ML20010D222

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A. Gilberston Presentation for 1/16/2020 Public Meeting to Discuss Proposed Revisions to Regulatory Guide (RG) 1.200, an Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities
ML20010D222
Person / Time
Issue date: 01/10/2020
From: Anders Gilbertson, Ed Miller, Sunil Weerakkody
NRC/NRR/DORL/LPL2-1, Office of Nuclear Regulatory Research
To: Ed Miller
Office of Nuclear Reactor Regulation
Miller E
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1 Miller, Ed From:

Miller, Ed Sent:

Friday, January 10, 2020 7:41 AM To:

Miller, Ed

Subject:

Material for 1/16/2020 Public Meeting - Anders Presentation Attachments:

Anders-presentation-publicmeetinh-1-16-20.pdf Attached is the subject presentation material for the Jan 16, 2020, public meeting.

Status Update:

Regulatory Guide 1.200 Anders Gilbertson Office of Nuclear Regulatory Research Anders.Gilbertson@nrc.gov, 301-415-1541 January 16, 2020

OVERVIEW

  • Proposed changes to RG 1.200 for Revision 3
  • Planned Path forward 2

RG 1.200, Status Update January 16, 2020 Public Meeting

Status of RG 1.200 (1 of 2)

  • Revision 3 being prepared for publication as a draft RG
  • Has been in development for about 2 years; staff position has been informed by

- multiple public meetings

- observation of pilots for new peer review guidance and consensus standard requirements

- participation in Owners Group workshops

  • Public meetings have been conducted on RG 1.200, Revision 3 to:

- share the staffs draft work product

- solicit input from external stakeholders on proposed changes 3

RG 1.200, Status Update January 16, 2020 Public Meeting

Status of RG 1.200 (2 of 2)

  • Anticipated light-water reactor PRA standard endorsements in RG 1.200, Revision 4:

- Next edition of the ASME/ANS Level 1/LERF PRA standard

- ASME/ANS Level 2 PRA standard 4

RG 1.200, Status Update January 16, 2020 Public Meeting

Proposed Changes to RG 1.200 (1 of 4)

  • Changes are intended to provide additional clarity, improve process efficiency, and enhance safety
  • Proposed changes include:

- New staff endorsements

- Enhancements/clarifications to guidance

- Updates related to organization of RG content 5

RG 1.200, Status Update January 16, 2020 Public Meeting

Proposed Changes to RG 1.200 (2 of 4)

NRC staff endorsements:

- NEI 17-07, Revision 21

  • Appendix X - F&O independent assessment process
  • NDM peer review requirements

- ASME/ANS RA-S Case 1 for seismic PRA2

- PWROG-19027-NP, Revision 13

  • definitions related to newly developed methods, PRA maintenance, and PRA upgrade (Section 2)
  • A process for determining whether a change to a PRA is PRA maintenance or a PRA upgrade (Section 3)
  • requirements for peer review of newly developed methods (Sections 4 and 5)

Endorsements include consideration of comments from internal and external stakeholders (e.g., public, ACRS, NRC/OGC, etc.)

1 See Agencywide Document Access and Management System (ADAMS) accession No. ML19241A615 2 Available via http://www.asme.org 3 See ADAMS accession No. MLXXXXXXXXX 6

RG 1.200, Status Update January 16, 2020 Public Meeting

Proposed Changes to RG 1.200 (3 of 4)

  • Enhancements/clarifications to guidance:

- Key assumptions and sources of uncertainty

- Risk-informed decisionmaking

- Glossary of terms

- Listing of hazards

- Incorporates resolution of DPO-2016-0014

  • Updates related to organization of content:

- Reorganization of Sections A and B 4 See ADAMS accession No. ML17013A015 7

RG 1.200, Status Update January 16, 2020 Public Meeting

Proposed Changes to RG 1.200 (4 of 4)

  • Sections A and B - Reorganized and includes discussion on PRA acceptability
  • Section C.1 - Minor revisions, reorganized for clarity
  • Section C.2 - Revised to expand staff position and include related new endorsements
  • Section C.3 - Minor revisions related to key assumptions and sources of uncertainty
  • Section C.4 - Revised to reflect changes in Section C.2
  • Added glossary of terms
  • New appendices for endorsements 8

RG 1.200, Status Update January 16, 2020 Public Meeting

Revisions to Sections A and B

  • Reorganized for clarity
  • Discussion on PRA acceptability added consistent with resolution of DPO-2016-001
  • Provides current status of PRA standards efforts 9

RG 1.200, Status Update January 16, 2020 Public Meeting

Revisions to Section C.1

  • Revised to provide clarity and consistent language
  • Subsections on PRA technical elements arranged consistent with Parts in the ASME/ANS Level 1/LERF PRA standard
  • Staff position on low-power and shutdown PRA moved into separate subsection in C.1 10 RG 1.200, Status Update January 16, 2020 Public Meeting

Revisions to Section C.2

  • Revised for clarity
  • Includes language related to ASME/ANS RA-S Case 1 for seismic PRA 11 RG 1.200, Status Update January 16, 2020 Public Meeting

Revisions to Section C.2.1

  • Includes language regarding PRA state of practice and peer review of a newly developed method 12 RG 1.200, Status Update January 16, 2020 Public Meeting

Revisions to Section C.2.2

  • Includes language related to the peer review of newly developed methods
  • Divided into three main subsections:

2.2.1 Peer Review of a Base PRA Model 2.2.2 Peer Review of a PRA Upgrade or Newly Developed Method 2.2.2.1 Peer Review of a PRA Upgrade 2.2.2.2 Peer Review of a Newly Developed Method 2.2.3 Facts and Observation Independent Assessment 13 RG 1.200, Status Update January 16, 2020 Public Meeting

Revisions to Section C.2.2.1

  • Includes added language on the peer review process, team qualifications, and documentation, consistent with NEI 17-07, Revision 2 14 RG 1.200, Status Update January 16, 2020 Public Meeting

Revisions to Section C.2.2.2

  • Provides guidance on determining whether a change to a PRA is a PRA upgrade or PRA maintenance
  • References Appendix C, which endorses process in PWROG-19027-NP, Revision 1 15 RG 1.200, Status Update January 16, 2020 Public Meeting

Revisions to Section C.2.2.2.1

  • Defines PRA upgrade
  • Refers to NEI 17-07, Revision 2, for related guidance on the peer review of a PRA upgrade
  • Endorses requirements in PWROG-19027-NP, Revision 1, related to focused-scope peer review 16 RG 1.200, Status Update January 16, 2020 Public Meeting

Revisions to Section C.2.2.2.2

  • Defines newly developed method and provides guidance on a peer review thereof
  • Refers to NEI 17-07, Revision 2, for guidance on the peer review of a PRA upgrade
  • Endorses requirements in PWROG-19027-NP, Revision 1, for the peer review of a newly developed method; includes documentation requirements and expectations on the outcome of such peer reviews 17 RG 1.200, Status Update January 16, 2020 Public Meeting

Revisions to Section C.2.2.3

  • Endorses NEI 17-07, Revision 2, guidance on Facts and Observations (F&O) Independent Assessments.
  • Guidance is consistent with the staff position documented in the NRC letter5 on the NEI Appendix X to NEI 00-02, NEI 05-04, and NEI 07-12
  • Provides overall endorsement of NEI 17-07, Revision 2, as a means of satisfying the peer review requirements in ASME/ANS RA-Sa-2009 5 See ADAMS accession No. ML17079A427 18 RG 1.200, Status Update January 16, 2020 Public Meeting

Revisions to Section C.3

  • Provides clarifications regarding key assumptions and sources of uncertainty 19 RG 1.200, Status Update January 16, 2020 Public Meeting

Revisions to Section C.4

  • Revised to include documentation requirements related to a PRA upgrade, the use of newly developed method, and F&O independent assessments 20 RG 1.200, Status Update January 16, 2020 Public Meeting

New Glossary of Terms as-built, as-operated as-designed, as-to-be-built, as-to-be-operated assumption key assumption base PRA consensus method/model conservative current good practice (or state-of-practice) key assumption key source of uncertainty level of detail model*

newly developed method*

PRA PRA acceptability PRA maintenance*

PRA method PRA upgrade*

realism risk significance significant accident sequence significant basic event/contributor 21

  • These terms and their definitions have been adopted from PWROG-19027-NP, Revision 1 RG 1.200, Status Update January 16, 2020 Public Meeting

New Appendices (1 of 2)

  • Appendix A: Endorsement of ASME/ANS RA-Sa-2009, unchanged from RG 1.200, Revision 2
  • Appendix B: Endorsement of ASME/ANS RA-S Case 1, Case for ASME/ANS RA-Sb-2013 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment of Nuclear Power Plant Applications 22 RG 1.200, Status Update January 16, 2020 Public Meeting

New Appendices (2 of 2)

  • Appendix C: Guidance for Classifying Changes to a PRA as PRA Maintenance or a PRA Upgrade
  • Appendix D: Other Hazards 23 RG 1.200, Status Update January 16, 2020 Public Meeting

Planned Path Forward

  • January 2020 - Public meeting to share draft
  • February 2020 - ACRS Subcommittee Briefing
  • NEI 17-07, Revision 2, and PWROG-19027-NP, Revision 1, to be revised to incorporate stakeholder comments 24 RG 1.200, Status Update January 16, 2020 Public Meeting
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