff practices in other technical divisions,
- Challenges\Next Steps:
- Imposition of a time limit may be interpreted to limit the NRCs authority to question the acceptability of the methods.
- Similar to other aspects of PRA models, licensees will be responsible to demonstrate the adequacy of their PRA models (including Newly Developed methods) in accordance with their licensing basis.
- Next Steps:
- Examine other NRC program\rules for an acceptable model.
- Is a model similar to that used in 10 CFR 50.59 work for Newly Developed methods?
Public Meeting on Newly Developed 08/30/2018 14 Methods
Providing Reports on PRA Upgrades to NRR Project Manager & Resident Inspector
- Progress:
- Continuing consultations with NRR\DORL staff & management, NRR\DIRS staff &
management , and regional staff to socialize proposal and receive feedback.
- Challenges:
- Assess needs to adjust processes, training, resources to enable process. Some key issues are:
- Access to subject matter experts (SMEs) to support inspections.
- Adequacy of procedures; Establishing clarity on enforceability.
- Plan\Next Steps:
- Enhancing the existing ROP to focus on safety performance of implanting risk-initiatives.
- Additional consideration for appropriate level of regulatory oversight if the NRC approves an approach for licensee self-approved New methods (i.e., no LAR).
Public Meeting on Newly Developed 08/30/2018 15 Methods
Content of the PRA Upgrade Report
- The alternative license condition proposes that the report contains the following: (a) The description of the PRA model upgraded, (b) The peer-review and finding closure reports available to the NRC for oversight and inspection activities, (c) The number of, and characterization of the open findings in the upgraded model, and (d) Identification of any RICTSs of less than 30 days calculated to change by more than 50% pf zero-maintenance configuration.
- Progress:
- Staff is evaluating the proposal and need further discussion on points such as:
- The need to clearly identify whether Newly Developed methods have been used in the upgrade.
- Means to prevent receiving reports on upgrades that are not of interest to the staff (reduce undue burdens to staff and licensees),
- Adequacy of the 50% threshold.
- Challenges\Next Steps:
- Align on the thresholds for reporting, contents of the report, and create a template for licensees use.
Public Meeting on Newly Developed 08/30/2018 16 Methods
Concluding Remarks
- Staff has established an adequate approach to receive\review LARs relating to Tech Spec 4b.
- Staff will collaborate with industry to develop an acceptable alternative License Condition for Tech Spec 4b and TSTF 505 within the construct of Reg. Guide 1.200 construct.
- Staff is working on key short-term (e.g., public meetings, workshops) and working on longer-term strategies (e.g., RG 1.200 update, developing a risk-informed oversight process for risk-informed initiatives) to provide long-term clarity and predictability.
Public Meeting on Newly Developed 08/30/2018 17 Methods