ML18333A192
| ML18333A192 | |
| Person / Time | |
|---|---|
| Issue date: | 11/29/2018 |
| From: | Candace Spore NRC/NRR/DRA/APOB |
| To: | |
| Spore C | |
| References | |
| Download: ML18333A192 (3) | |
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Risk Informed Steering Committee NRC Activity Status Activity Current Status Issue: NRC informed industry last year that resources were available for 10 reviews/year for completion within 12 months of acceptance. Seventeen 50.69 LARs were submitted in the first year of reviews (after the pilot). After the first 10 were submitted, 50.69 NRC starting planning for 15 month review schedules for the subsequent submittals. NRC issued the SE for approval of the first non-pilot 50.69 LAR (Limerick) in 11 months from the date of acceptance (one month ahead of the 12 month review schedule). NRC also issued approval of the seismic PRA for the Vogtle 50.69 pilot plant which was originally approved using the seismic margins safe shutdown list instead of a seismic PRA. NRC recently completed 4 other 50.69 LARs with another LAR to be complete by the end of November, all of which were accepted for review last fall. NRC currently has 8 LARs under review and anticipates 3 additional submittals in by the end of the calendar year. With many reviews completed in the first year, NRC is now scheduling new 50.69 submittals on a 12 month schedule. The use of the seismic alternative for 50.69 has not yet been reviewed by the NRC and industry informed NRC that a lead-plant LAR will be submitted this fall. The schedule for the seismic alternative lead plant will most likely extend past one-year. A pre-submittal meeting has been conducted for this review. A second lead plant for a seismic alternative will be submitted next calendar year.
Next Steps:
NRC: Several audits have been conducted, and additional audits are being scheduled. Staff recently conducted a virtual audit for resource efficiency and will assess its effectiveness for future reviews. 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. LARs which 1) follow the industry template and 2) have technically acceptable PRAs (i.e., necessary peer reviews completed with F&Os adequately dispositioned) require less time and resources for NRC to review. NRC and Industry are planning a 50.69/4b lessons-learned workshop in late January.
Issue: Staff provided a modified TSTF-505 to the TSTF in May, based on the Vogtle pilot but with no provisions for use of a RICT on TSTF - 505 loss of safety function. The original TSTF-505 included a RICT for loss of safety function, and the Vogtle pilot included some very limited use of RICT for loss of safety function. The TSTF responded with a full traveler revision excluding RICT for loss of safety function for staff review rather than comments on the staff revision. This increased the scope of the staff review. Regarding plant-specific 4b reviews, the staff issued the SE for Calvert Cliffs on 10/30/18, and anticipates issuing the Turkey Point SE by the end of November. Staff is actively working to complete the reviews of St. Lucie and Palo Verde LARs by early 2019. On July 27, 2018, Farley submitted a LAR that did not reference the TSTF-505 travel but, instead, is consistent with the guidelines of NEI 06-09, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines. The NRC staff accepted the LAR for review on August 31, 2018, with a scheduled completion date of August 2019.
Next Steps: The TSTF revision is currently under review, and staff expects to lift suspension by the end of November 2018. NRC and Industry are planning a 50.69/4b lessons-learned workshop in late January. The workshop will include a discussion on risk-informed licensing amendment workload forecasting for more effective resource planning.
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Risk Informed Steering Committee NRC Activity Status Issue: For risk-informed LARs, the NRC determines the acceptability of a licensees PRA using peer-reviews. As a result of staff New observations during the review of LARs relating to NFPA 805, the staff became concerned about the adequacy of these process, Methods especially relating to new methods. Staff believes that the regulatory framework (e.g., Reg Guide 1.200) must be updated to accommodate lessons learned from Fire PRA and other recent LAR reviews to maintain due reliance on the peer-reviews as they pertain to new PRA methods. In 2015, the Nuclear Energy Institute (NEI) had proposed a vetting panel process to address this issue (NEI 16-04). In January 2018, NEI provided an alternative proposal, which was revised and presented formally at a public meeting in June 2018. Also in June NEI requested that the staff stop its review of NEI 16-04. NRC staff is evaluating the new proposal.
Next Steps:
NRC: NRC held three public meetings (June 18, 2018, September 6, 2018, and November 14, 2018) and participated in two Owners Group meetings to work on activities related to NEIs new proposal. During the meeting on November 14, industry representatives affirmed that they agree with NRCs path forward and requested that we expedite completion of tasks essential to enable implementation of NEIs alternative. There are three tasks that must be completed: a) issuing a letter endorsing NEI 17-07 with necessary classification, b) documenting components that would normally reside in ASME\ANS Standard (e.g., definition of PRA Upgrade, Newly Developed Method) in a formal document pending publication of ASME\ANS Standard and Rev. 3 of RG 1.200, and c) creating or enhancing processes procedures to implement NEIs alternative. Barring any unanticipated significant changes to resolution of issues or events that requires significant PRA resources, NRC is making plans to complete these three activities in FY 2019.
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 Fire PRA NFPA 805 program.
Realism Next Steps:
NRC: Ongoing public meetings (quarterly) review and update FAQs. Four (4) remain to be reviewed/resolved. RES/NRR observing VEWFDS expert elicitation week of Nov. 12th. RES/EPRI engagement ongoing.
NRC and Industry: Continue to work towards resolution of remaining draft fire PRA FAQs.
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 several activities to enable licensees to appropriately credit FLEX. There are several Flex in challenges that require NRC & Industry RISC engagement. Key Issue on FLEX, EOPs, and relationship to Maintenance Rule scoping RIDM criteria has been resolved. Draft NRC Reg. Guide has been issued.
Next Steps:
NRC (NRR\DRA&RES\DRA): Finalize draft report on Expert Elicitation that will be made publicly available (1st Qtr. 2019).
Industry: Sharing FLEX operational experience data with NRC staff. (End of year, 1st Qtr. 2019)
Industry: Provides schedule for delivering any industry guidance relating to HRA method development.
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Risk Informed Steering Committee NRC Activity Status 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: Draft SEs in final issue review for two of three pilot-plants. Staff to re-state existing and describe potential new options for remaining licensees to restore compliance within EGM expiration date. Staff in place to support efficient review of remaining 10+
LARs expected to be submitted in FY19.
Industry: Four post-pilot licensees have notified NRC of intent to submit TMRE LARs late 2018, following issue of first TMRE SE.
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