ML18352A750

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12/06 and 12/17/2018 Summary of Meetings with the Nuclear Energy Institute and Other Industry Representatives Regarding NEI 17-07
ML18352A750
Person / Time
Issue date: 01/02/2019
From: Blake Purnell
Plant Licensing Branch III
To: David Wrona
Division of Operating Reactor Licensing
Purnell B
References
Download: ML18352A750 (4)


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,, ***** January 2, 2019 MEMORANDUM TO: David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Blake Purnell, Project Manager Plant Licensing Branch Ill aj./', ,_ .fi\./l.,/---v J

Division of Operating Reactor Licensing 17 Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF DECEMBER 6 AND 17, 2018, MEETINGS WITH THE NUCLEAR ENERGY INSTITUTE AND OTHER INDUSTRY REPRESENTATIVES REGARDING NEI 17-07 On December 6 and 17, 2018, two Category 2 public meetings were held between the U.S.

Nuclear Regulatory Commission (NRC) staff and industry representatives for power reactors.

The purpose of the meetings was to discuss NRC feedback on the draft Nuclear Energy Institute (NEI) guidance document NEI 17-07, "Performance of PRA [Probabilistic Risk Assessment] Peer Review Using the ASME/ANS [American Society of Mechanical Engineers/American Nuclear Society] PRA Standard," Revision A (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17341A548). The meeting notice and agenda are available in ADAMS at Accession No. ML18341A164. A list of attendees is enclosed.

The NRC staff plans to eventually endorse NEI 17-07 in Revision 3 to NRC Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities" (ADAMS Accession No. ML090410014). On November 9, 2018 (ADAMS Accession No. ML18313A246), the NRC provided detailed comments to NEI on the draft NEI 17-07, Revision A, by e-mail. During a public meeting on November 14, 2018 (ADAMS Accession No. ML18331A370), the NRC staff provided high-level feedback on the draft NEI 17-07. In addition, the staff asked NEI to also consider staff comments (ADAMS Package Accession No. ML18025C022) on NEI 12-13, "External Hazards PRA Peer Review Process Guidelines," and the ASME/ANS PRA standard as they relate to NEI 17-07.

During the December 6, 2018, meeting, NEI sought clarification on the NRC staff comments on NEI 17-07. The staff provided clarification regarding NRC comments 1, 4, 8, 10, 13, 15, 17, 20, 21, 27, 33, 45, and 68 on NEI 17-07. During the meeting, the staff withdrew comments 4 and 20 based on the discussion. With regard to comment 15, the staff stated that it would likely do a gap assessment of the revised ASME/ANS PRA standard as part of its review for endorsement in Regulatory Guide 1.200.

The NRC staff also provided clarification regarding NRC comments 4, 15, 17, 23, and 32 of NEI 12-13 during the December 6, 2018, meeting. It was also noted that NRC comments 91-97

on the ASME/ANS PRA standard were relevant to a guidance document that the Pressurized Water Reactor Owner's Group (PWROG) was developing, and that this document would be discussed at a workshop in January 2019.

By e-mail dated December 10, 2018 (ADAMS Accession No. ML18344A083), NEI provided a revised version of NEI 17-07 and a comment resolution table. The proposed NEI resolution of the NRC staff's comments on NEI 17-07 was discussed during the December 17, 2018, meeting. In particular, the staff indicated that additional changes to NEI 17-07 may be needed to address NRC comments 1b, 1c, 13, 27, 33, 44, and 68. NEI agreed to enhance the discussion regarding internal flooding to include walkdowns and spatial considerations. In addition, NEI agreed to add stronger language, similar to NEI 12-13, regarding walkdowns to address NRC comment 33.

In response to NRC comment 13, the revised NEI 17-07 guidance also added aspects of a newly developed method that should be demonstrated during the review. The NRC and PWROG both stated that this information belongs in the ASME/ANS PRA standard and not in NEI 17-07. While the standard is being revised, the PWROG will have an interim document covering these aspects. Although the NEI 17-07 could retain this information, the.NRG staff stated it needs to be consistent with what is being developed for the standard. The staff also noted that the discussion regarding PRA maintenance and upgrades (comment 44) may need to be revised to be consistent with the standard that is under revision.

The NRC staff also discussed comment 1 on NEI 12-13, regarding the "in-process approach used for certain seismic PRA peer reviews. NEI stated that NEI 17-07 does not preclude the use of an "in process" approach, but licensees may not have interest in using this approach in the future. The staff stated that if NEI 17-07 is applicable to an "in-process" approach, then it needs to address the additional NRC comments on NEI 12-13.

At the December 17, 2018, meeting, NEI stated that it would revise NEI 17-07 by the end of the week to address the NRC staff's comments. This draft would then be used for pilot plant applications. Additional changes to NEI 17-07 would be made after the pilots are completed and the PWROG document of interim changes related to the ASME/ANS PRA standard is developed.

Public meeting feedback forms were not received. Please direct any inquiries to me at 301-415-1380, or Blake.Purnell@nrc.gov.

Project No. 0689

Enclosure:

List of Attendees cc: Listserv

LIST OF ATTENDEES DECEMBER 6 AND 17, 2018, MEETINGS WITH INDUSTRY Name Affiliation Blake Purnell NRC Mary Drouin NRC Sunil Weerakkody NRC Antonios Zoulis NRC Stephen Dinsmore NRC JS Hyslop NRC Greo Casto NRC Felix Gonzales NRC Mehdi Reisi Fard NRC Adrienne Driver NRC Shilo Vasavada NRC De Wesley Wu NRC Jonathan Evans NRC Earl Bousquet NRC Zachary Coffman NRC Mihaela Biro NRC Jana Bergman Curits-Wrioht Roy Lithicum PWROG Victoria Anderson NEI Greg Krueaer NEI Jeff Stone Exelon Stanley Levinson Framatome Victoria Warren Jensen Hughes Justin Hiller Ameren Mike Annon l&C Enoineering Associates Ernie Kee Brad Dolan Tennessee Valley Authority Cindy Williams NuScale Power Enclosure

SUBJECT:

SUMMARY

OF DECEMBER 6 AND 17, 2018, MEETINGS WITH THE NUCLEAR ENERGY INSTITUTE AND OTHER INDUSTRY REPRESENTATIVES REGARDING NEI 17-07 DATED JANUARY 2, 2019 DISTRIBUTION:

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