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

Intro 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

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Insights 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

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Insights 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

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Proposed Solution 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.

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PSA Applications Guide

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Proposed CDF thresholds

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CDF Trending vs MSPI CDF Trending MSPI One value for entry into CDE Significant CDE data entry Some sites are already 5 separate sub-indicators each performing CDF Trending as with at least 2 trains/segments part of normal business with both planned and When properly configured with unplanned UA fields site (a)(4) tool, is automatically Some sites are entering calculated to eliminate manual monthly actuals for run time scrubbing of logbook entries and demands Auditing the automatic process Many fields get modified could be used as a means for during PRA model changes inspecting the indicator including the addition or removal of scope

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CDF Trending vs MSPI CDF Trending MSPI Simpler to perform Complex/difficult to modify Easier to understand planned UA baseline Greater insights 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

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Process Diagram

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Process Diagram

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Impact to NRC 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.) ©2019 Nuclear Energy Institute 12

Short-Term Supporting Actions 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

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Short-Term Supporting Actions 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)

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Short-Term Supporting Actions 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.

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Summary/Actions 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

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