ML19017A020

NEI Presentation on CDF Trending ROP Indicator at January 17, 2019 ROP Public Meeting

ML19017A020
Person / Time
Site:	Nuclear Energy Institute
Issue date:	01/17/2019
From:	Diven S, David Gudger Nuclear Energy Institute
To:	Office of Nuclear Reactor Regulation
Garmoe A
References
Download: ML19017A020 (16)

Text

Enhancement of ROP Indicator with CDF Trending Dave Gudger Scott Diven January 17th, 2019

©2019 Nuclear Energy Institute 2 Need to address challenge of MSPI faced by both the industry and the NRC Need broad solution to address knowledge issue while reducing MSPI resource burden Solution under consideration is a CDF trending indicator to augment the intent of MSPI

• Simpler to perform

• Easier to understand

• Greater insights

• Efficiency gains and alignment with other programs/industry Intro

©2019 Nuclear Energy Institute 3 CDF trending, augmentation of the current MSPI indicator, is an integrated risk informed indicator Availability of all modeled systems will impact the indicator

• Not limited to the five deterministically chosen systems currently in MSPI

• Components currently outside of MSPI could have a much larger impact on CDF e.g. DC Power Insights

©2019 Nuclear Energy Institute 4 An improved indication of risk impact of equipment performance Drives risk-informed decision making behaviors Focus of CDF trending is with online unavailability

• Considers the impact of the UA of multiple systems, which MSPI does not

• Failure rates will be updated during scheduled PRA model updates (not when failures occur)

• Outage UA and reliability will be addressed by other existing processes Maintenance Rule SDP Insights

©2019 Nuclear Energy Institute 5 Expand the ROP Indicator to leverage CDF Trending, consistent with the guidance in NEI 18-10

• Replacement for all sites regardless of implementation of MR 2.0

• One integrated indicator for data entry into CDE:

CDF

• Proposal to use a sliding scale, consistent with EPRI TR-105396: PSA Applications Guide

• Not a RG 1.200 application - a revised NEI 99-02 Appendix G would be used for PRA model technical requirements

• Eliminates duplicative/overlapping programs and greatly simplifies guidance/reduce resource burden.

Proposed Solution

©2019 Nuclear Energy Institute 6 PSA Applications Guide

©2019 Nuclear Energy Institute 7 Proposed CDF thresholds

©2018 Nuclear Energy Institute 8 CDF Trending vs MSPI CDF Trending MSPI

One value for entry into CDE

Some sites are already performing CDF Trending as part of normal business

When properly configured with site (a)(4) tool, is automatically calculated to eliminate manual scrubbing of logbook entries

Auditing the automatic process could be used as a means for inspecting the indicator

Significant CDE data entry

5 separate sub-indicators each with at least 2 trains/segments with both planned and unplanned UA fields

Some sites are entering monthly actuals for run time and demands

Many fields get modified during PRA model changes including the addition or removal of scope

©2018 Nuclear Energy Institute 9 CDF Trending vs MSPI CDF Trending MSPI

Simpler to perform

Easier to understand

Greater insights

Complex/difficult to modify planned UA baseline

Significant time/resources spent determining if UA is planned or unplanned

Significant time/resources spent determining what is and is not a failure of a MSPI monitored component

Fractured and complex guidance

©2019 Nuclear Energy Institute 10 Process Diagram

©2019 Nuclear Energy Institute 11 Process Diagram

©2019 Nuclear Energy Institute 12 NRC has the capability to inspect the indicator

• Can be done entirely under the inspection of the site (a)(4) tool (IP 62706)

• Inspection of initial automated processes NRC indicator will be able to compare site to site across the industry

• All sites will need to adopt this proposed change and start performing CDF Trending, if not already being performed

• Sites of similar baseline mean CDF will have similar margin Needs to be coordinated with other ROP enhancements currently being considered (abbreviated inspections, 95001 changes, etc.)

Impact to NRC

©2019 Nuclear Energy Institute 13 CDF Trending is a longer term solution Looking for short term change as an interim step to the long term solution

• Eliminate data collection and reporting on MSPI Planned Unavailability Represents one of the greatest resource burdens associated with MSPI Contributes to the difficulty for the NRC to limit annual PI verifications to 19-38 hours IAW PI Verification (IP 71151)

Has the least impact on MSPI margin Short-Term Supporting Actions

©2019 Nuclear Energy Institute 14 Removal of planned UA from MSPI:

• Allow 0 to be entered for all systems baseline and actual planned UA

• Allowance to change the baseline already normalizes any notable difference between the baseline and actual values

• Risk from planned UA is already managed to a finer level of detail under (a)(4)

Short-Term Supporting Actions

©2019 Nuclear Energy Institute 15 Unplanned UA to be maintained

• More readily apparent, as CAP ensures that failures of these components are well communicated at the sites

• With only one remaining definition of unavailable, less time/resources will be spent labeling hours with the appropriate categories

• Revise guidance to ensure all unavailability resulting from failure of a MSPI monitored component will be treated as unplanned.

Short-Term Supporting Actions

©2019 Nuclear Energy Institute 16 Provided a status update for our 1G Initiative Long Term Solution:

• Will continue to perform feasibility studies and validate what the data is telling us

• Will present an update to the NRC w/ an engagement strategy in 6 months

• In parallel - working on drafting indicator details

• Pilot an indicator by Oct Short Term Solution: Continue to work with the NRC to determine the best means to address Summary/Actions